The Hazardous and Additional Waste Export and Import Act, S. 1082, is the single best mechanism for implementation of the Basel Convention now before the Senate. S. 1082 prohibits the export and import of hazardous waste and "additional" wastes (i.e., municipal and hazardous waste previously exempted by regulation) unless conducted under pursuant to an international agreement. For the wastes for which exports will be permitted, S. 1082 leaves the development of appropriate standards and criteria to the Environmental Protection Agency. CMA is prepared to work with the Agency in addressing the criteria required to assess the capability of an importing government to manage wastes in an environmentally sound manner. Congress should not make the unwarranted assumption, however, that adherence to anything but the RCRA standard is somehow less protective of human health or the environment. Recycling activities, whether in the U.S. or abroad, must be encouraged. CMA suggests that special provisions for recyclable or recoverable materials must be included in S. 1082. Recyclable wastes, destined for appropriate facilities, pose little threat of harm to health or the environment. Spent metal catalysts, for example, pose little risk under the current conditions of their export, treatment, and return to the United States. VI. CONCLUSION CMA agrees with the underlying premise of the Basel Convention: exports of wastes must be subject to a control mechanism that assures responsible management of the waste material, whether intended to treatment, disposal, or recycling. Exporting governments clearly have a responsibility to provide the information necessary for effective control of the wastes. Expeditious ratification and implementation of the Basel Convention in the United States is necessary, however. The United States must maintain its role as a leader in waste management, and should promote reasonable alternatives to disposal, such as recycling. CMA looks forward to helping Congress and the Administration craft an export control program that promotes sound waste management in every importing country. 1. QUESTIONS FOR THE RECORD JUNE 5, 1991 SENATOR FRANK R. LAUTENBERG ANSWERS SUBMITTED BY DIANA GALE, DIRECTOR CITY OF SEATTLE SOLID WASTE UTILITY Does recycling in multistory buildings present any unique problems? There are several problems associated with the development and implementation of recycling programs for multistory buildings that are generally much easier to solve for single family homes. Internal storage of recyclables - Residential units in apartment complexes tend to be significantly smaller than single family homes. Finding an adequate space to store recyclables is frequently a problem. This problem is magnified when the recycling system in question requires a higher degree of source separation. Numerous recycling containers have entered the market in an attempt to provide apartment dwellers with a convenient and workable storage system. At least two cities, San Diego, CA. and Newark, N.J., have building code requirements that stipulate building design incorporate both internal and external space for the storage of recyclables. Transfer of recyclables to external storage Many old multistory buildings were designed with a trash chute that was accessible on each floor of the building. This allows residents to simply walk down the hallway to dump their garbage. With the advent of recycling systems, residents must either take their recyclables down to the external storage container, or the garbage chute must be modified to handle multiple materials. (For an example of garbage chute modification, please see Resource Recycling. June, 1991 "The Challenge of Multi-family Recycling" pp. 34-40) The greater the distance the resident has to transport his or her recyclables, the less likely they are to participate in the program, External storage of recyclables -Any recycling system requires a separate external container for the storage of the recyclables. Such containers must be designed to meet existing fire codes. In addition, external containers compete with garbage dumpsters for a limited amount of space. Both garbage and recycling containers compete with cars for parking space. Higher degree of mobility than single family homes - Apartment dwellers tend to move with a greater frequency than residents in single family homes. This increases the need for an ongoing education program to inform tenants about any multistory program that is actually being offered. 2. 3. Lack of visible economic incentive - Recycling programs are sometimes linked to volume based garbage rates, wherein residents pay a higher bill for increasing amounts of garbage. When such rates are employed, the resident has an incentive to reduce their bill through the utilization of available recycling programs. In multistory buildings the cost of utility services are frequently incorporated into the rent. When this occurs, the tenant loses the direct connection between their waste generating behavior and the costs of disposal. The absence of direct economic incentives or disincentives has a direct effect on an individual's willingness to recycle. Should building codes provide that multistory buildings be built in a way which encourages recycling? Yes. The extent to which new residential and commercial buildings incorporate a "design for recycling" will have a direct impact on recycling program effectiveness. Actually, there are two challenges here. The first is designing new buildings to reflect the fact that the waste stream is no longer being treated in a homogeneous fashion. The second is the much larger challenge of "retrofitting" existing buildings to accommodate existing or proposed recycling programs. Any building code requirements that are developed need to be flexible enough to accommodate the diversity inherent in recycling collection systems. At a minimum, square foot requirements for both internal and external storage are useful. Ease of accessibility to storage containers is another critical factor that can directly impact program viability. Would 8. 988 which requires EPA to develop a model building code to encourage recycling in new multistory buildings lead to additional recycling efforts in these buildings? At a minimum, the presence of a model building code would offer guidelines which could help to remove one of the most significant barriers to multistory recycling, lack of properly designed space. Proper building design facilitates recycling by making it more accessible and more convenient to the user. Removing such a barrier increases the likelihood that such buildings will eventually implement a recycling system if such services are offered and readily available. 4. $976 Are additional Federal efforts necessary to stimulate recycling in multistory buildings such as providing technical assistance to develop alternative collection strategies and research and development for pilot collection programs? Absolutely. Many large cities find themselves having to provide recycling programs in order to comply with state law. At the same time, limited revenues significantly impair a jurisdictions' ability to experiment with a variety of collection systems in order to determine their relative merit. The development of federally funded alternative collection strategies with a strong program evaluation component could provide a common resource base that would be useful to most major metropolitan areas. At a minimum, such efforts should be targeted at several "profile" cities which capture different geographic and demographic factors. Recycling programs for low-income, multistory housing projects, and for high density (New York, Philadelphia, Chicago) and low density (Phoenix, Dallas) cities are just a few of the structural variables that need to be taken into consideration when developing multistory recycling programs. Potential utilization of existing personnel and capital equipment from municipal solid waste collection systems would benefit from further exploration as well. I hereby submit the following answers to the questions in your letter of July 9, 1991. Recycling in Multi-story Buildings: 1. Does recycling in multi-story buildings present any unique problems? Yes. Multi-story buildings have unique problems since the structures were not designed to accommodate either the collection or the storage of recyclable materials. Narrow hallways inhibit placement of collection or separation containers. There may not be storage space on individual floors. Storage capacity on the ground floor or basement level may not be adequate for even short term storage of the quantity of recyclables generated in the building. Custodial contracts and/or unions may inhibit the additional labor required to transport recyclables from generator to storage. In congested urban settings, even additional exterior storage space may be unavailable. Recycler or waste hauler's access to storage areas may also be limited. Tenant education and enforcement is far more difficult. Higher tenant turnover requires ongoing education programs and regular replacement of collection containers at a higher cost. Telephone 401-277-2771, TDD 277-6800, FAX 274-7337 100% recycled paper |