f . ^S _ %. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C, 20460
EPA-SAB-LTR-EEC-91-005
OFFICE OF
April 29, 1991 THE ADMINISTRATOR
Honorable William K. Reilly
Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Subject; Science Advisory Board's Letter Report
on Review of QRD's Proposed Project Entitled
"Potential Hazards of Municipal Waste
Recycling"
Dear Mr. Reilly;
The Municipal Solid Waste Recycling Subcommittee (MSWRS) of
the Environmental Engineering Committee (EEC) of the Science
Advisory Board (SAB) met at IPA's Washington, D.C. Headquarters and
via teleconference, on December 19, 1990, to confer with the
Environmental criteria and Assessment Office (ECAO) of the Office
of Health and Environmental Assessment (OHEA) of the Office of
Research and Development (ORD) on recommendations related to the
balance of the scope of work for the project entitled "Potential
Hazards of Municipal Waste Recycling," and to provide
recommendations for a proposed expert panel to be formed by ECAO to
guide and critigue the above study.
The Subcommittee provided initial responses to the 1CAO staff
and their support contractor at the meeting, and transmitted
written comments directly to the program staff* The major points
made and accomplishments of this particular discussion are given
below.
With regard to the appropriateness of the Scope of Work, the
MSWRS members and consultants suggested the following:
1. To reduce the scope of the project to identify hazards
associated with recycling municipal solid waste, and not the more
difficult and long-term task of fullv assessing risks associated
with recycling of municipal solid waste,
Printed on Recycled Paper
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2. To identify the target audience of the project in terms of
constituency as well as level of knowledge,
3. To recognize and then define the type of recyclables, such as
post-consumer versus pre-consuraer recyclables for this study,
4. TO embrace the notion of a requirement of ultimate (waste)
disposal for fractions not amenable to recycling, as well as the
realities of activities specifically driven by the market place.
Recycling also creates wastes that must be handled,
5. To avoid an a priori declaration of recyclable material types
based upon a predisposition toward a particular technology, which
could bias the assessment,
6. To focus on post-consumer flows, and to be clear on the intended
level of detail of the study, in particular which aspects ranging
from consumer separation to municipal recovery facilities will be
covered,
7, To consider dispelling myths and clarifying or substantiating
anecdotal information associated with recycling, and
8. Data from developing countries which may have have
epidemiological studies on scavenging from disposal areas should be
sought.
With regard to recommendations of the expert panel, the MSWRS
members and consultants suggested the following:
1. Individuals chosen should have direct experience with solid
waste management issues, regardless of primary expertise or
institutional affiliation,
2. Scientific and/or technical qualifications are the only
legitimate factors with which the ECAO/ORD should concern itself.
"Balance," for instance is not a relevant criterion for generating
a large candidate list,
3. The composition of the expert panel should include engineers
from several disciplines, an epidemiologist, an expert on risk
assessment/risk management, an expert in community medicine (an
appropriately chosen epidemiologist might also fill this role), and
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an industrial hygienist (since the hazards of interest are not
solely those of respiratory exposure, but include other hazards,
such as physical injury. Ideally, the industrial hygienist should
have experience or interest in ergonomics), and
4* The views of the solid waste management industry should be
sought in order to sensitize the process with the realities of
practice.
The SAB's MSWES suggested twenty-nine (29) possible candidates
for the expert panel. We were encouraged to hear that six (6) of
the thirteen members chosen (we understand that five accepted) by
ECAQ for the expert panel came from the SAB's suggestions.
We appreciate the opportunity to assist and provide
suggestions on issues such as these. This letter report does not
involve complex scientific issues and therefore only a brief
acknowledgement by you of its receipt and consideration is
anticipated.
Raymond c. Irf>ahr7"~€hairman
Executive Committee
Science Advisory Board
Richard A. Conway, chairman
Environmental Engineering Cosusittee
Science Advisory Board
Francis C, McMichael/ Chairman
Municipal Solid Waste Recycling
Subcommittee
Science Advisory Board
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