WMTE MINIMIZATION Major Problems of Data Reliability and Validity Identified

In your letter of January 31,1990, you asked us to evaluate the quality of the Environmental Protection Agency (EPA) data that will be used to determine the need for mandatory waste minimization requirements. We presented initial fmdings in response to this request in August 199 1. This report presents our detailed findings on this issue; that is, our assessment of (1) the degree and causes of measurement error in EPA'S National Survey of Hazardous Waste Generators, (2) how to reduce or eliminate these errors, and (3) how to minimize any future problems. If you have any questions or would like additional information, please call me at Executive Summary Purpose National policy concerning the management of hazardous waste has undergone a profound shift since the passage of the Resource Conservation and Recovery Act of 1976, the first national legislation specifically addressing this issue. Hazardous waste minimization, which seeks to avoid the production of waste, has now become the preferred alternative to the handling of waste once it has been produced. To gauge the amount of hazardous waste minimization occurring and to assess the need for related regulatory statutes, the Environmental Protection Agency (EPA) must have hazardous waste minimization data that are valid enough to measure the extent to which the U.S. industrial sector is preventing the generation of hazardous waste, as well as the factors that are associated with successful waste production avoidance. However, the EPA hazardous waste information system has suffered from serious deficiencies, making the quality of the data questionable. Accordingly, Senators Baucus and Burdick of the Senate Environment and Public Works Committee asked GAO to examine the reliability and validity of these data. Background The Resource Conservation and Recovery Act of 1976 (RCRA) established federal requirements for managing hazardous waste; the emphasis of this first attempt was to assure that management was monitoring hazardous waste streams from " cradle to grave " and to ensure that wastes were managed in an environmentally safe manner. The Congress declared hazardous waste minimization to be the national policy of the United States in the Hazardous and Solid Waste Amendments of 1984 (HSWA).~ However, hazardous waste minimization programs have not been mandated. EPA has relied on voluntary efforts by industry to achieve hazardous waste minimization, and according to EPA, hazardous waste minimization is driven by a number of potential incentives. These incentives include the increasing costs of treating hazardous waste, difficulties in …