Hazardous Waste (HW) Generation Trends

“Hazardous waste” is a term that has a very specific meaning in Wisconsin and federal laws. The term includes an incredibly wide variety of materials each of which potentially poses some risk to human health or the environment. A DNR publication, available in electronic format at http://dnr.wi.gov/org/aw/wm/publications/anewpub/WA106.pdf, provides a detailed explanation of what is and is not considered a hazardous waste and what kinds of risks these materials pose. Under certain circumstances, regulated facilities must report to DNR the amount of hazardous waste (HW) they generate (or create) in a given year, which provides us with this performance measure.

As explained above, this performance measure only considers HW generation data reported in odd-numbered years because by law those reports are more comprehensive and accurate than reports in even-numbered years. The baseline year for this performance measure is set at 1997 in order to provide enough data points to discern meaningful trends.

Between 1997 and 2005, reported HW generation dropped by about 40% among participating ECPP companies and for the rest of Wisconsin as a whole. DNR is aware that the HW generation data indicates erratic performance and, in the case of the ECPP companies, worrying trends. We are concerned that there may be errors in the data collected for 1999, which would account for the spike in HW generation by the rest of Wisconsin during this period. We are currently looking into this possibility.

After examining the causes of the recent upswing in HW generation by ECPP companies, DNR discovered that the increase is attributable not to an actual decline in performance but rather to a change in the way HW data are reported by just one company, Cook Composites and Polymers (CCP), for just one of their byproducts.

CCP has always generated this particular byproduct in very high volumes. Until the late 1990s, it was reported as HW generation. CCP then discovered that they were not in fact required to report that byproduct as HW generation because they treated it on-site. As a result, CCP stopped including this byproduct in their HW generation reports and the amount they reported plummeted - even though the byproduct was still being generated in very high volumes. More recently, CCP has discovered a way to recycle the byproduct, but they have to ship it offsite to do so, and this means that it once again is classified as hazardous waste. Ironically, the decision to improve their environmental performance by recycling this byproduct led to an apparent dramatic increase in HW generation, because of some of the arcane details of DNR’s reporting regulations.

Given what we’ve learned about the difficulties in accurately reporting HW generation, DNR intends to re-evaluate whether HW generation is a meaningful performance measure and whether it should be included in future reports.