Waste Minimization

Major Problems of Data Reliability and Validity Identified Gao ID: PEMD-92-16 March 23, 1992

National policy now makes hazardous waste minimization, which seeks to avoid waste production in the first place, the preferred way of handling such material. The Environmental Protection Agency (EPA) needs valid data to measure how well U.S. industry prevents the generation of hazardous waste, as well as factors associated with successful waste production avoidance. GAO found that EPA's baseline hazardous waste minimization data are fraught with measurement problems, most of which are severe enough to greatly limit the data's usefulness in profiling the extent of waste minimization progress. These problems include ambiguities in definitions of key concepts, terms, and questions; governmental reporting requirements; and the relationship of production amounts and types to the volume of hazardous waste produced. These ambiguities cause reliability and validity problems for waste minimization program elements, waste stream information, and production mix data. The problems are so severe that the data cannot be adjusted to account for imperfect measurement; hence, waste minimization progress cannot be determined.

GAO found that: (1) the EPA baseline hazardous waste minimization data are fraught with reliability and validity problems that are severe enough to limit the data's usefulness in examining the extent of waste minimization progress; (2) EPA has not sufficiently defined several concepts, terms, and questions used in its survey instruments, causing respondents to make an array of individual judgments when completing waste minimization questionnaires; (3) since EPA has not refined the Resource Conservation and Recovery Act (RCRA) categories that use codes to profile hazardous waste types, it cannot accurately profile the extent and determinants of minimization for specific hazardous wastes; (4) the lack of stringent EPA reporting requirements has caused company recordkeeping systems to vary greatly in quality and accessibility; (5) due to the lack of sufficient recordkeeping capabilities, individual respondents are led to make judgments and estimations of data that may not be representative of information collected; (6) because data on waste stream production amounts are flawed, EPA does not accurately characterize production mix as it relates to waste output; (7) such nonproduction activities as research and such one-time events as spill cleanups generate waste, but are not accounted for by production activities; and (8) due to such ambiguities, EPA waste minimization data cannot be adjusted to account for imperfect measurement, and waste minimization progress cannot be ascertained.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

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