Re: Definitions that Further NRC's Goals
Fri, 22 Jan 1999 16:24:20 -0500

[Re: Definitions that Further NRC's Goals]

I think Bill Sheehan's point about recycling not just being a part of
waste is right on the money. We are still fighting a perception problem
with the media, the public, and politicians that recyclables are: trash,
garbage, waste, etc. If the National RECYCLING Coalition adopts a
definition of recyclable materials as solid waste, we might all want to
start working on our resumes.

Dave Wade, Recycling Coordinator
University of California, Santa Cruz


Bill -

Here are some thoughts on various sections of what we were sent.
To me, the most critical part is the purpose for the definitions; I think
that needs to be decided before the definitions can be developed.
Probably more important than the definitions is then the establishment of
goals for managing the material we handle, regardless of what we call them

John Reindl

> I am concerned about definitions that imply or state that recyclables
> are a subset of waste, and therefore that recycling is just a part of,
> rather than an alternative to, managing used resources as waste. With
> two of the proposed definitions ('solid waste' and 'municipal solid
> waste') the implication is by omission; the third definition
> ('integrated waste management') declares outright that recycling (as
> diversion) is a subset of managing waste.

Here are some parts of Wisconsin's law:

s. 144.01 (15) "Solid waste" means any garbage, refuse, sludge, .. and any
other discarded or salvageable materials,..."

s. 159.01 (13) "Solid waste management" means planning, organizing, ...
the storage, collection, transporation, processing, recycling or final
disposal of solid wastes ..."

s. 159.05 State solid waste reduction, reuse, recycling, composting and
resource recovery policy. The following are declared to be policies of the
state concerning the reduction of the amount of solid waste generated, the
reuse, recycling and composting of solid waset and resource recovery from
solid waste: [ long list follows in statutes ]

s. 159.05 (12) That in the management of solid waste, whenever possible
and practical, the stae encourages the following priorities:

(a) The reduction in the amount of solid waste generated.
(b) The reuse of solid waste.
(c) The recycling of solid waste.
[ and on and on with the usual hierarchy ]

As a long-term garbage guy and recycler, I don't have a problem with
calling recycling a method to deal with solid waste. But I also understand
the philosophical problem of when does something become a `waste', and the
practical/legal problems of environmental regulation of waste vs raw
materials. On the one hand, I do not like the word `waste' as applied to
recycling as it implies there is no value, and that the facilities that
handle the recyclables are like landfills. But on the other hand, I don't
like the approach of ISRI that asks for non-coverage of recycling
operations as potential Superfund sites, when we have places in Wisconsin
that recycled lead-acid batteries and solvents that, regardless of what
you call them (superfund or not), the groundwater and soil are badly
polluted and need to be cleaned up.

> The NRC Board recently made a bold and necessary departure from
> conventional usage of 'waste' as all-encompassing. At the September 10,
> 1995 meeting, the Board approved the definition of 'waste' as "Discarded
> materials and products that are landfilled or incinerated, rather than
> reused, recycled, or composted," and 'discards' as "materials ... no
> longer useful to the generator ... that are ... [recycled, reused,
> composted]... or landfilled or incinerated."

If we are to call the recycling processing of material as not dealing with
waste (even if it costs us to have the materials processed, such as mixed
paper and glass in today's market), then I think we have to call the
incineration of material to recover energy as also not dealing with waste.

> The proposed definitions for phrases using the word 'waste' are a
> reversal of the approved definition. The proposed definition for 'solid
> waste' reads (in part): "A general term for waste, garbage, refuse,
> trash, rubbish and other disposed materials, resulting from commercial,
> institutional, industrial, mining, agricultural, domestic (residential)
> and community activities." If it is necessary for a recycling
> organization to define 'solid waste' (as distinct from 'waste') at all,

I'm not sure what the distinction is between `solid waste' and `waste'.
Can you help me out here?

> we should be explicitly consistent with the adopted definition of
> 'waste' as a subset of 'discards.'
> The definition of 'solid waste' should start with the same 'Discarded
> materials ... that are landfilled or incinerated ..." The phrase "...
> garbage, refuse, trash, rubbish and other disposed materials" should be
> changed to "... garbage, refuse, trash, rubbish and other materials that
> are landfilled or incinerated" since there is not universal consensus as
> to the limits of the word 'disposed.'
> Likewise, the proposed definition for 'municipal solid waste' as "The
> mixture of solid waste typically handled by municipal collection
> programs ..." does nothing to alert the reader that we have defined
> 'waste' in a narrow sense, and are excluding recyclables and
> compostables that are also typically handled by municipal collection
> programs. Given the widespread usage of 'waste,' alerting the reader is
> critical.

We here in Wisconsin define `municipal solid waste' broader, including
commerical and industrial, but not industrial process waste.

> Perhaps we should step back and ask what our organization aims to
> achieve and whether the proposed definitions serve those aims. We
> should build our vocabulary around our core goals.

This I strongly agree with. Part of the question should be whether we want
the federal and state governments to update their definitions to have a
common definition.

> The mission statement I recall and relate to involves maximizing
> recycling and conserving resources. I suggest we consider how the
> proposed definitions might affect perceptions of materials that people
> are holding in their hands, ready to discard: if they are thought of as
> waste they will likely be placed with the mixed garbage; if they are
> perceived as used resources they are more likely to be recycled.
> Discards can either be reused, recycled, or wasted by mixing and burying
> or burning them. It then becomes clear that wasting is something we
> choose to do; it is not the inevitable fate for 75 percent of the
> discard stream.

Some 10 years ago, BioCycle asked me (I was then the state recycling
coordinator) how much waste was recycled in Wisconsin. I scoured the
records and came up with a figure in excess of 75%, because I included all
materials that *could* be landfilled, such as sewage sludge, old
automobiles (these were a real big problem in the late 1960's), paper mill
sludge, etc. They, of course, did not like my answer; for some reason
unknown to me, they wanted a narrow view of life, and were only interested
in household waste. Since household waste is a tiny fraction of what was
produced in the state, I didn't understand why they were limiting
themselves so much.

> Similarly, the definition proposed for 'diversion' ("To divert from ...
> incineration and landfilling") reinforces the notion that recycling is
> just an add-on or afterthought to a landfilling or incineration system.
> Why don't we say landfilling and incineration are diversions from
> recycling?

I refuse to include incineration in the same category as landfilling.

I think that the diversion from landfilling is used because every system
today has a landfill, and if the other parts of the system can't accept
the waste, it will still go to a landfill.

But if we're really talking about an integrated solid waste system, why
talk about diversion at all, and instead talk about how much is managed by
the various components?

> If we accept conventional usages, we also accept conventional wisdom
> about the limits of recycling, as well as the aims and goals of those
> who hold those views.

Luckily (or unluckily), I don't know what the conventional wisdom (an
oxymoron, no doubt) is for the limits to recycling, so I don't feel so