BioForward Wisconsin closely follows news stories about its members and invites them to contribute blogs and profiles to inform and advance the Wisconsin biohealth community. Read the recent BioForward Wisconsin member blog on KTL’s scalable systems for helping companies manage compliance business processes more efficiently and effectively.

There are currently more than 4,700 known per- and polyfluoroalkyl substances—more commonly known as PFAS—and these numbers are growing as industry continues to invent new PFAS chemicals.

Because of their persistence in the environment, persistent nature, and widespread use in firefighting foams and products that resist grease, water, and oil, PFAS are found in the blood of people and animals all over the world. In fact, a 2011-2012 report by the Centers for Disease Control (CDC) and Prevention National Health and Nutrition Examination Survey (NHANES) found PFAS in the blood of 97% of Americans tested.

As of August 2021, 2,854 locations in 50 states and two territories are known to be contaminated with PFAS (Environmental Working Group (EWG)). Because of the sheer magnitude of chemicals that fall into this category and its persistence in the environment, PFAS contamination is an extremely complicated issue to regulate and manage—one that no single agency will be able to address alone. And one that industry must pay attention to, because it is not going away.  

Preparing for the Perfect PFAS Storm

All the various impact studies, regulatory actions, and legislative efforts are coming together to form a perfect PFAS storm, and industry must be ready to respond. Consider the following questions and best management practices (BMPs):

• Have you considered the risk(s) of introducing PFAS to your site—or do you know what PFAS you currently have on your site (either in current use or due to historical contamination)?
• Do you have an environmental management system (EMS) to help identify, manage, and prevent the risks associated with PFAS? Is PFAS included as part of your aspects and impacts analysis?
• Do you have the appropriate operational controls and training in place to prevent or minimize a fire at your facility?
• Do you have an Emergency Response Plan?
  • Have you contacted your local emergency responders to discuss the potential for using PFAS-containing aqueous film-forming foam (AFFF) at your facility in the event of a fire?
  • Do you have an emergency response checklist? Does it include inquiring about the foam being used to fight a fire?
  • Have you evaluated when and how to use PFAS-containing foams considering likely fire hazards; properties of the foam; nature of the emergency; risks to life, public safety, and property; and potential environmental, public health, and financial liabilities?
  • Do you conduct any emergency response testing that includes the use of AFFF?
  • Do you have controls in place (e.g., floor drain covers) and adequate supplies to keep foam runoff from leaving your site in the event of a fire?

PFAS Primer

PFAS are a group of manmade chemicals that have been manufactured and used in a variety of industries since the 1940s. PFAS can be found in:

• Food packaged in PFAS-containing materials, processed with equipment that used PFAS, or grown in PFAS-contaminated soil/water
• Commercial household products (e.g., stain- and water-repellent fabrics, nonstick products, polishes, waxes, paints, cleaning products)
• Firefighting foams (i.e., aqueous film-forming foam (AFFF))
• Industries such as chrome plating, electronics manufacturing, oil recovery, automotive
• Drinking water, typically associated with a manufacturer, landfill, wastewater treatment plant (WWTP), firefighter training facility, etc.

PFAS are made of chains of carbon and fluorine linked together. This carbon-fluorine bond is one of the shortest and strongest bonds in nature. It does not easily break down under natural conditions—hence the reason PFAS are often referred to as “forever chemicals”. Correspondingly, PFAS are very persistent in the environment and the human body, where they bioaccumulate in blood and organs over time.

Scientific studies have begun to show that exposure to some PFAS may be linked to harmful health effects in humans and animals, including developmental delays, reproductive health issues, neuroendocrine issues affecting the kidneys and liver, cancer, thyroid imbalances, and cardiovascular concerns.

Most PFAS exposure comes through ingesting food and water that becomes contaminated with PFAS when it migrates into soil, water, and air during use and/or disposal. Disposal of PFAS-containing items into municipal solid waste landfills can be a significant source of PFAS transport and contamination since PFAS can migrate into the leachate collection system. Since wastewater treatment does not remove PFAS, the subsequent use of wastewater biosolids as fertilizer, etc. may further distribute PFAS into the soil, surface water, and groundwater.

Focus on Firefighting Foam

Aqueous film-forming foam (AFFF) is highly effective foam for fighting high-hazard flammable liquid fires that has garnered a lot of attention for its role in contributing to PFAS contamination. AFFF are Class B commercial firefighting foams historically produced with PFOS or polyfluorinated precursors that break down to PFOA—the two most extensively produced and studied PFAS chemicals. Long-chain PFAS like PFOS and PFOA are of particular concern because they are recognized as persistent, bioaccumulative, and toxic (PBT).

When used, AFFF has the potential to create adverse environmental impacts, particularly if the foam is uncontrolled and reaches drinking water sources, groundwater, or surface waters. Many states and companies have been forced to deal with the aftermath of PFAS used to extinguish fires. State legislatures are considering not only how to remediate the chemicals found on these sites, but also who is responsible for the associated cleanup.

Regulatory Actions

Federal regulatory action related to the management of PFAS contamination thus far has been limited. However, on October 18, 2021, EPA Administrator Michael Regan announced EPA’s comprehensive Strategic Roadmap to tackle PFAS contamination. According to the EPA press release, the Roadmap is centered on three guiding strategies:

1. Increase investments in research.
2. Leverage authorities to act now to restrict PFAS chemicals from being released into the environment.
3. Accelerate cleanup of PFAS contamination.

Strategies are intended to advance more concrete actions that will address the entire lifecycle of PFAS chemicals. Per EPA, this specifically includes:

• Aggressive timelines to set enforceable drinking water limits under the Safe Drinking Water Act (SDWA) to ensure water is safe to drink in every community.
• A hazardous substance designation under CERCLA, to strengthen the ability to hold polluters financially accountable.
• Timelines for action on Effluent Guideline Limitations under the Clean Water Act (CWA) for nine industrial categories.
• A review of past actions on PFAS taken under the Toxic Substances Control Act (TSCA) to address those that are insufficiently protective.
• Increased monitoring, data collection, and research so that the agency can identify what actions are needed and when to take them.
• A final toxicity assessment for GenX, which can be used to develop health advisories that will help communities make informed decisions to better protect human health and ecological wellness.
• Continued efforts to build the technical foundation needed on PFAS air emissions to inform future actions under the Clean Air Act (CAA).  

Along with the Roadmap, EPA has also announced a new testing strategy requiring PFAS manufacturers to provide EPA with toxicity data and information on categories of PFAS chemicals.

Congress has also been working to develop legislation in absence of federal regulations, with more than 80 pieces of legislation introduced within the 116th Congress. The fiscal year 2021 omnibus appropriations bill included nearly $300 million to address the regulation and cleanup of PFAS split among several federal agencies, including Department of Defense (DOD) – remediation efforts; EPA – scientific, regulatory, and cleanup work; and Food and Drug Administration (FDA) – safety of PFAS in food packaging.

In addition, states are taking their own measures. In 2020, state legislatures considered over 180 bills related to PFAS, many of which have focused on efforts such as restricting PFAS in firefighting foam and consumer products, regulating PFAS in drinking water, and appropriating funds for remediation activities. For more information on state actions, visit:

• Safer States
• Environmental Council of the States

Seeking Assistance

KTL does not see the challenges associated with PFAS going away any time soon. If anything, we anticipate more and more facilities will be directly impacted by mitigation efforts and future regulatory action. Proper usage strategies, a comprehensive EMS, and a forward-thinking Emergency Response Plan will remain vital tools for companies potentially dealing with PFAS to effectively manage the associated risks.

If you are facing challenges related to PFAS or would just like a fresh set of eyes to evaluate your current environmental risk level, please contact KTL. Our staff has hands-on experience assessing environmental risks and developing strategies to minimize them to the extent possible. Our team writes Emergency Response Plans and routinely works with LEPCs to coordinate emergency response efforts and exercises to keep communities informed and safe. In addition, we have a strong network of partners that can assist with testing and remediation strategies, when necessary.

Read the entire October 18, 2021 EPA press release: EPA Administrator Regan Announces Comprehensive National Strategy to Confront PFAS Contamination.

KTL will once again be sponsoring the Midwest Environmental Compliance Conference (MECC) held by live streaming video October 26-27. MECC takes a fresh, regional approach to the increasingly difficult task of environmental compliance, permitting, enforcement, and other critical environmental issues that impact Midwest facilities and institutions. KTL will a featured presenter as part of the technical agenda:

Preparing for U.S. EPA Inspections in Region 7
Tuesday, October 26
2:00 pm – 2:40 pm CT

In recent months, regulated facilities have experienced an uptick in U.S. EPA information surveys and multimedia inspections. KTL’s Becky Andersen will present guidance on steps you can take to prepare for inspections and minmize your risk of compliance findings and enforcment actions.

Lithium-ion batteries (LIBs) are powerful, relatively inexpensive, and lightweight energy sources that are used to power a vast assortment of electronics and portable tools. Given this, it is not surprising that the number of LIBs in circulation is continuing to increase at a near exponential rate with technology advances. Subsequently, the number of fires caused by LIBs in the waste management process is also on the rise.

The Risks of LIBs

Many in industry know firsthand the risks associated with LIBs in waste/recycling. LIBs have high energy density and are made from materials that make them more prone to combustion or explosion when they are damaged. This is attributed to “thermal runaway”, a reaction in which the battery unexpectedly releases its energy and begins self-heating. This reaction can produce enough heat to ignite materials near the battery, even if the battery itself does not ignite.

The Environmental Protection Agency (EPA) is really taking notice. In a recent report, An Analysis of Lithium-ion Battery Fires in Waste Management and Recycling, EPA provides an evaluation of areas of risk associated with LIBs, as well as some excellent data and case studies of events that have occurred. The report discusses that physical damage to the LIB is one of the most common causes of thermal reaction and that much damage can occur at many different steps of the waste management system.

This information serves as a good reminder of just how risky and prevalent these batteries are—and how important it is to manage them appropriately. 

Mitigating Risk

While the EPA information is very good, the report doesn’t offer suggestions in how to improve operations and mitigate this type of risk—and it can be a very challenging risk to try to address.

KTL has staff with strong backgrounds working in recycling facility operations with hands-on experience developing strategies to minimize this risk. Solutions may be as simple as identifying and using special storage containers in designated areas, to as comprehensive as conducting onsite process evaluations to determine the best ways to segregate batteries and safely transfer them for further processing. 

KTL does not see this problem with LIB management going away any time soon—nor does EPA. We continue to explore alternatives and work with companies to mitigate risk to the extent possible. Please contact us if you are facing challenges with LIB recycling and management or would just like a fresh set of eyes to evaluate your current risk level. We can work together to make your company operations safer.

Last month, KTL published an article on the national incinerator slowdown many Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) are experiencing firsthand right now. We included some guidance for facilities being adversely impacted by the current backlog on how to proactively manage this situation based on KTL’s conversations with EPA and waste management companies.

On August 10, 2021, the U.S. Environmental Protection Agency (EPA) Office of Resource Conservation and Recovery (ORCR) issued a formal memorandum in response to the national incinerator backlog for containerized hazardous waste. The memo states that as of late July 2021, EPA has heard from over 20 states that they have received requests from hazardous waste generators for extensions to the accumulation time limit (i.e., 90 days for LQGs and 180 days for SQGs*)—and some states have begun receiving requests for second extensions.

The Agency also predicts that this backlog may not fully resolve until the end of the first quarter of 2022 due to a number of factors, including the following:

• Labor shortages resulting from COVID-19 that are impacting transportation and incinerators.
• Shutdowns for scheduled and unscheduled maintenance, as well as from winter storms in the southern U.S.
• Increased manufacturing and resulting hazardous waste generation as the economy recovers from the pandemic.

The EPA memo goes on to explain multiple existing regulatory options for various regulated entities that generate and manage hazardous waste to address the backlog. These options are primarily focused on providing storage extensions for LQGs and SQGs and granting permit authorization for increased storage capacity at RCRA-permitted transportation, storage, and disposal facilities (TSDFs). These are intended to be temporary solutions to help ensure hazardous waste continues to be safely managed during this unusual circumstance.

KTL remains engaged with EPA and numerous hazardous waste disposal vendors to carefully monitor the incinerator backlog situation. We understand the challenges facilities are facing and can help navigate the regulatory environment and implement one of the recommended storage extension strategies to keep facilities in compliance. 

* Or 270 days for SQGs if the waste must be transported 200 miles or more.

Early in the COVID-19 pandemic, many of our nation’s distilleries and ethanol plants began producing ethanol-based hand sanitizer to meet global demands. Many of these sanitizers are 60% or greater ethanol content (greater than 24% alcohol), have a flashpoint below 140^◦ F, and must be coded as D001 hazardous waste if disposed. 

Some of these hand sanitizers are going unused due to their odor, over-procurement, and other issues. This excess hand sanitizer has created some concern from various regulatory entities, including the U.S. Department of Agriculture (USDA) and Environmental Protection Agency (EPA), on compliance issues regarding the safe handling and disposal of hand sanitizer.

In response, EPA issued guidance in a June 24, 2021, letter to the USDA addressing considerations and requirements for appropriate hand sanitizer disposal. According to the memo, “…when recycled, hand sanitizer is exempt from hazardous waste regulations and does not have to ship on a Uniform Hazardous Waste Manifest. If not recycled, the disposal of alcohol-based hand sanitizers requires full cradle-to-grave management, including (but not limited to) hazardous waste notification, hazardous waste labeling, manifesting, and waste reporting to the state or the federal government.”

These requirements provide an idea of just how robust the penalties for improper (i.e., “down-the-drain”) disposal would likely be. Facilities may want to try returning the sanitizer to the manufacturer as an easy first step or continue using it for its “intended purpose,” if possible. Alternatively, KTL has the in-house expertise to identify options for hazardous waste management and/or reuse of resources that can help facilities manage excess hand sanitizer or excess hazardous waste. We are currently working to identify alternative end-use destinations for hand sanitizer, including reverse distribution or other entities that may have a use for such products.   

As discussed in Part 1 of KTL’s series on Creating Sustainable Impacts, sustainable materials management (SMM) broadens the ideas behind integrated waste management (IWM) to examine all the environmental impacts of material production and consumption, not just waste diversion or recyclability. It considers the entire lifecycle (i.e., extracting, manufacturing, distributing, using, and end-of-life management) of a product and/or process. Adopting sustainable materials management (SMM), organizations can improve their triple bottom line (TBL)—reducing their environmental impacts significantly, while still increasing profit—and contribute to the overall sustainability of our world.

Analyzing the Entire Lifecycle

These SMM solutions are most effectively identified through a lifecycle analysis (LCA). As the name implies, an LCA considers potential environmental impacts at every stage of a product’s life. An LCA can demonstrate that seemingly obvious solutions are not always the best solutions. For example, non-recyclable packaging may actually have fewer environmental impacts than recyclable packaging if it is lighter and occupies less space. Understandably, solutions like this can seem counterintuitive to waste management professionals, but this example demonstrates the importance of considering the impacts of a material across its entire lifecycle.

LCAs do not replace the basic principles underlying EPA’s Waste Management Hierarchy, especially the importance of source reduction and waste prevention. In fact, LCAs generally show that most of a product’s environmental impacts occur earlier in its lifecycle (i.e., upstream) vs, at the end of its life (i.e., downstream). Thus, choosing a different raw material—or finding ways to use less—is often more impactful than end-of-life waste management solutions.

But as LCAs will show, even this concept of reducing material use is not a given for all products. For example, food packaging is vital in reducing food spoilage and subsequent wasted food. Reducing or eliminating packaging may save material, but in the end, this may lead to more wasted food and even greater environmental impacts.

As consumer goods and related packaging get more complex, an LCA considers the most effective management for materials, including how they are used, potentially reused, and eventually discarded. This ultimately helps organizations identify environmental sustainability priorities; move past one-dimensional waste management goals; and then design, select, and manage products accordingly.

Conducting an LCA

LCAs identify and quantify inputs and outputs in a process and use data to assess the potential environmental impacts across the lifecycle. According to the Sustainable Materials Management Coalition, this allows more informed decisions that:

• Evaluate environmental consequences of a given product.
• Analyze the environmental tradeoffs associated with one or more specific products/processes.
• Quantify environmental releases to air, water, and land in relation to each lifecycle stage.
• Compare the potential environmental impacts between two or more products/processes.
• Identify potential impacts to one or more specific environmental areas of concern.
• Provide a comprehensive view of the environmental aspects of the product or process and a more accurate picture of the true environmental tradeoffs in process and product selection.

ISO 14040 defines the principles and frameworks to adequately conduct an LCA, while ISO 14044 specifies the related requirements and guidelines. An ISO LCA is conducted in the following four stages:

• Goal and Scope: What do we want to measure (i.e., product/company/service)? The LCA objectives, scope, and boundaries need to be carefully selected and clearly framed.
• Lifecycle Inventory: What data do we need? Collect all the inputs and processes to be measured (i.e., raw materials, energy used/purchased, supplier data). The inventory data is used to assess the energy, water, and materials used, as well as identified environmental releases.
• Impact Assessment: What is the impact of the lifecycle inventory? Impact assessments take the results of inventories and convert them into more easily understood impact categories, such as global warming potential or carcinogenic potential.
• Interpretation: What does this all mean? (i.e., How high are our emissions? How do our products compare? Can we improve them? Can we improve our processes? What are the biggest levers for us?)

While not all LCAs need to follow the rigors of these ISO standards, it is useful to incorporate lifecycle thinking such as this into SMM decision-making. In some cases, it might be as simple as considering the potential environmental ramifications of major steps in the value chain. Adopting this lifecycle perspective will help to provide a clearer understanding of the environmental implications of everyday choices.

Part 3 of our series on Creating Sustainable Impacts dives into one of the largest opportunities for SMM — wasted food.

According to Environmental Protection, more than 200 million tons of hazardous waste are generated each year. Much of that hazardous waste is destroyed in permitted, regulated incinerators located throughout the U.S. These incinerators are heavily monitored and have robust emissions management systems in place. In fact, the U.S. Environmental Protection Agency (EPA) considers hazardous waste incineration to be the Best Demonstrated Available Technology (BDAT) for most organic hazardous waste because of how safely and effectively hazardous constituents are destroyed and waste is converted into ash, flue gas, and heat. Frequently, these facilities also have energy recovery systems that capture BTU value from the incinerated waste, resulting in peripheral benefits from the process.

Not only does burning hazardous waste destroy toxic organic constituents, but it also reduces the sheer volume of hazardous waste. Incinerators actually reduce the solid mass of the original waste by 80-85% and volume by 95-96%, decreasing the load placed on landfills while preventing potentially dangerous materials from leaching into the environment.

Treatment, Storage, and Disposal Facilities (TSDFs)

Hazardous waste facilities that treat, store, and/or dispose of waste are known as Treatment, Storage, and Disposal Facilities (TSDFs). Hazardous waste incinerators are regulated under EPA’s Clean Air Act (CAA) and Resource Conservation Recovery Act (RCRA). These facilities must have a permit to construct and operate.

This permit authorizes the types and quantities of waste a TSDF can accept and the treatment, storage, and/or disposal activities that the facility may conduct. It also outlines operating conditions and recordkeeping procedures the TSDF must follow and regulates the emissions that result from the combustion process (e.g., organics, hydrogen chloride (HCl), particulate matter (PM), and fugitive emissions).

There are currently 22 TSDFs in the U.S. permitted to incinerate hazardous waste.

National Capacity

In December 2019, EPA published its National Capacity Assessment Report, which evaluates the nation’s long-term capacity for hazardous waste recovery, treatment, and landfilling and RCRA-permitted commercial TSDFs. According to this most recent Report, the U.S. has sufficient recovery, treatment, and disposal capacity for managing all hazardous waste generated through 2044.

Despite this analysis, however, consolidation and restructuring in the commercial hazardous waste industry has resulted in fewer RCRA-permitted energy recovery facilities, incinerators, and landfills. Additionally, new federal regulations, permit denials, statutory limits on landfills, changes in fire code requirements, allowed disposal methodologies for certain types of hazardous waste, and changing market conditions all have the potential to disrupt TSDF operations and capacity limits.

The continually changing hazardous waste market is creating a fair amount of uncertainty whether hazardous waste management capacity can actually meet demand. Implications of this are evident in the delays currently being experienced for disposal and incineration. Many Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) are experiencing a hazardous waste incineration slowdown firsthand right now. Most, if not all, of the permitted TSDF incinerator facilities are currently backlogged several months.

One waste management company KTL works with has received letters from five different incinerators stating they will not approve or accept incineration material for 60-90 days and, most likely, through the end of 2021. There is a backup of hundreds of loads of material to incinerate. Shutdowns and outages for maintenance and rebricking have caused some of these issues. Regulators retracting some storage permits has caused a glut of material in need of immediate processing, as well.

This is causing many fuel-blend/solvent-based incineration-destined waste streams to stack up. This presents great cause for concern for some businesses (i.e., LQGs) that may exceed the 90-day LQG storage limits, as set forth in the CAA. If the backlog worsens, SQGs with a 180-day limit for storing hazardous waste onsite (unless travel to dispose exceeds 200 miles) might also have reason for concern.

What You Can Do

If you are an LQG or SQG being adversely impacted by this backlog and reaching your storage limits, it is important to take the actions necessary to remove the risks of compliance penalties and fines. This starts with:

• Knowing what waste and volumes you have onsite.
• Being proactive. Do not wait to dispose of your waste and allow for plenty of time for scheduling issues. It will be easier to dispose of smaller amounts than larger quantities.
• Evaluating the different disposal alternatives (e.g., fuel blending) and making sure you have secondary disposal options.
• Documenting everything.

If you are in the situation where you are coming up against your time limits, contact your EPA Regional Administrator and ask for guidance on how to manage the situation. Considering writing a letter to the EPA Regional Administrator (ECAD/CB/RCRA) detailing hazardous waste management concerns:

• Include dates, quantities, and waste descriptions.
• Document correspondence with all incinerators you contact.
• Document all other disposal options considered and evaluated.
• Inform EPA of the ongoing plan for safe storage of hazardous waste during the lag in disposal options.  

Facilities must keep very careful and accurate records of all hazardous waste information to demonstrate appropriate management. Once the waste is eventually shipped off site, facilities should once again notify the EPA Regional Administrator with details, especially if it takes more than 30 days.

KTL is actively engaged with EPA and having ongoing conversations with hazardous waste disposal vendors to assist our customers through this difficult challenge. The risk of penalty is great, and we are working diligently to provide guidance, support, and regulatory assistance to navigate this situation as safely and compliantly as possible.

How we use materials and products is a large factor in energy use, climate change, raw material consumption, and our economic stability. Correspondingly, our consumption habits play a major contributing factor to all these statistics, as cited by the U.S. Environmental Protection Agency (EPA):

• Between 1970 and 2004, worldwide greehnouse gas (GHG) emissions increased by 70%.
• The U.S. consumed 57% more materials in the year 2000 than in 1975.
• With less than 5% of the world’s population, the U.S. was responsible for about one-third of the world’s total material consumption from 1970-1995.
• In 1900, 41% of materials used in the U.S. were renewable. By 1995, only 6% of materials consumed were renewable.
• Of all the materials the U.S. consumed in the past 100 years, more than half were consumed in the last 25 years.

As developing nations continue to industrialize and increase their material consumption, resource demands and pressures on our supply chains will only increase. According to EPA, “the implications of current patterns of material use for the environment (including climate), the economy, and our survival are profound and unsustainable.”

But it is possible to stop this pattern from continuing along this path.  

The Triple Bottom Line

Most entities are familiar with the triple bottom line (TBL) as a framework to measure performance that goes beyond traditional financial metrics to also measure social and environmental performance. At its core, the TBL is a system where economic growth is tied directly to factors that reduce environmental impacts, encourage social justice, and generate financial returns. It is also one of the best indicators of how sustainable an organization is.

By adopting sustainable materials management (SMM), organizations can improve their TBL—reducing their environmental impacts significantly, while still increasing profit—and contribute to the overall sustainability of our world.

Sustainable Materials Management vs. Integrated Waste Management

Identifying and managing wastes is important. If waste is incorrectly managed, there are regulatory compliance risks, exposure risks, and potential financial penalties that can have lasting impacts. This is what Integrated Waste Management (IWM) is about—managing materials after they have reached the end of their useful life and keeping materials out of the landfill to the extent possible.

SMM broadens the ideas behind IWM to examine all the environmental impacts of material production and consumption, not just waste diversion or recyclability. It considers the entire lifecycle (i.e., extracting, manufacturing, distributing, using, and end-of-life management) of a product and/or process.  EPA expands on this concept stating, “SMM is an approach to serving human needs by using/reusing resources productively and sustainably throughout their lifecycles, generally minimizing the amount of materials involved and all associated environmental impacts.” And, subsequently, contributing to the TBL.

EPA cites several ways SMM is different than current IWM approaches:

Regulatory Drivers

The Resource Conservation and Recovery Act (RCRA) provides the legislative basis for EPA’s SMM Program. RCRA establishes a preference for resource conservation over disposal. EPA’s Waste Management Hierarch further emphasizes source reduction/waste prevention and reuse over the options of recycling and composting, energy recovery, and treatment and disposal.

Even with these preferences, the current U.S. environmental regulatory requirements focus largely on controlling end-of-pipe emissions to the air, water, and the land. The regulatory system does not focus on sustainability; as such, current environmental regulations do not require a lifecycle focus when it comes to waste management.

Despite the lack of regulatory requirements, EPA is working to promote efforts to manage materials and products from a lifecycle perspective through the U.S. EPA Sustainable Materials Management Program Strategic Plan: FY 2017-2022 (October 2015) and the related Sustainable Materials Management: The Road Ahead (June 2009) document. The Agency reinforces the need to identify new approaches and better integrate programs to address how materials are extracted and subsequently designed, manufactured, used, and managed at end-of-life to ensure there are sufficient resources to meet not only today’s needs but also those of the future.

One of the best ways an organization can help achieve these goals is to conduct a lifecycle analysis (LCA), which considers potential environmental impacts at every stage of a product’s life. Part 2 of KTL’s series on Creating Sustainable Impacts will dive into conducting the LCA.