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Gossman Consulting, Inc.                     September, 1993
Guidance for the Elements of a Waste Minimization Plan

Jim Woodford

Guidance for the elements of a waste minimization plan were published in FR58, page 31114 on May 28, 1993. The EPA recommends that a disposal facility document its program in writing and then have that documentation signed by the corporate officer responsible for ensuring compliance. The general requirements are outlined in the following text:

Top Management Support

EPA suggests that top management support can be demonstrated by some combination of the following techniques or similar techniques.

- Make waste minimization part of organization policy.

- Set explicit goals.

- Commit to implementing recommendations.

- Designate waste minimization coordinator.

- Publicize success stories.

- Recognize individual and collective accomplishments.

- Train employees on waste generating impacts.

Characterization of Waste Generation and Waste Management Costs

EPA suggests that characterization include:

- a waste accounting system to track types and amounts

- rates and dates of generation

- a determination of true costs associated with waste management and cleanup including costs of:

Periodic Waste Minimization Assessments

EPA suggests some options here.

- Identify sources of waste by tracking material that end up as waste.

- Perform mass balance calculations.

- Establish a waste minimization team of independent experts outside the organization structure.

- Establish an in-house waste minimization team.

Whichever option(s) chosen, the EPA believes that most successful waste minimization assessments have at least two common elements:

- Identification opportunities at all points in a process where materials can be prevented from becoming waste.

- Analysis of waste minimization opportunities based on the true costs associated with waste management and cleanup.

Cost Allocation

"Where practical and implementable", EPA wants generators to allocate costs to the activity that produced the waste rather than simply to overhead. This assigns responsibility rather than allowing waste production to get lost in the overhead numbers.

Technology Transfer

EPA believes that "It is important to seek or exchange technical information on waste minimization from other parts of the organization/facility, from other companies/facilities, trade associations/ affiliates, professional consultants and university or government technical assistance programs."

Program Implementation and Evaluation

EPA recommends that a facility; "Implement recommendations identified by the assessment process, evaluations, waste minimization teams, etc.. Conduct a periodic review of program effectiveness. Use these reviews to provide feedback and identify potential areas for improvement."