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12. Staff

13. Staff

"Additives render polymers photodegradable at controllable rates" in SPE JOURNAL, January 1971, Vol. 27.

"This mulch will self-destruct" in CHEMICAL WEEK, February 16, 1972.

14. Princeton Polymers Laboratories

"Photodegradable Plastics - A Novel Low Cost Additive For Controllable Degradation of Plastics", undated.

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"Ecolyte: Bio-Cyclic Plastics" by James E. Guillet, undated.

ABOUT THE AUTHORS

LAUREL LUNT PRUSSING

Mrs. Prussing is an economist with research and practical experience in the economics and politics of recycling. Her academic background includes A.B., Wellesley College, A.M., Boston University, and graduate study at the University of California, San Diego. She is presently a Ph.D. candidate in the Department of Economics at the University of Illinois at Urbana-Champaign. official of Champaign County, Illinois, she is charged with the responsibility of finding solutions to county solid waste problems. She was formerly an Urban and Regional Economist with Arthur D. Little, Inc., Cambridge, Massachusetts and an Economist at the Center for Advanced Computation, University of Illinois.

As an elected

JOHN E. PRUSSING

Dr. Prussing is an Associate Professor of Aeronautical and Astronautical Engineering at the University of Illinois at Urbana-Champaign.

His academic degrees are S.B., S.M.,

and Sc.D. from the Massachusetts Institute of Technology. His research and teaching interests are in optimal control of dynamic systems, a field in which he has published numerous articles in professional journals. Prior to joining the faculty at the University of Illinois, Dr. Prussing was Assistant Research Engineer and Lecturer at the University of California, San Diego and at M.I.T.

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I have just had the opportunity to review your bill S. 3560, the "Solid Waste Utilization Act of 1974."

It is the most progressive, beneficial, and systematic proposal that I have seen in the important area of solid waste management, resource and energy recovery. The environment, our nation, business, and the American public will benefit when S. 3560 becomes law.

Please know that your leadership is appreciated and we fully support the "Solid Waste Utilization Act of 1974."

Sincerely,

cc: Stuart Symington

Thomas F. Eagleton

August A. Busch III

Keep
America

Beautiful

Pitch

In!

The B. F. Goodrich Company

1800 K STREET, N. W. WASHINGTON, D. C. 20006 PHONE 202-872-0570

ROBERT D. BUEHLER

DIRECTOR OF GOVERNMENT RELATIONS

August 8, 1974

The Honorable

Jennings Randolph

Committee on Public Works
United States Senate
Washington, D.C. 20510

Dear Mr. Chairman:

The B. F. Goodrich Company appreciates the opportunity to comment on S. 3560, the Solid Waste Utilization Act of 1974, and S. 3549, the Energy Recovery and Resource Conservation Act of 1974.

The B.F. Goodrich Company is a diversified manufacturer with major manufacturing facilities in fifteen states. Our products generally fall into two main categories: tires and related products; and chemicals, plastic materials, and synthetic rubbers. As a result of our diversity in products and manufacturing operations, the impact and implications of this proposed legislation is most important for our company.

The Company supports the timeliness and need for legislation dealing with the proper management of disposal and treatment of solid and hazardous wastes and the utilization of energy recovery systems. this regard, we would like to submit the following comments:

1.

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Because of the complexities of the problem, it is important
there is a clear definition of terms, particularly the
terms "waste" and "hazardous wastes. Hazardous wastes
are unique items and should be clearly distinguished from
non-hazardous substances and treated separately.

In the case of hazardous wastes, we recommend Congress direct the Federal Environmental Protection Agency to prepare criteria for classifying wastes as "hazardous" subject to formal rule-making procedures. In order to maximize the procedure of identifying hazardous wastes and the designation of safe disposal practices, we suggest that Congress

In

...in pursuit of excellence

The Honorable Jennings Randolph
August 8, 1974
Page 2

provide the Administrator with the benefit of expert technological advice by authorizing the formation of an advisory committee made up of experts from Federal and state governments, the academic community and industry. In dealing with non-hazardous waste, the states should be directed to institute waste management planning and control programs under general guidelines prepared by the Environmental Protection Agency.

The thrust of this legislation in both instances should be to place, to the greatest extent feasible, administrative authority in the hands of local/regional entities.

2. Any legislation should take into account the over-lapping of statutory and agency responsibilities and regulatory activities. For example, OSHA currently has jurisdiction over the safe handling of 'potentially hazardous materials within a manufacturing or processing facility. The Department of Transportation has jurisdiction over the proper transporting of waste materials and tire performance standards. The latter regulations could be in conflict with proposed Environmental Protection Agency disposal require

ments.

3. We support the concept of a permit system but as the disposal of solid wastes presents peculiar problems, we feel that such requirements and considerations should be designated by specifically tailored legislation and regulations separate from the permit provisions of the Federal Water Pollution Control Act of 1972. In addition, we feel that permits should only be required of the disposal site operator. Such a permit would automatically dictate what materials may be disposed of at the site.

4.

We support the concept of resource recovery, especially with
the timely implications it has for energy conservation.
However, we are deeply concerned with the concept of defin-
ing acceptable products, containers, and packaging based
upon wastes produced in their manufacture, or upon their
potential for resource recovery. The promulgation of such
regulations as proposed in Sections 111 and 112 of S. 3549
in terms of their complexity, effect upon supply and demand,
and ultimately the functioning of our entire economic struc-
ture are adverse to the public interest. We strongly urge
the committee to carefully review and evaluate such far-
reaching considerations as to their practicability and
impact upon the economic system.

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