Review of Industrial
Waste Exchanges
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ACKNOWLEDGEMENTS
This project was produced by the Waste Minimization Branch, Office of Solid Waste.'
For further information contact Patrick Pesacreta, Project Manager, or Donna Perla, Branch
Chief, at: U.S. Environmental Protection Agency, Waste Minimization Branch, 5302W, 401
M Street SW, Washington, D.C. 20460. Or you may call the Resource Conservation and
Recovery Act (RCRA) Hotline at: 1-800-424-9346.
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CONTENTS
EXECUTIVE SUMMARY
MAJOR FINDINGS - NON-FEDERAL EXCHANGES
MAJOR FINDINGS - FEDERAL EXCHANGES
RECOMMENDATIONS
Chapter 1 - BACKGROUND
INTRODUCTION
BACKGROUND
1
2
2
4
4
Chapter 2 -PROFILES OF CURRENT NORTH AMERICAN WASTE EXCHANGES 7
OVERVIEW 7
NATIONAL MATERIALS EXCHANGE NETWORK (NMEN) 14
OPERATIONS OF INDIVIDUAL WASTE EXCHANGES 16
Southeast Waste Exchange (SEWE) 16
Iowa Waste Reduction Center (IWRC) 17
Industrial Materials Exchange Service (IMES) 18
California Materials Exchange (CALMAX) 18
Resource Exchange Network for Eliminating Waste (RENEW) 19
Pacific Materials Exchange (PME) . • . ' 20
Canadian Chemical Exchange (CCE) ' .20'
Canadian Waste Materials Exchange (CWME)/Ontario Waste Exchange
(OWE) .' 21
California Waste Exchange (CWE) 22
FEDERAL WASTE EXCHANGES CONTACTED 22
Department Of Defense . 22
Other Federal Agencies , 23
Chapter 3 DESCRIPTION OF WASTES AND CUSTOMERS OF WASTE
EXCHANGES 25
WASTES LISTED AND TRANSFERRED BY WASTE EXCHANGES 25
WASTES EXCHANGED 27
TYPES. OF WASTES EXCHANGED •'•'._. . 28
ONE TIME VERSUS ON-GOING EXCHANGES OF MATERIALS 29
TYPES OF COMPANIES USING WASTE EXCHANGES " 29
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CONTENTS (continued)
Chapter 4 - EVALUATING SUCCESS 31
WASTE EXCHANGE GOALS 31
MEASURING SUCCESS IS DIFFICULT 32
Number of Listings 32
Number of Exchanges Accomplished , 33
Ratio of Exchanged Waste to Listings 34
Cost of Exchange per Ton Exchanged 34
Number of Inquiries 35
Savings to Business from Waste Exchange 35
Educational and Outreach Activities 36
IMPORTANT SUCCESSES NOT EASILY MEASURED 36
Chapter 5 - FUNDING MECHANISMS 38
TIPPING AND WASTE FEES 39
OTHER PUBLIC SOURCES OF FUNDING . 39
CATALOG SUBSCRIPTION FEES 40
LISTING FEES 40
TRANSFER FEES 40
REVENUES FROM ADVERTISEMENTS 41
Chapter 6 - RELATIVE MARKET POSITION OF WASTE EXCHANGES 42
WASTE EXCHANGES 42
BROKERS 42
CORPORATE SECONDARY-MATERIALS MARKETING , 43
RELATIVE MARKET STRENGTHS OF INDIVIDUAL WASTE
EXCHANGES 44
Chapter 7 - WASTE EXCHANGES AND ENVIRONMENTAL LIABILITY ISSUES 45
RCRA LIABILITY 45
CERCLA LIABILITY 46
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CONTENTS (continued)
Chapter 8 - ROLES OF WASTE EXCHANGES . '•' J
ROLES OF WASTE EXCHANGES - ,
Providing Information to Identify Potential Trades
Matching Buyers and Sellers
Facilitating Reuse of Wastes as Secondary Material
Facilitating Market Development
Providing Education and/or Technical Assistance
Relating Recycling to Pollution Prevention and Other Waste
Minimization Options
FACTORS INFLUENCING SUCCESS/FAILURE
Chapter 9 - FINDINGS AND RECOMMENDATIONS
GENERAL FINDINGS
Current Operations
Types And Amounts Of Wastes Transferred
Funding . •
Benefits To Participants
Benefits To State/Local Governments
SPECIFIC FINDINGS
. Non-Federal Waste Exchanges
Federal Waste Exchanges •
RECOMMENDATIONS
49
49
49
49
50
50
50
51
51
53
53
53
53
54
54
55
56
56
56
57
NOTES
59
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EXECUTIVE SUMMARY
Waste exchanges were established to facilitate recycling and reuse of industrial and
commercial waste. This study reviews the current activities and status of North American
waste exchanges, including marketing systems for waste and surplus from the federal
government. It also provides recommendations for encouraging greater levels of reuse and
recycling through waste exchanges.
MAJOR FINDINGS - NON-FEDERAL EXCHANGES
• The service provided by waste exchanges varies significantly. Most exchanges list
waste available and waste wanted. The listings most commonly appear in a catalog
format, however, some exchanges are beginning to utilize on-lme computer information
systems While some exchanges simply manage these listings and respond to requests
for information, others are proactive in: ,
seeking companies which might need their services
matching generators with companies that need materials
-.,'." providing outreach through workshops, bulletins, and advertising
- . providing on-site plant assessments of reuse and recycling opportunities
referring generators to. state technical assistance centers to evaluate waste
reduction opportunities.
• More non-hazardous than hazardous wastes are,transferred through waste exchanges;
liability concerns and RCRA restrictions limit reuse and recycling of hazardous wastes
through exchanges. ,
• • Waste exchanges tend to receive listings of wastes which are more difficult to transfer
or have a lower value than those transferred through specialized brokers (dealing
generally with narrow, higher-profit market segments) or directly sold by companies
(which often have their own networks for large volume or continuously-produced
process wastes). ' ,
• Waste exchanges are small, ranging from;only a fraction of one person's time to six
full-time people, and have budgets between $10,000 and $200,000. Some serve a
single state while others are regional.
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While individual waste exchanges are relatively small, the number of waste exchanges
is rapidly increasing. Many states are now forming their own exchanges in response to
concerns about disposal and treatment capacity.
A major reason for the increase in the number of exchanges appears to be the
establishment of the National Materials Exchange Network (NMEN). This network is
a national, computerized listing service, funded by EPA, in which all but two current
U.S. exchanges participate. Participation in NMEN might reduce the administrative
burden of establishing, managing, and publicizing listing services for some local
exchanges.
Measures of "success" for waste exchanges are not simple. Financial self-sufficiency
appears to be an unrealistic goal, since so many of the wastes listed have a low value or
are difficult to exchange. Other measures (e.g., number or volume of listings, number
of transactions or volumes of waste transferred) all have limitations. In particular, the
value of educational, promotional and technical assistance services with respect to reuse
and recycling is difficult to assess. By some measures (e.g., cost/ton transferred),
however, waste exchanges appear to compare well to other forms of publicly-funded
reuse and recycling efforts.
MAJOR FINDINGS - FEDERAL EXCHANGES
• DoD's Defense Reutilization Marketing Organization (DRMO) has an extensive system
for the sale and/or reuse of recyclable materials (hazardous and non-hazardous).
Materials turned in by individual DoD facilities are first made available within DoD
and then offered externally.
• GSA's waste/surplus system is less extensive in the area of hazardous waste and not as
well differentiated as the DoD system. It nonetheless offers substantial volumes of
surplus/waste for reuse and recycling.
RECOMMENDATIONS
• Consider mechanisms to limit liability for exchanges and users of exchanges and clarify
regulatory issues regarding the reuse and recycling of hazardous waste. Currently, a
company might make a good-faith effort to exchange a hazardous material with another
company, but will continue to be held financially responsible for any future mishandling
of that material by the receiving company or any other company. The effect of this
high-risk scenario is that companies are forced to. forgo the potential savings from
avoided disposal that an exchange could provide, in order to protect against potential
future liability. .
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Promote the integration of non-federal and federal waste exchange information systems,
including the sharing of listings and the promotion of exchanges in both directions. By .
creating a larger marketplace, an integrated system could be a magnet for increased
private sector participation in exchanges.
Continue support for a national information network. Many of the new arid developing
exchanges are depending on the advertising potential of a national network.
Additionally, the presence of a national information service allows exchanges to focus
on more proactive services to match users and donators of wastes.
Consider alternatives (e.g., grants) to support the development/continuation of model
waste exchanges, providing more proactive services (e.g., education, technical ;
assistance, direct marketing of services). Such model approaches should include some
provision for market-testing of exchange services. Possible examples might include a
competitive approach such as that utilized by the Iowa Waste Reduction Center, or a
requirement that the waste exchange receive a certain portion of its funds from non-
governmental sources (fees, private-sector matching funds, or other alternatives).
Interested exchanges should be encouraged to propose their own market-testing
approaches. . - . . -'
Consider additional ways to promote the visibility of all waste exchanges in the
business community and among trade groups.
Consider an in-depth analysis^of the exchange of hazardous wastes, including: who is
making the trades, and the types of wastes which can be most effectively transferred
via waste exchanges in spite of the potential regulatory barriers.
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Chapter 1
BACKGROUND
INTRODUCTION
Waste exchanges provide a mechanism for recycling and reusing industrial waste. In ;
general, waste exchanges try to "match-up" generators of waste with companies interested in
recycling or reusing these materials. The benefits of waste exchanges include: reduced
disposal costs; reduced disposal quantities; reduced demand for natural resources; and, a
potential increase in the value of wastes. - This document examines the effectiveness of
industrial waste exchanges as a tool, to minimize waste disposal and to encourage the reuse and
recycling of valuable materials. :
The focus of this investigation is the potential for increasing the role of waste
exchanges. In researching current waste exchange activities, both private and government "•-"
exchanges were examined. Data regarding exchanges were obtained from literature searches
as well as inndepth interviews with operators of several exchanges. Data gathering,focused on
the following topics: . ~
Operational requirements, constraints
Users of waste exchanges
Typical wastes exchanged -
Impact of government regulations : . ,
Alternative methods of exchanging wastes -. . •
Measuring success
Funding sources ,
Marketing efforts . ..
Impact of regional, national exchange efforts.
BACKGROUND
During World War II, waste exchanges were established to conserve valuable resources
and equipment. The earliest known waste exchange, the National Industrial Materials •'._ ,
Recovery Association, was established by the British in 1942. When World War II ended,
most exchanges had met their resource conservation goals and ceased to exist.
In 1972, the concept of promoting transfers of industrial wastes was reborn in Europe.
In that year, the European chemical industry formed two exchanges; the Federation of Belgian
Chemical Industries and the Association of Netherlands Chemicals Industries. Both of these
exchanges took the form of information clearinghouses that listed wastes available and
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requested. Neither exchange actively worked to facilitate transfers between potentially
interested parties. Nevertheless, estimates from the Netherlands exchange, the VNCI Waste
Exchange, suggest that 30% of their listings resulted in successful transactions.
Shortly after these two exchanges commenced operations, other European nations
began to recognize the environmental benefits of promoting the reuse of industrial wastes and
established their own exchanges. From 1972 to 1976, approximately 12 exchanges were
established in Europe. Among these were exchanges formed to serve industrial waste
generators and potential users in Austria, Finland, Germany, Italy, Norway, Sweden, and
Switzerland. Notably, an international waste exchange was established in 1975 by a federation
of industries hi Denmark, Finland, Norway, and Sweden. By 1978, France had joined the
growhig number of European exchanges.
At the same tune, nations outside of Europe also began to consider establishing waste
exchanges to help conserve resources and reduce the volume of wastes requiring disposal.
During the early to mid 1970s, numerous waste exchanges were set up in New Zealand. The
government of Australia in 1977 set up an Industrial Waste Exchange which still operates
today. A waste exchange was also set up hi Israel during the late 1970s.
The first North American Waste Exchanges were established in 1973. Zero Waste
Systems in California was the first U.S. exchange. Concurrently, ORTECH International, a
provincial research organization hi Ontario, Canada, established an exchange that is still
operating as the Canadian Waste Materials Exchange (CWME). This exchange has become
the hub of a growing network of active Canadian waste exchanges currently serving Ontario,
Manitoba, Alberta, and British Columbia. CWME is funded by the Canadian government, but
it also receives some supplemental funding from industry participants.
By the mid to late 1970s, waste exchanges were beginning to proliferate in the United
States. In 1975, exchanges began in Boston and St. Louis. By the end of 1976, waste
exchanges were operating hi Iowa, Illinois, and Georgia. Additional exchanges were open in
Ohio, Minnesota, New York, New Jersey, Indiana, Texas, North Carolina, and Washington
State by the end of 1978.
Most of these early waste exchanges served as information exchanges and did not
actively pursue matches of industrial waste generators and users. While some of the early
exchanges operated for-profit, most were not-for-profit. The for-profit exchanges tended to
deal solely with surplus inventories, while the not-for-profit exchanges facilitated transactions
in surplus inventories, off-spec products, and waste products. Hazardous wastes were
included on many of the waste exchanges and, hi fact, some exchanges dealt primarily with
hazardous wastes. Waste exchanges were generally limited to trades on a regional rather than
national basis. Funding for the early exchanges came from several sources: government
(federal, state, and local), private donations, listing fees, and subscription fees. In general,
exchanges that specialized in higher value materials could survive without government
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funding; exchanges working to create transactions with impure, low value, or hard-to-place
materials required ongoing government support.
The initial waste exchanges established during the 1970s, with the exception of the
Southeast Waste 'Exchange (SEWE) and the Canadian Waste Materials Exchange (CWME),
are now closed. They succumbed to reduced financial support from governments or to
changes in solid waste disposal regulations that severely restricted transactions involving
hazardous wastes. The January 4, 1985 revisions to the regulations governing hazardous
waste reuse and recycling (Resource Conservation and Recovery Act [RCRA]) provided
definitions for several methods of reuse and recycling arid types of secondary materials. In
addition, the preamble to this rule contained guidance on distinguishing shani reuse and
recycling situations (50 FR 638). After promulgation of this new regulatory framework, it
became necessary for firms engaged in hazardous waste reuse and recycling to take steps to
ensure that their reuse and recycling operations were legitimate and protective of human health
and the environment. The unintended result of this change was that many companies stopped
using waste exchanges for hazardous wastes because cradle to grave liability made the
potential risk too great. Generators were also discouraged from using waste exchanges
because the time it took to transfer items could often exceed the limits for hazardous waste
storage established under RCRA. The early 1980s also marked a time when government
funding (federal and state) for solid waste programs was reduced dramatically. It became
increasingly difficult to obtain funding for waste exchanges.
The effect of these changes can be documented. A review of the North American
Waste Exchanges listed in a 1980 EPA Report, Waste Exchanges: Background Information
(SW-887.1), indicated that .many of the exchanges listed in this report have ceased operation.
In recent years, computers and telecommunications technology have increased the ease
with which waste exchanges can.be set up and managed. For instance, a national computer
bulletin board is linking regional markets together. States and municipalities are starting local
exchanges, hi contrast to the larger regional exchanges that were popular in previous years.
Waste exchanges began as information sharing entities, but have recently begun to actively
seek wastes and markets for those wastes.
, Throughout their history, waste exchanges worldwide have faced similar problems as
they attempt to expand and grow. As the waste exchange concept grows and becomes part of
standard business operating procedures, today's operational problems (e.g. funding,
marketing, liability Concerns) will need to be solved for waste exchanges to succeed.
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Chapter 2
PROFILES OF CURRENT NORTH AMERICAN WASTE EXCHANGES
OVERVIEW
• ' • . • . ',"-->-
More than fifty waste exchanges are currently operating in North America, providing a
mechanism for companies generating or hi need of waste materials to identify possible markets
for waste sources as well as for raw materials. Exhibit 2-1 shows the locations of waste
exchanges currently operating hi North America. Exhibit 2-2 is a directory of these
exchanges. The number of exchanges appears to be increasing rapidly, especially with the
recent creation of a government-funded, national information system. Waste exchanges
generally promote the transfer of a wide variety of waste streams. ,
„ Waste exchanges have a variety of approaches for facilitating the transfer or sales of
wastes. The most common (but not universal) mechanism is a catalog or other listing system
through which companies can learn about each other's available or needed wastes. Providing
a passive listing service of this kind requires .less staff and financial resources (many waste
exchanges have only one full-time employee, or a fraction of one person's time). Most waste
exchanges also joined a new national computerized listing system funded by EPA, the National
Materials Exchange Network (NMEN). NMEN began operating early in 1993. Some waste
exchange listings include names and contacts for the companies listing wastes or needs so that
an interested company can make direct contact without going through the waste exchange.
However, waste exchanges generally- require the interested party to contact the exchange to
obtain that information. This is done to be able to track transactions, to determine levels of
interest hi particular materials, or to obtain the information necessary to charge fees,of various
kinds.
Few waste exchanges have the resources to take a more proactive approach. Some
exchanges seek out companies which potentially might generate, or have a use, for, common
waste streams. Few even provide on-site plant assessments to help companies identify their
reuse and recycling opportunities. These assessments also can include evaluation of waste
reduction opportunities, or referrals to state pollution prevention technical assistance
"programs. Other exchanges provide training and educational services on reuse and recycling,
or advertise on the benefits of reuse and recycling. As expected, these more proactive
approaches require staff with considerable expertise about reuse and recycling opportunities
and often involve field staff whose primary role is to pursue possible matches of needs and
supplies. , - -
As is apparent from a glance at the map (Exhibit 2-1), there are waste exchanges in
most of the U.S. states and some Canadian provinces. Some of these are very small, less
active services limited to the particular state. Others provide service to, and receive
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Exhibit 3-1
Location of Waste Exchanges Operating in North America
NORTH
ATLANTIC
OCEAN
NORTH
PACIFIC
OCEAN
Haiti Dominican
Jamaica Rtpubfc
CARIBBEAN SEA
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Exhibit 2-2
Directory of Waste Exchanges Operating in North America
(As of March, 1994)
Note: [] indicates primary market area.
CANADA
Alberta Waste Materials Exchange (AWME)
Ms. Cindy Jensen
Building 350
6815 - 8th Street, NE.
Calgary, AB T4N 6K8
403297-7505 FAX 403 297-7548
British Columbia Waste Exchange (BCWE)
Ms. Jill Gillette " '
Suite 102, 225 Smithe Street V6B 2X7
Vancouver, BC V6B 2X7
604 731-7222 (will change March 25th)
FAX 604 734-7223 (will change July 1st) . '
[BC]
Canadian Chemical Exchange (CCE)
Mr. Phillipe La Roche
P.O. Box 1135
Ste-Adele, QU JOR 1LO
800561-6511 FAX 5 14 229-5344
[Canada]
Canadian Waste Materials Exchange (CWME)
Dr. Robert Laughlin
2395 Speakman Drive
Mississauga, ON L5K 1B3
905 822-4111 ext. 265
.FAX 905 823- 1446
[Canada] , .
Manitoba Waste Exchange (MB WE)
Mr. Todd Lohvineko
1812-330 Portage Avenue
Winnipeg, MB R3C OC4
204942-7781 FAX 204 942-4207
[MB]
Ontario Waste Exchange (OWE)
Ms. Mary Jane Henley
2395 Speakman Drive
Mississauga, ON L5K 1B3 -
905 822-4111 ext. 656 or 358
FAX 905 823-1446
[Ontario]
Durham Region Waste Exchange
Ms. Elaine Collis
Region of Durham
Public Works Department
Box 603, 105 Conaumers Drive
Whitby, ON LIN 8A3
416668-7721 FAX 416 668-2051
[Durham,ON]
Essex-Windsor Waste Exchange
Mr. Steve Stephenson
Essex-Windsor Waste Management Committee
360 Fairview Avenue West
Essex, ON N8M 1Y6
519 776-6441 FAX 519 776-4455
[Essex-Windsor, ON]
Waterloo Waste Exchange
Mr. Mike Birett
Region of Waterloo
925 Erb Street West
Waterloo, ON N2J 3Z4
519883-5137 FAX 519 747-4944
[Waterloo:ON]
Quebec Materials Waste Exchange (QMWE)
, Dr. Francois Lafortune
14 Place Du Commerce,
Bureau 350
Ile-Des-Soeurs, QUB3E 1T5
514 762-9012 FAX 514 873-6542
[QU]
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Saschachewan Waste Materials Exchange
(SWME)
Mr. Eugene Ogu
515 Henderson Drive
Regina, SK S4N 5X1
306787-9800 FAX 306 787-8811
ISK]
UNITED JSIAIES
Alabama Waste Materials Exchange (ALME)
Ms. Linda Quinn
404 Wilson Dam Avenue
Sheffield, AL 35660
205383-5630 FAX 205 383-
fALJ
Alaska Materials Exchange (AME)
Ms. Andrea Meyer
441 W. 5th Avenue, Suite 300
Anchorage, AK 99501
907 272-5364 FAX 907 272-4117
Arizona Waste Exchange (AZWE)
Mr. Barrie Herr
4725 E. Sunrise Drive, Suite 215
Tucson, AZ 85718
602299-7716 FAX 602 299-7716
IAZJ
Arkansas Industrial Development
Commission (AIDC)
[IL IMES participator]
Mr. Ed Davis
1 Capitol Mall, Room 4B215
Little Rock, AR 72201
501 682-1370 FAX 501 682-7341
[AR]
California Waste Exchange (CWE)
Ms. Claudia Moore
P.O. Box 806
Sacramento, CA 95812-0806
916 322-4742 FAX 916 327-4495
[CA Hazardous Waste]
California Materials Exchange (CALMAX)
Ms. Joyce Mason
c/o California Integrated Waste Management
Board
8800 Cal Center Drive
Sacramento, CA 95826
916 255-2369 FAX 916 255-2220
[CA Solid Waste]
Florida Recycling Material System (FRMS)
Dr. Paul Still
2207 NW. 13th Street, Suite D
Gainsville, FL 32609
904392-6264 FAX 904 846-0183
[FL]
Hawaii Materials Exchange (HEMEX)
Mr. Jeff Stark
P.O. Box 1048
Paia, HI 96779
808579-9109 FAX 808 579-9109
[HI]
Hudson Valley Materials Exchange (HVME)
Ms. Jill Grouper
P.O. Box 550, 1 Veterans Drive
New Paltz, NY 12561
914 255-3749 FAX 914 255-4084
[NY, Hudson Valley]
Industrial Materials Exchange (IMEX)
Mr. Bill Lawrence
506 2nd Avenue, Room 201
Seattle, WA 98104
206296-4899 FAX 206 296-3997
[OR,WA]
Indiana Materials Exchange
Mr. Jim Britt
P.O. Box 454
Carmel, IN 46032
317 574-6505 FAX 317 844-8765
[IN]
10
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Industrial Materials Exchange Service (EMES)
Ms. Diane Shockey
P.O. Box 19276
Springfield, IL 62794-9276
217 782-0450 .FAX 217 782-9142
[AR,IL,KY,MO,OK,WI]
Intercontinental Waste Exchange (TWE)
Mr. Ken Jucker
5200 Town Center Circle, Suite 303
Boca Raton, PL 33486
800 541-0400 FAX 407 393-6164
[US, Canada, Carribean]
Iowa Waste Reduction Center (IWRC)
Ms. Susan Salterberg
75 BRC-University of Northern Iowa
Cedar Falls, IA 50614-0185
319273-2079 FAX 319 273-2926
PA]
Kansas Materials Exchange (KME)
Mr. Russell Fallis, Jr.
P.O. Box 152 . -
Hutchinson, KS 67504-0152 . •
316662-0551. ^FAX 316 662-1413
[KS]
KY Department of Environmental .
Protection (KY DEP)
Mr. Charles Peters
14RileyRoad
Frankfort, KY 40601 ,
502564-6716 FAX 502 564-4049
[KY] : .
Future Minnesota Alliance Participators: * .
* Businesses Allied to Recycle through
Exchange and Reuse (BARTER)
Mr. Jamie Anderson
2512 Delaware Street SE.
Minneapolis, MN 55414
612627-6811 FAX 612 627-4050
[MN]
* Minnesota Technical Assistance Program
Materials Exchange (MNTAP)
Ms. Helen Addie
1313 5th Street, Suite 207
Minneapolis, MN 55414
612 627-4555 .FAX 612 627-4769
[MN]
* Ohnstead County Materials Exchange
(OCME)
Mr. Jack Stanfield
2122 Campus Drive SE.
Rochester, MN 55904 "
507 285-8231 FAX 507 287-2320
[MN]
* Review Materials Exchange
Mr. AdamHaecker
345 Cedar Street, Suite 800
St, Paul, MN 55101
612 222-2508 FAX 612 222-8212
[MN]
* Southeastern Minnesota Recyclers
Exchange (SEMREX)
Ms. Anne Morse .
121 W. 3rd Street
Winona,MN 5.5987 .
507457-6464 FAX 507 457-6469
[MN]
* Tri-County Materials Exchange
(TRI-MEX)
Mr. Doug Lien
601 N. 20th Avenue
St. Cloud, MN 56303
612255-6140 FAX 612 255-6146
[MN]
* Western Lake Superior Sanitary District
Mr. Jamie Harvey
2626 Courtland Street
Deluth, MN 55806
218 722-3336 ext. 440
FAX 218 727-7471
[MN]
11
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Missouri Environmental Improvement
Authority
Mr. Thomas Welch
325 Jefferson Street, Box 744
Jefferson City, MO 65102
314751-4919 FAX 314 635-3486
[MO]
Mississippi Technical Assistance Program
(MISSTAP)
Ms. Pat Lindig
P.O. Drawer CN
Mississippi State, MS 39762
601 325-8068 FAX 601 325-2482
[MSJ
Montana Industrial Waste Exchange (MIWE)
Ms. Dee Durand
P.O. Box 1730
Helena, MT 59624
406 442-2405 FAX 406 442-2409
fMTJ
National Materials Exchange Network
(NMEN)
Mr. Bob Smee
4708 E. Jaremko Street
Mead, WA 99021
Modem # 509 466-1019
[US, Canada]
WasteCap - New Hampshire Material
Exchange (NHME)
Ms. Emily Hess
122 N. Main Street
Concord, NH 03301
603 224-5388 FAX 603 224-2872
[NH]
New Mexico Materials Exchange (NMME)
Four Corners Recycling
Mr. Dwight Long
P.O. Box 904
Farmington, NM 87499
505 325-2157 FAX 505 326-0015
[NM]
Northeast Industrial Waste Exchange
(NIWE)
Ms. Carrie Mauhs-Pugh
620 Erie Boulevard West, Suite 211
Syracuse, NY 13204
315422-6572 FAX 315 422-4005
[MD,NY, OH,PA,ME, VT,MA,RI, CT,NJ,
DE,WV,VA,DCJ
Ohio WasteNet
CEC Consultants
6907 Brookpark Road '.
Cleveland, OH 44129
216 749-2992 FAX 216 398-8403
[OH]
Oklahoma Waste Exchange Program
(OWEP)
[JLIMES particpator]
Ms. Dianne Wilkins
1000 NE. 10th Street
Oklahoma City, OK 73117-1212
405 271-1400 FAX 405 271-8425
[OK]
Pacific Materials Exchange (PME)
Mr. Bob Smee
4708 E. Jaremko Street
Mead, WA 99021
509 466-1532 FAX 509 466-1041
[ID,ND,NE,NV, SD, UT, WY, VA, TN,NC, GA]
Portland Chemical Consortium (PCC)
Dr. Bruce Brown
P.O. Box 751
Portland, OR 97207-0751
503 725-3811 FAX 503 725-3811
[OR]
Resource Exchange Network for Eliminating
Waste (RENEW)
Ms. Hope Castillo
P.O. Box 13087
Austin, TX 78711-3087
512463-7773 FAX 512 475-4599
[TK,LA,OK,AR,NM, Mexico]
12
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Rocky Mountain Materials Exchange
(RMME)
Mr. John Wright
1445 Market Street
Denver, CO 80202
303 744-2153 '- /
[CO]
South Carolina Waste Exchange (SCWE)
Mr. Doug Woodson
Rt. 1, Box388A .
Prosperity, SC 29127
803364-1008 FAX 803 364-0667
[SC]
Southern Waste Information Exchange
(SWIX)
Mr. Gene Jones
P.O. Box 960
Tallahasee, PL 32302
800441-7949 FAX 904 574-6704
[KY, TN,NC, SC, GA,AL,MS,FL,
Puerto Rico]
Southeast Waste Exchange (SEWE)
Ms. Maxie May
Urban Institute
University of North Carolina,, Charlotte
Charlotte, NC 28223
704 547-4289 .FAX 704 547-3178
[US]
Trans-Continental Materials Exchange
Ms. Rita Czek
1419 CEBA
Baton Rouge, LA 70803
504388-4594 FAX 504 388-4945*
'[US, Canada, Overseas]
Vermont Business Materials Exchange
(VBMX)
Ms. Connie Leach Bisson
P.O. Box 630
Montpelier, VT 05601
802223-3441 FAX 802 223-2345
[VT]
WI Deptartment of Natural Resources (WI
DNR)[SW/3]
Mr. SamEssak ,
101 S. Webster Street
P.O. Box 7921
Madison, WI 53707-7921 ' '
608267-9523 FAX 608 267-2768
[WI]
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support from, an entire region. In the past, for example, the Northeast Industrial Waste
Exchange (NIWE), based hi Syracuse, has provided service to, and received funding from,
most of the states hi the northeast. Currently, only four of the fourteen states served by the
exchange are funding its operation due to reductions in state budgets. It is not clear yet
whether the combined effect of the proliferation of state exchanges and the National Materials
Exchange Network (NMEN) system will be to augment or reduce the role of regionally-based
exchanges.
NATIONAL MATERIALS EXCHANGE NETWORK (NMEN)
In 1991, as a result of a Congressional appropriation, EPA awarded a grant of
$350,000 to the Pacific Materials Exchange (PME) and $150,000 to the Great Lakes Exchange
to develop a computerized National Materials Exchange Network (NMEN). The Great Lakes
Exchange subsequently went out of business. Their funding and development responsibilities
were shifted to PME. NMEN became operational in January of 1993.
The rationale behind the establishment of a national exchange network is as follows:
• materials exchanges take place at both local and national levels.
• different geographic regions have distinct waste materials and markets.
• the greater the number of materials identified, the more diverse the markets.
• the more people exposed to the listings, the greater the possibility of accomplishing
successful exchanges.
NMEN is a multi-user electronic bulletin board with material listings from the 42
participating exchanges. The available and wanted listings, which can be accessed by
computer modem, are divided into 17 material categories. Listings can be sorted by region,
state and category. The NMEN software automatically keeps track of the number of users, the
number of calls, and the number of inquiries about each listing (with the listings identified
with the appropriate waste exchange). Users accessing the listings can find the same type of
information available in catalogs. When the listing firms do not want to be directly contacted,
the inquirer is referred to the waste exchange supplying or managing the listing. Participating
waste exchanges can use the system to find out who has inquired about their listings and who
has put new listings on the board. The exchange can then follow up with the inquirers to
facilitate ah exchange of materials or to market then: exchange's services.
NMEN has enlisted the participation of 42 of the 53 known currently operating North
American waste exchanges hi the network, giving those accessing the database the opportunity
to view over 9,000 listings. An on-line bulletin board can substantially reduce the amount of
tune between when a material is listed and when the listing can be accessed by users.
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The existence of NMEN, along with state and local waste reduction requirements, is
spurring the development of new state and local exchanges. NMEN reduces the start-up costs
; for an exchange by providing a nationwide computer system which can publicize listings
generated by an exchange and can provide access to a large number of listings. To reduce the
cost of running an exchange, the staff working with NMEN has developed software which
allows an exchange to download all of its listings into a database. The software sorts the data
and loads it into WordPerfect to print a catalog or customized listing for clients.
The NMEN staff recognize that they can not rely on the federal government for all
financial support. PME is currently searching for other ways to finance the operations of
NMEN by pursuing grants from foundations and continues to search for corporate support.
PME is finding that Fortune 500 corporations, while supportive and often enthusiastic about
the idea of a national waste exchange, are not as responsive to providing financial support.
Representatives of large corporations contacted by PME have indicated that it could take
seyeral years to educate management about the potential of waste exchanges. PME is also
considering ways to partially finance NMEN by selling individualized computer generated
reports to interested parties, such as brokers. NMEN is reluctant to charge for its basic
services because it is still so new and needs to build a large base of users hi order to be useful..
Although funding needed to run the exchange totals only about $200,000 annually, it is not
evident whether it can be raised privately in the near future.1
NMEN has just completed one year of operation and has not yet had the full
opportunity to demonstrate its impact on waste exchanges. Many of the newer exchanges,
such as the Arizona Exchange, are dependent on the system for their operation. The viability
of many exchanges, particularly those now in development, might depend on the existence of
the national network. Some of the established exchanges are finding NMEN to be a useful
tool and are using it actively. Other exchanges are still trying to obtain the hardware
necessary to run NMEN or are in the process of learning how it works. Using NMEN can
initially add to the workload of an exchange if it has to manage the records on NMEN as well
as the exchange's own system. During this transitional time, NMEN staff are managing
records and informing exchanges when users place new listings or inquire about existing
listings hi their region.
Two established exchanges maintaining an electronic bulletin board service of their
own have chosen not to participate in NMEN. In fact, some exchanges that have tried
regional bulletin board services are not enthusiastic about their value. ORTECH International,
a provincial research organization in Canada, surveyed exchanges' use of electronic bulletin
boards; for the three exchanges answering the question about the percentage of exchanges
made through the on-line system, the average was only two percent. The electronic bulletin
boards considered hi the survey, however, carried an average of only 150 listings. This is far
fewer than the over 9,000 listings on NMEN which also has a much broader market of users.
Many of the established exchanges are taking a wait and see attjtude about NMEN, although
one commented that "business loves the idea of the national electronic network" .2
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NMEN could be a valuable tool for states or localities for a number of reasons.
Because of NMEN, technical assistance programs desiring to offer waste exchange as an
alternative to disposal do not need to devote resources to starting and administering a local ,
waste exchange. In the long run, NMEN offers established waste exchanges the opportunity
to reduce some of the mechanical tasks of running an exchange by allowing the listings to be
managed hi the system and placed by companies directly. In fact, 171 direct entry listings
have been placed in the first four and a half months of operation. Freeing the exchanges of
mechanical tasks has the potential to allow them to devote more tune to facilitating exchanges.
OPERATIONS OF INDIVIDUAL WASTE EXCHANGES
For the purposes of this study, nine waste exchanges currently operating in North
America were contacted. Publicly available information, such as catalogs and annual reports,
from a number of other exchanges were also reviewed. Lastly, waste exchanges operated by
branches of the federal government, such as the Department of Defense and the General :
Services Administration were contacted. A general profile of each of these exchanges is
provided below.
Southeast Waste Exchange (SEWE)
The Southeast Exchange, formerly the Piedmont Exchange, began hi 1978 with county
funding and is the oldest operating exchange hi the United States. It has a staff of three,
which is sometimes supplemented by student interns and faculty members working on special
projects. The salary of the director, her secretary, and office space are all paid by the
University of North Carolina at Charlotte, In addition, SEWE has a budget of about $100,000
annually. An estimated 25 to 30 percent of the $100,000 budget comes from catalog or
bulletin board subscriptions, listings, and advertising fees. Other funding conies from grants,
industry fund drives, and Mecklenberg County. The bulletin board service operated by SEWE
also generates income for the exchange. SEWE reports 402 exchanges of over 98,150 tons of
material hi 1992, with savings to business of $9,027,283.
The exchange has always sought to actively assist companies with their waste
problems. SEWE often provides callers with immediate information on companies that might
be able to use the caller's waste. For this reason, many of the materials it deals with never
make it into the catalog. The SEWE staff also suggest waste minimization, waste reduction,
and pollution prevention options. In addition, SEWE refers businesses to state agencies for
regulatory advice and works directly with the North Carolina Office of Waste Reduction to
provide further technical assistance on waste management options. For wastes which can not
be reduced or recycled, SEWE provides lists of hazardous waste management firms with small
quantity generator programs. The exchange conducts outreach through workshops run twice a
year in the spring and the fall. These workshops often attract between 100 and 150 attendees,
many of whom are from small quantity waste generating companies. It also participates in
programs sponsored by the Chamber of Commerce and other business groups.
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SEWE believes that companies contact the exchange more readily than government
agencies because the exchange is private, located at a University, and respects confidentiality.
The exchange also has its own bulletin board with listings from SEWE, Southern Waste
Information Exchange (SWIX) and Northeast Industrial Waste Exchange (NIWE), along with
other information on reuse and recycling. Access is limited to those with a subscription to the
service. SEWE does not participate in the National Material Exchange Network.
Iowa Waste Reduction Center (IWRC)
The IWRC Waste Exchange, was begun in 1990 as a pilot project funded by a $60,000
Pollution Prevention Incentive for States (PPIS) grant from EPA. The need for a waste
exchange became evident as more and more businesses in the state began asking IWRC for
help in locating markets for their waste. In the spring of 1991, the Iowa legislature introduced
legislation that authorized the collection of a $.10 per ton tipping fee for the express purpose
of funding the exchange. These funds, which are channelled through the Iowa Department of
Natural Resources, currently amount to approximately $200,000 per year. Of this amount,
$25,000 is allocated for IWRC administrative support and $175,000 is available for grants to
regional representatives of IWRC.
Potential representatives, who are usually affiliated with Community Colleges, compete
annually for the grants. The grants currently range from $16,000 to $50,000 and allow the
grantees to spend from 25 percent to 100 percent of their time visiting businesses, promoting
the waste exchange, and searching for/waste listings and markets. Grantees also provide
information on where to get assistance with waste reduction, waste minimization or regulatory
concerns.
The regional representatives are not necessarily technical experts in waste reduction or
waste generating practices, but do have experience with economic development and understand
the needs and concerns of businesses. The IWRC interacts with the representatives and
provides them with technical information and training to help them identify waste reduction,
reuse and recycling, and energy conservation opportunities as well as potential waste markets.
One employee of IWRC is very knowledgeable in hazardous waste and provides technical
assistance and information to the regional representatives when needed. Although only a small
proportion of the exchange's listings are hazardous materials (7 percent'of total listings; 11
percent of material matched hi FY 92), in the future, the exchange expects to focus more on
hazardous waste and less on plastics and paper as those markets become more consistent.
The IWRC Waste Exchange currently has about 1000 listings, half of whick it
advertises as part of the IWRC newsletter. The exchange works with businesses of all sizes,
although it finds that much of the interest in the waste exchange comes from small businesses.
In the last fiscal year IWRC facilitated the exchange of 254 materials totalling 29,547 tons.
The savings to business from avoided disposal costs resulting from these exchanges was
calculated to be approximately $547,000. Avoided disposal costs are based on state tipping
fees of $25 per ton for solid, non-hazardous waste, estimated at $200 for 55 gallon drums of
hazardous waste, and estimated at $800 for 55 gallon drums of paints. IWRC keeps in close
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contact with companies that list on the exchange through its regional representatives, and is
tracking exchanges carefully. IWRC is a member of NMEN, and expects to use the service
primarily to locate markets for its listed materials.
Industrial Materials Exchange Service (BMES)
The Industrial Materials Exchange Service began in 1981 as a service of the Illinois
Chamber of Commerce. It was subsequently taken over and run primarily by the Illinois EPA
with support from the Illinois Chamber of Commerce. Since 1989, IMES has been a part of
Illinois EPA's Office of Pollution Prevention, which supervises and funds its employees and
activities. The IMES distributes over 13,000 catalogs nation-wide, although its market is
primarily in the midwest. The exchange actively seeks markets for waste as well as generators
of marketable wastes.
Two individuals serve as Waste Exchange Activators, one in the Chicago area and one
in Southern Illinois. The Activators visit companies and offer the services of the exchange as
well as advice on pollution prevention and waste reduction. The Activators identify uses for
waste and match wastes with companies that might be able to use them. They find that many
companies are not aware of the composition of their own waste and have never considered that
the wastes might contain resources valuable to other users or for their own reuse. Because
such companies do not recognize the opportunities for modifying or recycling their waste
streams, the site visits provide the Activators with valuable information that can't be obtained
over the telephone.
The IMES staff use waste generation reports to identify companies generating reusable
or recyclable waste streams. They work with companies of various sizes, from conditionally
exempt smaller generators (e.g., vehicle maintenance facilities) to larger companies interested
in reducing disposal costs. Many large companies, however, remain hesitant to work with the
exchange because of liability concerns. Less than half of the companies contacted by the
exchange staff are willing to trade. They often do not provide any reason for their reluctance
to trade.
IMES reports 1991 exchanges totalling 7,619,700 gallons or gallon equivalents of
materials, with a value of $13,092,444. In order to obtain these statistics, IMES sends out an
annual survey to listing companies to find out if they have exchanged materials, the quantity
exchanged, the value of the exchange as measured by both the avoided disposal cost, and the
value of the materials. About 50 percent of the companies answer the mail survey. IMES
follows up with the remainder by telephone. Many listing companies are negotiating
exchanges at the time of the annual survey and the outcome of these negotiations is not
followed by IMES. Therefore, statistics on exchanges are likely to be understated.
California Materials Exchange (CALMAX)
The California Materials Exchange was organized in July, 1991 in response to
California Assembly Bill 939, which requires local jurisdictions to reduce landfill disposal by
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25 percent in 1995 and by 50 percent in 2000. CALMAX handles only non-hazardous waste.
In its first 'full year of operation, it was responsible for at least 65 exchanges accounting for
nearly 112,000 tons of material. Funding for the waste exchange, which is estimated at about
$175,000, comes from the California Integrated Waste Management Board, which is funded
from a $.75 per ton1 tipping fee surcharge. CALMAX is operated byjts contractor, the Local
Government Commission (LGC), which handles the day to day activities of maintaining the
listings, printing the catalog, and answering phone inquiries. LGC follows up on the listings
after they run for two months in order to track exchanges and update the catalog. LGC is a
nonprofit, nonpartisan membership organization of local elected officials. .
CALMAX does not currently have staff to actively pursue waste exchanges, but hopes
to be able to do so in the future. The waste exchange is actively marketed by its director
through articles'in magazines and speeches to industry and trade groups. It is sponsored by
other state and local governmental authorities, as well as business groups, who often include
information encouraging the use of CALMAX in mailings sent to members or in free
advertisements in newsletters. The catalog, which is divided intersections by California region
as well as by waste type, is sent to more than 5500 subscribers. CALMAX is a member of
NMEN. The exchange has recently been reorganized into the Waste Diversion and Education
division of the Integrated Waste Management Board, Business Assistance Section, which will
more actively encourage business to reduce, reuse and recycle waste. In another educational
effort, CALMAX organized the 1993 North American Conference on Industrial Recycling and
Waste Exchange sponsored by EPA.3
Resource Exchange Network for Eliminating Waste (RENEW)
RENEW was established by the Texas Water Commission (TWC) in 1988 in response
to Senate Bill 92 of the 70th Texas legislature. Its purpose is to promote the reuse and
reclamation of materials and to disseminate information on the treatment and recovery of
metals. Its annual budget of approximately $100,000 is funded through state general revenues
received by the Texas Water Commission. In addition, a small amount of revenue is received
from the sale of advertising space in the bi-monthly catalog.
In fiscal 1992, RENEW received 142 new listings, documented 30 successful
exchanges, and had 100 inquiries hi negotiation. Disposal cost savings of $22,680 were ". -
reported to RENEW by companies as a result of the exchanges. Since FY 1989, RENEW has
listed close to 659 materials, resulting in at least 82 successful exchanges. In order to track
listings, RENEW sends out self addressed stamped cards with every inquiry about a specific •
material or listing, asking information such as: whether the exchange was successful or not,
and if not, why it was not; quantities exchanged; annual amount of material transferred;
disposal cost avoided; revenues earned from the material; distance of exchange; proposed
usage of material; and pre-exchange usage. RENEW staff estimate that less than half of the
cards sent out are returned, so it is likely they are missing some transactions.
RENEW, as part of me Commission's Office of Pollution Prevention and
Conservation, is part of an effort to provide non-regulatory technical advice and information
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on waste reduction and waste minimization. Other services of the Office of Pollution
Prevention include on-site pollution prevention assessments, pollution prevention workshops,
and a recycling products directory of Texas. RENEW markets its waste exchange services
through contact with companies referred to it by Office of Pollution Prevention professionals
doing on-site assessments, as well as by staffing a RENEW information booth at trade shows.
Due to lack of staff, the exchange does not aggressively seek markets for waste
materials, but it does target companies with specific waste streams for receipt of their free
catalogs and mailings. They access the TWC's Registration System data base and select those
generators with waste streams of interest either for economic value or for reuse and recycling
potential. The RENEW catalog listings can also be accessed on the Texas Marketplace's
electronic bulletin board, which is a state-sponsored service allowing buyers and sellers of
goods and services access to electronic advertising. RENEW is part of NMEN, but has not
yet utilized the service fully because of equipment difficulties.4
Pacific Materials Exchange (PME)
The Pacific Materials Exchange is a private, non-profit 501(c)(3), public benefit
corporation, started in 1988 after a feasibility study funded by a grant from the local utility,
the Washington Water Power Company. It is currently funded from revenues received from a
$48 per year subscription fee, as well as funds generated from hosting the 1991 North
American Waste Exchange Conference on Industrial Recycling. The exchange, which once
shared a catalog with the now defunct Great Lakes Exchange, is primarily a waste exchange
listing service. Statistics on exchanges have not been maintained due to lack of staff and.
resources.
The National Materials Exchange Network, described in more detail earlier, was
developed by the Pacific Materials Exchange under a grant from EPA and started service in
January 1993. It is a multi-user, multi-tasking, bulletin board which contains available and
wanted listings from 43 member exchanges including the PME.
Canadian Chemical Exchange (CCE)
The Canadian Chemical Exchange is a for-profit brokerage dealing mostly with virgin
materials such as off-spec or overstock chemicals, dyes, pigments and Pharmaceuticals. It
generates over $1 million Canadian dollars of revenue annually by purchasing excess
chemicals and reselling them for a profit. The profit it earns depends on transportation costs,
chemical purity, and the type of chemical it is reselling. CCE takes possession of the
chemicals 95 percent of the time, and does not reveal the source to the buyer. It often uses
non-profit and government agency waste exchanges for leads to help identify sources of
chemicals. CCE has a good working relationship with the Ontario Waste Exchange on the
narrow band of materials with which it works. It will often accept and warehouse chemicals
identified by the Ontario Exchange for which there might be no immediate use.
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CCE would like to handle larger volumes and/or, "dirtier" chemical wastes, but that
would require more research, testing facilities, and knowledge of the processes generating the
individual waste. It would also increase liability .concerns.5
.Canadian Waste Materials Exchange (CWME)
Ontario Waste Exchange (OWE)
The Canadian Waste Materials Exchange and the Ontario Waste Exchange are both run
by ORTECH International, a provincial research organization. The CWME is a passive listing
service started in 1978. It publishes a bi-monthly catalog with a budget of approximately
$70,000 Canadian dollars per year. An estimated 30 to 35 percent of the budget comes from
advertising fees and a $70 subscription fee, with the remainder coming from the government.
The CWME, which is now connected to NMEN, takes less than one full time person to run.s
Total documented exchanges from 1978 through April 1992 for CWME number 803, with
441,000 tons per year of ongoing exchanges and one time exchanges of 112,500 tons.
The Ontario Waste Exchange, which was initiated hi 1984, began actively seeking
markets for waste and waste generators in 1987. It has a staff of three and a half people who
maintain an internal database (not currently accessible to the public) of listings, information on
company waste arid waste needs. They match waste generators with potential waste users by
phone or by printing out a list of potential markets for the waste and faxing it to inquirers.
Staff try to focus their efforts on the wastes they expect to be harder to place. Over 60 percent
of the exchange's contacts are through referrals (about equally divided) from either industry
colleagues or the provincial environmental or commerce ministries. About 3600 waste streams
are placed on the waste exchange each year. The Ontario Waste Exchange has no printed
catalog. Listings older than two months go into the Canadian Waste Material Exchange's
catalog. The Ontario Waste Exchange is also a member of NMEN.
The OWE keeps track of transfers by faxing follow-up letters requesting information
on possible exchanges resulting from their efforts. A recent report issued by ORTECH, which
surveyed the exchange's clients, found that their method of follow-up underreports exchanges
of waste materials. ORTECH estimates 502 exchanges per year, with an estimate of 100,000
tons of new excess materials exchanged per year. Slightly more than half of the exchanges
each year are for non-hazardous materials, which is an increase compared to past years.
The Ontario Waste Exchange annual budget is approximately $250,000 Canadian
dollars, with most of the funds provided by the Ontario government. The exchange calculated
that in 1991-1992 it was able to facilitate new exchanges at a cost of $3.50 Canadian per ton
compared to publicly financed curbside pickup costs of $100-$20Q per ton and hazardous
household waste programs costing $2000-$10,000 per ton of materials diverted from disposal.6
-- " - . . j - .
California Waste Exchange (CWE)
The California Waste Exchange, which is part of the Department of Toxic Substances
Control, began operation in 1976. It is an informational exchange dealing only with hazardous
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waste. CWE produces one newsletter/catalog per year and an annual directory of industrial
recyclers. It gets approximately 15 to 20 new listings a year and takes less than one person
working full time to run. CWE does not track exchanges and has no way of knowing whether
they occurred.
The majority of CWE listings are for surplus laboratory chemicals and unused
materials. While there are some industrial process wastes in the catalog, most of them are old
listings. The 1992 catalog had some listings of available material from as far back as 1986.
The old listings were deleted from the 1993 catalog after CWE called listers to' see if the
materials were still available.7
FEDERAL WASTE EXCHANGES CONTACTED
There are two "waste exchange" operations in place in the federal government: the
Department of Defense Reutilization, Transfer and Donation Program (DoD R/T/D Program)
and the General Services Administration (GSA) Utilization and Donation Department. The
DoD R/T/D Program is part of the Defense Reutilization Marketing Organization (DRMO)
which is run by the Defense Reutilization Marketing Service (DRMS) which is part of the
Defense Logistics Agency. DRMO offices are located at all DoD facilities world-wide. The
GSA program is run from GSA headquarters.
Department Of Defense
A military installation with an item it can no longer use or a" waste it wants to recycle
fills out a DoD material transfer form and gives a description of the material to the DRMO
office located on-site. The DRMO office catalogs the material based on a generalized
groupings list (paint, acid, cleaning'compound, etc.). This general description makes up the
first four digits of an item's stock number. People looking for a general type of product can
search for all items listed with that four digit code. Items are listed on a computerized DoD-
wide database indicating the item's stock number, general category, name, specific chemical
ingredients (if they are available), the percent of hazardous components, manufacturer,
quantity, supplier location, supplier name, and date listed on the database. Items then remain
on the system until they are exchanged, sold, or disposed of as waste. The database also
makes notations of the last activity regarding a given stock number. For example, if 75
barrels of a commodity were listed, but only 50 were exchanged, the database would note that
25 barrels were still available for transfer. The DoD program handles primarily hazardous
wastes, but does include some non-hazardous waste.
The DoD R/T/D Program was established by Congress hi 1972 and is free to DoD
facilities, although the receiving facility is required to pay for shipping. Most, if not all,
military and government owned DoD facilities participate in the DoD R/T/D Program. If an
item has been offered to other DoD facilities and no request has been made for it, then the
surplus item is made available to other federal agencies, state and local governments and the
public. After an item has been offered to other DoD facilities, the DRMO will provide a
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listing of a surplus item to the GSA Utilization and Donation Department, which provides;
federal agencies and state and local governments access to the military's surplus items.
Federal agencies and state and local governments can obtain surplus items at a cost that covers
the DRMO's administrative expenses plus shipping costs. The public is able to obtain a
catalog from DRMO of available materials that it can purchase at market price plus shipping
/fees. .'-..'• ' •. - : '••'•";.' . ~ - .-" . '• ; •
DRMS has very strong concerns about their potential liability when surplus hazardous
materials are transferred out of a military facility. Because DRMO is the supplier of a
hazardous waste in these transactions, they are classified as a waste generator and have all the
liability assigned to generators. Therefore, DRMS goes to great lengths..to find out how a
material will be used. They carefully review all outside requests for surplus hazardous
materials and examine how the material will be re-used and eventually disposed.
One key to the success of the DoD R/T/D Program is that DRMO staff knows which
materials are available and who could use them. Facility staff periodically review the listing
information to see if materials are listed that they know an organization is interested in
receiving and reusing. As a result of these efforts to cultivate clients, 60 percent of the
surplus items generated by the military is sold to federal, state, local, and private interests.
An additional 15 percent is traded within the DoD. The remaining twenty-five percent is
disposed of as waste. In reviewing hazardous waste transactions, approximately 50 percent of
all listed hazardous wastes are successfully transferred by the DoD program. " --'
DoD procurement contracts often require the supplier to take back or provide a refund
for unused materials. For example, a paint supplier might sell 20 cans of paint to an Air
Force base that ends up using only 16 cans. The supplier would then be required to take back
the four unused cans. Many DoD materials are also designed to very precise specifications set
out by the military. When a product is designated as "used" by the military, it might still be
useable hi other, less demanding operations. For example, an Air Force cleaner used hi
cleaning fragile electronic parts could be cheaply recovered for use in cleaning automotive
parts. This "low-technology" use for a previously "high-technology" product gives it an added
life-span before it is eventually disposed. .
Other Federal Agencies
For civilian federal agencies, all surplus item transfers (including industrial wastes) are
facilitated by the GSA's Utilization and Donation Departments, which are located in 10
regional offices around the country.. Anyone in any federal agency can offer a surplus item,
new or used, to the GSA regional office to be listed as available for transfer. The GSA has
not established a separate office to handle hazardous waste, due largely to a lack of volume, so
surplus chemicals are listed using the same process as that for automobiles, forklifts,
computers, or any other surplus item available for transfer. Hazardous materials handled by
GSA are largely consumable items, i.e., paints, solvents, glues, detergents, and lubricants.
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To transfer an item, department or agency employees fill out an excess property sheet
and send it to the Utilization and Donation Department regional office for their area. The item
is listed in a computer database and in a hard-copy paper listing. There are thousands of items
in the database at any one time. A federal civilian employee can access this database through
his or her computer and a modem. A hard-copy listing is distributed to state governments
and, through the state, to local governments. Any remaining surplus items are offered to the
general public via auctions. These are advertised by distributing flyers and bid packages
listing items to be offered and auction information. The majority of the excess materials the
Utilization and Donation Department disposes of each year is sold at public auction, rather
than transferred to other federal agencies or state governments.
GSA Utilization and Donation Department personnel could not provide a hard figure on
the amount 'of hazardous materials they transfer each year, but anecdotally they state that there
is not a large quantity of hazardous materials relative to the non-hazardous items that they
handle. The amount of non-hazardous surplus materials the Utilization and Donation
Department transfers each year is also anecdotal, with the figure put in terms of billions of
dollars worth of merchandise. A Washington, D.C. Utilization and Donation employee
mentioned that she was able to sell $12 million of surplus items in one month (this value
includes very little, if any, hazardous waste). The key difference between listing hazardous
and non-hazardous materials in the GSA is that hazardous materials require a Material Safety
Data Sheet (MSDS) to be completed, must be labeled properly, and must be shipped in
accordance with Department of Transportation regulations. If an item is sold to the public, the
receiving individual must fill out a certification form that states who he or she is .and for what
purpose the chemical will be used. Otherwise, a pallet of surplus paint is no different from a
used desk, and can be transferred, donated, or sold to the public. The largest generators
outside of DoD are the four GSA supply depots located in Stockton, CA, Fort Worth, TX,
Atlanta, GA, and Burlington, VT.
GSA admits that due to a lack of staff resources, there is no real follow up to see how a
chemical was used or disposed. GSA regional offices have established hazardous materials
committees to address some liability concerns. A committee is made up of personnel
responsible for procurement, storage and disposal within the regional office. The committee's
purpose is to ensure that proper precautions are hi place so that no harm comes to a federal
agency, its employees, or local communities hi the transportation or disposal of chemicals.
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Chapter 3
DESCRIPTION OF WASTES AND CUSTOMERS OP WASTE EXCHANGES
WASTES LISTED AND TRANSFERRED BY WASTE EXCHANGES
Most exchanges maintain records of number and types of the wastes listed. They do
not, however, keep the information in the same format, nor does the information cover the
same time period, making it difficult to provide exact totals of wastes .listed by category by all
of the exchanges in North America. Some of these exchanges are new within the last year and
do not have a published record. Some exchanges did not respond to requests for information
and others are primarily listing services. In order to get a sense of the types of wastes listed,
both available and wanted, we requested a breakdown from the National Materials Exchange
Network (NMEN)- The figures they supplied were based on the number of listings in the
National Materials Exchange Network as of May 19, 1993. They represent most of the
listings of the exchanges participating in the network. They do not, however, include listings
from the Southeast Waste Exchange (SEWE) and the Southern Waste Information Exchange
(SWIX), because they do not participate in NMEN. The figures also do not include exchanges
made through direct contacts by exchange staffs which do not result hi listings.
Figures provided by NMEN are presented hi Exhibit 3-1. These numbers indicate that
there are almost three times as many materials available as wanted. In many categories,
however, the totals desired are similar, to those available. It is clear from the statistics that the
number of laboratory chemicals available far outnumber those wanted and that plastics and
rubber represent more than a quarter of the wanted listings.
Unfortunately, at this tune, NMEN cannot compile statistics on the volume of materials
by waste category. Categories such as laboratory chemicals are lower weight or volume
materials while metal sludges, wood, and paper, are higher weight or volume materials.
Exhibit 3-2 presents a table on percentages of available materials by number and weight from a
1991-study prepared by the SWIX for the 1991 North American Waste Exchange Conference
on Industrial Recycling. It illustrates the point that the percentage of the number of listings by
category and the percentage of materials by quantity are vastly different. In terms of quantity,
over half of the materials listed were classified as miscellaneous, although miscellaneous
listings represent only 15 percent of total listings.
25
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Exhibit 3-1
Listings of Materials Wanted and Materials Available
by Category from the NMEN*
January 1, 1993 to May 19, 1993
Category
Acids
Alkali
Construction Material
Container and Pallet 366
Durable and Electronic
Glass
Laboratory Chemicals
Metal and Metal Sludge
Miscellaneous
Oil and Wax
Other Organic Chemicals
Other Inorganic Chemicals
Paint and Coating
Plastic and Rubber
Solvent
Textile and Leather
Wood and Paper
Materials
Available
197
181
45
5% -
32 .
39
2,350
367
677
234
410
508
96
826
313
165
594
7,400
Percentage of Materials Percentage of
Total Wanted Total
3%
2%
1%
79
0%
1%
32%
5%
9%
3%
6%
7%
1%.
11%
4%
2%
8%
50
51
27
4%
45
15
8
234
278
84
82
97
11
505
67
70
196
1,899
3%
3%
1%
2%
1%
0%
12%
15%
4%
4%
5%
1%
27%
4%
4%
10%
These data do not include approximately 460 listings of available materials and 150
wanted listings from the Southeast Industrial Exchange and the Southern Waste
Information Exchange based on recent catalog listings.
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Exhibit 3-2
Percentage of Materials Available and Quantities Available
by Waste Category from the 1991 SWIEC Study on Waste Exchange
Category
Acids
Alkali .
Other Inorganic Chemicals
Solvent
Other Organic Chemicals
Oil and Wax
Plastic and Rubber
Textile and Leather
Woodi and Paper
Metal and Metal Sludge
Miscellaneous
Number
Available
271
280
426
326
360
252
301
62
313
470
546
3,607
7
8
11
9
10
7
8
•'2.
9
14
15
Quantity
(metric tons)
.186,506
-287,090
541,788
39,127
13,971
67,809
230,439
31,675
525,047
934,269
5,008,486
2
4
7
12
64
7,866,207
Comparing the percentage of listings in each category for Exhibit 3-1 and Exhibit 3-2
illustrates the difficulty in analyzing quantitative information from waste exchanges. Table 3-1
is based on a total number of available listings of 7,400 materials in 17 categories in 1993,
while Exhibit 3-2Is based on 3,607 listings in 11 materials categories, from 1990 or 1991
data. NMEN has expanded the miscellaneous category into seven categories to accommodate
requests from newer exchanges dealing in non-hazardous waste and to divide what was
becoming a large category into smaller sections. The data in Exhibit 3-1 excludes two major
exchanges, while the data in Exhibit 3-2 excludes listings from hew exchanges, including the
very active IWRC and CALM AX. :.'.-••
WASTES EXCHANGED
Total exchanges of materials taking place as a result of waste exchange have been
estimated to be about 12,000,000 tons. Since many transfers are not documented, this figure
is based on an estimate that 10 to 30 percent of materials listed are ultimately transferred.
Collecting information on transfers is difficult. Only nine of the exchanges contacted for ,
publicly available information published materials on.number of transfers. In addition, the
numbers obtained were from varying years; some sent 1990 statistics, while others sent 1991
or 1992 figures.
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TYPES OF WASTES EXCHANGED
Examination of catalogs and listings indicate that there are substantial differences hi
the types of materials listed by region. The Iowa Waste Reduction Center lists a large amount
of waste agriculture products, while the Southeast Waste Exchange has a much higher
proportion of industrial waste. CALM AX only lists non-hazardous waste and, therefore, has a
higher proportion of high volume materials such as wood and construction materials.
Very few waste exchanges publish statistics on transactions broken down by materials
category. Therefore, it is hard to generalize about the types of wastes transferred successfully
through waste exchanges. Exhibit 3-3 presents the percentages of quantities exchanged by
SEWE, IMES, and NIWE, and gives a sense of the regional diversity of types of wastes
exchanged.
Exhibit 3-3
Percentage of Wastes Traded by Category (Quantities)
Category . SEWE
1992
Acids 78
Alkali < .5
Other Inorganic Chemicals 7
Solvent 7
Other Organic Chemicals < .5
Oil and Wax 2
Plastic and Rubber 2
Textile and Leather 3
Wood and Paper < .5
Metal and Metal Sludge < .5
Miscellaneous < .5
IMES
1991
8
2
<.5
1
52
6
1
< 1
22
7
NIWE
1990
59
0
1
0
5
0
6
6
22
There was no consensus from the waste exchanges contacted for this study about the
easiest wastes to trade. There was agreement, however, that material quality was a critically
important variable. Issues of purity, volume, and location are as important as the type of
waste. The best information comes from the ORTECH report, which ranks the probability of
being able to identify markets for different waste categories. According to the report, wastes
with the highest probabilities of being traded are metal, glass, thermoplastic, wood,
containers, furniture and equipment. The lowest were acids, thermoset, leather, textiles, metal
sludges, construction and demolition waste, and lab chemicals.8
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ORTECH analyzed problem wastes to try to understand why they did not trade. For
available wastes, the major reasons for not trading were that the chemical concentration was
too low, contamination levels were too high, quantities were.too high or too low, location was
too far from markets, or no market existed for the material. For wanted wastes, the issues
were the same. Companies wanted wastes of high concentration and little or no .
contamination. Distance arid competition from other sources was also a problem, as were
volumes requested. .
The more active exchanges, including OWE, IWRC, SEWE, and IMES, often suggest
ways of avoiding some of these problems to make their wastes more exchangeable. They
advise companies on ways to make their wastes more concentrated or less contaminated.
These exchanges also try to find more than one buyer for a large waste stream or more than
one source of materials for a company wanting more of a material than can be supplied by one
generator.9
ONE TIME VERSUS ON-GOING EXCHANGES OF MATERIALS
Waste exchanges list wastes available in a certain quantity on a one time only basis as
well as wastes which will be available on an on-going basis. For those listing on-going
wastes, it is important to find a user willing to commit to taking the waste consistently;
otherwise, listing on the waste exchange becomes inefficient. The only information compiled,
on the percentage of exchanges talcing place on an on-going basis is from the Ontario Waste
Exchange. It found that 42 percent of exchanges were on an on-going basis and that 9O
percent of these were expected to last into the foreseeable future.10
TYPES OF COMPANIES USING WASTE EXCHANGES
Waste exchanges do not generally release the names of companies listing materials
except to parties inquiring about specific materials. Some listers ask that their names and
addresses be kept confidential by the waste exchange. In such cases, the waste exchange .
passes contact information from the inquirer to the listing firm. They then decide, whether to
make the contact. Confidentiality is an important issue to many companies, who do not
necessarily want the world to know about their wastes. Sometimes wastes provide important
clues about the processes the company is using or the types of goods they are making. Waste
exchange officials know that they must maintain confidentiality in order to attract business.
Representatives of the waste exchanges contacted for this study were not willing to
generalize about the types of firms using their services. According to the representatives, the
firms range from Fortune 500 companies to gas stations and small repair shops.
The Ontario Waste Exchange provides a good example of the diversity of firms listing
waste on the exchange. The organizations listing successfully exchanged materials ranged
from a dentist's office with approximately 100 pounds of rigid plastic to a waste management
29 : : .-
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company listing 6,570 tons of food waste. Waste haulers frequently used the exchange to
transfer materials. Hazardous waste haulers listed off-specification and surplus materials, such
as animal shampoo, ink, vitamins for animal feed and mineral oil. Brokers accepted these
materials, presumably for resale. Over 12 percent of the 122 wastes were transferred to
brokers, while about 22 percent went to various types of recyclers and oil re-refiners. Schools
and charities also received exchanges of many types of excess materials and old equipment.
The Ontario Waste Exchange was able to encourage 14 listers to reuse their own waste in their
process.
n
According to several representatives of waste exchanges, one of the major difficulties
exchanges have hi encouraging materials exchange is that the exchanges are relatively
unknown among potential users, despite waste exchange marketing efforts. A 1991 survey of
275 Puget Sound businesses conducted by IMEX volunteers found that only 15 percent were
aware of the concept of waste exchange and that only one had used IMEX to list waste.12
Exchanges are frequently marketed through state environmental agencies, trade groups,
Chambers of Commerce and through newspapers and trade journals, but they still have a
visibility problem. It takes many years to build a business following. The Ontario Waste
Exchange reports that 32 percent of their users heard about the exchange from the Ministry of
Environment and the Ontario Ministry of Commerce, and 30 percent heard of them from
industrial colleagues.
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Chapter 4
EVALUATING SUCCESS
This chapter discusses the factors used to evaluate the success of waste exchanges. It
begins with a general discussion of the overall goals of publicly operated or funded waste
exchanges. Different indicators of success and the factors surrounding their use are described;
however, directly measuring success is problematic. The importance of intangible measures of
success and some examples are provided in the last section.
WASTE EXCHANGE GOALS
Success of waste exchanges must be measured against clearly defined goals. The
progress of the waste exchange towards meeting the goal can be measured. The greater the
progress, the more successful the waste exchange. ,
Generally, the main goals are to encourage and facilitate the reuse or recycling of
Industrial waste materials in order to conserve resources and reduce the risks to human health
and the environment by lessening the amount of waste being treated and disposed. Recycling
wastes is a preferred waste management method to treatment and disposal. Recycling
conserves natural resources and poses lower environmental and human health risks compared
to waste treatment and disposal. ~ _
Waste exchanges also have the following goals:
• Providing an opportunity for the exchange of wastes to reduce waste
management and raw material costs.
• Educating firms on the potential benefits of avoiding waste disposal. -
• Facilitating the recycling of wastes with low market value.
• Providing waste management assistance to small companies.
• Reducing the need to build new publicly funded treatment and disposal
facilities. , . .
While these goals are important, most waste exchanges view these as secondary to the
overriding goal of reducing the risk to human health and the envuronment.
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MEASURING SUCCESS IS DIFFICULT
A direct measurement of the success of waste exchanges in attaining these goals is not
possible for two reasons. First, the relevant data are typically not available. Collecting data
and statistics is expensive and labor-intensive. The quality of the statistics and their value in
indicating success is dependent in part on the amount of effort expended in their collection.
Exchanges, particularly those with low budgets, are not able to devote the resources necessary
to collect complete accurate statistics.
Secondly, many waste exchange goals are intangible and difficult to directly measure,
even if data were available. Quantify ing the reduced risk to human health and the environment
is challenging. Linking reduced risk to increased waste recycling brought about by a waste
exchange is extremely difficult.
As a result, success must be evaluated through indirect indicators or surrogates, These
indicators are used to measure the societal benefit derived from increasing the amount of waste
that has been recycled versus treated and disposed.
There are many different indicators for the success of waste exchanges. Quantitative
measurements include the number of listings; number of inquiries; and number, quantity, and
value of transactions. If accurate, these indicators reflect some of the successes of the waste
exchanges. Active waste exchanges could also measure success in terms of the quantity of
educational and informational services provided to industry and the public. Success in terms
of the waste exchange's ability to generate new markets for wastes and surplus materials is
another indicator.
For this study the following indicators were selected for further evaluation:
Number of listings
Number of exchanges accomplished
Ratio of exchanges to listings
Cost of exchange per ton of waste exchanged
Number of inquiries
Savings to business
Educational and outreach activities
The following section briefly describes each of these indicators and the advantages and
disadvantages of its use. ,
Number of Listings
According to a 1992 survey of 16 North American Exchanges by ORTECH, the
number of listings is rated as the number one quantifiable indicator of waste exchange
effectiveness.13 However, the number of listings waste exchanges report might not necessarily
indicate the present potential for exchanges. If the number of listings is an average, or the
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number of listingsr at any one given tim&, it can include many older listings than have proven
difficult to trade. A better measure of waste exchange activity is the number of new listings.
Counting the number of listings is relatively straightforward, making it an easy
indicator to track. The ability to draw a large number of listings indicates that the exchange is
serving as a forum for companies interested in exchanging wastes. It might also indicate the
level of awareness among companies that recycling is a viable waste management option. The
number of listings also might indicate that the waste exchange is becoming known within the
business community.
Number of Exchanges Accomplished
When an exchange is accomplished, it signifies that a waste material has been
transferred from one party to another for the purposes of reuse,or recycling. If the data also
include the types and quantities of wastes exchanged, this information could be used to
indicate the relative level of risk reduction accomplished.
Data on the number of exchanges accomplished is not easily obtained. Waste
exchanges normally link companies together by providing them with information which allows
them to make contact with each other. The waste exchange does not generally get involved in
the actual exchange negotiations, and, therefore, is often not aware that a transfer has
occurred. Most companies do not report successful transfers automatically. Waste exchanges
often must contact listing firms repeatedly to learn of successful exchanges. Additionally,
companies initially connected via a waste exchange might continue to exchange material in the
future. If the companies deal directly with one another rather than through the waste
exchange, there is no record of these additional exchanges.
The main methods used to document a successful exchange are calls to listing
companies, mailing post-cards requesting information, faxing requests, and obtaining
information through personal contact with company representatives. The ORTECH survey
indicated that, on average, waste exchanges attempt to find out about transfers from about half
of listing companies. Three exchanges questioned did not follow-up at all, and two contacted
less than 10 percent of their listing companies. On the other hand, three followed up on 100
percent of their listings and four contacted between 75 and 100 percent of the listing
companies.
Attempts to follow up do not automatically mean information on transfers is
documented. Since waste exchanges often contact the listing companies months after the
listings are published, companies often might forget about the exchange, or might forget waste
exchange's role in the exchange. In addition, because follow-up is time consuming, exchanges
might choose'not to contact companies listing small quantities of excess materials or wastes.
The timing of follow-up efforts can make a large difference in the number and quantity
of trades documented by exchanges. Companies often report that they are hi negotiations
when responding to a waste exchange survey. For example, the Industrial Material.
'. ' 33 ; '
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Exchange's 1991 survey found that 902 exchanges were under .negotiation. In comparison, 98
exchanges were reported in 1991. Because the survey is annual and based on listings hi the
previous year, these 902 listing companies with exchanges under negotiation will not be
contacted later to obtain results. It is likely that many of these negotiations will lead to
transfers, but these will not be reported in IMES's annual report.14 This should not be a major
issue if surveys are conducted regularly and more than one year's survey is examined.
Most waste exchange officials agree that the available statistics on number and quantity
of transactions facilitated by exchanges are vastly under counted. This reduces the value of
measuring the success of a waste exchange solely on the number of transfers reported.
Additionally, there is no standard method of recording or tracking exchanges. Waste
, exchanges have different methods which makes aggregating or comparing statistics difficult.
i
Caution should be used in trying to directly equate the number of exchanges with
reduced risk to human health and the environment. An exchange means that one company
transferred a waste material to another firm. It does not necessarily mean that 100 percent of
the exchanged waste was reused or recycled. Data on how the waste was actually reused or
recycled is generally not available. Without this data it is not possible to determine what
percentage of the waste material or what constituents of the waste were actually reused or
recycled. For example, foundry sand can contain different metals in various concentrations.
The company accepting the foundry sand might only extract one or two of the metals. The
remaining metals, and the sand, are then treated as a waste. Another factor is that the reuse or
recycling process might generate additional waste.
Ratio of Exchanged Waste to Listings
One way that waste exchanges can measure success is by means of a ratio of exchanges
to listings. This represents a transfer rate. It can show a waste exchange which types of ' •. .
listings are more easily exchanged, and which wastes might need more market development.
It might help waste exchanges which are actively seeking markets determine where to devote
resources. The transfer rate can only be calculated correctly, however, if transfers are well
documented.
Cost of Exchange per Ton Exchanged
One way to measure, in relative terms, the efficiency of transfers through waste
exchanges is to compare the transaction cost per ton of waste exchanged through waste
exchanges to the cost per ton of other.means of recycling. The Ontario Waste Exchange
estimates the cost per ton of matches made through its services at $2 to $3, compared to $100
to $200 for Ontario's curbside recycling programs.15 The IWRC Exchange calculated cost per
ton of waste transferred as a result of matches made by them in their first year at less than $22
per ton (excluding a large transfer of foundry sand), compared to an Iowa curbside recycling
program which costs more than $50 per ton in public funds.16
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Comparing waste exchanges with curbside collection programs illustrates the relative
cost effectiveness of waste exchange. The figure is primarily valuable in illustrating that waste
exchanges are providing a service at a low cost and a service which, like publicly financed
municipal curbside recycling, seeks to keep waste from being disposed. However, comparing
a waste exchange and curbside recycling programs is not a perfect comparison. Widespread
use of waste exchange to facilitate recycling of household waste is not feasible. Additionally,
many curbside recycling programs are required by state or local recycling mandates whereas
waste exchanges are typically not established to meet a.statutory requirement. Also, very
few, if any, curbside programs include industrial and hazardous wastes.
Number of Inquiries
The number of inquiries received by a waste exchange is an indication of how well the
exchange is marketing its services. It is partially dependent on the number and quality of
listings on the exchange. Exchanges often keep statistics on the number of inquiries by
category. This can help them see which types of materials are of more interest, and which
materials require more market development,
Savings to Business from Waste Exchange
. Waste exchanges collect information on savings to businesses resulting from exchanges
in several ways. Many collect "success stories" which describe the materials exchanged,
companies or type of companies involved, and an estimate of savings incurred by the
businesses. Valuations are usually based on avoided disposal costs by waste generators and
the value of the waste product to the users. Success-stories can be valuable hi marketing the
waste exchange and can help the exchanges illustrate their success, when fund raising.
However, the savings numbers reported can be of varying quality depending on how they were
calculated. Exchanges themselves can make estimates of savings", or they can ask the ,
companies for estimates. It is not unusual for companies to underestimate savings or to report
"ballpark" figures. V • ' .
Some waste exchanges try to calculate savings to business not only to enhance
marketing efforts, but to measure the effectiveness of the exchange. The valuations are not
calculated the same way by each waste exchange, making comparisons difficult. IWRC
calculates savings based on the amount companies would have to spend to dispose of the
wastes. Therefore, numbers will vary depending on the types of materials exchanged.
Savings are based on estimated tipping fees of $25 per ton for solid non-hazardous waste, $200
per 55 gallon drum for acids and solvents and $800 per drum for paints. Calculating avoided
disposal costs this way is straightforward and can easily be performed by IWRC staff, with
little reliance on estimates by business. -
The Southeast Waste Exchange (SEWE) and the Industrial Materials Service (IMES)
include the value of materials to the receiving firms as well as the avoided disposal cost. Any
payment made by one company to the other for the transfer is included in the estimate.
Clearly, in most cases, the waste has some value to the receiving firm, either because it gets
-------
paid to receive it or because it replaces a resource that it would otherwise have to purchase.
These values generally take the form of estimates supplied by the companies involved. The
methodology used by companies to report savings might not be consistent.
Educational and Outreach Activities
In their effort to increase their markets and to educate businesses about waste
reduction, waste exchanges often initiate or participate in conferences or workshops. One
measure of success for them is participation from business in these events. IWRC is reporting
increasing business interest in its waste exchange seminars. The well-established Southeast
Waste Exchange has also had high attendance at recent semi-annual workshops.17
IMPORTANT SUCCESSES NOT EASILY MEASURED
Many exchanges report that intangible successes are as important as quantifiable
success hi meeting their goals. For example, the Southeast Waste Exchange has a broad
mandate to encourage reuse and recycling and to help organizations find alternatives to reduce
the economic and environmental costs of traditional waste management programs. They
provide advice and seminars on a whole range of waste minimization and recycling subjects
and help steer companies to the appropriate regulatory agencies for information. Educating
people to reduce, reuse and recycle is as important to SEWE as effecting the exchange of
excess materials through the exchange.
One successful project involves the recycling of plastic six-pack containers. At the
request of a member of the university community, exchange staff worked With the
manufacturer of the six-pack containers to set up a recycling program at the University of
North Carolina at Charlotte. This was so successful that the manufacturer has expanded the
program throughout the region and from universities all the way down to elementary schools.
The value of the program goes beyond the reduction of disposal costs or new materials costs to
business. It also serves as an educational program that changes the way children and adults
look at waste.18
Another non-quantifiable way that waste exchanges aid in minimizing waste disposal is
to publish advertisements for recyclers, brokers and surplus materials trading firms in their
catalogues, usually for a fee. These catalogues go out to large numbers of companies who
might decide to contact the advertisers directly. The waste exchange would never hear of the
exchange, but through its catalogue, its service would be partially responsible for the
transaction.
The exchanges' efforts to assist companies hi modifying their waste streams into more
readily marketable forms, should not be discounted, nor should extraordinary efforts to trade
hard-to-exchange wastes. The existence of these services is important to the overall ability of
waste exchanges to reduce the amount of waste disposed, but success is hard to measure.
36
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Intangible benefits of waste exchange accrue to businesses,.particularly small
generators. Those that are facing environmental regulation for the first time are seeking
information and cost effective solutions for their wastes. The types of assistance some waste
exchanges provide to small generators, such as finding markets for their waste or helping them
rethink how they might reuse waste are not easily measurable. Exchanges generally try to
help all organizations with waste problems. They do not discriminate against those with small
quantities nor do they discriminate on the basis of waste types. The waste exchange provides
a valuable service, including information.services, that might not otherwise be available.
37 .
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Chapter 5
FUNDING MECHANISMS
Waste exchanges currently receive financing from various sources. Some receive
public funding from tipping fees, from hazardous waste disposal fees or from general revenues
at the state or local level. Several exchanges receive funding through universities or through
grants from public and private sources. Exchanges supplement these funds with revenues from
listing fees, transfer fees, membership fees, conference and workshop fees, advertisements in
catalogs and donations from industry and the public. Some exchanges receive support from
Chambers of Commerce and other business groups. Most exchanges operate as not-for-profit
organizations.
Waste exchanges uniformly operate with relatively small budgets. The ORTECH
survey of 15 North American exchanges reports an average budget of $106,000 dollars, and a
range of $5,000 to $200,000 for the ten exchanges answering the question. Information from
exchanges for this study indicates that budgets for most exchanges performing more than
listing services range from $100,000 to $250,000. The annual budgets for all of the waste
exchanges currently active in the United States totals less than $3.5 million dollars.
The ORTECH survey reports that the bulk of funding for waste exchanges comes from ~
governments. Other fees and revenues account for an average of only five percent of the
budgets of waste exchanges. Non-government revenue is more critical for exchanges such as
SEWE, which seeks industrial support, than for exchanges which are funded from tipping fees
or other stable public sources. .
The level and stability of funding affects the effectiveness of exchanges. Most
exchanges would argue that they are under funded and understaffed. With the exception of
IWRC, exchanges are run with four or fewer full tune employees. Those exchanges without
stable funding must spend valuable time each year tracking down sources of revenue. The
tune spent securing funding reduces the amount of tune the exchange can spend promoting and
facilitating materials exchanges. Even those relying on public funds are not immune to budget
cuts; CALMAX's budget was cut in half in FY 92. The Northeast Industrial Waste Exchange
(NIWE) lost budget support from New York (its largest source of funds), Ohio, New
Hampshire, and Maryland, as well as more than a half year delay in receiving its grant from
Pennsylvania during 1991 and 1992.19 Funding difficulties keep staffs small and limit the
amount of services exchanges can provide and market. NIWE, for example, lost the support
needed for its on-site plant evaluations. Limited staff resources also affect the quality and
quantity of statistics, which could provide information about the successes of waste exchanges.
38
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TIPPING AND WASTE FEES
IWRC and CALMAX are funded from tipping fees collected when waste is disposed in
landfills. IWRC receives, by legislative mandate, a $0.10 per ton tipping fee, while
CALMAX receives a small portion of the $0.75 per ton tipping fee which funds its parent
organization, the California Integrated Waste Management Board. The Industrial Materials
Exchange (IMEX) in Seattle is part of the King County Hazardous Waste Plan and is funded
from a surcharge placed on all waste hauling and sewage treatment activities. The IMEX
budget is only a small part of the $9.6 million collected from the waste surcharge.20 The
Mississippi Waste Exchange is part of the Mississippi Technical Assistance Program
(MissTAP), which is funded by a hazardous waste disposal fee.
Waste fees are currently serving as a stable source of revenue. Ironically, the more
successful exchanges become in reducing waste going to landfills, the smaller the revenue to
support their program without increases in the fees per ton of waste.
OTHER PUBLIC SOURCES OF FUNDING
IMES (Illinois) and RENEW (Texas) receive most of their funding from general state
revenues. IMES is funded through the Office of Pollution Prevention in the Illinois EPA.
The Office of Pollution Prevention receives funding from both the state and the federal
government. Illinois and Texas both collect tipping and waste fees, but the revenues are not
directed specifically toward waste exchange. The Northeast Industrial Waste Exchange
(NIWE) still receives some general funding from member states, although much reduced from
previous years. Other smaller programs, such as Minnesota's MnTAP (Minnesota Technical
Assistance Program) Exchange, receive funding from general revenues.
Grant funding from federal, state, and local governments often contributes to
establishing new exchanges, and sometimes remain important as a revenue source as
exchanges mature. The IWRC was begun as a pilot project funded by a $60,000 EPA PPIS
(Pollution Prevention Incentives to States) grant. Arizona and Louisiana have recently
provided grant money to launch their exchanges. The Arizona Waste Exchange received a
$35,000 grant from the state Department of Environmental Quality to establish the private
non-profit exchange. Louisiana's waste exchange is receiving a"$25,000 grant from Louisiana
DEQ to contribute to start-up funding. Louisiana State University and its Institute of
Recyclable Materials is also contributing funding on a one-time basis.
Another example of public funding is the Southeast Waste Exchange, which is housed
at the University of North Carolina at Charlotte. The University pays the salary of the
Director and her secretary, and provides space. Other benefits of this arrangement are the
ability to use graduate students and professors to perform research or consult on special
projects.
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Federal funds have been used as grants to start up waste exchanges, such as Iowa's,
which was started after a pilot project funded by an EPA PPIS grant. Other federal funds are
channeled through state environmental programs into waste exchanges. In addition, EPA has
funded the establishment of NMEN with an initial grant of $350,000.
CATALOG SUBSCRIPTION FEES
Exchanges sometimes charge fees for catalog subscriptions. For many exchanges,
printing and distribution fees for .catalogs are the largest expenses outside of salaries. Catalogs
can cost as much as $5 per copy to produce. SEWE charges $25 per year for catalog
subscriptions; Pacific Materials Exchange (PME) charges $48 per year. NIWE instituted a
subscription fee, but few paid it; NIWE then cut the distribution of its catalog (previously
21,000) by almost half. The Louisiana/Gulf Coast Exchange is publishing its catalog listings
in a business magazine called BIC, in order to receive a large distribution at a reduced cost to
the exchange. Even those exchanges which charge for subscriptions send out many catalogs
free of charge as tools for marketing the exchange.
LISTING FEES
At least two exchanges charge fees for listing materials. SEWE charges fees of $50
per year for listing up to 10 materials either available or wanted. NIWE charges listers $75
per year if they are from a sponsoring state, and $150 per year if they are from a non-
sponsoring state. According to SEWE, companies are not reluctant to pay a limited fee when
they realize that the exchange is not funded by the government. Listing fees can help provide
a revenue source for an exchange, but they are not a major source of funding. Assuming an
exchange has 400 listers, a $50 listing fee would only generate $20,000 annually. At its peak,
listing revenues for the NPvVE amounted to about $30,000 per year.
TRANSFER FEES
At least two exchanges are charging fees for transfers accomplished using the
exchange. Late in 1991, in an effort to decrease dependence on government funding, as well
as in response to a decrease in state funding, the NIWE4nstituted a charge on transactions
equalling the sum of 10 percent of the value of the exchange or 10 percent of the avoided
disposal cost; the listing fee would be credited towards the cost of the transaction fee. For
continuing transactions, the fee would be reduced by half in each of the second and third
years, and eliminated in the fourth year. The Arizona Exchange is also charging a fee for
successful transactions.
As of the end of 1992, NHVE had collected little money as a result of the transfer fee.
Worse, NP\VE lost several tunes the revenue in listing fees (which fell by half) that it gained in
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transfer fees; companies dropped their listings in the catalog because they felt the proposed
transaction fee reduced the already minimal financial benefit of recycling the materials listed.
The Great Lakes Waste Exchange, one of the exchanges funded by EPA to establish
NMEN system, also attempted to charge transaction fees. The effort was financially
unsuccessful, however, and in spite of the grant support from EPA, the Great Lakes Waste
Exchange is no longer hi business.
REVENUES FROM ADVERTISEMENTS
Many of the exchanges, both non-profit and public, obtain revenue from publishing
advertisements in their catalogs. This is a limited source of funding, however, because"the
catalogs are small and are usually only printed bi-monthly. SEWE charges $300 for a full
page advertisement running for a whole year. Based on a review of their catalog and
advertisement charges, it is estimated that they receive fewer than $5,000 from advertisements
in catalogs.
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Chapter 6
RELATIVE MARKET POSITION OF WASTE EXCHANGES
In addition to waste exchanges, the current reusable or recoverable waste market
includes:
• informational waste exchange system which provides information for buyers and sellers
who lack their own existing networks
• private brokerage services which buy and sell wastes
• individual corporate networks through which much of the large corporations'
recyclable materials are traded.
The relative market strength of individual waste exchanges depends on their geographic
situation, their method of operation, and the adequacy of the financial support for their
operations.21 " •
WASTE EXCHANGES
As noted previously, waste exchanges currently depend heavily on public sector
support. Those exchanges which have attempted to find ways to become self-supporting have
not experienced success. On the other hand, some waste exchanges have been successful at
defraying a portion of their costs through various fees or charges.
The market limitations of waste exchanges, however, are only one part of the recycling
picture. Local and state governments, which have established and continue to fund waste
exchanges, have found that the recycling market is not adequately efficient in recycling wastes
to meet local or state objectives to reduce the future need for additional treatment and disposal
facilities. The recent rapid increase in the number of waste exchanges provides evidence that
the perceived need for additional stimulation of the recycling market is increasing, hot
decreasing.
BROKERS
There are, of course, for-profit brokerage companies which specialize in transferring
wastes from sellers to buyers. Some of these are very successful. They have a substantially
different role in the marketplace than waste exchanges. Brokerage operations tend to
specialize in particular commodities or waste streams. Because they are operating on a for-
profit basis, a major consideration is the relative value and profitability of the materials in,
which they specialize. In addition, by focusing on relatively narrow market niches, they
develop expertise on the materials in which they trade,including: the processes which produce
or'Utilize those materials, their chemical and physical characteristics, and the companies which
' - •' . 42 . -.'.-•'
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need to dispose of or obtain those materials. Many operate on a national basis. Brokerage
companies often specialize in unused surplus chemicals, solvents, precious metal wastes, and
heavy metal sludges. The Canadian Chemical Exchange, for example, deals primarily with
off-spec or overstock virgin chemicals, dyes, pigments and Pharmaceuticals. Some brokerages
specialize only hi overstock chemicals resulting from plant closings.
The nature of such for-profit operations implies certain restrictions. Small, complex,
or heavily contaminated waste streams are likely to involve too much risk and too little profit
to be worth handling. Waste streams with recoverable or reusable materials which are
inexpensive in then: virgin form provide too small a potential margin of profit. Further, a
waste stream falling outside the usual realm of expertise of the company will generally involve
transaction costs which are too high (because of the need to spend more time identifying
potential markets or sources) for the potential financial return. Therefore, there are large
sectors of the waste stream which are of interest to generators and to the public (e.g., because
of increased demand for landfill space) but which are unlikely to be handled by brokers.
There are also limitations hi the roles that brokers can play due to concerns about liability.
\ -
The value of brokers hi the marketplace is their specialized knowledge of markets and
sources for the particular materials in which they, trade. Brokers usually operate in one of two
ways to protect the market value of their knowledge. First, they might actually purchase and
sell the material, taking legal possession, though usually not physical possession, of the
material. While they will provide a complete analysis of the physical and/or chemical
characteristics of the materials they are selling, they will often not inform either the seller or
the buyer of the identity of the other party. Such an approach can make transfers of any
hazardous wastes very risky for all parties including the broker, and significantly limits the
degree to which brokers are likely to involve themselves in recycling hazardous wastes. For
most generators, not knowing the ultimate buyer and user of a hazardous waste is likely to be
equally unacceptable due to liability concerns.
The second mode of operation for brokers is to serve as the middleman, but not to
actually buy or sell the waste. The broker will obtain non-circumvention agreements from
both parties prior to introducing buyer and seller, including a guarantee of a fixed percentage
or price per unit of the materials sold. This mode of operation is most common for smaller
brokerage operations dealing with high-volume, high-value commodities (e.g., natural gas).
While this would be a more viable approach for trades involving hazardous wastes, since the
seller would be able to determine the security or liability risk of sending such wastes to the
potential buyer, it creates a long-term risk for the broker of being cut out of future transactions
(although some brokers have long-term and/or exclusive contracts with their buyers).
CORPORATE SECONDARY-MATERIALS MARKETING
Large corporations have become increasingly sensitive to the costs of disposal and the
potential risk of liability due to the wastes they generate. Pollution prevention has become a
major strategy for reducing wastes requiring treatment or disposal. For those wastes which
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are generated, however, determining potential reuse options and locating marketing is
important. .To the. extent that these materials are large-volume and routinely generated, large
companies have tended to develop their own networks and markets. Where the wastes are
hazardous, corporations will either have their own audit teams determine that the risk of future
liability from recycling to an external source is minor, or will treat and dispose of the
materials.22 ~
Even for those wastes which are neither hazardous nor routine, there are limitations to
the roles which waste exchanges presently play. The time required for transfers through the
waste exchange are often longer than large companies are willing to wait. NMEN, of course,
has only just started (January, 1993), and could help to facilitate greater utilization of waste
exchanges by large corporations.
RELATIVE MARKET STRENGTHS OF INDIVIDUAL WASTE EXCHANGES
Public and non-profit exchanges generally do not discriminate as to type, purity or size
of waste streams. They list just about all wastes, thus playing a role in the marketplace for
generators that is not presently played by brokers. Because the exchanges deal with all kinds
of wastes, and because they are extremely small, they lack the specialization of brokerages.
As noted previously, there is a regional variation in the materials listed on exchanges. While
they might provide a service to, and work cooperatively with brokers, their ability to serve
generators in their service areas is limited by their ability to develop a significant and
economically viable market role similar to that of the brokers.
Competition from other exchanges is a major concern for exchanges relying on private
funds and grants, and for exchanges which serve a large regional role (SEWE, SWIX, PME,
NIWE). Those exchanges with state funding from tipping fees (IWRC, CALMAX) or with
funding from other stable state revenues (IMES, RENEW) seem unconcerned about
competition. Competition does affect PME, which began hi 1988, just before IMEX. IMEX
is located in the industrial region of the state of Washington. PME's industry base in eastern
Washington, northern Idaho, and western Montana is too small to support a non-profit
exchange. IMEX's services are funded through a waste tax and are free, while PME has to
seek industrial support and grants.
Questions about the ability of new waste exchanges to enter the market could be
somewhat misleading, if this is put in the usual market context of for-profit organizations.
Evidence in recent years gives little reason to believe that waste exchanges serving a broad
role in recycling wastes of allkinds could be financially self-sufficient. On the other hand,
additional waste exchanges might be able to better facilitate the marketing of wastes which
would otherwise go to disposal. The addition of numerous waste exchanges in the last year
indicates that states regard them as serving a market need, even if that need can only be met
through state funding. The^ existence of NMEN might be a factor hi these additional start-ups,
since many of these excha'hges can take advantage of the existence of a large listings base and
the ability to manage listings using NMEN service and database.
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Chapter?
WASTE EXCHANGES AND ENVIRONMENTAL LIABILITY ISSUES
One of the key disincentives to the use of waste exchanges in the United States is the
fear of incurring legal liability under one or more environmental laws. .This section presents a
general overview of the liability concerns under RCRA and CERCLA associated with the use
of waste exchanges, from both the exchange's and the user's perspective. The information is
based oh review of articles23 and summary materials,24 not a summary of pertinent case law.
As such, me findings presented below should be viewed as preliminary.
Waste exchanges and users of waste exchanges face potential liability under the
Comprehensive Environmental Response Compensation and Liability Act (CERCLA), the
Resource Conservation and Recovery Act (RCRA), and common law theories, commonly
known as "toxic torts." Potential liability under these laws depends on the nature of the
material being managed (i.e., whether the waste is a "hazardous waste," "hazardous
substance," or is toxic in nature), the actions of the parties, and the results of those actions.
For purposes of this discussion, it is presumed that waste exchanges function in a role where
they:
• arrange for contact between a party wishing to transfer a waste/secondary
material and a party wishing to obtain such materials.
• do not take possession of the waste (i.e., no control, storage, etc.).
• do not transport or arrange for the transport of the waste material.
In addition to these assumptions, several other observations are worth noting. Most
waste exchanges are private entities, although the government, at various levels, is
increasingly becoming involved in waste exchange operations. In addition, although most of
the materials that are managed through waste exchanges today are non-hazardous, some
exchanges do manage hazardous wastes.
RCRA LIABILITY
RCRA regulations identify those wastes that constitute "hazardous wastes" and impose
specific regulatory requirements on hazardous waste generators, transporters and treatment,
storage and disposal facilities. These requirements are designed to ensure that such wastes are
properly managed and tracked at each point between generation and disposal, thereby ensuring
protection of human health and the environment.
: Upon applying RCRA requirements to waste exchanges, it appears that the waste
exchanges are not subject to RCRA liability if they do not generate, transport, treat, store, or
-45 '
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dispose of hazardous wastes.25 As noted above, waste exchanges do not possess or actively
manage the wastes they list and, thus, they do not generate, transport or otherwise manage
hazardous wastes. From the perspective of a waste exchange, the most significant aspect of
the RCRA hazardous waste regulations is that RCRA "hazardous wastes" are defined as
"hazardous substances" under CERCLA (CERCLA liability is discussed below).
In contrast to the lack of direct RCRA regulation of waste exchanges, such regulations
do potentially impact individuals or corporations that use waste exchanges (i.e., waste
generators and recyclers). Under the hazardous waste rules, hazardous waste generators are
subject to manifest, pre-transport, record-keeping and reporting, and certain land disposal
restriction requirements, m addition, if a generator stores hazardous waste on-site for more
than 90 days he/she must obtain a RCRA permit. Therefore, many hazardous waste
generators are interested in ensuring the disposition of their waste as quickly as possible,
which is not always compatible with the use of waste exchanges. RCRA regulations also
contain complex provisions applicable to the recycling of hazardous wastes. Under these
provisions, many secondary materials being recycled continue to be subject to regulation when
transported, stored, treated or disposed of (the recycling process itself is generally not
regulated, with certain exceptions). Thus, recyclers that might accept wastes from wastes
exchanges must understand these rules and be capable of complying with them. Some of the
requirements, such as the permit arid corrective action requirements, can be extremely
burdensome. In addition, penalties for violating these requirements are substantial. Products
generated through hazardous waste recycling are generally not regulated (again, some
exceptions exist), however, wastes might be regulated as hazardous under the mixture or
derived-from rules. Such wastes must be treated and disposed of in compliance with land
disposal restriction treatment requirements as well as technical RCRA disposal requirements.
To summarize, waste exchanges do not appear to be subject to significant potential
liability under RCRA because they do not generate or manage hazardous waste. However, the
generators and recyclers that use waste exchanges might be reluctant to become involved in the
exchange of hazardous waste due to their lack of confidence that such transactions will be
conducted in compliance with the requirements of RCRA, The technical nature of these
requirements (which often results in a lack of understanding regarding compliance and
liability), severe penalties, stigma associated with hazardous waste, and remaining CERCLA
liability for listers might outweigh economic gains that can be achieved by reusing wastes
through exchanges.
CERCLA LIABILITY
CERCLA imposes liability for the cleanup costs, response costs, and damages to
natural resources upon specific persons associated with the release of hazardous substances
into the environment. Hazardous substances are specifically defined in implementing
regulations and include, but are not limited to, those wastes that are RCRA hazardous wastes
(See, 40 CFR §302). It is important to note that non-hazardous wastes might also constitute
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hazardous substances where they contain compounds or constituents listed as hazardous
substances. CERCLA response cost liability might be imposed upon:
• owners and/or operators of a facility that is releasing or has released hazardous
substances to the environment,
• persons who arranged for the treatment or disposal, or the transport prior to the
treatment or disposal, of hazardous substances owned or possessed by such
person (i.e., the generator of the hazardous substance).
• persons^ who acceptor have accepted hazardous substances for transport to
disposal or treatment facilities or sites selected by such persons.
CERCLA was enacted to empower the federal government so,that it could respond to
releases of hazardous substances and to clean up inactive or abandoned dump sites. The Act
imposes a standard of strict liability (i.e., no element of fault must be proven) in combination
with joint and several liability (i.e., any legally responsible party can be held liable for all
cleanup/damage costs imposed). This combination, when linked to the.extensive list of
hazardous substances regulated, has dramatically increased the potential liability encountered
by anyone managing hazardous substances.
Applying these provisions to a situation where a waste contains a hazardous substance
and is being transferred via a waste exchange, several observations can be made. If, as noted
above, waste exchanges do not take ownership or possession of the waste, they do not appear
to be subject to CERCLA liability. This is a result of the general requirement that a person
"own or possess" the waste hi order to incur liability. However, no specific research has been
conducted regarding the precise meaning of the terms "own or possess" under CERCLA, arid
thus, absolute conclusions cannot be drawn. Traditionally, ownership is indicated by the
holding of legal title, and possession by physical control or management. Where an exchange
does take possession or ownership of the waste, it is plausible that they could be subject to
CERCLA liability. This result could occur if reuse of the waste is viewed as disposal or
treatment under CERCLA or where some of the waste is ultimately treated or disposed.
Again, additional research would have to be conducted to determine how these terms have
been interpreted. .
Persons that generate hazardous substances are clearly subject to CERCLA liability
because they arrange for the transport, disposal, and treatment of their waste. Generators have
sought to avoid CERCLA liability by claiming that they were selling such wastes (i.e., that the
waste comprised a product). Such arguments have generally been rejected by the courts,
although at least one case agreed with this argument. Thus, there might be a legal line of
demarcation beyond which reuse is sufficiently commercial to avoid generator (and recycler)
liability. Additional research would be needed to clarify this issue. Note that since RCRA
hazardous wastes are defined as hazardous substances, all RCRA generators are potentially
subject to GERCLA liability.
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Potential users of transferred .wastes will also be subject to CERCLA liability where
any of the waste they are managing is treated or disposed (because, by necessity, they must
own or take possession of the waste as part of the recycling process). Where none of the
waste is treated or disposed (i.e., all is recycled), the question arises as to whether different
forms of recycling meet the definition of treatment or disposal under CERCLA. As noted
above, the meanings of these terms as applied under CERCLA have not been researched for
this task. Finally, products are generally not defined as hazardous substances.
To summarize, where a waste exchange does not "own or possess" the waste at issue,
it is unlikely that they would be subject to CERCLA liability. However, generators of
hazardous substances are clearly subject to CERCLA liability. As a result, they are very
concerned about who receives their waste and how that entity manages the waste. This is
because mismanagement of the waste that results hi a release or potential release to the
environment might subject the generator to considerable liability. Users of transferred wastes
are also subject to potential liability if they treat or dispose of any of the waste, or if their
recycling process is defined as treatment or disposal for purposes of CERCLA.
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Chapters
ROLES OF WASTE EXCHANGES
ROLES OF WASTE EXCHANGES
In reviewing the various waste exchanges, there appear to be a number of unique roles.
Possible roles are discussed in this chapter and include:
- . ' *"' - - ' • - .' , ' l'--~
• providing information to identify potential trades
• facilitating generators access to the appropriate recycling market.
• facilitating the reuse of complex, unusual, impure, smaller volume and/or low value
••- wastes or secondary materials.
• facilitating the development of new markets for waste materials.
• providing education and/or technical assistance with respect to reuse and recycling
options.
• relating recycling to other available options (e.g., source reduction).
. Providing Information to Identify Potential Trades
Providing information is the basic function of most waste exchanges, and, in many
cases, the only service provided. Information can be provided through a catalog or an onrline
system. The system could involve only a few listings, or many. It could be supplemented by
technical support or just identify possible contacts. .•
A national system, such as NMEN, clearly has the capability to broadcast the
information on wastes needed and wastes available to a much greater audience than local
exchanges and thus has the potential to improve the market-value of the information. On the
other hand, some exchanges are only viable within limited geographic areas, either because of
size or cost of waste transport. The existence of NMEN, however, can help to reduce the
administrative and maintenance costs, even for locally-based exchanges.
Matching Buyers and Sellers
, Another role for waste exchanges involves direct efforts to match buyers and sellers.
This might involve either active efforts by exchange staff to find a specific match for a waste,
or efforts to link generators with possible buyers with whom they could work in the future.
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A more proactive approach could involve outreach to appropriate industries to attempt
to find, or generate interest in, a particular waste stream, either on a one-tune or long-term
basis. Finally, exchange staff might use available state data (e.g., on waste generation) to
identify targets for direct marketing outreach about recycling opportunities. The Iowa,
Illinois, and Ontario exchanges all have staff whose role includes this kind of continual
outreach and exploration.
Any version of this role is more costly than simply providing a listing service. The
more proactive the approach, the more staff is required, and the higher the costs are to
maintain the exchange. However, from the perspective of sponsoring state or local
governments, the benefit of such an effort to reduce disposal costs by recycling as wide a
variety of waste streams as possible might be seen as necessary.
v
Facilitating Reuse of Wastes as Secondary Material
Waste exchanges tend to handle a significant proportion of waste streams which are
difficult to trade. Assuming the higher estimate from the 1991 SWIX study, only 30 percent
of wastes listed with an exchange are traded, meaning that as much as 70 percent of the wastes
listed eventually require treatment or disposal. Management of a database with such a high
percentage of materials which are not traded means that a significant portion of, administrative
and/or marketing tune is used for waste streams with limited exchange potential. From a
sponsoring state or local government perspective, however, this can be an appropriate and
necessary part of the exchange's activity; it also might be critical for some of the smaller
businesses in the exchange's service area.
Facilitating Market Development
Finding and developing new markets for potential waste streams, or identifying hew
companies to bring into the recycling market, is an on-going activity for a proactive exchange.
The potential market is not finite or stable; there are continual changes both in the wastes to be
traded, and hi the companies involved. Exchange staff who spend considerable time in the
field need to continually research new technologies and new markets, both to identify new
waste sources and new potential users for existing waste streams.
Providing Education and/or Technical Assistance
Several of the more proactive waste exchanges provide a variety of educational
outreach and technical assistance services. For instance, SEWE provides workshops on
recycling for companies hi its service area. IWRC and IMES provide on-site evaluations of
recycling opportunities at plants. These services are free, and are meant to maximize
educational impact and service to industry. They are similar in approach to services offered
through state pollution prevention technical assistance programs.
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Relating Recycling to Pollution Prevention and Other Waste Minimization Options
Another role of waste exchanges is to tie the activities of the exchange to related efforts
of other agencies. For instance, staff at some waste exchanges look for waste reduction
possibilities and/or refer the company to the state pollution prevention technical assistance
office following site visits. For companies having a hard time finding a market for a-waste,
some waste exchanges explore options for internally reducing the waste stream. In some
.cases, there are strong and direct ties between the waste exchange and the pollution prevention
office. Specifically, waste exchanges in Texas, Illinois", Minnesota and Iowa are part of the
state pollution prevention office. SEWE also has strong ties with the North Carolina pollution
prevention office. Another example is the effort of IMEX to work with DRMO at Fort Lewis.
Tying together the exchange efforts of the non-federal waste exchanges to those of DoD offers -
a major opportunity to expand the effectiveness, market size and market attractiveness of the
exchanges. . ,
FACTORS INFLUENCING SUCCESS/FAILURE
As noted in Chapter 4, one, of the difficulties in defining whether an individual waste
exchange is successful, or whether waste exchanges in general are successful, is finding an
appropriate measure for success. If the measure of success is that waste exchanges should
become financially independent of government support, there appear to be no current
successful exchanges. Those organizations which have made trade in wastes a successful self-
supporting business limit their activities to selected waste types, qualities and volumes.
Even the largest waste exchanges are relatively small organizations with limited
budgets. There were numerous waste exchanges identified in EPA's 1980 report, but very few
of today's waste exchanges have even a ten-year track record. Even one of the two waste
exchanges funded by an EPA grant to establish the NMEN system has since failed. -Not all the
factors providing a higher probability of success are within the control of individual waste
exchanges. .
Budget stability is the least controllable, though it can significantly depend on other
factors. If waste exchanges are unlikely ever to be entirely market-based and self-sufficient,
they will be in need of state and local government support. A sufficiently severe budget crisis
could undercut even a strong, service-based organization. When New York faced its budget
crisis, not only did NIWE lose its support, but the state's pollution prevention technical'
assistance office in the Environmental Facilities Corporation (one of the oldest technical
assistance programs hi the country) was placed on a fee-for-service basis.
The waste exchanges which have achieved greater stability, however, appear to be .
those which have filled more of the roles for waste exchanges identified above. Waste
exchanges which provide education, technical assistance and other support for businesses
which assist companies in identifying and maximizing exchange opportunities seem to be the
most successful. The two oldest current North American exchanges, OWE and SEWE, both
• , • 51
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provide some of those services. (State pollution prevention technical assistance programs
(TAP) have often found that, when state budgets are being cut, businesses in the state become
important allies. Where the TAPs have developed strong working relationships with
companies, the companies do not want to lose useful services.) This does not mean that
exchanges should not seek other sources of funds, only that some of the more important
services of a waste exchange are likely to continue to require government support.
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Chapter 9
FINDINGS AND RECOMMENDATIONS
GENERAL FINDINGS
Current Operations ,
The number of waste exchanges is growing rapidly. In addition to the 42 waste
exchanges already participating in NMEN and the two known non-participants, there are at
least 9 additional waste exchanges operating in North America. The majority of these
exchanges appear to be information exchanges providing a place to list available or needed
wastes. .
For most of the newer or smaller exchanges, it appears that a national bulletin board -
could play an important role in reducing some of the administrative burden of matntahiing
and/or publishing a separate listing system. Thus the opening of NMEN in January 1993
might be a factor supporting the increasing number of exchanges. .
The largest operating exchanges are those serving federal agencies, operated by DoD
and GSA. At present, there is little interaction between the non-profit exchanges serving state
and private sector interests and the federal exchanges. Information on the federal exchanges,
for example/is not listed on NMEN nor is information from NMEN incorporated into the
federal system. ''.-'• -
Until recently,, there appeared to be a trend towards a few regional exchanges serving
the needs of the states in fairly wide geographic areas (e.g., NIWE in the northeast, IMES in
the midwest, SWIX for the south coast). But this now appears to be changing with the
proliferation of individual state exchanges. This could be due to the availability of the national
database or to the perceived inability of regional waste exchanges to adequately serve the
needs of individual states. The future relationships of these exchanges are still evolving.
Types And Amounts Of Wastes Transferred
Information on volumes of and types of wastes transferred through exchange operations
are difficult to estimate, since exchanges tend not to have the resources to either gather Or
verify such information. However, a 1991 SWIX study showed almost eight million metric
tons of waste materials available through listings on waste exchanges, based on 3,607 listings
(Exhibit 3-2). Data from NMEN in 1993 indicates more than twice that number of listings,
without indicating tonnage. Percentage estimates of listings which result in trades are also
unreliable, since most exchanges do not systematically track transactions; however, the 1991
SWIX study estimated between 10 percent and 30 percent of listed materials are traded:
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Typical wastes transferred include plastics, solvents, acids, alkalis, wood and paper,
metals and metal sludges (see Exhibits 3-1 through 3-3). Most exchanges estimate that a
substantial majority of their transactions are for non-hazardous rather than hazardous wastes.
Some of the older exchanges indicate that there has been a continuing trend hi that direction,
perhaps due to the regulatory and liability issues surrounding the recycling of hazardous waste,
or the related economics of hazardous waste transfers.
As noted in Chapter 6, data to estimate the percentage of the recycling market served
by waste exchanges were not developed during this study, and would be difficult to estimate
due to the lack of adequate transaction information maintained by the exchanges. The
percentage of wastes transferred through exchanges might be small, but it is likely to include a
disproportionate amount of difficult-to-transfer wastes (e.g., small volume wastes, wastes from
small companies with limited market access and information, complex, contaminated or
unusual wastes, and wastes with little or no market value). These are the waste streams for
which other market systems for transactions are likely to be unavailable or ineffective.
Funding
Most waste exchanges operate with very limited budgets; an average of slightly over
$100,000 per year with a total for all waste exchanges of about $3.5 million per year. While
there are no reliable figures on which to base total transfer volumes, it seems likely that the
average cost per ton figure might be well under $10 per ton (see transfer estimates in Chapter
Waste exchanges are largely dependent on budget support from federal, state and local
governments, either through direct budget outlays, grants, indirect support through
universities, tipping fees or other mechanisms. Some exchanges have defrayed their expenses
through fees for catalogs, listing fees, or grants from industry. Efforts to exist totally
independent of government funding have not been successful.
EPA has provided support for the non-federal waste exchanges both through the
funding of NMEN, and through grants to develop support individual waste exchanges or
specific waste exchange activities. For example, the Iowa waste exchange was started with
funds from a PPIS grant from EPA's Pollution Prevention Division, and NIWE received a
grant from EPA's Industrial Solid Waste Branch to evaluate opportunities for recycling of
foundry sands.
Benefits To Participants
The roles and modes of operation of waste exchanges vary significantly. Some are
primarily listing systems. Others are actively involved with the industries in their geographic
areas, providing outreach and education services to make companies aware of the benefits and
opportunities of recycling, providing on-site assessments of recycling or waste reduction
opportunities at plants, and working closely with state pollution prevention technical assistance
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programs. Some have their own electronic bulletin board systems, while others have no
computerized system or catalogs. ,
There are strong incentives for companies to-pursue, and for states to promote,
recycling of materials that would otherwise require treatment or disposal. Even with waste
reduction as a priority, there will still be a continuing need for resource recovery and reuse.
For companies, the advantages of reuse and recycling are fairly straightforward. The seller
can reduce disposal costs and/or increase profits from the sale of recoverable materials. The .
buyer, if quality needs can be met, can lower raw material costs by using waste material as
substitutes for virgm materials.
While the services of waste exchanges are either low-cost or free to the user, the use of
waste exchanges by companies will depend on whether the exchanges can provide better, more
efficient market access or alternatives than are otherwise available. For some smaller ,- -
companies, waste exchanges might be a primary source of access to a needed recycling
market. For larger companies, the issues are likely to be the size of the market accessible
through an exchange and the speed with which possible sources or markets can be identified.
Benefits To State/Local Governments
For state and local governments, there are direct benefits to increased support for waste
exchanges. Supporting waste exchanges has the potential to provide a low-cost method to
promote reuse and recycling (some waste exchange programs have budgets as low as
$10,000). In addition to reducing disposal costs, an active recycling/waste exchange program
can benefit state and local economies. Promoting reuse and recycling through waste
exchanges can also help to reduce the demand for new landfill and waste treatment capacity.
Further, by establishing a waste exchange, a state or local government can demonstrate its
willingness to provide a favorable atmosphere for business.
There are, however, some cost tradeoffs involved. For instance, all of the roles
described in the preceding section cannot be met with budgets as low as $10,000. Waste
exchanges with restricted budgets and extremely limited services might not provide significant
benefits to the business community. Adding the capabilities which can lead to real service by
an exchange, such as on-site assistance at plants and proactive, knowledgeable assistance in
targeting waste streams for reuse and recycling, can increase the impact on severely strained
budgets. Even the largest exchanges identified hi this study have annual budgets slightly in
excess of $200,000 which, if the exchange were effective, could be a bargain compared to
avoided waste management costs and/or the benefits of support to local companies.
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SPECIFIC FINDINGS
The following are some of the specific findings from the review of non-federal and"
federal waste exchanges.
Non-Federal Waste Exchanges -
• The expectation that waste exchanges can become self:sufficient is unrealistic. Many
of the materials listed on exchanges are low value wastes. Even if listers were willing
to pay a minimal fee, an exchange would have to have 4,000 organizations listing
materials for a $50 fee hi order to raise $200,000; enough to fund a staff of two or
three people. The largest waste exchanges currently have far fewer than ,1,000 listing
companies. .
• Waste exchanges provide listing services at very low cost. Exchanges facilitate
materials transactions at costs as low as $10 per ton.
• Waste exchanges have increased their effectiveness through increased interaction with
waste generators, either through technical assistance program tie-ins (workshops,
conferences, on-site assistance), regional representatives visiting potential users, or
aggressive telemarketers. Many of the more proactive waste exchanges have staked
out roles as market developers by finding uses for hard-to-move items and_shifting
resources to unusual trades.
• Some state-funded exchanges (CALMAX, IWRC) are relying on tipping fees as major
funding support. This ties them into state solid waste reduction goals and gives them
an element of stability (both funding and purpose).
• The existence of NMEN is helping to stimulate the development of new state and local
exchanges, many of which are being started at reduced cost because they have access to
the large NMEN database and can use NMEN software to.manage their own records.
• For most of the exchanges, hazardous waste is playing a lesser role than non-hazardous
waste, particularly in terms of the number of actual trades. Many of the hazardous
waste listings merely get carried-over from catalog to catalog. Liability is the largest
barrier to hazardous waste transfer.
Federal Waste Exchanges
• The federal waste exchanges (DoD, GSA) could provide a major impetus to the growth
of a national waste exchange market by sharing listings with NMEN at the national
level and working cooperatively with the individual exchanges near military bases and
other federal facilities.
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Until a more complete linkage can be developed between federal and non-federal
exchanges, non-profit and state waste exchanges can offer a valuable service of their
own to these federal programs. The public does not have direct access to either the
DoD R/T/D Program or GSA Utilization and Donation Department databases. Local
exchanges could provide information on .items available at federal auction. Publicizing
auction dates will provide greater visibility for the government's surplus items and
generate greater interest in public auctions. ... .
The change to the use of computers for tracking items available for transfer has
increased the efficiency of GSA transfers substantially. .
As with the non-federal waste exchanges, the key factor to success in the federal
exchanges appears to be a proactive approach to transfers and sales, including
knowledge of sources and potential recipients of materials, as well as knowledge about
the materials transferred. ,
RECOMMENDATIONS
Based upon the research conducted for this study, the following recommendations were ,
reached regarding possible mechanisms to encourage the recovery of industrial wastes.
• Consider ways to limit concerns over liability and clarify regulatory issues regarding
recycling and reuse of hazardous wastes. The exchange of hazardous materials will
always need to be regulated to protect public health. Waste exchange transactions will
grow if liability is transferred with the material in an exchange where good-faith is
exhibited. Criteria outlining procedures for carrying out a good-faith exchange could
be developed that would have to be followed, documented, and approved in order to
transfer liability. It may also be necessary to guarantee that the receiver of the
hazardous material is in a financial position to be responsible for it and/or has a clean
accident record and practices good materials handling. ,
• Consider continued support for NMEN, in whatever location, so that it can be allowed
to develop to its fullest potential. While it is not a substitute for a geographically
localized exchange, it does offer the potential of a larger market than would be
available regionally or locally. In addition, many of the new and developing exchanges
are depending on it. PME is attempting to make the system easier to use and is
working on more software which will help exchanges work with the system more
efficiently. ,
• Consider alternatives to support the development/continuation of model waste
exchanges;-waste exchanges which fulfill the range of objectives and roles which it
considers to be appropriate. As discussed in the previous chapter, this might include a
proactive approach to promoting recycling, integrating waste exchange efforts with
pollution prevention technical assistance and/or economic development efforts of a
-. • ' ,57 ," . '. ' ' . ; . •
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state, educational outreach, or other factors EPA considers important. EPA could
promote the development of such waste exchanges through limited competitive grants,
or through the development of recommended roles which could be the basis for state
requests through other federal grant programs.
One additional consideration might be that the waste exchange model should include
some method through which the provision of waste exchange services can be market-
tested to avoid the bureaucratization of waste exchange services. Possible examples
might include a competitive approach, such as that utilized hi Iowa (see Chapter 3), or
a requirement that the waste exchange receive a certain proportion of its funds from
non-governmental sources (fees, private-sector matching funds, or other alternatives).
If EPA were to provide competitive grants, waste exchanges could be encouraged to
propose their own models for market-testing their services.
Encourage the integration of NMEN and Federal waste exchange information systems
(DoD and GSA). This could involve sharing listings and promoting exchanges hi both
directions. One advantage of such an integration is that it would create a much larger
transactions marketplace, and thus create a magnet for increased private sector
participation in NMEN. Among the issues requiring resolution would be ensuring
compatibility between Federal procurement rules' and the way in which NMEN and
individual waste exchanges are used for advertising available waste or hazardous
materials.
Consider additional ways to promote the visibility of waste exchanges, and of NMEN,
within the business community and with trade groups.
Consider reviewing, through associations or with companies, the hazardous wastes that
are transferred through waste exchanges. Such a review could try to determine who is
making the trades, and the types of wastes which can be most effectively transferred
via waste exchanges hi spite of the potential regulatory barriers. If appropriate, this
information could be publicized through the exchanges to promote greater recycling,
rather than disposal, of hazardous wastes.
Consider developing tools to help waste exchanges track transactions and other
activities.
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NOTES
1. Materials received from Bob Smee, PME, NMEN, 5/19/93 and phone conversations
with Bob Smee on May 1, 1993, June 21, 1993.
2. Phone conversation with Diane Shockey, IMES, June 14, 1993.
3. Materials received from Joyce Mason including California Integrated Waste
Management Board Planning Committee, March 2, 1993 Agenda Item #4; Article by
Joyce Mason entitled "The California Materials Exchange(CALMAX): .Companies
Swap Waste, Lighten Landfills" to be printed in Current Municipal Problems. Summer
1993; CALMAX "Materials Listings Catalog", March/April 1993; and phone
conversation with Joyce Mason on June 6, 1993.
4. Texas Water Commission, "Resource Exchange Network for Eliminating,Waste : 1990
Annual Report" February 1991; RENEW "Catalogue Listings", April 1993;
RENEW's "Blue Card"; RENEW Fact Sheet; and Phone Conversation with Kenneth
Zarker and Hope Costillo of Texas Water Commission's Office of Pollution Prevention
and Conservation and RENEW, June 17, 1993.
5. Phone conversations with Philippe Laroche, Canadian Chemical Exchange, May 14,
1993; Bob Laughlin, Ontario Waste Exchange, May 5, 1993 & June 1, 1993.
6. ORTECH International, "Waste Exchanges: Their Role in Enhancing Waste Diversion
in Canada;" ORTECH International, "The Ontario Waste Exchange - A Preferred
Option." A presentation to the Metropolitan Toronto Waste Management Conference.
October 29,1992; ORTECH International, "Identification of Opportunities for
Increased Efficiency of Waste Exchange." April 27, 1993; and phone conversation
with Robert Laughlin, May 1, 1993.
7. Phone conversation with Claudia Moore, June 16, 1993; "California Waste Exchange
Directory of Industrial Recyclers," 1992; "California Waste Exchange
Newsletter/Catalogue, 1992;" Description of the California Waste Exchange from the
CWE.
8. ORTECH, "Identification of Opportunities for Increased Efficiency of Waste
Exchange" p.97. ..„.-..
9. Phone conversations with Bob Laughlin, Ontario Exchange, May 5, 1993, Maxie May
SEIWE, May 24, 1993; Susan Salterberg IWRC, May 21, 1993.
10. ORTECH, "Increased Efficiency of Waste Exchange," p.33.
11. ORTECH, "Increased Efficiency of Waste Exchange," Table 3, p. 77-80.
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12. Memorandum from Bill Lawrence (IMEX) to Todd Yerkes, "1992 Annual Report -
IMEX," December 30, 1992.
13. ORTECH, p.90.
14. Phone conversation with Diane Shockey, Industrial Materials Exchange, June 14,
1993.
15. Comments by Bob Loughlin, of the Ontario Exchange and ORTECH, at the National
Roundtable of State Pollution Prevention Programs conference in San Diego, April 29.;
1993, and subsequent phone conversation, May 1993.
16. Phone conversation with Susan Salterberg", IWRC. May 21, 1993. Cost per ton
calculated by dividing IWRC Exchange Budget by quantity of exchanges made
($221,000/10,000 tons). Including the foundry sand would yield a figure of $7.37 per
ton.
17. Phone conversation with Maxie May, Southeast Waste Exchange. May 24, 1993.
18. Phoneconversation with Maxie May, Southeast Waste Exchange, May 24, 1993.
19. Materials on NIWE provided by one of the authors, Robert Kerr, a former member of
NIWE's Board of Directors.
20. King County Hazardous Waste Management Program. Pamphlet "Working Together to
Reduce Hazardous Waste." February, 1993 and a printed description of IMEX.
s
21. Because of limitations on the scope of this study, it is not possible to provide statistical
information on the relative roles of the different recycling markets referred to in this
chapter. The resource and survey limitations precluded gathering information from
brokerage or corporate recyclers, or trying to access or develop databases to compare
their relative roles. In addition, the inadequacies of the data on transactions available
through the waste exchanges would make meaningful comparisons difficult to
construct. Nonetheless, it is possible to sketch out some information on the market
roles, based on the information provided by the waste exchanges.
22. See R. Kerr, "Computerization of Waste Exchange Operations," report to the
Regulatory Reform Staff, OPPE, EPA, 1985.
23. Hodge, J.A., Implementing Recycling Within the Regulations: Reducing the
Uncertainty Over Liability. 1987 National Conference on Waste Exchange, Charleston
S.C. 3/3/87. . - . .
24. Schraff, C.R., and Steinberg, R.E., RCRA and Superfund. Garland Law Publishing,
1988.
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25. N6te that these terms are specifically defined under 40 CFR §260.10.
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