United States
Environmental Protection
                     Solid Waste
                     and Emergency Response
April 2000
Waste  Reduction Tips

For  Hotels  and  Casinos

In  Indian  Country

         Tribally owned hotels, motels, resorts, casinos, and bingo halls
         have numerous opportunities to prevent waste when purchasing
         supplies and food, serving customers, or cleaning guest rooms.
There are approximately 400 hotels, motels, and resorts, and 200 casinos
and bingo halls located in Indian Country. These facilities generate a tremen-
dous amount of solid waste, including food waste, glass containers, metal
cans, plastics, paper and cardboard. Hotel and casino operators have found
that waste prevention reduces purchasing costs and disposal fees. So, waste
prevention not only can help protect the environment and conserve natural
resources, it makes economic sense.

Starting a  Waste Reduction Program
Step 1 - Secure support. A successful waste reduction program requires both
a philosophical and financial commitment from facility managers. Without
this commitment, employees may be reluctant to fully embrace the program.
Designate a "green team" comprised of representatives from each facility
operation (e.g., housekeeping, kitchen, grounds keeping, purchasing) to pro-
vide support and input for the waste reduction activities.
Step 2 - Conduct a waste characterization study (waste assessment or
audit). This study will help determine waste stream composition by identify-
                     ing waste volumes, existing waste management
                     practices (e.g., reuse, recycling, disposal), and the
                     associated costs. It will help identify which por-
                     tions of the waste stream could be recycled,
                     reduced, or eliminated altogether. A waste audit
                     also will help to identify disposal costs. Using a
                     full cost analysis approach, taking into account
                     complete lifecycle costs such as procurement, use,
                     and final disposal, can further clarify the true costs
                     of different materials and practices.

                                            (continued on page 4)

Turning  Solids
into  Soil
Eastern Band of Cherokee
Indians of North Carolina
The Cherokee Indian Reservation, located in western
North Carolina, attracts 5 to 8 million tourists annual-
ly. After opening its casino in November 1997, the
Eastern Band of Cherokee Indians (EBCI) initiated a
pilot project, assisted by $69,500 in EPA grant fund-
ing, to evaluate windrow and particle screening
processes for composting food waste from their new
casino and its three restaurants. EBCI already had an
established composting program for wastewater treat-
ment sludge (biosolids) and vegetative waste, and
used their experience to develop a progressive system
to compost food waste. EBCI collects approximately
1,200 pounds of food waste a day from the casino
and its restaurants for composting. The Tribe distrib-
utes the  final product to landscapers, nurseries, and
individual homes both on and off reservation.
EBCI shares information about their program through
newsletters and newspaper articles. For more infor-
mation, contact John D. Long,  sanitation manager, at
828 497-6977.
Once is Not Enough
at Mohegan  Sun
Mohegan Indian Tribe
of Connecticut
The Mohegan Tribe of Indians have experienced
tremendous success with their waste management
efforts. The Tribe's Integrated Pollution Prevention
(P2) Program resulted in recycling more than
44 percent of the solid waste stream of the Mohegan
Sun Casino and Tribal Office in 1997; that's twice
the average recycling rate for towns and cities in

Before the casino was built, the Mohegan P2 Team
transformed waste disposal costs into revenue
through the sale of recyclable materials such as cor-
rugated cardboard, paper, plastic, cans, and glass.
Even more waste was prevented by reusing clothing,
toys, books, and other household materials. The casi-
no itself was constructed through adaptive reuse of
existing, older buildings. Since the casino's opening,
the Tribe has pursued additional environmental initia-
tives. Automotive emissions from reservation visitors,
for example, are voluntarily offset by the Tribe's pur-
chase of emission offset credits from other facilities.
  1997 Waste Stream Assessment
                                                                           ~_7%  Cooking
                                                                             ^^^ Grease

                                  /  Trash
                                                       Courtesy of the Mohegan Indian Tribe of Connecticut
Food waste was a major problem for the Tribe, con-
stituting 37.5 percent of the waste stream before
waste reduction efforts. The Mohegans now send
more than 2,190 tons of food waste produced each
year in the casino's restaurant operations to an off-
reservation piggery for use as feed, avoiding
$184,000 in hauling and landfill disposal fees. Pig
waste and bedding from the piggery are composted

and reimported onto the reservation for landscaping
use, thus "closing the loop" on food wastes. The pig-
gery does not need to grow grain to feed the pigs and
the Tribe does not need to purchase peat moss for
mulch. The Tribe also sells waste fat, bones, and
grease to a Tenderer for use in the production  of ani-
mal feed and other products. For example, the sale of
approximately 52 tons of cooking grease earns
$3,000 annually and avoids $84 a ton in disposal
fees, saving another $4,368 a year.

Pollution prevention education of employees and
contractors is a key aspect of the Mohegan program.
More than 6,000 individuals involved in waste man-
agement have been through a P2 training program.
The Mohegans also practice environmentally prefer-
able purchasing, buying recycled-content products
whenever possible. For more information, contact
Dr. Norman Richards at 860 204-6112.
Waste Isn't Worth
the  Gamble  at
Mashantucket Pequot Tribe
of Connecticut
Eight years ago, Foxwoods was nothing more than a
bingo hall housed in a two-story building in the
Connecticut woods. Today, Foxwoods Resort and
Casino is bigger than most small towns, employing
11,500 people and hosting more than 55,000 visitors
during  peak season. According to Mike Van Splinter,
Foxwoods' director of environmental services, the
Mashantucket Pequot Tribe was able to incorporate
environmental designs from the start—rather than
having to retrofit an established resort complex—
because the Tribe was building in an undeveloped,
rural environment. The Tribe made environmental
protection a priority well before Foxwoods reached
its current size and popularity.

According to Van Splinter, Foxwoods recycles
everything that is practical, including glass, steel,
aluminum, plastic, and paper. To find the most prof-
itable outlets for common materials such as corrugat-
ed cardboard, Foxwoods issues Requests for
Proposals (RFPs) to secure vendors. To ensure maxi-
mum return on recyclables, Foxwoods purchased a
baler to pack the corrugated cardboard and a combi-
nation can rinser/crusher to process steel cans. The
facility uses more than 260 tons of steel cans in one
year, but  it recycles about 99 percent of them. The
baler and rinser/crusher minimize the volume of
Foxwoods' recyclables, increasing both dollar return
and the number of vendors willing to accept the
materials. To further facilitate its recycling efforts,
the Tribe is creating two "mini-MRFs," or materials
recovery  facilities, which, in addition to processing
Foxwoods' materials,  also will accept materials from
surrounding areas.

The Tribe also has employed a number of waste pre-
vention measures. It has, for example, arranged for
used wooden pallets to be picked up by their vendor
and house wine to be delivered in bulk recyclable bar-
rels rather than individual bottles. In addition, the
Tribe composts its yard trimmings on site and is look-
ing into new technology that can convert its food resid-
uals into  energy. To reduce the weight of its waste, the
Tribe has invested in dewatering equipment, common-
ly used by the pulp  and paper industry, to extract water
from its waste stream (water often comprises more
than 30 percent by weight of the waste stream).

Van  Splinter cites two important aspects of
Foxwoods' waste management practices: separation
of recyclables at the point of generation and a strong
commitment from the Tribe and the Foxwoods staff.
If you have questions about Foxwoods' waste man-
agement  practices, contact Mike Van Splinter at

Starting a Waste Reduction Program
(continued from page 1)
Step 3 - Develop a waste reduction plan. Based on
the waste assessment findings, set waste reduction
priorities and goals for the facility. Goals should iden-
tify the extent to which each waste stream is to be
reduced, reused, or recycled (e.g., recycle 20 percent
of corrugated packaging).

Step 4 - Implement the program. Once waste
reduction goals have been set, educate employees on
      the waste reduction activities that will become a part
      of their jobs or responsibilities. Continually monitor,
      evaluate, and fine-tune waste reduction efforts by
      identifying more effective and efficient methods of
      reducing waste, increasing reuse and recycling, and
      identifying additional opportunities to remove or
      eliminate materials from the waste stream.
   Three  R's Checklist:
 * Buy in bulk to avoid excess packaging.

 * Provide recycling containers in guest rooms and
   common areas to promote recycling.

 * Recycle used bingo cards or purchase reusable

 * Compost food, paper, and grass clippings and
   other yard wastes, and chip larger branches for
   use as mulch.

 * Implement an integrated pest management
   system to reduce the use of pesticides.

 * Replace disposable items with reusable ones
   (e.g., ceramic mugs versus Styrofoam cups).

 * Replace paper hand towels in rest rooms with
   hand dryers or cloth towel machines.

 * Buy recycled-content products (e.g., paper
   towels, office paper, printer toner cartridges).
      * Use plastic lumber made from recycled
        plastic for benches, tables, fencing, signs
        and car stops.

      * Talk to a local pallet vendor about reusing,
        reconditioning, or recycling pallets.
       Linens washed daily in hotels and motels around
       the world use millions of gallons of water. If you are
       staying with us for more than one night and feel it is
       unnecessary to change you bed linens every day,
       please leave this card on your pillow. Your bed will be
       made up and you will be helping to conserve water.
       Thank you.

Tips   for  Reducing  Waste
* Sell used decks of cards in casino gift shops as
  souvenirs (after drilling or cutting corners to prevent
  unauthorized reintroduction to game tables) or leave
  them in hotel rooms for your guests' use. The Prairie
  Island Indian Community in Minnesota donates their
  used cards to retirement homes, churches, scout
  troops, and other charitable organizations.

* Reuse—or donate for reuse—shipping, food, and
  other types of containers. The Lac du Flambeau
  Band of Lake Superior Chippewa Indians reuses its
  casino's small plastic coin containers in art projects
  at a local museum and cultural center, and five-gal-
  lon plastic containers find new uses at the fish
  hatchery and other tribal enterprises.

* Compost food, paper, and landscape trimmings on
  site and use the resulting nutrient-rich humus as a
  soil amendment or mulch.

* Purchase cleaning products in bulk or in concen-
  trated forms. Educate staff on the proper mixing of
  concentrates to avoid waste and save money. The
  Lac du Flambeau Band of Lake Superior Chippewa
  Indians refills individual cleaning product bottles on
  housekeeping carts from a centrally located supply
  dispenser station. The cleaners are nonphosphated
  products bought in bulk, and reduce nutrient load-
  ings to the environment.

* Install refillable shampoo and soap dispensers in
  bathrooms rather than using disposable plastic bot-
  tles or individual bars of soap.

* Offer guests the option of reusing their linens and
  towels. The Bois Forte Band of Chippewa provides
  guests staying more than one night with the option
  to reuse bed linens and bath towels, which helps
  reduce water usage.

* Landscape with indigenous plants adapted to the
  local climate and soil conditions. In dry climates,
  water requirements are reduced
  when use of water dependent
  plants such as lawn grasses is
  minimized. In other climates,
  mulching helps plants retain
  moisture as well as nutrients.
  Planting indigenous species
  rather than normative ornamen-
  tal ones also reduces the need
  for chemical pesticides and fer-
  tilizers because the plants are
  adapted to the area.

* Become a WasteWise partner.
  Partners commit to reduce
  waste, establish waste reduction
  goals, and track their progress.
  Many tribes have already
  become partners quickly and
  easily by signing up online at
  or calling 800 EPA WISE
* Use Environmental Protection Agency guidelines
  for purchasing goods for your business. EPA
  programs such as the Comprehensive Procurement
  Guidelines Program  and
  Environmentally Preferable Purchasing program
   outline criteria for
  purchasing products with high recycled content and
  a reduced effect on the environment.

* Buy long-lasting, energy-efficient fluorescent light
  bulbs, energy-efficient computers and appliances,
  and water-efficient fixtures. Consider joining EPA's
  Greenlights, Energy Star , and Water Alliances for Voluntary Efficiency
  These voluntary partnership programs offer techni-
  cal assistance, publications, software, and other
  tools to help make your facilities more energy
  and water efficient.

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American Hotel and Motel Association. 1993. Recycling
and Source Reduction for the Lodging Industry.
Washington, DC. Available by calling: 202 289-3100.

California Integrated Waste Management Board. 1994.
Waste Reduction in Hotels and Motels. Sacramento, CA.
Available by calling: 800 553-2962.

Georgia Hospitality Environmental Partnership. 1996.
Waste Reduction in Hotels and Motels: A Guide for
Hotel and Motel Managers. Decatur, GA. Available by
calling: 404 371-2405.

Greater Chicago Recycling Industry Council. 1994. Eat,
Drink, and Recycle: A Guide to Recycling for
Restaurants, Bars, and Clubs. Chicago, IL. Available by
calling: 312 493-2200.
INFORM, Inc. 1996. Less Garbage Overnight: A Waste
Prevention Guide for the Lodging Industry. New York,
NY. Available by calling: 212 361-2400.

Montana Pollution Prevention Program. 1995. Pollution
Prevention in the Hospitality Industry: A Tool Kit for
Environmental Management. Bozeman, MT. Available
by calling: 406 994-3451.

National Restaurant Association and U.S. Department of
Agriculture.  1997. Food Donation: A Restaurateur's
Guide. Washington, DC. Available by calling:

NYC Department of Sanitation, NYC Department of
Environmental Protection, and the Hotel Association.
1994. Make Waste an Unwelcome Guest: The NYC
Guide to Hotel Waste Prevention. New York, NY.
Available by faxing: 212 837-8162.