AT YOUR  FACILITY
            Harry M. Freeman
    Chief, Waste Minimization Branch
             Mary Ann Curran
          WRAP Program Director
        Waste Minimization Branch
  Risk Reduction Engineering Laboratory
          Cincinnati, OH  45268
  For presentation at the Conference on
Waste Minimization in the Tri-State Area
             Cincinnati,  Ohio
             August 17,  1989
         CINCINNATI, OHIO 45268


      Today's rapidly developing and changing technologies and industrial
products and practices frequently carry with them the increased generation of
materials that, 1f improperly dealt with, can threaten both public health  and
the environment.  The U.S. Environmental Protection Agency is charged by
Congress with protecting the Nation's land, air, and water resources.  Under a
mandate of national environmental laws, the Agency strives to formulate and
Implement actions leading to a compatible balance between human activities and
the ability of natural systems to support and nurture life.  These laws direct
the EPA to perform research to define our environmental  problems,  measure  the
Impacts, and search for solutions.

      The Risk Reduction Engineering Laboratory is responsible for planning,
implementing, and managing the research, development and demonstration of
programs to provide an authoritative, defensible engineering basis in support
of the policies, programs, and regulations of the EPA with respect to drinking
water, wastewater, pesticides, toxic substances, solid and hazardous wastes,
and Superfund-related activities.  This publication is one of the  products of
that research and provides a vital communication link between the  researcher
and the user community.

      The EPA encourages generators of hazardous and non-hazardous waste to
carry out assessments in their facilities to identify opportunities for waste
minimization.  This paper was prepared by the EPA's Risk Reduction Engineering
Laboratory to describe six elements which should be considered when
establishing a waste minimization program for a facility.  These non-binding
guidelines, as suggested by the Agency, have applications across a wide range
of industries and manufacturing processes and can assist a waste generator in
meeting regulatory requirements.


      There is underway today in manufacturing facilities in the United States
and other industrial countries, a clear movement toward "waste minimization"
as a means for reducing environmental problems caused by the generation,
treatment, and disposal of hazardous wastes.  In many respects this is only a
continuation of efforts by industry to increase product yields and profits by
reducing wastes.  However, as it has become increasingly clear that there is a
limit as to what can be achieved through "end-of-the-pipe" approaches to
solving problems, waste minimization has become increasingly popular.

      This paper offers several suggestions for implementing an effective
waste minimization program.  Included is a review of the EPA's recently issued
guidance for establishing a waste minimization program.


      With the passage of the Hazardous and Solid Waste Amendments (HSWA) of
1984, the U.S. Congress established a national policy declaring the importance
of reducing or eliminating the generation of hazardous waste.  This policy
statement is:

            The Congress hereby declares it to be a national policy of
            the United States that wherever feasible, the generation of
            hazardous waste is to be reduced or eliminated as
            expeditiously as possible.  Waste that is nevertheless
            generated should be treated, stored, or disposed of so as to
            minimize present and future threat to human health and the

      In this declaration, Congress established a clear priority for reducing
or eliminating the generation of hazardous wastes (a concept referred to as
waste minimization) over managing wastes that were "nevertheless" generated.

      EPA believes that hazardous waste minimization means the reduction, to
the extent feasible, of hazardous waste that is generated prior to treatment,
storage or disposal of the waste.  It is defined as any source reduction or
recycling activity that results in either: (1) reduction of total volume of
hazardous waste; (2) reduction of toxicity of hazardous waste; or (3) both, as
long as that reduction is consistent with the general goal of minimizing
present and future threats to human health and the environment.1

      The transfer of hazardous constituents from one environmental medium to
another does not constitute waste minimization.  Neither would concentration
conducted solely for reducing volume unless, for example, concentration of the
waste allowed for recovery of useful constituents prior to treatment and
disposal.  Likewise, dilution as a means of toxicity reduction would not be
considered waste minimization, unless later recycling steps were involved.1

      In a related action, the EPA published in the Federal Register on
January 26, 1989, a proposed policy statement on source reduction and
recycling.  This policy commits the Agency to a preventive strategy to reduce
or eliminate the generation of environmentally-harmful pollutants which may be
released to the air, land, surface water or ground water.  It further proposed
to incorporate this preventive strategy into EPA's overall mission to protect
human health and the environment by making source reduction a priority for
every aspect of Agency decision-making and planning, with environmentally-
sound recycling as a second priority over treatment and disposal.2  The
Agency's encouragement of waste minimization is an example of the pollution
prevention policy for RCRA hazardous wastes.

Current Federal Regulatory Requirements for Waste Minimization Programs

      Besides establishing the national policy, Congress also enacted several
provisions in HSWA for implementing hazardous waste minimization.  These
include a generator certification on hazardous waste manifests and permits for
treatment, storage, or disposal of hazardous waste.  These certifications
(effective September 1, 1985} require generators to certify two conditions:
(1) the generator of the hazardous waste has a program in place to reduce the
volume or quantity and toxicity of such waste to the degree determined by the
generator to be economically practicable; and (2) the proposed method of
treatment, storage or disposal is that practicable method currently available
to the generator which minimizes the present and future threat to human health
and the environment.1

      In addition, Congress also added a new provision in 1984 that requires
hazardous waste generators to identify in their biennial reports to EPA (or
the State): (1) The efforts undertaken during the year to reduce the volume
and toxicity of waste generated; and (2) the changes in volume and toxicity
actually achieved in comparison with previous years, to the extent such
information is available prior to 1984.1

Waste Minimization Approaches and Techniques

      Waste minimization is inevitably site and plant-specific, but a number
of generic approaches and techniques have been used successfully across the
country to reduce many kinds of Industrial wastes.

      Generally, waste minimization techniques can be grouped into four major
categories: inventory management and improved operations, modification of
equipment, production process changes, and recycling and reuse.  Such
techniques can have applications across a range of industries and
manufacturing processes, and can apply to non-hazardous as well as hazardous

      Many of these techniques Involve source reduction -- the preferred
option on EPA's hierarchy of waste management.  Others deal with on and off-
site recycling.  In practice, waste minimization opportunities are limited
only by the ingenuity of the generator.  In the end, a company looking
carefully at bottom-line returns may conclude that the most feasible strategy
would be a combination of source reduction and recycling approaches.

      The approaches discussed and illustrated in Figure 1 provide waste
minimization examples for generic and specific processes.
Figure 1.  Waste Minimization Approaches and Techniques
Inventory Management ft Improved

'Inventory and trace all raw materials.
•Purchase fewer toxic and more nontoxic
  production materials.
'Implement employee training and man-
  agement feedback.
'Improve material receiving, storage,
  and handling practices.

Modification of Equipment

'Install equipment that produces
  minimal or no waste.
•Modify equipment to enhance recovery
  or recycling options.
•Redesign equipment or production
  lines to produce less waste.
'Improve operating efficiency of
•Maintain strict preventive mainten-
  ance program.
 Production Process Changes
 •Substitute nonhazardous for
   hazardous raw materials.
 'Segregate wastes by type for
 'Eliminate sources of leaks and
 'Separate  hazardous from non-
   hazardous wastes.
 •Redesign  or reformulate end
   products to less hazardous.
 •Optimize  reactions and raw material

Recycling and Reuse

'Install closed-loop systems.
•Recycle onsite for reuse.
•Recycle offsite for reuse.
"Exchange wastes.
Source:  EPA/530-SW-87-026
Elements of a Waste Minimization Program

      So, what is a "waste minimization program?"  Understandably,  the Agency
has been asked this many times since the September 1985 date,  after which
generators were to have certified that they had one in place.

      The generator has a wide latitude in structuring his or  her program.
Also, since Congress indicated in its accompanying report to HSVIA that
"economically practicable" is to be determined by the generator and is not
subject to subsequent evaluation by the EPA, the generator has even more
latitude in defining a program.  The EPA has, in a June 12,  1989 Federal
Register Notice, issued some non-binding guidelines as to what the elements of
an effective waste minimization program might include.  These  elements are:


Top Nanagement Support

      The first step In developing a program Is to establish a clear corporate
policy.  The full commitment from management of time, personnel and financing
is extremely important.  Lack of this commitment is often one of the most
formidable obstacles to waste minimization.  The chances for obtaining this
commitment are often enhanced by outlining the potential incentives for waste
minimization as shown in Table 1.

        *  Landfill disposal cost increases.
        "  Costly alternative treatment technologies.
        *  Savings in raw material and manufacturing costs.


        *  Certification of a WM program on the hazardous waste manifest.
        •  Biennial WM program reporting.
        "  Land disposal restrictions and bans.
        *  Increasing permitting requirements for waste handling and


       •  Potential reduction in generator liability for environmental
            problems at both onsite and offsite treatment, storage, and
            disposal facilities.
       •  Potential reduction in liability for worker safety.

      Public Image and Environmental Concern

       *  Improved image in the community and from employees.
       •  Concern for improving the environment.

Source: Waste Minimization Opportunity Assessment Manual (EPA/625/7-88/003)

      An appreciation of the necessity for top management support is summed up
very well by G. J. Hollod:

      "Lack of senior management support will doom a waste minimization
      program from the start.  Many managers in addition to the standard
      business functions have become occupied with other priorities in
      the environmental area like land bans, right-to-know and
      occupational health considerations.  Waste minimization is
      competing with other environmental priorities but management must
      be convinced that waste minimization is a program that deserves
      priority and should be part of the "daily diet" for the line
      organization and not just another environmental headache left to
      the site's environmental coordinator."10

                  Make waste minimization a company policy.

      The objectives of a waste reduction program are best conveyed to a
business's employees through a formal policy statement or management
directive.  A business's upper management is responsible for establishing a
formal commitment throughout all levels of the business.  An environmental
policy statement or the business's operating guidelines might include the
following points:

      Environmental protection is a production line responsibility and an
      important measure of employee performance.  In addition, every employee
      1s responsible for environmental protection in the same manner(s) he is
      for safety;

      Reducing or eliminating the generation of waste has been and continues
      to be a prime consideration in research, process design, and plant
      operations, and is viewed by management like safety, yield, and loss
      prevention; and

      Reuse and recycling of materials has been and will continue to be given
      first consideration prior to classification and disposal as a hazardous

      As an example of such a policy the 3M Company of St. Paul, Minnesota,
has a part of its official environmental policy that the company will "prevent
pollution at the source wherever and whenever possible."  It might be noted
that this company also has as part of its policy to "develop products that
will have a minimum effect on the environment."  While this is somewhat
outside the goals of a typical waste minimization program, it is clearly
within the goals of an overall pollution prevention program, and should
certainly be considered by any company producing products that will ultimately
end up in the wastestream.

            Set specific goals for reducing the volume or toxicity of
            waste streams.

      Quantitation helps.  Some examples of waste minimization goals are:

      The U.S. Department of Defense is committed to reducing its hazardous
      waste disposal rates by 50 percent by 1992.3

      The Dupont Company has stated that its wastes will  be reduced by 35
      percent by 1990 compared to 1982 values.4

      As a benchmark for evaluation of waste minimization goals,  a
      report on waste reduction issued by the Congressional Office of
      Technology Assessment in 1986 states that "substantially more
      waste reduction is feasible and more will become feasible.
      Setting a national voluntary waste reduction goal of perhaps 10
      percent annually for 5 years would be useful."5

            Commit to Implementing recommendations Identified through
            assessments, evaluations or other means.

      A sure way to undermine a program is to not follow up on recommendations
developed by a committed group of employees.  Although it may be  unreasonable
to expect facility management to make wholesale commitments to accept
recommendations, it is not unreasonable to expect management to commit to
giving a high priority to considering such recommendations and then doing  it.

            Designate a waste minimization coordinator and select a team
            at each facility to ensure effective implementation of the

      For a small facility with only a few waste streams, one person such  as a
plant manager, plant engineer, or environmental engineer may be responsible
for the entire waste minimization program.  For larger, highly integrated
facilities with many different processes and emission sources, a  team or task
force might be established.  As shown in Figure 2, team members should
represent major departments that are involved in waste generation and
management and different areas of expertise.  A team may include  members from
production, facilities/maintenance, environmental engineering, process
engineering, safety and health, and quality assurance departments.  Your
appointed minimization "champion" should lead the effort and coordinate all
involved departments.  Outside consultants and/or corporate staff should also
be considered, depending on the company's nature, the facility's  complexity,
and available in-house skills.

           Figure 2.  Suggested Waste Minimization Team Organization
                               Corporate itenagement
         Source: National Association  of Manufacturers,  1989.
      A summary of functions that might  be  assigned  to the waste minimization
team are shown in Table 2.
                              Define Objectives
                              Review with  Site Management
                              Communicate  to  site
                              Buy-in from  generators
                              Representation  from  areas
                              Ongoing  awareness  and training
                              Provide  Resources
                              Accounting System
                              Upgrade  projects
                              Schedule reviews
                              Conduct  audits
                              Summarize site  progress
Source:  Hazardous Waste Minimization  (McGraw Hill,  1989)

            Publicize success stories. - - Regard employees that identify
            cost-effective waste minimization opportunities; train
            employees on aspects of waste minimization'that relate to their

      Employees often cause the generation of waste and they can contribute to
the overall success of the waste reduction program.  Just as incentives are
used to boost employee productivity, management should provide incentives for
the development of useful waste reduction ideas.  To utilize this important
resource, many businesses give their employees incentives such as:

.     Recognition awards for outstanding waste reduction projects and
      individuals, as well as for resource and energy conservation
      projects; and

      Bonuses or financial awards for innovative approaches to waste

      Public recognition helps to inform the public of actions taken by the
business to reduce and control hazardous waste.  Recognition programs can be
varied to accommodate each business, their level of involvement, and local
attitudes.  For instance, public recognition such as an award or certificate
may be welcomed by many businesses.  Other businesses, however, maintain a
"low profile" as a matter of policy.  In such cases, a letter from the Board
may be preferred.  The effectiveness of this program could be increased by
combining it with other awards, such as an employee-of-the-month program, or a
percentage of the cash savings realized by the suggestion.  Regardless of the
form of the incentives, employees should realize part of the benefits of their
waste reduction ideas and efforts.  In some businesses,  meeting the waste
reduction goals is used as a measure for evaluating the job performance of
managers and employees.11

      The Dow Chemical Company incorporates these elements into its widely
recognized and very successful Waste Reduction Always Pays Program; through
utilizing company newsletters to publicize waste reduction success stories,
and through recognition for teams of employees that propose changes that lead
to decreased waste generation.  The company also strives to incorporate the
principles of waste reduction into all of Its training activities.

Characterization of Waste Generation

      Maintain a waste accounting system to track the types, amounts and
hazardous constituents of wastes and the dates they are generated.  It has
been our observation, and we might add the observation of many others active
in encouraging waste minimization, that most generators do not really know
what is in their wastestream, or what possibilities might exist for reducing
the volume or toxicity of the streams through relatively simple means.
Information about waste streams can come from a variety of sources.  Some
information on waste quantities is readily available from the completed
hazardous waste manifests, which include the description and quantity of
hazardous waste shipped to a Treatment Storage and Disposal Facility.  The
total amount of hazardous waste shipped during a one-year period, for example,
is a convenient means of measuring waste generation and waste reduction
efforts.  However, manifests often lack such information as chemical analysis


of the waste, specific source of the waste, and the time period during which
the waste was generated.  Also, manifests do not cover wastewater effluent,
air emissions, or nonhazardous solid wastes.  Potential sources of information
on waste streams are shown in Table 3.
                     hazardous waste manifests
                     biennial hazardous waste generator reports
                     SARA Title III Section 313 environmental  release reports
                     environmental audit reports
                     permits (RCRA Part B, National Pollution  Discharge
                       Elimination System (NPDES< etc.)
                     lab reports/characterization data
                     chemical Inventory and usage records
                     NPDES monitoring reports
                     Material Safety Data Sheets (MSDSs)
                     Internal waste tracking system records
                     production records

            Source:  National Association of Manufacturers, 1989

      A useful form for conducting waste stream characterization is shown in
Figure 3.  This is from the EPA Waste Minimization Opportunity Assessment
Manual (EPA/625/7-88/003).

      In addition to providing a means for measuring the effectiveness of your
program, there are currently three reasons why it is very important to track
your progress in this area.

      •  First, HSWA requires that generators report on the progress of their
         waste minimization program with the biennial generator report.
      *  Also, EPA can make a minimization program and associated reporting a
         condition of a RCRA permit.
      •  Finally, SARA Title III reporting allows for minimization to be
         addressed, and although this is currently voluntary it may become

      The tracking function or recordkeeping at a minimum should record and
identify the generator or "owner" of the waste reduction method being used to
reduce that particular waste stream.  Table 4 shows a typical  printout from a
computer tracking program that has been used by the DuPont Company.10

      One reporting function that would be of particular interest to any
program is the tracking of the most successful or most often used waste
minimization technique.  Table 5 lists the validation codes for the typical
waste minimization techniques that are used at DuPont.  This information can
be used by business managers and technical managers to Inform manufacturing
facilities in different locations of the country to what might be the most
successful waste minimization technique to apply.

FIGURE 3 Form for

Conducting Waste Minimization Characterizatim
Waaia Minimization lieenineni
Pnv IMsnpw
Pm| MB

SDMI JL_ ol J_ Page 01

want iD/Nama:
Component/or Propcny of Oonnn)
Annual G*n«rvllon Rttt (unttt )
• .. . _
Contpontntd) of conoorn

Cost of DIspoMl
Unn Con (Spar: )
Ovarvll (par yav)

Method of Uanao«nanf

Prtorliy Rating Crtaftf WL^JJn
Regulatory Compllaneo
Traatmam/Diapoaat Cost
Potamial Liability
Wattt Quantity Gananlad
Waatt Haxard
Salaty Hazard
MlnlmUatlon PotamW
Potential to Ramova Bottlanack
Potantlal By-product Racovory
Sum of Prtonty Rating Scoraa
Stream No. 	



Stream No. 	



Stream No.



Notaa: 1. Straam numoars, HappllcaWa. sfiouU oorrMoond to tnoaa uaad on procM* flow diagrams.
1. For aiampia, unitary landfill, hazardout waata landflll. onalta racycla. Inclnantlon. eombuatlon
«rtth haat raeovary. dutlaallo^ dawatanng, ate.
9. Rate aa<*etn»am in aaeh category on aacali from O(nona) to 10 (high).

                                                  Table 4
                                Typical Column Headers In Computer Printouts
Organic Acid
Spent Catalyst
Lab Solvent
Acid Catalyst
• Flammable
M Ib/yr
Disposal Costs
Source:  Hazardous Waste Minimization (McGraw Hill,  1989)




Process Change
Modify Operating Procedure
Advanced Process Control
Substituted Chemicals
Use Higher Quality Materials

Direct Use in the Process
Direct Use in Another Process
Regeneration for Reuse
Use as a Fuel

Improve Waste Treatment
Waste Filtration
Waste Decantation
On-Line Treatment

Administrative Controls
Minimizing Washdown
Reduce Cleaning Frequency
Longer Turnaround Time
Improved Spill Control
Separate Hazardous from Nonhazardous
Discontinue Manufacture
Source:  Hazardous Waste Minimization (McGraw Hill 1989)
Periodic Waste Minimization Assessment

      An important element in a waste minimization program is to perform
periodic waste minimization assessments, sometimes referred to as "waste
reduction audit."  Conducted by an in-house assessment team or with an
independent outside expert, a waste minimization assessment is simply a
structured review of potential opportunities to reduce or recycle waste.  Its
focus can be broad or narrow.  Most find that it is usually more effective to
select a few waste streams or processes for intensive assessment rather than
to attempt to cover all waste streams and processes at once.

      The USEPA has published a manual for conducting waste minimization
assessments.  This manual entitled Waste Minimization Opportunity Assessment
Manual (EPA/625/7-88/003) is available free from the Waste Minimization
Branch, USEPA, 26 W. Martin Luther King Dr., Cincinnati, OH 45268. The
procedure recommended by the EPA is outlined in Figure 4.

                       The need to minimize waste

                     * Gel management commitment
                     * Set assessment program goals
                     • Organize assessment program task force
                     i or gam noon and
                     * Identify and track waste Breams
                     • Compile process and facility data
                     • Prioritize and select assessment targets
                     • Select people for assessment teams
                   Priorma and daa
                   for the aueumem
The WM Assessment
• Inspect she
• Generate options
• Screen and rank options
• Select options for feasibility study
                 Assessment report of
                   •uuuicd opooos
                     FEASIBILITY ANALYSIS STEP

                     • Technical evaluation
                     ' Economic evaluation
                     • Select options for implementation
                finil report, including
                recommended options
                     • Justify projects and obtain funding
                     * InstaD or modify equipment
                     • Implement new procedure
                     • Evaluate performance of projects
                                        Select ne»
                                      assessment targets
                                      Repeal the process
                          Succcssfull; Implemented
                         waste minimization projects

      Waste rinimizatior opportunity assessments are an extremely good way to
focus attention on potential improvements.  The reader is encouraged to obtain
a copy of the EPA manual.

A Cost Allocation System

      Departments and managers should be charged "fully-loaded" waste
management costs for the wastes they generate. In addition to the actual
disposal fee for a wastestream of interest, the generator should also consider
other cost elements such as:

         Generator Fees/Taxes
         Onsite Storage and Handling
         Pre-disposal Treatment
         Permitting, Reports and Recordkeeping
         Emergency Preparedness and Site Cleanup Contingency
         Pollution Liability Insurance
         Raw Materials
         Operating and Maintenance Costs

Encourage Technology Transfer

      Seek or exchange technical Information on waste minimization from other
parts of your company, from other firms, trade associations, State and
university technical assistance programs or professional  consultants.  Many
techniques have been evaluated and documented that may be useful in your

      To facilitate the transfer of technical information EPA was mandated by
the Congress to establish a national clearinghouse to provide easily
accessible and reliable information on waste minimization/pollution
prevention. The clearinghouse is to contain both technical information on how
to identify and implement pollution prevention opportunities, and general
information conveying the message that, "We, as a society, must begin to
integrate pollution prevention into the way we design, build, buy and

      EPA's Pollution Prevention Information Clearinghouse (PPIC), which is
supported by the Agency's Pollution Prevention Office as  well as OR&D, has
been created to fulfill this mandate.  PPIC (pronounced pea-pick) is being
pilot-tested by some 300-400 users this year and will be  in full operation,
accessible to all, in 1990.  PPIC collects and disseminates technical and
other information on pollution prevention through a telephone hotline and an
electronic information exchange network.  Indexed bibliographies and abstracts
of reports, publications and case studies on pollution prevention will be
available.  PPIC will also include a calendar of pertinent conferences and
seminars, information on federal and State activities and legislation,
information on pollution prevention abroad, a directory of waste exchanges and
lists of knowledgeable contacts within State organizations, trade associations
and the EPA.  Copies of various reports will be made available by the
clearinghouse either by electronic transfer or through the National Technical
Information Service (NTIS) or other sources.


Program Evaluation

      Conduct a periodic review of program effectiveness.   Use these reviews
to provide feedback and identify potential areas for improvement.


      We feel that waste minimization provides opportunities to deal more
efficiently and effectively with wastes that are hazardous to human health and
the environment.  The program outlined in this paper is one way a company
might pursue establishing a waste minimization program.  They reflect the
results of agency analyses conducted over the last several years and extensive
interaction with private and public sector waste minimization program
managers.  However, it is recognized that programs must be tailored to fit
various companies.  We would leave you with a request,  that since nothing
happens until somebody does something, do something and incorporate a program
that fits your facility.


1.   Federal  Register,  Vol  54,  #lll/Monday June  12,  1989.   EPA Draft  Guidance
     for Hazardous Waste Generation on the Elements  of  a Waste Minimization

2.   Federal  Register,  January  26,  1989 (54FR 3845)  Pollution  Prevention
     Policy Statement.

3.   Kaminski,  J.A. "Hazardous  Waste Minimization  Within the Department of
     Defense."   JAPCA Volume 38:1042-50,  1988.

4.   Hollod,  G. S. and R.  F. McCartney.  "Waste  Reduction  in the  Chemical
     Industry."  JAPCA 38:174-179,  1988

5.   Serious  Reduction of Hazardous Waste.  Office of Technology  Assessment-
     U.S. Congress.  OTA-ITE-317.

6.   Waste Minimization: Environmental Quality with  Economic Benefits. USEPA,
     Washington, D.C. EPA/530-SW-87-026,  1987

7.   Waste Minimization: Manufacturers Strategies  for Success.  National
     Association of Manufacturers,  Washington, D.C.  1989

8.   Schecter and Hunt,"Minimization of Hazardous  Waste Generation."  Chapter
     5.1, Standard Handbook of  Hazardous  Waste Treatment and Disposal.
     Editor:  H. M. Freeman, McGraw Hill, 1989.

9.   Hanlon and Fromm,  "Waste Minimization Opportunity  Assessments,"  Chapter
     5,  in Hazardous Waste Minimization.
     H.  M. Freeman, McGraw Hill, 1989 (in publication).

10.  Hollod,  "Implementing Waste Minimization Programs  in  Industry."  Chapter 4
     Hazardous  Waste Minimizations.
     H.  M. Freeman, McGraw Hill, 1989 (in publication).

11.  Waste Reduction Assessment and Technology Transfer: Training Manual. TVA
     and University of North Carolina, Asheville,  Environmental Quality
     Institute, 1989.

12.  Waste Minimization Opportunity Assessment Manual.  USEPA,  Cincinnati,  OH
     EPA/625/7-88/003,  1988.