DATE:         March 5, 1979

SUBJECT:   Meeting on Hazardous Waste Regulations of June 15, 1978.

FROM:        William Sanjour, Chief, Waste Reduction Branch Resource Recovery Division

TO:              Record

    On June 15, 1978, Mr. John Lehman, Director of the Hazardous Waste Management Division, met with the entire staff of the Division. The purpose of the meeting was to explain to the staff the new orders he had received from Mr. Jorling on June 12 and to present Mr. Jorling's explanations for these orders.

    He said there are several recent developments including:

  • President Carter's directive to reduce the Federal budget to fight inflation;

  • Many new congressionally mandated programs in EPA with not enough resources to fully implement them, and

  • The so-called taxpayers revolt.
  • As a result of these, Mr. Jorling feels the hazardous waste management regulations have to be reduced in scope.

        In particular, Mr. Jorling felt the definition of what waste will be covered by the regulations will have to be changed. The definition cannot be based on such characteristics of a waste as whether it

  • causes cancer

  • causes birth defects or

  • is poisonous,
  • because by doing that it is not possible to accurately predict how much waste or which industry will be pulled into the program (thus making it difficult to accurately assess the cost to the polluting industries in advance).

        Mr. Lehman said we will delay implementing the regulations in order to examine alternatives for reducing the scope and that the staff will be involved in determining the economic impacts of those alternatives as well as their ramifications on other programs within the Agency. This exercise will consist mainly of cutting things out of the regulations that are currently there.

        I, and several others at the meeting told Mr. Lehman that they felt the orders were illegal and inconsistent with our congressional mandate to "protect human health and the environment."

    William Sanjour's home page

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