To determine if a degree of hazard analysis could be implemented, a statistically representative sample of the Resource Conservation Recovery Act (RCRA) Special Wastes and the non-RCRA Special Wastes manifested for disposal in 1984 in Illinois were analyzed. The term “Special Waste” includes all federally-regulated hazardous wastes as well as industrial process wastes and pollution control wastes as defined by the State of Illinois (non-RCRA wastes). A criticism of the present Illinois regulatory system is that all Special Wastes have similar requirements for applications that allow their transport and disposal. The current system does not address the different environmental and health risks posed by these waste streams. A degree of hazard evaluation of Illinois Special Waste streams was an appropriate method to determine the impact of these wastes upon the public health and environment.

To conduct a degree of hazard evaluation of Special Waste streams it is necessary to have quantitative data of high quality. The degree of hazard approach permits a distinction among Special Waste streams based on an estimate of hazard based on scientific evidence. For poorly defined mixtures a need for a set of toxicity assessment tests is clear. Such tests would need to be rapid and within reasonable economic costs. Such a hazard evaluation could be conducted in a consistently fair manner with a high degree of accuracy.

Although this study was not designed to determine how the degree of hazard analysis could be used in a regulatory sense, it does illustrate procedures that could be employed by regulators. The degree of hazard evaluation has the added benefit of being relatively rapid while reducing subjectivity in the decision-making process. Finally, the evaluation can be economically positive in that those industrial waste streams that demand more costly disposal techniques may be identified and separated from those waste streams that pose little hazard to human health and the environment.

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