Wakefield, RI.
By Michael A. Rice
Proper disposal of toxic waste is a very necessary fact of modern life. Cases of people injured and lives destroyed by negligent toxic waste disposal such as the Love Canal, New York case have entered the public consciousness, and other cases such as the “Erin Brockovich” case in Hinkley, California and the “A Civil Action” case of Andover, Massachusetts case have become mainstays of pop culture story telling. Concern over the proper disposal of toxic waste led directly to the passage of the federal Clean Water Act in 1972 and the formation of the Environmental Protection Agency.
We have our fair share of EPA Superfund cleanup sites in Rhode Island due to our industrial history such as our own Rose Hill dump site in South Kingstown, but most Rhode Islanders are now proud of the fact that we have some of the most stringent toxic waste handling and disposal standards and regulations in the nation. But, is it possible that overly ambitious toxic waste regulations can in fact be counter-productive?
Proper toxic waste disposal is a pretty expensive proposition. After all, the Love Canal or the Andover cases would have never occurred if there were cheap ways to get rid of all of those leftover chemicals. Typically specialized companies handle disposal of toxic chemical waste with personnel using protective clothing. Cleanup of toxic spills can be quite a sight as we’ve all probably seen those guys using ‘moon suits’ and respirators. Even when all proper safety procedures are followed and accidental spills don’t occur, the toxic wastes are generally collected from their sources, then sorted by hazard class and then transported to other companies that eventually destroy the wastes by very high temperature incineration, chemical treatment, reprocessing, or disposal in heavily monitored repositories that assure against problems such as ground water contamination.
That sounds simple enough, but just what is a toxic chemical anyway? Some chemicals are pretty easy to classify. Just about everybody knows that really nasty stuff like arsenic, methyl-mercury or benzene are toxic because those will either kill you quite quickly if ingested or cause cancer in lab rats in pretty short order, but there are thousands of chemicals out there and different new ones are being created every day. How do we know which ones are really toxic or just a little toxic, or even innocuous so we don’t have to worry about them, for that matter? The federal Occupational Safety and Health Administration (OSHA) and the EPA generally use a standard LD-50 as a measure of chemical toxicity. LD-50 is the dose of an injected chemical that will cause 50% of test animals (usually lab rats) to die in four days. So the lower the LD-50 number, the more toxic the chemical is because it kills in lower concentrations or in a shorter amount of time.
Both OSHA and the EPA use an LD-50 value of 50 parts per million as the standard definition of a toxic chemical. So this roughly means that a chemical is classified as toxic if about one one-hundredth of a pound or about 5 grams will kill a 200 pound person in four days. Under this 50-ppm standard, toxic industrial materials such as benzene, arsenic, cadmium, and formaldehyde are covered.
In Rhode Island the state toxic waste regulatory community (DEM and the Health Department) under public pressure to ‘get tough’ on toxic waste generators and protecting public health has taken the unusually cautious approach of setting the toxic chemical standard 100 times higher at 5,000 ppm (RIDEM Hazardous Waste Regulations, effective 11/13/2001, Sections 3.31, 3.32, 3.67). What this means is that some commonly used household chemicals are considered ‘toxic’ in Rhode Island and thus should require special disposal beyond just tossing in the trash. Among these chemicals that have LD-50 lower than 5000 ppm values not only include all of the cleaning supplies under the kitchen sink but some of the ‘chemicals’ in the pantry as well. Sodium chloride, or common table salt, is a toxic chemical in Rhode Island. Acetic acid, the main ingredient of vinegar is also classified as a toxic chemical in Rhode Island, and the list goes on and on.
I shudder to think that our thoughtful regulators are concerned that I might poison myself on gallons of raspberry vinaigrette dressing and not overly concerned about the mountains of road salt piled in the DOT maintenance yard, but there are some serious practical ramifications to an over-cautious regulatory stance. First of all, regulations for toxic waste disposal are pretty stringent and most transfer stations in the state don’t accept toxic waste. Technically, if that pound of salt in the kitchen got wet and as hard as a rock you would have to segregate it as toxic waste, store it and then wait for DEM to hold an ‘Eco-Depot’ event to dispose of it properly. I’d hazard a guess, but I doubt if even the most environmentally conscious individual would be that fastidious.
Aside from this problem of proper classification of just what is toxic and what is not, the disposal of bona-fide toxic chemicals in Rhode Island remains problematic. Most Rhode Islanders really do care about environmentally responsible actions, but there is no convenient way to dispose of used paints and thinners, used alkaline batteries, or that used anti-freeze that helped the car through the winter. Perhaps permanent chemical waste collection stations at each of the transfer stations in the state, including our own Rose Hill Transfer Station would greatly reduce the temptation to hide household chemicals in the trash bag. I suspect that the costs involved with compliance with Rhode Island’s stringent hazardous waste rules keeps the number of collection stations very low. A state contracted toxic waste company permanently stationed at each of the solid waste transfer stations would go a long way toward good management of household toxic wastes and help protect sols and ground water. Furthermore, a realistic look at the state’s toxic waste standards should control taxpayer costs and help keep the guys in the ‘moon suits’ from taking my salt shakers.
Michael A. Rice, an occasional contributor, is professor and chairman of the Department of Fisheries, Animal and Veterinary Science at the University of Rhode Island and serves as the chairman of the South Kingstown Conservation Commission.