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Proactive government steps in improving U.S. industrial hazardous waste management.

A recent survey of a large number of industrial firms showed that only 9 percent had risk management tools in place.

In the last 10-15 years society has become increasingly aware of the pervasive chemical contamination of its ground water and soil and of the associated damage caused by such contamination. Most of the problems can be traced to improper hazardous waste management. Several forces have put pressure on the business community to solve these current problems and prevent their reoccurrence. These forces derive from the actions of the waste generator's employees, the general public, and government and the courts.

Employees, concerned about the safety implications of working in contaminated areas, have pushed for, and often received, specific measures to improve occupational health and safety. For example, "right-to-know" laws and additional training have generally improved the workplace environment. In contrast, the general public, often harmed with exaggerated or inaccurate information, has called for impractical idyllic solutions or for regultions that place an undue burden on business. Faced with this environment, many firms decided to wait for more coherent public opinions tro emerge. This long-awaited emergence may now be underway as the general public focuses less on calls for new regulation and more on using the market mechanism to expedite change. Because purchasing decisions are beginning to be based on the environmental performance of the manufacturer, studying which actions are rewarded in the marketplace should yield a true picture of current attitudes and opinions.

Federal, state and local governments have reacted to the problems with the enactment of an impressively large array of laws. These laws were often drafted quickly, after a minimal amount of problem analysis -- and consultation with industry and enforcement agencies -- in an attempt to appease an uneasy electorate. This "process" often resulted in inenforceable, redundant and confusing laws.

The courts have responded by enforcing strict liability clauses found in many hazardous waste regulations. It is estimated that Superfund liability could approach $500 billion by the year 2000. In addition, courts recently started levying criminal penalties on the managers of firms found to be in serious violation of environmental laws. In 1989, for example, there were 107 such convictions, resulting in $12.75 million in fines and 53 years in jail sentences.

Considering the strength of these forces, proper hazardous waste management must be considered essential for the long-term survival and profitability of American industry. Industry, however, has been unwilling or unable to implement a viable system. A recent survey of a large number of industrial firms showed that only 9 percent had risk management tools in place. The threat of crippling environmental liabilities, coupled with waste cleanup and disposal costs that have increased tenfold in the last decade, mandates a reform in current hazardous waste management techniques.

This article addresses issues relevant to the design and implementatiuon of an effective and efficient hazardous waste management system, starting with a description of relevant regulations.

Following will be an assessment of stakeholder actions that have helped perpetuate the current problems. Results of empirical research into attitude similarities and differences between knowledgeable industry professionals and the general public is then presented. Afterward, a discussion of current techniques is presented. Lastly, a workable integrated solution, and ideas for the future, are proposed.

Survey of literature

Hazardous wastes are defined by federal regulations as chemical wastes that can be ignited, are corrosive, reactive or appear on a list of toxic substances. The relevant federal regulations dealing with these wastes can be broken down into four categories. The first category, which is relatively narrow in scope, deals with worker and workplace hazardous waste safety standards. The major regulation in this area is the Occupational Health Safety Administration's (OSHA's) Hazard Communication Standard. The second category deals with the regulation and tracking of hazardous waste outside the workplace. The primary components in this category are the Resource Conservation and Recovery Act (RCRA) and its various amendments, and the Hazardous Materials Transportation Act (HMTA). The third category deals with the control and cleanup of presently existing pollution, and with emergency planning. Major regulations in this area are the Comprehensive Environmental Response, Compensation, and Recovery Act (CERCLA) -- better known as "Superfund" -- and the Superfund Amendments and Reauthorization Act (SARA). Further specification in this area is provided by such regulations as the Clean Air Act (CAA), the Clean Water Act (CWA) and the Safe Drinking water Act (SDWA). Regulations in the last category attempt to prevent future pollution. Major regulation in this category is the Toxic Substanves Control Act (TSCA).

The goal of first category regulation is worker protection. The OSHA standard calls for hazards of all chemicals, including wastes, to be identified and documented. Workers are presented with this informantion and trained in the precautions and techniques necessary for the safe handling and use of these chemicals. The standard was written in a somewhat general fashion to allow it to apply to the maximum number of situations. The standard, for example, is not limited to chemicals on specific lists, so it does not have to be rewritten every time a new hazard is discovered. Furthermore, the rule is performance oriented. Instead of stipulating the specific processes that employers must use to achieve workplace safety objectives, it simply states its requirements in terms of goals. The individual firms are then free to decide on the most suitable method to achieve these goals, given their special business situations and specific hazards involved. Although the use of generalities provides strength to the standard through durability, it is also the greatest weakness. The ambiguity makes implementation difficult. It is often a matter of interpreting whether a particular business is abiding by the standard.

The remaining three categories encompass a much broader scope that includes the protection of the general public's interests. The second category attempts to stop the mismanagement of hazardous waste (i.e., prevent the environmental catastrophes) through regulations designed to prevent mishandling and improper transportation of such waste. The biggest strength of regulations like RCRA is the list of do's and don'ts they provide to industry. RCRA also allows states to assume direct responsibility for the management of their own hazardous waste. Nearly all states have done so, some enacting regulations. This provision has the advantage of allowing the states to tailor programs to fit their specific needs. The disadvantages are related to the associated destabilization of the regulatory environment. Rules are no longer uniform across states and change more often.

The third category of regulations protects the public primarily by forcing industry to cleanup contaminated sites, monitor and treat currently active waste streams and plan for emergencies. CERCLA and SARA require notification when specific chemicals are released, accidentally or otherwise, into the environment. In addition to reporting "what" and "how much," the releasing party must report on the release's known and anticipated health risks and on the proper medical treatment for exposed individuals. SARA also requires Material Safety Data Sheets and inventory reporting the each hazardous substance stored on the premises as well as documented emergency planning. While these rules do protect the public, they require an enormous amount of time be spent on paperwork. Possibly the most noteworthy and far-reaching aspect of CERCLA and SATA, however, is the strict liability imposed on violators. This huge risk, which cannot be insured against, may well reduce a firm's value. Also included in this category is the EPA Office of Research and Development's (ORD's) Superfund Research Plan. The program's goal is to reduce or eliminate the environmental risks encountered during the uncontrolled release of hazardous substances. The plan covers all research, development, demonstration and technical assistance performed by the various ORD departments. Again, this program is targeted at existing waste problems.

[TABULAR DATA OMITTED]

Regulations in the last of the four categories, because of their proactive approach, are most ambitious in their pursuit of public protection. TSCA, for example, attempts to prevent future pollution by imposing controls prior to the manufacturer of new chemicals, requiring toxic testing, record keeping, and reporting, and, in some circumstances, by direct regulation of chemicals. The act grants the EPA the authority to control chemical substances which "present an unreasonable risk to human health." While such loose working allows the act to cover nearly all present and possible future hazards, it also leads to the same types of problems encountered with the OSHA standard. Disagreements over what constitutes an "unreasonable risk" occur both inside and outside of the EPA. The law also leads to a great deal of government intervention in business, extra paperwork and added expenses.
Question Mean (1) Mean (2) Mean (P)
1 2.304 2.682 2.489
2 2.217 2.636 2.422
3 3.696 3.909 3.800
4 4.087 3.955 4.022
5 3.565 3.545 3.556
6 2.522 2.909 2.711
KEY: (1) = General public subset
(2) = "Industry knowledge"
(P) = Pooled data
TABLE 2


Considering the four regulation categories as a whole, all areas of hazardous waste management appear to be covered. Such comprehensive coverage implies that the crisis in hazardous waste management would be solved if firms would only "follow the rules." Problems exist, however, to a much greater degree than can possibly be explained by the actions of the few truly deliberate environmental outlaws. Ground water monitoring regulations, for example, are only complied with about 20 percent of the time. Most firms would like to comply with all environmental laws but cannot, for a variety of reasons.

Constraints on legal compliance

The first constraint often arises because federal, state and local laws conflictl produce multiple reporting requirements; and require differetn inspections of the same facilities. The mass of actions required by a literal interpretation of these regulations would overwhelm both industry and the agencies charged with enforcement. It is also difficult to follow rules that are constantly changing. This year, for example, senate majority leader George Mitchell announced party's commitment to rewrite RCRA and CWA. Because of this confusion, often both EPA and industry decide to stay with the present course of action until clarification is made.

General public opposition is the second factor inhibiting the adoption of proper hazardous waste management techniques. Government and industry analysts agree that overcoming the political obstacles to hazardous waste siting is much more difficult than overcoming the technical obstacles. A well documented example is the so called Not-In-My-Backyard (NIMBY) syndrome. This growing problem is typified by a ground swell of public opposition to a new hazardous waste disposal site. Communities often organize to politically block permits. Between 1986 and 1988, the number of groups in the U.S. protesting the disposal of toxic waste grew from 1,700 to 3,650. A resulting lack of suitable facilities has created a serious logistical waste management problem.
Question Mean (1) Mean (2)
7 2.692 3.273
8 2.609 3.727
9 3.435 2.636


KEY: (1) = General public subset (2) = "Industry knowledge" subset Table 3

Poor overall communication is a third contributing factor to the problem. Much of the NIMBY problem could be alleviated with better communication. Instead of feeling that waste management firms are economically aiding an area -- by bring jobs, etc. -- opponents often visualize environmental disaster. These opponents often see city leaders as having conflict of interest, where one small community is sacrificed to fill city coffers. This lack of communication extends to cleanup contractors and their respective hiring parties (private industry or government). Instead of paying for the actual cleanup of contaminated sites, for example, a recent study study has shown that nearly one third of Superfund expenditures have done to pay for the contractor's management costs. This poor communication of goals is also evidenced by the "technology fix" mentality that often infects industry and government officials. This is shown by a focus shift from solving the basic problem to attempting to improve present solutions. Instead of advocating the latest fad in soil remediation, for example, time and money would often be better spent on the development of source reduction rechniques (i.e., techniques to decrease the volume of waste generated).

Inadequate communication between upper and lower management can also lead to problems. Top managers are often well educated in productivity and front end raw materials management issues. Usually, however, they are not nearly so well educated in back-end costs. Upper management is often so far removed from the production process that it does not know what chemicals are used or what wastes are generated. Conversely, line managers often know specifically what wastes are generated but do not know the terminal (end of process) waste disposal costs. Back-end costs go straight to the bottom line -- because they arise after the incurrence of all "normal" production costs. These educational and knowledge communication failures therefore damage the firm and its direct stakeholders by lowering profitability.

Methodology

The findings of this article are based on a combination of primary and secondary research. To obtain the primary research data, a survey was designed to gauge attitudes on important hazardouss waste management issues. Specifically, the purpose was to detect attitudes that will impact the design and eventual success of a comprehensive hazardous waste management system. To ascertain if opinions vary significantly between industry professionals and the general public, the distribution of the survey was split between the two groups. Any evidence of a significant difference between the groups may indicate the necessity of the use of extraordinary measures to assure successful system implementation.

A total of 55 surveys were distributed, and 45 were returned. Using address listings found in industry publications, surveys were sent to 20 randomly selected industry professionals across the U.S. Fifteen were returned. In addition 10 surveys seven of which were returned, were distributed in the greater Dayton area to people known to be knowledgeable in hazardous waste management issues. The distribution of surveys to the general public was limited to the greater Dayton area. A total of 25 surveys were distributed to this group (23 were returned). A comparison of the two subsets reveals that the "industry knowledge" subset is older, has more work experience, and is comprised of a larger percentage of males. Table 1 summarizes the distribution and demographic data.

The survey instrument consisted of nine questions. For each question, respondents were aaked to rate their opinions on a scale of 1 to 5 (1 = Strongly Disagree; 5 = Strongly Agree). For six of the nine questions, no significant differences between the two populations could be inferred from the sample data. In these cases, the data was pooled and overall attitude inferences were made. This pooled data is discussed first.

The first question asked respondents whether the EPA adequately enforces environmental law. The second asked if the penalties most commonly given to violators are strong enough. Most respondents fell that EPA is doing an inadequate jon of enforcement and that the penalties lack lack sifficient strength. These beliegs are not firmly held, however. The third question asked whether the environmental reputation of a firm affects the amount of business it receives. Respondents believe more strongly that it does. Question four, which asked if government should pace a high priority on regulating hazardous waste generates and cleaning up hazardous waste sites, generated the highest agreement level in the survey. Question five asked about the willingness to pay higher taxes to support the regulation and cleanup. They survey shows that although most people are willing to pay higher taxes to support implementation of his high governmental priority, their conviction is not nearly as strong. The sixth question that did not generate statistically different responses between the populations asked respondents whether they thought environmental activists are damaging the profitability and international competitiveness of U.S. firms. The respondents mildly disbelieved damage was being done. The data for these first six questions is summarized in Table 2.

The populations were shown to exhibit significant differences on three of the nine questions. The first of these questions, question seven, asked respondents to gauge the level of most firms' compliance with EPA regulations. In general, industry people believe -- although not strongly -- that most firms full comply. The general public, however, does not quite believe this to be the case. The eight question asked if the current EPA guidelines are sufficiently stringent. Industry people believe fairly strongly that they are. Again, members of the general public do not quite believe this to be the case. The ninth question asked if the EPA should force a violating company to immediately being cleanup, even if doing so could force the company into bankruptcy. The general public subset believes that the EPA should force the issue, while the industry subset does not. The results of these three questions are summarized in Table 3.

The survey highlights some of the most important factors and attitudes that must be considered when designing a workable hazardous waste management program. Although no clear cut public mandates can be inferred from the survey, approaches and suggestions aimed at solving current hazardous waste management problems are abundant in the literature. Nearly all of these "solutions," however, focus on fixing only one or two aspects of the problem. There are, for example, literally dozens of technical methods currently used to clean up hazardous waste contamination. Some of the more popular techniques used to decontaminate groundwater and soil include soil washing, chemical treatments, and the various forms of bio-remediation and leachate control. In addition, new and promising techniques, such as using lasers to degrade PCBs and dioxins, are continually beign developed and introduced. The development of new and better ways to contain contamination is just as dynamic. The point is that the widespread failure of U.S. firms to properly manage their hazardous waste is not due to a lack of efficient technical methods. A more than competent job can be done with existing technology. In addition, with the hazardous waste cleanup market expected to be worth $20 billion a year by 1995, contractors wil undoubtedly produce a never ending stream of new methods. The focus can therefore safely be shifted to other areas of hazardous waste management.

To improve hazardous waste management in the workplace, many have suggested the use of an employer-employee committee, similar to the joint steering committees mandated by the Canadian government. The committee, composed of employer and employee representatives and a neutral chair, works together toward the common goal of developing and reviewing regulations that control exposure to hazardous substances. When an adversarial approach is used -- the norm in the U.S. -- the development and review process is painfully slow because each side is constantly questioning the other's motives and "scientific evidence." The steering committee approach brings the stakeholders together and therefore speeds the process. The Canadian regulation assures a high level of technical competence by requiring at least two of the committee members of certified in workplace hazardous waste management issues.

Other suggestions for improving current hazardous waste management have focused on ways to make the EPA more effective in its development and implementation of strategies and plans. For example, an expert panel recently recommended that EPA officials take the advice of scientists external to the agency more often. Also recommended was the creation of a peer question-and-answer program and a science advisor position. The advisor would develop EPA science strategy, evaluate agency scientists and act as a intermediary between scientists and decision makers. With these changes in place, the panel surmised that EPA decision makers would have access to the best scientific data. The use of an issue-based planning process would the lead to a coherent science agenda and operational plan. Other suggestions to improve the EPA's effectiveness include focusing resources where it is possible to achieve the greatest degree of risk reduction, the use of environmental cost/benefit analysis, the use of risk based analysis for long term planning, increasing general public and technical work force educational efforts, emphasizing pollution prevention, rather than pollution control and making greater use of market based incentives. While the adoption of these suggestions would certainly improve the EPA, many of the suggestions are vague enough to make implementation very difficult.

Another "solution" category involves using the market mechanism to push industry into actively seeking to resolve hazardous waste management problems, instead of just waiting for regulatory clarity. For example, the SEC requires corporations to report any liability incurred as a result of environmental law. When the SEC found indications that some firms were not adequately reporting these liabilities, it took steps to protect investors. Through a recent agreement, the SEC now receives Superfund liability information from the EPA on a quarterly basis. In return, the SEC performs a "full disclosure" of corporations for the EPA. The threat of disclosure should force firms to be even more careful with their waste, since stock performance and environmental performance may now be more closely correlated. A recent decision by the Emergency Task Force of the Financial Accounting Standards Board (FASB) should also have this effect. As of Fall 1990, firms could no longer treat hazardous waste cleanup costs as capital costs. Instead of being able to amortize the costs over several years, firms must now expense them as one time operating expenses. Since these costs will now have a more dramatic effect on a firm's financial statements, and therefore a greater possible effect on investor evaluation of the firm's value, greater steps may be take to avoid and/or minimize their incurrence.

Other ideas involve using direct economic incentives to push firms toward more responsible hazardous waste management practices. One approach calls for a fee to be charged to hazardous waste generators in accordance with the volume and type of waste produced. Firms would then be encouraged to use waste reduction techniques to achieve a lower fee. The advantage of this idea is that the firm is free to choose whatever method it feels is most appropriate and efficient. Efficiency should increase because the market will likely outperform government bureaucrats in identifying the best methods. The "fee" approach also has a provision to encourage the proper treatment and disposal of the waste that is still generated. A firm would receive a fee rebate if it is able to show documented proof that it turned over its waste to a certified waste treatment facility.

In summary, the approaches and suggestions found in the literature are generally good, but only applicable to a very limited range of hazardous waste management problems. Also, there ideas generally do not consider the effects implementation would have on the other aspects of hazardous waste management. If success is to be achieved, programs that attempt to improve U.S. hazardous waste management performance must consider attitudes of the relevant stakeholders. This article's empirical research, which considers two broad groups of stakeholders, attempts to shed light on these attitudes. Broad based support can be achieved through the building of a system that satisfactorily addresses the six areas of agreement found by the survey.

Areas of disagreement present a much greater challenge. Education and persuasion of one or both of the groups will probably be necessary to ensure success. To achieve the most effective use of scarce funds, these efforts should primarily be directed at the group with the most weakly held belief. Once a more coherent belief emerges, the associated factor can be built into the new hazardous waste management program. If opinion agreement is not achieved after some reasonable length of time, it will be necessary for some compromise to be made. To maintain the strong support base, education and persuasion efforts should continue even after program implementation.

Recommendations

The previous discussion of literature research attempted to clarify the goals and objectives of current hazardous waste management policies and practices. For one or more reasons, often lotistical, the combined use of these myopic approaches is insufficient to solve all of the current problems. The only solution is the development of an integrated hazardous waste management system. This system must combine and coordinate the best current ideas, maximizing their strengths while minimizing their weaknesses. Research has lead to two recommendations for the construction of such a system: empowering the EPA and creating a new government agency.

With regard to justifying the first recommendation, regulatory stability must be at the heart of any coherent system. All members in the system loop must be given time to learn the rules before they are changed. Stability, however, is no more than a dream as long as policy generating power is simultaneously held by various government bodies and agencies across the country. Therefore, the first recommendation is to centralize this power. The EPA should be given the sole authority to draft environmental policies and regulations. With only one agency generating policy, the instances of rule conflict and redundancy should drop dramatically. To ensure political responsiveness, the members of the EPA directorate that will be in charge of policy generation should be congressionally appointed, in staggered terms, to provide some stability. Also, a provision for mandatory congressional ratification of any rules exceeding some pre-specified scope or dollar amount should be made.

Since political gamesmanship should no longer be the factor it was during the existence of disbursed authority, the EPA will be able to concentrate its efforts on achieving the greatest possible risk reduction with available funds. Also, the EPA should be better able to enforce environmental law, since the directorate that generated it will be more aware of the situational realities and limitations. This should help counter the general attitude that the EPA is not adequately enforcing environmental law. Furthermore, since it is fairly clear that the people support the enforcement of stiffer penalties, the legal consequences of violating environmental law should be increased.

To aid the EPA in focusing its efforts and to keep it from becoming an unmanageable bureaucracy the second recommendation calls for creation of a new agency. This agency, which would have no regulatory power but would work closely with the EPA, would relieve the EPA of several of its non-regulatory duties. The agency would oversee environmental education, advocacy of important issues, improved communications and survey research.

Education is perhaps the new agency's most important function. Included, for example, would be informing the general public of the actual extent of currently existing dangers. The supposed main purpose of many of the fringe groups -- public dissemination of information -- would then be accomplished, and without the use of scare tactics. Because society in general believes that corporations should engage ine environmentally responsible bahavior, the education function can also be used as a weapon to ensure regulatory compliance. The agency could publish the names of companies with poor environmental records, especially those firms not actively working to improve environmental performance. The actual effectiveness of this "weapon" will depend on the strength of the correlation between perceived environmental performance and marketplace decisions. Educational efforts should also help resolve any opinion differences that may exist between industry insiders and outsiders. By allowing the members of each group to see both sides of a disputed issue, increased educational efforts should help bring opinions closer together.

Closely tied to the education function is the advocacy function, which will stress specific environmental concepts and ideas. Going beyond the mere presentation of facts, persuasion techniques are to be used to convince industry and the general public (i.e., all relevant stakeholders) and the benefits of adopting certain practices and concepts outweigh the associated costs. For example, current advocacy targets might include source reduction and the establishment of Canadian style joint steering committees.

Communication improvement is another closely related function. Specifically, the new agency would help industry, waste management firms, and communities work together and solve differences. Improved communication should remove the barriers that exist because of faulty assumptions and misunderstandings, and lead to greater efficiency in the hazardous waste management process. Representatives of the agency, for example, could act as third party mediators during the hazardous waste siting decision process.

Lastly, the new agency would be responsible for conducting survey research. Changing attitudes must be monitored, allowing for a reasonable estimate of the associated effects on current and proposed EPA and corporate programs to be made. Furthermore, when new attitude differences are detected between populations, those working in the education function can be alerted. These attitudes can then be monitored to allow for the assessment of the effectiveness of the related educational efforts. Once a coherent attitude forms, the officials in charge of making policy can be notified. By taking these attitudes into account during policy formulation, the chances of success and broad based support are greatly increased.

Restructuring the current hazardous waste management process around the empowered EPA/additional agency concept will allow the problems and constraints plaguing the current "system" to be avoided. The EPA will provide regulatory stability and consistency, thus lifting the first constraint to legal compliance: conflicting and continually changing laws. Furthermore, with the addition of the new agency, the functions of hazardous waste management education, communication, and advocacy will be coherently organized and will finally receive the necessary levels of attention and general dissemination. The proper performance of these functions will help eliminate the second and third legal compliance constraints. Better education and information will help alleviate the general public's often hostile attitude. Also, through the agency's educational, informational, direct communication, and advocacy efforts, the overall effectiveness of hazardous waste management communication will be improved.

The addition of the new agency is necessary to maximize effeciency and minimize confusion. As a result of the wide span of duties it si required to perform, the EPA currently suffers from lack of clear focus. Simply expanding the EPA to encompass the additional duties would only exasperate this problem. Operational efficiency will be greatly enhanced by using two agencies, each with a definite focus. The specialization will also help clear away industry and general public confusion. Once the duties of each agency are widely known, specific questions and problems will be more quickly routed to the appropriate personnel.

In addition to improving the logistics of the hazardous waste management process, empowering the EPA and creating the new agency will show all that environmental issues are of primary concern to the U.S. government. Furthermore, obtaining the funds necessary to implement the recommendations should not be difficult, even in a time of tight budgets. Overall attitude indicates that the American people are willing to finance a system -- by paying higher taxes -- that will assure proper hazardous waste management.

The recommendations therefore appear to be feasible from the critical logistical, public and industry, support, and financial standpoints. The greatest feasibility problem lies with Congress. Lawmakers may be reluctant to give up some of their regulatory power. In addition, the individual agendas of some of those is Congress may cause them to attempt to block some portions of the legislation. Only through intense lobbying efforts by both industry and the general public will the recommendations stand a chance of being enacted reasonably intact.

Implications for stakeholders

The discussed findings have direct implications to industry, the general public and to the research field. Implementation of the recommendations will result in an industry wide reduction in direct and liability costs. Better environmental performance should also lead to an increase in revenue, since it has been shown that such performance is a positive marketplace factor. When these two points are considered simultaneously, it can be seen that industry value should increase. This should lead to increased stock prices and higher rated debt and therefore implies an increase in investor wealth. Also implied is the formation of a better business environment. Regulatory stability will result in less confusion, less effort required to "keep current", and greater regulatory compliance. The relationships with all stakeholders, including employees, investors, suppliers, and the general public, should be strengthened. Lastly, improved physical environment conditions (i.e., cleaner water and soil) are implied.

The implications to the general public are nearly as important. These implications include increased confidence and trust in the government, made possible through the proper placement of priorities and the improved protection that results from the better enforcement of stricter environmental laws. Increased education and regulatory stability implies a better public understanding of environmental law. Because the public will be in a better position to know if environmental law is being violated, a decrease in the widespread distrust of hazardous waste management practices is additionally implied. Lastly implied is a better environment to live and work in.

Although not as important as the implications to the whole of society, the implications to research are numerous. First, because of the high correlation of the answers between industry insiders and the general public, primary research implies that the general public is fairly well informed. The survey did not show some significant differences between the two populations, however. Gains in understanding the process by which the general public acquires and assimilates such information are implied. It may be possible to determine the areas in which differences are mostly likely to occur, and the likely direction of any associated biases. On the questions where the survey showed significant differences, the general public displayed a pessimistic attitude toward current hazardous waste management practices. This implies the possibly that the partial truths and scare tactics used by fringe groups may be having a significant effect on public opinion. Implied is research into the ease in which such groups and tactics can sway the opinions of those without first hand knowledge. The last implication rests in the fact that, even in a recession, the American public is willing to financially support programs of high perceived importance. This implies that other programs may have been incorrectly classified as infeasible. Further feasibility studies will need to be performed.

In the case of the primary research, fairly obvious limitations exist. First of all, the "general public" subset was not sampled at random and the sample was limited to one geographic area. Approximately one-third of the "industry knowledge" subset also suffers from these flaws. Secondly, the industry knowledge subset turned out to be a little older, comprised of a higher percentage of males, and in possession of a little more work experience than the general public subset. Furthermore, the sampled members of the general public population had acquired more education than the population average (nearly all those sampled were college graduates). This education disparity may have lead to an overestimate of the level of relevant knowledge possessed by the average general public population member. This, in turn, could be the reason behind the scarcity of significant differences in the surveyed opinions of the two groups.

The secondary research was limited by the voluminous amount of confusing and conflicting hazardous waste management literature. Because of the dynamic nature of the regulations, extreme care must be taken when assessing the validity and relevancy of any literature except the most current. Lack of regulatory clarity is also a problem. This lack of clarity is evidenced, for example, by the existence of a 30-40 page newsletter (published weekly) that is solely dedicated to reporting recent Superfund interpretations (Inside EPA's Superfund Report).

Future research

The most obvious directions for future research stem from the primary reearch used in this study. Both population subsets should be larger and should be sampled completely at random. Both samples should also be more completely geographically, and in the case of the "general public" subset, educationally dispersed. In addition, an effort should be made to see what effects the equalization of age, sex ratio, and work experience between the two groups will have on the results. Other related ideas include sampling the attitudes of narrower population groups, and the continual monitoring of population attitudes -- and attitude differences -- as education increases. Such monitoring will enable researchers to test the hypothesis that the attitudes of populations will converge in accordance with increases in the relevant knowledge.

Further research also needs to be done to determine the strength of the correlations between environmental and stock performances and between environmental and marketplace performances. In addition, research should be done to assess the specific reaction of industry and the general public to the recommendations presented. If some form of the recommendations were adopted, the effectiveness of the resulting integrated system should also be monitored. Lastly, research should be undertaken to devise alternative recommendatiions, as well as modifications to the recommendations presented.

The failure of current hazardous waste management techniques, and the present and future stakeholder consequences of such failures, illustrates the necessity of a departure from the status quo. The implementation of an integrated hazardous waste management system would serve the best interests of all stakeholders. In order to ensure coherent regulation and enforcement of environmental standards, the EPA must be given greater authority. To help the EPA achieve its mission, and to advocate the use of important new hazardous waste management techniques, a separate agency must also be created. These two agencies, whose programs are to be designed in consideration of stakeholder attitudes, should be able to solve much of the current crisis in U.S. hazardous waste management.
COPYRIGHT 1993 Institute of Industrial Engineers, Inc. (IIE)
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Copyright 1993 Gale, Cengage Learning. All rights reserved.

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Author:Petrick, Joseph A.; Rankin, Kevin D.
Publication:Industrial Management
Date:Sep 1, 1993
Words:6167
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