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---October 31, 1990---
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The American people are engaged in a great struggle. From the available evidence it is clear that we cannot go on as we have been. The way we conduct our business must change. Thoughtful people everywhere recognize that this is true.

Yet for the most part, thoughtful people do not make--or even affect directly--the decisions that create the problems. Those decisions are made privately by small groups of narrowly-focused individuals of enormous wealth and power, power that is exercised behind closed doors. These decisionmakers are motivated chiefly by the need to return quick profits to investors; all other considerations are strictly secondary. Such decisions have very farreaching, public consequences but they are not in any sense public decisions. For example, the decision to market chlorofluorocarbons (CFCs), the chemicals that are progressively destroying the earth's ozone shield, was made by executives of a single company--DuPont.[1] The decision to market PCBs--the potent toxins that have now polluted the farthest corners of the planet, from fish at the bottom of the deepest oceans to polar bears in the most remote reaches of the arctic--was made by executives of one company--Monsanto.[2] With 1000 new chemicals being introduced each year into commercial channels, the next chemical crisis is undoubtedly abuilding now, unbeknownst to anyone save for a handful of executives who made the latest (and so far unrevealed) disastrous decision. We have in place no mechanisms for discovering what that next disaster may be until it is too late, until it manifests itself in dreadful proportions. We have no way to affect the marketing of such chemicals except after a catastrophe has become apparent. We have no mechanism for requiring that private decision-makers consider the distant and delayed consequences of their decisions; in fact, we have no way to assure that any kinds of consequences besides the monetary will be considered at all. We have no mechanisms for bringing to justice the irresponsible decision-makers of companies like DuPont and Monsanto who have wrought global-scale mayhem; they have escaped justice entirely, and will no doubt continue to do so. For all practical purposes, we the people are powerless.

Yet despite our powerlessness to affect industrial decisions of awesome consequence, there is still great reason for hope because there is visible across America a remarkable movement of citizens at the grass-roots, local level. And they are being effective, forcing great changes indirectly.

None of us can directly affect the decision to make a new, disastrous chemical. But any of us-all of us--can send a strong message to the companies who do make these things: "Make whatever you want. We can't stop that (yet). But if you make toxic wastes in the process, you can't dump those on us. Those we know how to stop today."

There are only five basic options for toxic byproducts: (a) Hide them somewhere (landfill, deep well injection, ocean dumping, and so forth). (b) Burn them somewhere (in a hazardous waste incinerator, a cement kiln, etc.). (c) Detoxify them, break them down, by some almost-certainly-expensive chemical process. (d) Use them as a raw material in a new process (recycle them). (e) Don't make them in the first place.

Option (c) is almost never used because it means establishing a factory, with workers, that produces no useful products and therefore produces no income. Who will pay the workers? Option (d) is rarely used because chemical byproducts (wastes) are rarely pure and most industrial processes require raw materials that are purer than most wastes. This leaves only (a), (b), and (e). These options lie at the heart of the nation's great struggle today.

Option (e), everyone agrees, is what we need. The head of the EPA (U.S. Environmental Protection Agency) says so;[3] the EPA's distinguished Science Advisory Board says so;[4] even the Congress from time to time says so. Everyone important in Washington says so.

Unfortunately, this option requires American industry to do almost everything differently from they way they are doing things now. It means admitting error; it means confessing that it has been a mistake over the past two decades to create the "waste management" industry that now gobbles up $90 billion each year. It means going back to square one and re-engineering enormously complex and interrelated systems--thus destabilizing a manufacturing system which, although it is demonstrably destroying the planet, at least returns decent profits to most participants every quarter. It means spending money today that will not pay rewards for a decade or more, and those who are driven by the need to deliver profits to investors every three months cannot even contemplate such a proposition. It is literally unthinkable. No, pollution prevention is right and good and necessary, everyone agrees, but, for the most part, no one does anything about it. (There are exceptions, of course, but so far, we suspect, pollution prevention has guided far less than 1% of the industrial decisions made each year.)

Therefore, industry's only real choices today are options (a) and (b). Option (a)--land disposal--is a loser, everyone agrees. Organized crime still likes it, and those who dispose of their wastes by handing them to organized criminals, then averting their eyes, still like it. There is even a cadre of holdout enthusiasts hidden within the EPA itself; these are the candidates for the "revolving door" who plan to retire one day on the largesse of the organized criminals. But thoughtful people everywhere recognize that land disposal is dead. As the EPA's own Science Advisory Board said recently, "landfills are no longer an option for hazardous waste disposal."[5]

This leaves only one remaining disposal option--incineration. Given that powerful industrial decisionmakers are unable (for whatever reasons) to embrace pollution prevention, and given that no one in their right mind would bury dangerous wastes in the ground (except at midnight in New Jersey), the incineration of hazardous wastes is the only remaining option. The question is, does this last option make sense from the viewpoint of thoughtful people? Or should thoughtful people do the nation a favor and kill this option the way they've killed land disposal, thus forcing industry to embrace pollution prevention before we all drown in toxic soup? This is a question worth exploring in some detail, which we intend to do.

William Reilly's EPA has clearly decided that the nation must have more and more incinerators. While the boss is off giving blue sky speeches about the virtues of pollution prevention,[3] EPA's troops in the trenches are busy making sure that any johnny-come-lately who wants to set up an incinerator and start cashing in can do so with minimum interference from the locals and from government. In the April 27, 1990, FEDERAL REGISTER (pgs. 17862-17921), Mr. Reilly's minions proposed a set of hazardous waste incinerator regulations containing loopholes for polluters so large they make DuPont's global ozone hole (this year 12 million square miles in size) seem like a pin hole by comparison.

[More detailed analyses will follow.]
--Peter Montague, Ph.D. =============== [1] Sharon L. Roan, OZONE CRISIS; THE 15-YEAR EVOLUTION OF A SUDDEN GLOBAL CRISIS (NY: Wiley, 1989).

[2] See RHWN #144.

[3] William Reilly. "Aiming Before We Shoot: The Quiet Revolution in Environmental Policy." Speech delivered at the National Press Club September 26, 1990; available from the EPA Communications and Public Affairs Office (A-107), 401 M St., SW, Wash-ington, DC; copies are free from: (202) 382-4361.

[4] Raymond Loehr and others, REDUCING RISK: SETTING PRIORITIES AND STRATEGIES FOR ENVIRONMENTAL PROTECTION (washington, Dc: Science Advisory Board, U.S. Epa [washington, Dc 20460; publication #SAB-EC-90-021], September, 1990. Phone (202) 382-4126.

[5] Raymond Loehr and others, cited above, pg. 22.."

Descriptor terms: hazardous waste incineration; waste treatment technologies; cfcs; dupont; bcbs; monsanto; policies; chemical industry; waste disposal industry; landfilling; pcbs; william reilly; epa;

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