The U.S. EPA Draft Guide for Industrial Waste Management—Too Little, Too Late?

December 1999

Citation:

ELR 10764

Issue

Author

Jonathan J. Greenberg

Editors' Summary: EPA recently proposed for public comment a draft guidance document that discusses voluntary federal recommendations for hundreds of thousands of nonhazardous industrial waste sites that currently escape RCRA regulation. In this Dialogue, a member of the chartered advisory group that assisted the Agency in the development of the document discusses its attributes and shortcomings. The Dialogue describes the history of EPA's use of RCRA Subtitle D and the statutory and programmatic obstacles to meaningful federal regulation. It then outlines the draft Guidance and concludes that EPA's effort falls short of the important goal of assessing and addressing the risks presented by industrial waste disposal facilities.

The author is a private consultant in Washington, D.C., specializing in environmental legislative, regulatory, and policy matters. From 1988 to 1998, he was Director of Environmental Policy for Browning-Ferris Industries. Mr. Greenberg served as Special Assistant to the Director of the U.S. EPA Office of Solid Waste from 1985-1988. Previously, he worked as a geologist. He earned a M.P.H. from Yale University (1985) and B.S. in Geology and Geophysics from the University of California at Santa Cruz (1978). Mr. Greenberg was an industry representative to the chartered advisory group that assisted in the development of the guidance document discussed in this Dialogue. The opinions expressed are those of the author. Mr. Greenberg can be reached by e-mail at Ugreenberg@erols.com.

The U.S. EPA Draft Guide for Industrial Waste Management—Too Little, Too Late?

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The U.S. EPA Draft Guide for Industrial Waste Management—Too Little, Too Late?