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#113 - What We Must Do -- Part 13 More On Pollution Prevention, 23-Jan-1989

After pollution has been prevented at the manufacturing site (see RHWN
#112), we will still have the problem of consumer products being
discarded. If these consumer products contain toxic materials, their
discharge into the environment through landfills or incinerators will
damage humans and the environment.

Therefore, the prevention of pollution at the manufacturing site is
only a partial solution. Preventing pollution by consumer products is
an equally important aspect of the problem. This week, we consider
pollution prevention from the viewpoint of consumer products.

One way to prevent pollution is through regulation. For example, some
kinds of consumer products could simply be banned. For instance,
beverage cans made from metal and plastic (which makes recycling of
those cans nearly impossible) could be banned. Plastic packaging that
is not biodegradable could be banned. Certain "convenience" items, such
as non-refillable cigarette lighters, or disposable plastic cameras,
could simply be banned. An alternative to banning such items outright
is to lay on a large tax, to drive them off the market by making them
expensive.

More subtle product design regulations could be imposed (or encouraged
through taxes). For example, the percentage of secondary material used
in the manufacture of certain products can be regulated. For instance,
the amount of recycled paper in certain paper products, the proportion
of recycled glass in glass containers, and the amount of scrap aluminum
or scrap steel in new metal items can be specified by regulation. In
the extreme case, the use of a virgin material could be outlawed
entirely; for example, virgin cadmium could be outlawed, forcing all
users of cadmium to adopt recycled cadmium. This would create a market
for recycled cadmium and would induce people to recover cadmium, a very
toxic metal, rather than dump it.

An alternative is to establish procurement guidelines for local, state
and federal government agencies. For example, if a state government can
only purchase recycled paper, this alone creates a substantial market
for recycled paper in that state.

The durability of products, extending their useful lifetime, can be
encouraged by regulations (or through taxes). For example, requiring
unconditional warranty on specified products for specified minimum
periods would quickly result in design changes to increase product
life. Manufacturers could be charged a fee to pay the administrative
and enforcement costs of such a program. There is a precedent for this
type of regulation in the federal energy efficiency standards set for
certain home appliances. All governments could encourage product
durability by including minimum warranty provisions in the purchasing
specifications for their own purchases. A danger in imposing product
durability standards is that it could force manufacturers to change to
more toxic materials (for example, increasing durability by changing
from glass to PVC plastic). This danger would need to be addressed
specifically in any regulations (not a simple matter).

Regulations can require that products be made reusable. An obvious
example is beverage containers, which can be designed to be reusable.

Economic Incentives--Alternatives to Regulation

The simple, familiar bottle deposit can be (and, in a few places, has
been) extended to other products, such as automobile batteries, which
contain toxic lead. Other products that are good candidates for a
deposit are major household appliances, automobiles, automobile tires,
automotive lubricating oil, dry cell batteries (which may contain toxic
lead, cadmium, and nickel), and containers for pesticides, petroleum
products, organic solvents, and some kinds of paints. To work well,
such deposits require that consumers be able to return used products
easily, and an environmentally safe means of recycling or reusing the
products must be developed.

A related, but different, idea is the "product disposal tax." This is a
fee charged on a new product when it is manufactured; the fee is to
cover the hidden costs of disposing of the product, including long-term
costs such as groundwater contamination. The fee would be set larger or
smaller, depending on such items as (1) the eventual disposal costs of
the product; (2) the amount of waste generated by the manufacture of
the product; (3) the environmental impact of disposing of the product
and of its manufacturing byproducts.

In principal, the product disposal tax is an excellent way to encourage
manufacturers to produce smaller amounts of waste, and less-hazardous
products. Products made by the least-polluting methods using the least-
polluting materials would carry the smallest disposal tax. Low-
pollution products would thus be cheaper to buy and would enjoy an
economic advantage over more-polluting products in the marketplace.
This would cause market forces to tend to drive pollution out of
existence. There is no more powerful force than the market.

Money collected from the disposal tax could be used to fund the tax
collectors, enforcement efforts, and research to make sure the taxes
were being set properly to penalize the worst polluters the most.

To set such a tax properly, we would need to classify chemicals
according to "degree of hazard." High-hazard chemicals would be taxed
more than low-hazard chemicals. A simple system, ranking chemicals on a
scale of 1 to 3, should suffice to begin with; later the system can be
refined. Irving Sax's book, DANGEROUS PROPERTIES OF INDUSTRIAL
MATERIALS, ranks chemicals by acute (immediate) hazard on a 1 to 3
scale from the viewpoint of workers handling those chemicals. What is
now needed is a similar system ranking chemicals according to their
environmental impacts and their chronic (delayed) hazard. High-impact
chemicals can be taxed heavily, to make them more expensive and thus
less popular. [Degree-of-hazard ranking systems are discussed in Joel
Hirschhorn, TECHNOLOGIES AND MANAGEMENT STRATEGIES FOR HAZARDOUS WASTE
CONTROL (Washington, DC: Congress's Office of Technology Assessment,
1983), pgs. 233-242, 259-261.] It is pathetic that the U.S. government
in 1989 still has no hazard ranking system to guide development of
waste management policies.

The federal Community Right to Know law (SARA Title III) goes one short
step toward the system that is needed. It requires large manufacturers
to report discharges of 300-or-so toxic chemicals. If SARA looked at
more chemicals, and if it looked at them in relation to the amount of
product a facility produced each year, we'd have the necessary
information to begin to set a "product disposal tax" for consumer
products. This would put the marketplace to work driving toxics out of
products, a major step toward preventing pollution.

Many of these ideas are taken from Elliott Zimmerman, SOLID WASTE
MANAGEMENT ALTERNATIVES: REVIEW OF POLICY OPTIONS TO ENCOURAGE WASTE
REDUCTION. Springfield, IL: Illinois Department of Energy and Natural
Resources [325 West Adams, Room 300; zip: 62704-1892], Feb., 1988.
Available from: National Technical Information Service, Springfield, VA
22161; order PB 88-188-560; $15.95. Phone (703) 487-4650.

--Peter Montague

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Descriptor terms: pollution prevention; bans; regulation; pollution
tax; taxation; public policy; sensible public policies; materials
policy; durability; bottle bills; reuse; product disposal tax;