July 13, 1988


Subject:     Review of the draft report of the Municipal Solid Waste Task Force

From:        William Sanjour

To:            Matthew Straus

Per your request, I have reviewed the MSW Task Force report which is attached.



The cover letter takes the tone that somehow the American public is at fault for producing a lot of garbage. The public didn't demand, invent, promote, or sell disposable products and convenience packaging. The public a merely bought it when it was made available. If you want to lay a guilt trip on somebody, why not on the industries that promote and benefit f tom the "throw away society" without taking responsibility for the consequences. This "strategy" blames the victim for the problem.


More of the same. Blaming the victim for the problem and never once mentioning that the "throwaway mentality" (p.3) is the mentality of Coors, MacDonalds, Owens Corning, etc. etc. , etc.

As far as NIMBYs (Not In My Back Yard) go,. why is there no mention of all the beer and soft drink companies with their throw away containers? Aren't they NIMBYs? They don't want their containers in their backyard and they have fought every attempt to require them to put them in their backyard. One of the major arguments used to fight bottle bills is the claim by the bottlers that recycled bottles. would create a mess in the stores and with the distributors (remember the ads picturing roaches crawling over the recycled bottles). In other words, "not in my backyard" is the motto of the bottlers.

The same thing can be said for the fast food wrappers, disposable razor blades, etc. These industries have all made their fortunes by generating garbage for somebody else's backyard and not theirs.

In addition, their garbage is all manufactured out of plastics rather than biodegradable material, thus demonstrating gross indifference to the disposal problems that they have created. Maybe the reason that the Germans have less garbage than the Americans is that their manufacturers are more civic minded than their American counterparts.


Still more bashing of the poor American consumer. But the discussion does eventually come around to a very important point, even if it is in the most soft spoken off handed way. On p. 6 it says "Nor are there any incentives for manufacturers to design their products and packaging in a way that takes into account the. effective management of those products when they are eventually discarded."

One has hope that this may be a serious strategy document after all -- but no, in the next paragraph it returns to OSW's favorite pastime of bashing the stupid, unreasonable American public for not wanting dangerous ugly dumps ruining their neighborhoods and devaluing their property.

On p. 9 the strategy talks about the hierarchy of preferred options for managing solid waste with source reduction and recycling at the top and incineration and landfilling last. Then it chastises "public officials who pay lip service to the hierarchy" but who don't actually use it. This strikes me as a most egregious example of gall and hypocrisy since EPA, for the last decade, has been in the forefront of government agencies which pay lip service to source reduction and recycling, but do nothing to support it. while they put all their energies into promoting landfills, and more recently, incinerators. The strategy document piously asks "Why are the States and localities ignoring the waste management hierarchy in practice?" Maybe its because EPA has been ignoring it.


In the discussion on participation on p. 13, it recognizes the responsibility of industry "to consider source reduction and recyclability in designing products and packaging" and that "every individual and corporate citizen should assume responsibility for waste disposal". Nevertheless the strategy conspicuously refuses so much as suggest what industry should be doing, let alone recommending legislation to require corporate responsibility. Most aspects of municipal solid waste management are best handled at the state and local level, but this kind of legislation is the one area that only the federal government can do well, yet the strategy avoids it. Let me, therefore, make some suggestions of what the strategy might have considered:

  • mandatory beverage container deposits,

  • standardized interchangeable bottles (a la Canada),

  • biodegradable packaging materials,

  • a deposit system for unmanageable wastes such as tires and batteries which returns them to the manufacturer for recycling and disposal (see note regarding p. 41), and

  • a deposit system for the return of pesticide and other toxic material containers.

    NATIONAL GOALS (pp. 15-16)

    Setting a national goal for source reduction and recycling of 25% by 1992 without taking any of the hard actions necessary to reach the goal just tells the public that EPA is not serious about this and it is just another silly federal government hype campaign. (Lets recycle those old WIN buttons).

    AN AGENDA FOR ACTION (pp. 18-54)

    The agenda contains good and useful stuff but on a modest scale and it does not come near fulfilling the earlier hype of a grand national strategy and a 25% reduction.

    Page 19 encourages citizens to use double sided copying in a document that is copied on only one side.

    Page 29 suggests that the presence of toxic materials in municipal waste residues is due to household wastes whereas most people familiar with waste management know that it is far more likely to be coming from the illicit dumping of hazardous wastes, RCRA notwithstanding.

    Page 30 again pussyfoots around the whole subject of product manufacturers responsibility with award programs and workshops on design and packaging, while passing the buck to the consumer to reduce the number of tires he uses. I think that merits the "Weeny of the Week" award.

    The whole discussion on role-playing on p. 33 shows a deep lack of understanding of corporate America. Many companies which cater to the so-called throw away mentality got to be successful by catering to the throw away mentality and by displacing competitors who did not cater to the throwaway mentality. E.g. Budweisser and Coors with nonreturnable bottles and cans replacing local breweries with returnable bottles.

    For most companies source reduction costs money and costs business. Voluntarism will not get very much.

    Strange that EPA is recommending legislation for tax breaks and loans for companies purchasing recycled goods (p. 37) but won't go near the idea of recommending legislation to require companies to practice recycling and source reduction. In other words it's all right to recommend legislation when it involves dipping into the taxpayer's pocket to bribe companies to act nice but we should never never force them to be nice if they don't want to be.

    EPA has already studied and rejected the idea of a procurement guideline for used and rebuilt automotive parts (p. 39).

    Speaking of procurement guidelines, I don't know why the strategy did not recommend the two suggestions I made to them, namely that there be an implementation program and some sort of follow-up program for procurement guidelines.

    On p. 41, for the first time, we see a specific regulatory suggestion. "'Regulatory and regulatory options for recovery of lead-acid batteries, including a mandatory buy-back by manufacturers will be investigated to find feasible ways to collect them for safe recycling." Half a mark. I don't see why the American taxpayer should pay to find ways to collect them for recycling, why shouldn't the battery manufacturers do that? And why should the introduction of a mandatory buy-back program wait on such a finding?

    In other words. I think EPA and this strategy document ought to adopt the ethic that the safe disposal of a product is part of the responsibility of the manufacturer of the product. And if he doesn't know how to dispose of his products safely he has no business making them in the first place.

    I most strongly disagree with the concept on p. 41 of reduced liability for recyclers. Recycling is a business just like any other. If it can't be done safely, it shouldn't be done. Are the victims of irresponsible dumping any better off if the dumping were done by a recycler?

    On the subject of education and technical assistance (p. 47), EPA has continually failed to grasp that the government cannot promote the siting of waste management facilities and then expect the public to accept them as disinterested objective evaluators of the risks associated with the facility. Why do EPA and other government agencies find this simple obvious truth so hard to understand?  Surely no one in EPA accepts the used car dealers word that "it runs like a clock"--or do they?

    Page 55. No study of the "impact of household hazardous waste on landfill leaching and combuster emissions" should be undertaken unless it is done simultaneously with a study of the impact of illicit dumping of hazardous waste and small quantity generators on landfill leaching and combuster emissions.

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