. United States General Accounting Office Report to Collgressional Requesters GAO June 1990 TRUCK TIZANSPORT Little Is Known About Hauling Garbage and Food in the Same Vehicles . RESTRICTED-- Not ta be released outside the General Accounting OffIce nnless specifically approved by the Off’ice of Congressional Relationa ,,., GAO/RCED-90-161 Resources, Community, and Economic Development Division B-237484 June 28,199O The Honorable Glenn M. Anderson, Chairman The Honorable Bob McEwen, Ranking Minority Member The Honorable William F. Clinger, Jr. Subcommittee on Investigations and Oversight Committee on Public Works and Transportation House of Representatives In response to your July 26,1989, letter and as agreed in subsequent meetings with your offices, we have examined the practice of transporting municipal solid waste in multipurpose trucks that may also be used to carry consumer goods, such as food. Specifically, this report addresses the geographic area where “cross-hauling” may be occurring; the types of trucks, waste products, and foodstuffs involved; related environmental, economic, and health issues; and applicable federal laws and enforcement authorities. Unless you publicly release its contents earlier, we will not make this report available to interested parties until 7 days after the date of this letter. At that time, copies of the report will be sent to the appropriate congressional committees; the Secretaries of Transportation, Health and Human Services, and Agriculture; the Administrator of the Environmental Protection Agency; the Chairman, Interstate Commerce Commission; the Commissioner of Food and Drugs; and the Directors, Centers for Disease Control and National Institutes of Health. We wilI also make copies available to others upon request. This work was performed under the direction of Kenneth M. Mead, Director, Transportation Issu_es,(202) 275-1000. Other major contributors to this report are listed in appendix I. J. Dexter Pea& Assistant Comptroller General Executive Summary Press accounts in spring 1989 first alerted the public that some trucks Purpose that hauled garbage from the New York/New Jersey area to midwestern landfills were then used to carry meat, poultry, and produce. Concerned over the food contamination risk of alternately hauling, or “cross- hauling,” garbage and foodstuffs, the Subcommittee on Investigations and Oversight, House Committee on Public Works and Transportation, investigated and held hearings, concluding that the practice was occur- ring. The Subcommittee then asked GAO to examine the (1) geographic area where this may be occurring and the conditions fostering it; (2) types of trucks involved; (3) foodstuffs and types of garbage being transported; (4) associated health, economic, and environmental issues; and (5) federal laws, regulatiorqmd enforcement tools available to address the practice. As agreed with the Subcommittee, this report does not discuss the transport of commodities in tank trucks. Traditionally, “garbage trucks” collect municipal waste (garbage), Background which includes household and commercial nonhazardous waste, and transport it to local landfills. In the Northeast, many landfills have closed and others are near capacity, leading some communities-from Connecticut to New Jersey -to ship garbage to distant landfills in multi- purpose trucks (closed, open top, and flat bed) that, at other times, may carry many different commodities. The Environmental Protection Agency (EPA) expects that, by 1991,40 percent of our nation’s 6,000 plus landfills will close, providing added incentive to ship garbage. The food industry has primary responsibility for safe food transport. It carries out the Food and Drug Administration’s (m) and the Depart- ment of Agriculture’s (USDA) regulations related to food wholesomeness, EPA regulates environmental issues; the Department of Transportation (ear) and the Interstate Commerce Commission (ICC) regulate trucking safety; and the Centers for Disease 1 (CDC)and the National Insti- tutes of Health (NIH) oversee health YziiIcG . FDA,CDC,and NIH are part of the Department of Health and Human Services. Transporting food in a truck that previously hauled garbage inspires Results in Brief high emotions in many individuals regardless of whether it presents a real or perceived problem. GAO found only limited, anecdotal informa- tion on the extent that food is being transported in trucks that previ- ously carried garbage; the types of trucks that are doing so; or the foodstuffs carried. It is clear, however, that long-distance transport of garbage is on the increase and that it primarily originates in certam Executive !kmmuy northeastern communities that generate more garbage than they can dis- pose of locally. In these communities, the arrival of consumer goods, including food, by truck exceeds the quantity of goods leaving; garbage has become a paying trucking commodity on what might otherwise be an empty return trip. Each week, for example, about 9,000 truckloads of garbage from northern New Jersey and the New York City area are hauled for disposal to landfills from western Pennsylvania to Michigan. GAO visited four landfills and observed closed, open top, and flat bed trucks-the types of trucks that can also be used to transport consumer goods. The extent that the same trucks will subsequently carry food-or the types of food they would carry-is not known because federal regu- lations do not require this type of recordkeeping. The contents of a truckload of garbage will vary and can include such diverse substances as discarded food, yard wastes, soiled disposable diapers, pesticides, an$ cleaning solvents. As a result, many people con- sider it disgusting and health endangering that such garbage might be hauled in a truck that later carries the food they eat. According to fed- eral health and food safety experts, no research has been done to deter- mine the risk of such transport-related food contamination. These experts also contend, however, that no food contamination in the United States has been linked to cross-hauling garbage and then food. The food industry is responsible for ensuring that the trucks they use meet FDA’sand USDA’Scleanliness regulations, which do not include spe- cific truck-cleaning procedures or require records to be maintained that could identify trucks that have also hauled garbage. According to FDA and USLHofficials, the agencies’ inspection resources are used where contamination is known to occur, such as in food preparation. Their inspectors do not test trucks for bacterial or chemical residues that may remain in a vehicle after it has carried garbage because such tests would be too costly, complex, and time-consuming and because they have found no instances of contamination from cross-hauling. Both federal and food industry inspectors rely on sensory inspection-if a truck looks, smells, and feels clean, it is considered safe for food transport. Principal Findings Long-Distance Garbage New Jersey, where several major landfills have closed due to capacity or environmental concerns, transported an estimated 195,000 truckloads Transport Is Increasing of garbage to out-of-state landfills in 1989. New York also sent about 195,000 truckloads of garbage out of state, while Pennsylvania sent Page 3 GAO/RCED-WMl Uttle b Known About Gahge/Food Crow-Hauling Executive Summary about 65,000 truckloads. The quantity of New York/New Jersey garbage shipped out of state increased from less than 2 million tons in 1987 to about 9 million tons in 1989. Although long-distance transport of gar- bage now originates largely from Northeast urban centers, EPA and the disposal industry expect other urban areas, such as Chicago, to have similar landfill capacity problems that may force them to export gar- bage in the near future. Limited Information on The extent that the same trucks carrying garbage may later carry food and the type of food they may carry is unknown because records are not Trucks, Foods, and Wastes required. Also, while the composition of individual truckloads of gar- Involved bage will vary, estimates reported by EPA indicate that up to 1 percent of garbage contains hazardous material such as pesticides. Over a 58-hour period, GAO observed 157 multipurpose trucks-81 closed trailers; 53 open tops; and 23 flat beds-entering 4 landfills that accept Northeast garbage. The same types of trucks transport about 85 percent of ail meat and fresh fruits and vegetables consumed in the United States. GAO spoke to 84 drivers at 2 of the landfills. All said they would next haul nonfood items, such as coal or machinery; none disclosed plans to haul food. Health, Environmental According to CDCand NIH officials, the two institutions are aware of no incidents of food contamination in the United States from cross-hauling and Economic Issues garbage and then food nor any research to determine the potential risk or nature of such contamination. CDCis responsible for monitoring and investigating outbreaks of illness, and, according to CDCofficials, its monitoring system has not detected any illness caused by cross-hauling. However, CDCofficials acknowledge that the vast majority of food-borne illnesses are not reported to CDCand few reported cases are traced to their sources. Thus, while federal health experts may believe that the risk of food contamination from cross-hauling with garbage is low, they know neither the extent nor nature of the potential health risks. Fostered by continuing environmental and economic concerns, such as decreasing disposal capacity and high disposal costs in certain areas (about $3,000 per truckload in New York City vs. $450 at some rural landfills), long-distance garbage transport is likely to increase in quan- tity and expand geographically. As the number of multipurpose trucks engaged in long-haul garbage transport increases, the likelihood that food will subsequently be carried in the same trucks also increases. Page 4 GAO/RCED~l61 Little Is Known About Garbage/Food C-Hauling Executive Summary Federal Oversight FDA requires that food be protected against physical, chemical, and microbial contamination during transport and USDA requires that vehi- cles used to transport meat and poultry be free of chemical residue and foreign matter. According to CSDA and FDA officials, because they have found no instances of transport-related contamination, their inspectors do not test trucks for contaminants; moreover, such testing would not be practicable because so many possible contaminants exist and tests are lengthy and expensive. Inspectors focus where experience has shown that food contamination is likely to occur, such as in food preparation, and would test a truck only if contamination were linked to the truck. The food industry will continue to be primarily responsible for the safe transport of food. Currently there are no federal requirements that truckers maintain records of commodities carried to alert food shippers to more closely inspect a truck or reject its use for “high risk” foods, such as fresh produce. Also no federal standards or guidelines exist for truck cleaning. GAO believes that, as a minimum, the food industry needs better recordkeeping by truckers to identify commodities hauled in trucks and standards and guidelines for truck cleaning if it is to provide reasonable assurance that food is being safely transported. GAO recommends that the Secretary of Transportation take the steps Recommendations needed, including seeking authorizing legislation, if necessary, to develop regulations requiring that truckers maintain specific records of commodities carried in trucks that carry food. GAO also recommends that the Secretaries of Agriculture and Health and Human Services, in consultation with the Secretary of Transportation and the Administrator, EPA, develop standards and guidelines for truck cleaning. GAO discussed the information presented in this report with officials Agency Comments from CDC, m, EPA, FDA, NIH, and USDAand incorporated their comments where appropriate. The officials agreed with the factual information as presented and the report’s conclusions. As directed by the requester. GAO did not obtain official comments on a draft of this report. Page 6 Contents Executive Summary 2 Chapter 1 8 Introduction Background 8 Garbage and Long-Distance Transport 9 Federal Oversight Roles 14 Objectives, Scope, and Methodology 16 Chapter 2 19 Long-Haul Transport Northeast Garbage Transported in Multipurpose Trucks Multipurpose Trucks Haul Garbage to Distant Landfills 20 21 of Garbage-A Extent of Garbage/Food Cross-Hauling Unknown 24 Limited but Growing Environmental and Economic Conditions Foster Long- 26 Haul Garbage Transport Activity Conclusions 32 Chapter 3 Experts Do Not Know Limited Inspection of Trucks That Transport Food No Research on Potential Food Contamination From Potential Food Cross-Hauling Garbage, but Federal Health Experts Contamination Risks See Risk as Minimal Conclusions 42 From Cross-Hauling Recommendations 42 Garbage and Food Appendix Appendix I: Major Contributors to This Report 45 Tables Table 1.1: Composition of Municipal Solid Waste/Garbage 9 Table 2.1: Origin of Garbage Hauled by Drivers Spoken to 22 in Ohio Table 2.2: Types of Long-Haul Multipurpose Trucks 23 Observed Entering Four Landfills Figures Figure 1.1: Multipurpose Trucks Haul Garbage 12 Figure 1.2: Cross-Hauling Garbage and Consumer Goods 14 in Multipurpose Trucks Figure 2.1: Sign Outside Ohio Landfill 24 Figure 2.2: Years to Depletion of State Landfill Capacity 28 Page 6 GAO/RCEDWl61 Little Is Known About Garbage/Food CrosHauling Contents Figure 2.3: Landfill and Transfer Station Tipping Fees in 31 1988 Figure 3.1: Dry Van Hauling Loose Garbage 39 Abbreviations acquired immunodeficiency syndrome CDC Centers for Disease Control IxJr Department of Transportation EPA Environmental Protection Agency FDA Food and Drug Administration FSIS Food Safety and Inspection Service GAO General Accounting Office HI-IS Department of Health and Human Services ICC Interstate Commerce Commission NM National Institutes of Health NSWMA National Solid Waste Management Association CJTA Office of Technology Assessment USDA U.S. Department of Agriculture we7 GAO/RCED8O-161Little b Known About Garbage/Food (‘- tlauling Chapter 1 Introduction Historically, garbage has been a local, short-haul commodity, trans- ported in traditional “garbage” trucks designed to facilitate garbage pickup in the neighborhood and dumping at a nearby landfill. Today, however, some communities, particularly in the Northeast, are gener- ating more garbage than they can dispose of locally. To address this problem, long-haul, multipurpose tractor trailer trucks are being used to transport garbage to distant landfills. In 1989, the media reported, and various federal officials and two trucking firm owners confirmed, that some trucks were alternately hauling garbage and food. The trucking industry is composed of more than 260,000 firms and Background accounts for 77 percent of all freight transportation revenues in this country. Each year over 1 million private and commercial trucks are used in interstate transportation of industrial, commercial, and con- sumer goods. Open top, flat bed, and closed trailers (referred to as “dry vans” in the trucking industry) are the most common long-haul multi- purpose trucks. Open top trucks generally haul bulk-type commodities, such as gravel, coal, or grain, and can be raised up to dump their loads. Flat beds carry bulky items, such as machinery or crated produce, and the loads are often exposed to the elements. Dry vans, which include refrigerated trucks, may be used to transport any number of commodi- ties including manufactured goods, processed foods, and fresh produce and meat. These trucks typically transport a variety of loads from point to point regionally or cross-country. For example, a dry van might carry crated machine parts from Chicago, Illinois, to Buffalo, New York; cases of boxed cereal from Buffalo to Richmond, Virginia; bound reams of fabric from Richmond to Baltimore, Maryland; and loose tires from Baltimore to Chicago. Carrying various products in alternating loads-machine parts, cereal, fabric, and tires in the example-is referred to as “cross- hauling.“’ Since passage of the Motor Carrier Act of 1980, the number of firms in the trucking industry expanded and trucking became more competitive. When the Congress passed the Motor Carrier Act of 1935, it gave the Interstate Commerce Commission (ICC) authority to regulate the trucking industry. From 1935 until 1980, the ICC controlled entry, routes, services, and rates for motor carriers. The 1980 act changed the ‘This practice is &o referred to 89“back-hauling,” when the truck has a paying load on !ta return tip. P4e 8 GAO/ECED-WUl LIttIe L IKII~~II About Gub~@/%od Croao-fiuling Chapter 1 Introduction statutory requirements for entry, eliminated routing and service restric- tions, and provided carriers with greater freedom to set rates. Garbage and Long- Distance Transport Municipal Solid Waste/ The Environmental Protection Agency (EPA) is responsible for estab- lishing guidelines for planning and developing environmentally sound Garbage waste management practices. The actual planning and implementation of waste programs, including disposal options, are state and local functions. Municipal solid waste, which we generally refer to as “garbage” in this report, is generated at residences; commercial establishments, such as offices, retail shops, and restaurants; and institutions, such as hospitals and schools. As table 1.1 shows, municipal waste consists of paper, glass, metal, plastic, food, yard, and other wastes. While municipal waste is considered nonhazardous-disposal of hazardous waste is regu- lated separately-estimates reported by EPA indicate that up to 1 per- cent of municipal waste, such as cleaning solutions, drain openers, and pesticides, meet the definition of hazardous waste. Table 1.1: Composition of Municipal Solid Waste/Garbage Percentage by Type of waste weight Paper and paperboard 41 0 Yard wastes 179 Metals 8.7 Glass 8.2 Rubber. leather. textlIes. wood 81 Food wastes 79 Plastlcs 65 Miscellaneous moraanic wastes 16 Source: “The SolId Waste Dlemma: An Agenda for Actlon, ” EPA, Office of SolId Waste, Feb 1989 EPA reported that, in 1988, the nation generated about 160 million tons of garbage, of which 128 million tons was disposed of in landfills. EPA estimates that, by 1991, one-third of the nation’s 6,000 plus landfills will be full while disposal needs continue rising. The problem is most acute in heavily populated Northeast metropolitan areas where landfill Page 9 GAO/RCED9@161 Little Is Known About Garbage/Food CrossHauliug Chapter 1 Introduction capacity is insufficient to meet disposal needs. For example, because of the closure of major landfills in northern New Jersey, the amount of garbage disposed of in New Jersey’s landfills dropped from 9.2 million tons in 1987 to 5 million tons in 1988, requiring New Jersey to find alternate disposal sites. Many cities are having difficulty obtaining community approval to build new landfills or incinerators because people are concerned over poten- tial danger to human health and the environment from contaminated groundwater and toxic combustion emissions, which have occurred at many disposal sites. Communities also resist the nuisance factors, such as noise, odors, and truck traffic, often associated with disposal facili- ties. This disposal “crisis” has led some cities to send their trash to other states in long-haul, multipurpose trucks. Long-Haul Garbage According to congressional testimony from trucking industry officials, an imbalance exists in freight movements in and out of certain North- Transport eastern cities. Because these densely populated cities consume more than they produce, greater numbers of trucks are needed to meet the demand for food and other consumer goods traveling inbound than are needed to carry the limited freight hauled back to the South or Midwest. Many of these communities are the same communities that have a shortage of local landfill capacity. As a result, garbage has become a viable paying trucking commodity option to truckers facing the prospect of downtime or an empty return trip. Figure 1.1 consists of four photo- graphs taken by ICC’S Office of Compliance and Consumer Assistance in July 1989. They depict closed, open top, and flat bed trucks loaded with garbage. Page10 GAO/RCELMWl6l Little b Known About Garbage/Food Cmmo-Hauling Page 11 GAO/RCED4&161 Little Is Known About Garbage/Food CrowHauling Chapter 1 Introduction Figure 1.l : Multipurpose Trucks Haul Garbage r . -- Bales of garbage being loaded onto a flat bed trailer. - - ,.. .a Bales of garbage being dragged by a towline out of a dry van Page 12 GAO/WEIMO-161 Little Is Known About Garbage Fwd ( m- Hauling Chapter 1 Introduction Open top truck raw& to dump a load of garbage. Open top trucks, flat beds, and dry vans form separate lines at landfill entrance because a different procedure IS used to unload garbage from each type of truck. Source: Interstate Commerce Commission. Communities that export a portion of their garbage out of state gener- ally use facilities called transfer stations for receiving waste collected by local garbage trucks and loading it onto long-haul trucks. The transfer Page 18 GA0jECED-W161 Little b Known About Garbage/Food Crow-huling chapter 1 Introduction stations use brokers to arrange for long-haul trucks to transport garbage and for landfills to accept the truckloads of waste. Specialized equip- ment may be used, such as a baler, which compresses garbage into l-ton wire-bound bundles, maximizing truck capacity. Crane and lift machinery are used to load and unload bundled garbage. A dry van, open top, or flat bed can carry 20-23 tons of garbage. The transfer station will generally hire a broker to arrange for the trucks and contract with distant landfills to accept the truckloads of garbage. Truckers with incoming loads may be contacted by brokers or see advertisements directing them to the transfer stations. The broker contracts to pay the independent truckers or trucking companies and the landfills to dispose of the garbage. Figure 1.2 depicts the trucking cycle for cross-hauling garbage and consumer goods. Fiaun 1.2: Crow-Hauling Garbage and Consumer Qooda in Multipurpose Truck8 East Coast Midwest Consumer Goods Garbage L Landfill Al?! Transfer Station Roles portation. Two of the agencies- the Food and Drug Administration and Department of Agriculture-have regulations applicable to the cross- hauling of food and municipal waste. Page 14 GAO/ECEDfNW31Little b Known About Gdmge/Fod CrossHauling Chapter 1 Introduction l Environmental Protection Agency (EPA). EPA is responsible, under the Resource Conservation and Recovery Act of 1976, as amended, for municipal (nonhazardous) waste and hazardous waste issues. EP.~'Srole in municipal waste management includes establishing national minimum criteria for landfills and providing technical assistance to the states. EPA regulations address the transport of hazardous waste but do not address the transport of municipal waste. Primary responsibility for municipal waste management rests with the states. l Food and Drug Administration (FDA). The Secretary of Health and Human Services (HHS) is responsible for administering the Federal Food, Drug, and Cosmetic Act, as amended (21 U.S.C. sets. 301-393). The Sec- retary’s authority has been delegated to the Administrator, FDA. The act prohibits the adulteration of food, which includes food held in unsani- tary conditions where it may become contaminated with filth or may be rendered injurious to health. Further, FDArequires that finished food be transported under conditions that protect it from physical, chemical, and microbial contamination as well as from deterioration of the food or the container. F’DAhas authority to conduct compliance inspections where food is prepared, processed, stored, or transported. l US. Department of Agriculture (USDA).Sections 463 and 624 of Title 21 of the United States Code provide USDAwith authority to inspect trucks that transport meat and poultry in commerce. USDAregulations require that vehicles used to transport meat and poultry be reasonably free of foreign matter, such as dust, dirt, and rust, and free of chemical resi- dues. USI~A’SFood Safety and Inspection Service (FSIS)has been delegated responsibility for these activities and has authority to inspect vehicles used to transport meat and poultry. . Interstate Commerce Comn&sion (ICC). Although the ICChas authority over many aspects of truck transportation, the Congress has specifically exempted the transport of agricultural commodities from the Commis- sion’s jurisdiction. . Department of Transportation (nor). The Hazardous Materials Transpor- tation Act, as amended, gives nor responsibility to regulate the transpor- tation of hazardous materials. DUTdoes not have the statutory authority to regulate the transportation of municipal solid waste. In addition, the Centers for Disease Control (CDC),within HHS, maintains nationwide surveillance of many illnesses, including salmonellosis (a common type of food poisoning caused by salmonella bacteria), measles, and tuberculosis. CDCalso investigates the cause of unusual illnesses, such as it did when AIDSfirst appeared, and unexplained increases in incidents of monitored illnesses. CDCdoes not identify potential sources Page 15 GAO/ECEDWl61 Little h Known About Garbage/Food CrosbHadhg Chapter 1 Introduction of illness and would not investigate the source of an illness until after an outbreak actually occurred. Six bills have been introduced in the 1Olst Congress that address con- cerns about the cross-hauling of garbage and food. On March 27, 1990, the House passed H.R. 3386, which, as written, instructs the Secretary of Transportation to issue regulations covering the transportation of food and nonfood products in the same vehicle. At a minimum, these regulations must prohibit the cross-hauling, in refrigerator and tank food trucks,” of nonfood products that would make food products unrea- sonably dangerous to human health. Additionally, the regulations must require that asbestos and other products that present an extreme hazard to human health be carried in trucks dedicated to that purpose. This legislation has been referred to the Senate Committee on Commerce, Sci- ence, and Transportation. In a July 26, 1989, letter, the Chairman, the then Ranking Minority Objectives, Scope,and Member, and a member of the Subcommittee on Investigations and Over- Methodology sight, House Committee on Public Works and Transportation, asked us to examine several aspects of the food/garbage truck transport issue to supplement the Subcommittee’s investigation. Following Subcommittee hearings on August 2 and October 5, 1989, and in subsequent meetings with the requesters’ offices, we agreed to examine the l geographic area where food/garbage cross-hauling may be occurring and the conditions fostering it, l types of trllcks involved, l foodstuffs and nonhazardous wastes being transported, . health, economic, and environmental issues associated with food/gar- bage cross-hauling, and . federal laws, regulations, and enforcement tools available to address food/garbage cross-hauling. As agreed with the Subcommittee, this report does not discuss the trans- port of commodities in tank trucks. To determine the geographic areas involved, types of trucks involved, and the foodstuffs and nonhazardous wastes being transported, we interviewed officials and representatives from (1) EPA, ICC, FDA, LSDA. and DUI’;(2) the National Solid Waste Management Association, which ‘Tank trucks were excluded from this review. Page 16 GAO/RCED9lS161 Little Is Known About Garbnge/Tbod C-Hauling ChapterI Introduction represents the waste disposal industry; (3) the American Trucking Asso- ciation and Interstate Truckload Carriers Conference, which represent trucking firms and independent truckers; and (4) transportation and environmental programs in New Jersey, New York, Pennsylvania, and Ohio. We also interviewed the owners of two trucking firms who have transported garbage in multipurpose trucks. We reviewed documents, reports, and regulations supplied by the officials and representatives, including an ICC limited field study; reports of truck inspections con- ducted in June and July 1989, by ICC, USDA, FDA, and the Pennsylvania Department of Agriculture, at food warehouses and distribution centers; and an October 1989 Office of Technology Assessment (u'I'A) report enti- tled Facing America’s Trash: What Next for Municipal Solid Waste? We also visited a garbage transfer station in northern New Jersey and four landfills-two in Ohio and one each in Indiana and Virginia-to observe the types of trucks entering and leaving these facilities. We selected these landfills because they were identified by New York, Kew Jersey, or Pennsylvania officials as accepting out-of-state garbage. We excluded short-haul garbage trucks from our observations, which aver- aged 15 hours at each landfill. We interviewed the transfer station oper- ator and 2 Ohio landfill operators and spoke to 84 truck drivers entering those 2 landfills to determine their knowledge and experiences regarding garbage/food cross-hauling. At the request of state officials, we did not enter the landfills in Virginia and Indiana; therefore, we did not speak to the operators or the truck drivers at those facilities. To determine the health issues associated with cross-hauling garbage and food, we met with officials from the National Institutes of Health (NIH), cm, FDA, USDA, and state health officials from New Jersey and Pennsylvania. We reviewed CDC’Sstudies and reports monitoring food- borne diseases. To determine the economic and environmental conditions that gave rise to long-haul garbage transport, we,( 1) interviewed officials on EPA’S Municipal Solid Waste Program Task Force and reviewed OTAand EP.~ municipal waste studies, regarding the problems associated with land disposal, short-term and long-term trends in waste generation and dls- posal capacity, and options to landfills and (2) reviewed testimonies by trucking companies and associations and interviewed representatives of the American Trucking Association, regarding economic issues relatmg to why truckers are transporting garbage in long-haul, multipurpt)se trucks. We also reviewed environmental and trucking laws and ~4’s Page 17 GAO/RCED-W161 Little Is Known About GarbageiFod (‘rum Hauling Chapter 1 Introdnction April 1987 report entitled “Study of Joint Use of Vehicles for Transpor- tation of Hazardous and Nonhazardous Materials.” To determine existing federal regulations and enforcement tools that could apply to cross-hauling food and garbage, we reviewed laws and regulations and discussed with officials from m, ICC, EPA, FDA, and USDA, the agencies’ responsibilities for transportation, the environment, and ensuring the wholesomeness of the food supply. Our work was performed from August 1989 through May 1990 in accor- dance with generally accepted government auditing standards. DCT, EPA, FDA,ICC, and USDAofficials and representatives of the food, trucking, and disposal industries testified on this issue at one or more of several con- gressional hearings held between August 1989 and March 1990. We have incorporated agency and industry views, as expressed in the testimo- nies, where appropriate. In addition, we discussed the information presented in this report with officials from CDC,nor, EPA, FDA, NIH, and usm who agreed with the factual information as presented and with the report’s conclusions. nor expressed concern that it does not have the technical expertise to develop safe food transport regulations as required in pending legislation. USIX and F’DAofficials emphasized the complexity and high cost that would be involved if trucks had to be tested for bacterial and chemical residues. As directed by the requesters, we did not obtain official comments on a draft of this report. Page 16 GAO/B~6@161 Little Ia Known About Garbage/Food CrowHmling Long-Haul Tramport of Garbage-A Limited but Growing Activity Long-haul truck transport of garbage is currently expanding in certain Northeast cities where local landfill capacity is rapidly declining. In 1989, for example, approximately 460,000 truckloads of garbage- about 10.6 million tons-was transported from New York, New Jersey, and Pennsylvania to out-of-state landfills. By comparison in 1987 state records indicate that these states exported less than 2 million tons of garbage to distant landfills. Although a few other states, including Ohio and Illinois, are transporting garbage out of state, the practice appears to be concentrated in the Northeast. Landfills in states from Virginia to Michigan have accepted garbage from New Jersey and other northeastern states. We visited 4 such land- fills and observed 157 multipurpose trucks-81 dry vans, 23 flat beds, and 53 open tops-from out of state, entering the landfills during 58 hours of observation time. In Northeast urban centers, where garbage disposal problems are most acute and the demand for consumer goods entering the area exceeds the shipment of goods leaving, garbage has become a competing long-haul trucking commodity. Food is another such commodity. However, the extent that the same trucks will alternately haul garbage and then food in the Northeast and elsewhere is unknown. Environmental concerns and economic conditions encourage the expan- sion of long-haul garbage transport. Stringent landfill design and opera- tion criteria required by EPA,which include such environmental aspects as groundwater monitoring, are costly. In the absence of local landfill space or to counter the higher cost of dumping at nearby landfills that are still open- about $3,000 per truckload in the New York City area- some communities transport garbage by truck to midwestem landfills where dumping fees are about $450 per truckload. Truckers also benefit economically when otherwise empty trucking miles are converted into revenue-paying miles. These environmental and economic factors, in turn, increase the likelihood that food will be cross-hauled in the trucks that previously carried garbage. ‘Number of truckloads multiplied by an average load of 2.3tons per truck, the average amount of garbage carried by a long-haul multipurpose truck, according to garbage shippers and landfill operators. Page 19 GAO/RCED9@161Little Is Known About Garbage/Food CroeeHauling Chapter 2 Long-Haul Transport of Garbage-A Limited but Growing Activity Over the past 2 years, municipalities in the Northeast have dramatically Northeast Garbage increased the amount of waste sent by truck to out-of-state landfills. In Transported in densely populated Northeast communities, garbage generation is Multipurpose Trucks increasing, local landfills are reaching capacity and closing, remaining disposal capacity is becoming increasingly expensive, and new disposal facilities are not being built quickly enough to keep up with demand. New York and New Jersey are facing what their officials consider a dis- posal crisis. We estimate that, in 1989, these states shipped over 395,000 truckloads, or 9 million tons, of garbage to out-of-state landfills. South- east Pennsylvania, which also has a severe landfill capacity problem, sent approximately 65,000 truckloads of garbage out of state. A few other states, in and outside the Northeast region, are exporting some of their garbage, although to a much lesser degree. New York In its latest Solid Waste Management Plan, New York concludes that most of its 253 landfills will close by 1995 because they will reach capacity or they will violate state environmental standards such as those for ground- or surface water protection. In 1987, New York trans- ported 0.5 million tons of garbage out of state. New York estimated that, in 1989, the amount of garbage transported out of state had grown to 4.5 million tons. Most of the garbage comes from commercial transfer stations in New York City and surrounding municipalities on Long Island and is transported by truck to landfills mainly in Ohio and Pennsylvania. New Jersey According to the New Jersey Department of Environmental Protection, New Jersey is facing a disposal crisis because it generates more garbage than it can dispose of in-state. In previous years New York and Penn- sylvania had sent truckloads of garbage to New Jersey’s landfills until, in 1988, New Jersey legally stopped this practice. In addition, New Jersey has closed a number of major landfills and now must export much of its garbage. As recently as 1987, New Jersey disposed of 9.2 million tons of garbage in its own landfills. By 1988 the amount of gar- bage disposed of in-state had dropped to 5 million tons. New Jersey attributed the decrease to its closing of several major landfills that either had reached capacity or did not meet environmental standards. In 1989, New Jersey shipped about 4.5 million tons of garbage out of state. Almost all of New Jersey’s northern counties send their locally collected garbage to transfer stations where it is loaded onto flat beds, open top trucks, or dry vans for out-of-state disposal in Illinois, Indiana, Ken- tucky, Michigan, Ohio, Pennsylvania, Virginia, and West Virginia. Page 20 GAO/RCEDW161 Little Is Known About Garbage/Food C-Hauling Chapter 2 Long-Haul Transport of Garbage-A Limited but Growing Activity Pennsylvania In 1989, Pennsylvania disposed of 4.3 million tons of non-Pennsylvania garbage, primarily from New Jersey and New York, in Pennsylvania landfills, while at the same time exporting approximately 1.5 million tons of garbage for disposal out of state. The majority of garbage hauled out of Pennsylvania comes from commercial transfer stations in and around Philadelphia. According to a Pennsylvania Department of Envi- ronmental Resources official, landfills in the Philadelphia area have set daily capacity limits on the quantity of garbage they will accept in an effort to prolong the remaining life of the landfills. Because the daily limits are below the quantity of garbage that the Philadelphia area gen- erates, it is sending the excess, by truck, to landfills in Indiana, Ken- tucky, Ohio, and West Virginia. Other States We found only sketchy, mostly anecdotal information regarding the extent to which other locations may be shipping garbage by truck to distant landfills. As we note below, we spoke with two drivers of dry vans dumping at an Ohio landfill who told us they were carrying gar- bage from West Virginia and Connecticut. A third driver told us his load originated from within Ohio. According to an October 1989 OTA report, Illinois, Missouri, Ohio, and Wisconsin are exporting garbage, at least to some extent, to other states.” The report notes that, while interstate transport of garbage appears to have increased, little concrete informa- tion is available. Distant Landfills waste management plan acknowledges that 30 of its 130 landfills accepted out-of-state garbage in 1988. AIso, Pennsylvania reports 2 1 of its 71 landfills accepted garbage from New Jersey or New York during 1989. However, according to state officials, none of the landfills main- tain records on the types of trucks transporting garbage. We visited four of the landfills that reportedly have accepted truckloads of out-of-state garbage- two in Ohio and one each in Virginia and Indiana. At the request of state officials, we did not enter the Virginia and Indiana landfills; therefore, we did not speak with the operators or ?Facing America’s Trash: What Next for Municipal Solid Waste?, oTAXI-424. Oct. 1989 Page 21 GAO/RCRD-9S161Little Is Known About Garbage/Food Cross-Hauling Chapter 2 Lon&Haul Tramport of Garbage-A Limited but Gmwing Activity truck drivers at these facilities. The two landfill operators we inter- viewed in Ohio told us they do not maintain records on the types of trucks dumping at their facilities. At the first of the two Ohio landfills, the facility operator told us that the landfill receives about 40 percent of its garbage from out of state. The operator pointed out, however, that the facility does not have the special equipment necessary to unload dry vans and flat bed trucks; therefore all of the out-of-state garbage was shipped in open top trucks. We spoke to 29 drivers of out-of-state trucks at the first Ohio landfill, Ten of the drivers told us they planned to next haul commodities such as coal, stone, and concrete. Nineteen planned to return empty to the East Coast. None said they would haul food next. As table 2.1 shows, the drivers reported that the garbage originated in New York, New Jersey, and Pennsylvania. The second Ohio landfill, according to its operator, received approxi- mately one-third of its garbage from out of state. That landfill does have equipment to unload dry vans and flat bed trucks. Of 55 out-of-state truck drivers we spoke to, 20 operated dry vans, 18 operated open top trucks, and 17 operated flat bed trucks. Most of the drivers said they planned to haul commodities, such as steel and motor oil on their next load. None of the drivers told us they would use their truck next to carry a shipment of food. As table 2.1 shows, the 55 drivers told us the garbage came from New York, New Jersey, Pennsylvania, West Virginia, Connecticut, and Ohio. Table 2.1: Origin of Qarbaga Hauled by Drivers spoken to in Ohio Number of truckloada Origin of wasto First landfill Socond landfill New York 10 --~ 31 New Jersey 14 14 Pennsvlvania 5 7 Ohio 0 .- 1 West Virginia 0 1 Connecticut 0 1 TOW 29 55 At private landfills in Virginia and Indiana, we observed that the trucks entering the facilities were almost exclusively long-haul (from their license plates) multipurpose trucks. However, because we did not speak to the drivers, we were unable to determine the origin of their loads In Page 22 GAO/ltCEW@l61 Little b Known About Garbage/Food (‘m-Hauling Chapter 2 Long-Haul Transport of Garbage-A Limited but Growing Activity Virginia, we observed 30 trucks entering the landfill: 18 were dry vans, 6 open top, 6 flat beds. In Indiana, we observed 43 trucks entering the landfill: all were dry vans. Overall, 157 long-haul multipurpose trucks entered the four landfills during the 58 hours of our observations. Table 2.2 shows that 51 per- cent were dry vans, 34 percent were open top trucks, and 15 percent were flat beds. However, records were not maintained by landfill opera- tors or state officials regarding the type of commodities-such as food-that the trucks would carry next. Table 2.2: Typo8 of Long-Haul Multipurpore Trucks Obrarved Entering Landfills Four Landfills Ohio- Ohio- Percent by Truck type first sacond Virginia Indiana Total truck type Dry van 0 20 18 43 81 51 Open top 29 18 6 0 53 34 Flat bed 0 17 6 0 23 15 TOtal 29 55 30 43 157 Special attention was given by the media and at the congressional hear- ings on the use of refrigerated trucks to haul garbage, especially since these trucks frequently carry perishable foods. We observed two refrig- erated trucks entering landfills-one in Virginia and one in Indiana. However, since we were asked not to enter these landfills, we were unable to interview the drivers in an attempt to determine if these trucks cross-haul food. At both of the Ohio landfills we visited, the operators stated that, since the summer of 1989, they had not permitted refrigerated trucks to dump in their facilities. The owner of these two landfills, a major waste man- agement corporation, testified that because of adverse publicity over cross-hauling, reputable brokers do not want to use refrigerated trucks to transport garbage. Figure 2.1 shows a sign referring to refrigerated trucks at the entrance to one of the Ohio landfills. Page 23 GAO/RCJ3D9o-161Little Is Known About Garbageflood CrowHauling chapter 2 L.on#iaul Tranmport of Garba+A Limited but Growing Activity Figure 2.1: Sign Outside Ohio Landfill Multipurpose trucks transport about 85 percent of all meat and fresh Extent of Garbage/ fruits and vegetables consumed in the United States.:’ The extent to Food Cross-Hauling which the same trucks cross-haul garbage remains unclear. However, Unknown testimony by truckers engaged in garbage/food cross-hauling, investiga- tions by ICCand others, and anecdotal information from trucking firms confirm that the practice is occurring. Documented Examples of We spoke with officials of a Pennsylvania-based trucking firm and a Garbage/Food Cross- West Virginia-based trucking firm. Each uses dry vans to transport gar- bage. One official told us his company does not transport food. The Hauling Limited other acknowledged that his firm uses the same trucks to transport packaged food but emphasized that they do not carry perishable food products. ‘Taff, Charles A., Ph.D., Commercial Motor Transportation, 7th ed. (Centerville. Md: Cornell bntu-ne Press, 1986). Page 24 GAO/WED-9fhl61 Little In Known About Garbage/Food Cross-Hauling Chapter 2 Long-Haul Transport of Garbage-A Limited but Growing Activity None of the 84 truck drivers we spoke to at the two Ohio landfills told us that they transport food in the same truck used to haul garbage. Because drivers are not required to keep a specific record of the nonhaz- ardous commodities they transport, we were unable to verify their responses.’ Considering the media attention that cross-hauling food and garbage has received and concern that the practice might not be com- pletely legal, the drivers’ responses were not surprising. In response to media attention regarding cross-hauling, several teams of federal agents from m, ICC, and USDA, together with officials from the Pennsylvania Department of Agriculture, inspected 300 trucks during June and July 1989. These inspections were conducted at food distribu- tion centers in Philadelphia, Pennsylvania; a grocery warehouse in Pitts- burgh, Pennsylvania; and cold storage warehouses in Wilmington, Delaware. The inspectors were unable to determine if any of the trailers had previously been used to transport garbage. During interviews with over 50 drivers, 2 of the drivers admitted to the federal inspectors that they had hauled garbage in food trucks for former employers. The ICC was able to document one case of garbage/food cross-hauling by reviewing a trucking firm’s records after one of the firm’s refrigerated trucks was observed by ICCagents unloading garbage at a landfill in Ohio. ICC determined that the trailer had been loaded 29 times from March 10 through June 30,1989. During that period, the trailer carried 8 loads of fresh meat, 6 loads of garbage, and 15 other miscellaneous shipments. Pennsylvania Prohibits With limited knowledge of the extent of garbage/food cross-hauling but in apparent response to public concern about the practice, on March 13, Garbage/Food Cross- 1990, Pennsylvania became the first state to ban the knowing use of the Hauling same truck to carry garbage in one load and food in the next. The new law subjects first-time violators to a fine of $1,000 to $10,000. A second violation carries a fine of $5,000 to $25,000 or a possible l-year suspen- sion of the truck driver’s license. The law also deems any truck used in committing the offense to be contraband and, therefore, allows the state to confiscate it. Pursuant to the law, Pennsylvania state police will set up a toll-free phone number for the public to use to report violators. ‘Federal regulations require truck drivers to maintain a log of such activities as drivmg. slwpm& and off-duty times. Page 25 GAO/RCED4Wl61 Little Is Known About Garbage/Food C-Hauling Chapter 2 Long-Haul Transport of Garbage-A Limited but Growing Activity Pending Legislation As we noted in chapter 1, six bills have been introduced in the 1Olst Addresses Cross-Hauling Congress that address concerns about the cross-hauling of garbage and food. On March 27, 1990, the House passed H.R. 3386, and referred it to at Federal Level the Senate. As written, H.R. 3386 requires the Secretary of Transporta- tion to issue regulations covering the transportation of food and non food products in the same vehicle. These regulations must, at a minimum, prohibit nonfood products that make food unreasonably dangerous to human health from being cross-hauled in refrigerated and tank food trucks. The regulations also must require that asbestos and other prod- ucts that present an extreme hazard to human health be carried in trucks dedicated to that purpose. DOTofficials expressed concern to us that they do not have the technical expertise that will be needed to develop the safe food transport regulations required in pending legisla- tion. In their view, agencies such as FTX and USDAare more knowledge- able and better able, technically, to address safe food transport issues. As the number and capacity of local landfills decrease, the demand for Environmental and long-distance transport of garbage increases, and with it the likelihood Economic Conditions of cross-hauling food and garbage. Roth environmental and economic conditions contribute to the demand for long-haul transport of garbage Foster Long-Haul in multipurpose tractor trailer trucks. Garbage Transport Environmental Factors EPAestimates that over one-third of the nation’s approximately 6,000 municipal solid waste landfills will reach capacity and close by 199 1. While this does not equate to a similar reduction in disposal capacity- newer landfills in some cases are much larger-total disposal capacity is declining and new landfills are not being built quickly enough to replace capacity at closing facilities. According to representatives of EPAand the disposal industry, a major obstacle to building new disposal facilities, which on average take 5 years to locate and build, has been the diffi- culty in finding environmentally suitable locations that are also accept- able to community residents. In August 1988, EPAproposed regulations placing more stringent criteria on the design and operation of municipal landfills. States will have 18 months to implement the new standards, which EPAexpects to issue in June 1990. These more environmentally protective criteria include. among other things, new groundwater monitoring and landfill lining requirements. EPAofficials expect that at least some landfills that are nearing capacity will close before they are full rather than incur the Page 26 GAO/RCED9@161Little Is Known About Garbage/Food C-Hauling chapter2 Long-lid Tmnaport of Garbage-A Limited but Growing Activity expense to bring the facilities into compliance with the new require- ments. The criteria also set construction standards for new landfills, According to a task force official, capacity problems are most acute along the East Coast (the New York City/New Jersey/Philadelphia met- ropolitan area) and in population centers in the Midwest (particularly Chicago) and on the West Coast (particularly Los Angeles and Seattle). In May 1989, the National Solid Waste Management Association (NSWMA), a trade association representing 2,700 waste service companies including landfill operators and garbage transportation and disposal firms in the United States and Canada, reported that a number of states would exhaust their landfill capacity in the next 5 to 10 years (see figure 2.2) and more and more communities may turn to exporting their waste over that time. Page 27 GAO/~161 Little Ia Known About Garbage/Food (‘NY Hmd.ing chapter2 Long-Haul Transport of Garbage-A Limited but Growing Activity Fiaure 2.2: Years to Depletion of Stete Landfill Capacity I~ GreaterThanlOYears 510 Years LaaaThwl5Ymm Source: The National Solid Waste Management Association, May 1989. Alternatives to landfills, such as incineration and recycling, have, thus far, proven to be less than ideal. The former, because of the public’s concern over the effects of incinerator emissions on the atmosphere; the latter, because it requires community cooperation and markets for the recycled materials, to be fully effective. EPAestimates that about 160 incinerators are currently in operation: and communities in all geographic areas, especially in the Northwest and Page 28 GAO/RCEWWl61 Little la Known About Garbage/Food Cross-Hauling Chapter 2 Long-Haul Transport of Garbage-A Limited but Growing Activity along the West Coast, have implemented some type of recycling pro- gram. Also, according to EPAofficials, new incinerator regulations, pro- posed in December 1989, establish strict criteria aimed at minimizing incinerator emissions and call for continuous emissions monitoring on all new incinerator construction begun after the date that these regulations were proposed. With the new regulations, both landfills and incinerators are going to be much more expensive to construct and operate, according to EPA’SMunicipal Solid Waste Program Task Force. Casing long-haul, multipurpose trucks to transport garbage to distant landfills where capacity is available is a relatively simple, possibly even cost- saving, option available to municipal planners when compared with the cost of constructing new disposal facilities. In May 1989, PU’SWUesti- mated the cost of a new landfill at about $87 million5 Economic Factors Long-haul transport of garbage has become a more practical economic alternative because recent landfill capacity problems have resulted in insufficient local landfill space and higher disposal charges in areas where landfill space is scarce. Landfill capacity is depleted more quickly and tipping fees’ are generally higher in heavily populated areas where disposal demand is the greatest. Heavily populated areas also have a greater demand for the types of consumer goods and commodities that travel by long-haul trucks-but these communities may not generate enough goods to fill those trucks on the return trip. This scenario-not enough local disposal space or the likelihood of higher local disposal cost for communities and the promise of a paying load vs. an empty trailer for truckers-is one in whiwbage becomes a viable long-haul trucking commodity, as it has in New York City. To the extent that this scenario is repeated, long-distance transport of garbage will likely increase. In 1988, NSWMA surveyed tipping fees at landfills and transfer stations across the country. As figure 2.3 shows, tipping fees in the New York metropolitan area, as well as in nearby New Jersey and Pennsylvania, were among the highest in the nation-up to $132 per ton-as com- pared with $20 or less in many rural Midwest locations.i This means that a truck loaded with 23 tons of garbage-an average load according ‘Cost in 1988 dollars including land acquisition. “A tipping fee is the price per ton that a landfill or transfer station charges for acceptmg garh;w ‘The NSWMA survey was based on a judgmental rather than a random sample and may n()I J( 1II- rately estimate true averages of all tipping fees across the country. Page 29 GAO/RCED9&161 Little IE Known About Garbage/Food CrowHauling Chapter 2 Lor@iaul Transport of Garbag+A Limited but Growing Activity to communities exporting the garbage-would be charged $3,036 to dump in a New York City area landfill but only $460 to dump in a rural Midwest landfill. The economic incentive for communities to transport their garbage long distances might be mitigated to some degree if the cost of disposal at distant landfills increases. Municipalities that export garbage will have the option of paying higher disposal costs to use landfills closer to them or paying higher transportation costs to haul the garbage to even more distant facilities. Communities may respond to these cost-based incen- tives by turning toward incineration or other alternative methods of diSpOSZtl. Page 30 GAO/RCED~161 Little Ia Known About Garbage/Food CmwHauUng Chapter 2 Lang4iaul Transport of Garba@-A Limited but Growing Activity Figure 2.3: Landfill and Transfer Station Tipping Fees in 1988 Location ma Por TM lowtlon me0 Par Too Lowtlon Wee Per Ton ALABAMA MARYLAND Lonin County Huntsville 510.50 BaltimoreCounty 40.00 (Elyria) 15.51' ARKANSAS MontgomeryCounty 46.00(T) Youngstown 12.51' Fayettevills 24.00-27.00 PrinceGeoree’s OKLAHOMA N. Little Rock 6.75’ County - 35.00 Tulsa 12.75' CALIFORNIA MASSACHUSETTS PENNSYLVANIA LongBeach 17.06(T) FallRiver 75.00 ChesterCounty 25.00 LosAngeles Haverhill 65.00 Erii 19.80' no fee:municioalaccessonk Plainville 55.00-75.00 NorthamptonCounty 60.00 Richmond 31.24 * (undercontractonly) Philadelphia 65.00(T) Sacramento MICHIGAN ’ Pittsburgh 30.00 2p$ Detrod 26.00 (undercontractonly) SanDiego JacksonCounty 32.00 RHODEISLAND SanFrancisco 45:20(T) KentCounty Prwidence 49.00 coLoRAoo (GrandRapids) 23.60 (Il.00 to mur~ies) Boulder 10.56 Lansing 14.55 Warwick Denver 10.65’ MINNESOTA (21.35to municipalities) CONNECTICUT DakotaCounty SOUTHCAROLINA Hartford (St. Paul) 40.06 SpartanburgCounty 4.75 NewMilford i2l MISSOURI TENNESSEE DELAWARE KansasCity 13.00 7.50' KentCounty 24.62 St.Joseph 6.55’ 9.00 NewCastleCounty 37.30 St. Louis 13.50' SussexCounty 22.60 NEBRASKA Austin 7.50' FLORIDA Lincoln 6.00 Clute 10.50' BrowardCounty 32.00 NEVADA IMhS 7.00-9.24' DadeCounty 27.00 LasVegas SanAntonio 9.35 32.00(T) K&l-) VIRGINIA Tampa 27.40 NEWJERSEY FairfaxCounty 24.00 56.40(T) AtlanticCounty 60.76' 24.00(T) GEORGIA BurlingtonCounty 31.53' (14.wto O.C.govt.) Atlanta 13.50’ CamdenCounty 41.97 PrinceWilliam HAWAII CapeMayCounty 41.05 County 18.50 Honolulu 13.00 EssexCounty HenricoCounty ILLINOIS WswaM 10165(-r) (Richmond) 23.00 6loomrngton 13.20’ GloucesterCounty 48.57 Suffolk 25.00 Chicago 19.20’ MercerCounty 77.49(T) WASHINGTON Macomb 9.00’ NEWYORK KingCounty Ottawa 14.70' lslip 40.00 WW 42.00 INDIANA NewYorkCity 12O.W' 47.00(T) FortWayne 21.00-24.00' 132.00'(T) WISCONSIN 15.15' Rochester 30.00-40.00 GreenBay 9.55 KANSAS ’ 40.00(T) Madison 12.50 Wichita 4.07-4.64' NORTHDAKOTA Germantown 14.?5-23.10' LOUISIANA Bismark 9.00 NewOrleans 9.75' OHIO SAMPLEAVERAGE Cincinnati 15.51' l.8dflllS: Cleveland 22.50' nmufar: Source: National Solid Waste Management Association, 1988. Page 31 GAO/lUXBBO-161 Little b Kwwn Almut Garbnge/Food Cn~~Hauling Chapter 2 Long-Haul Trzmsport of Garbage-A Limited but Gruwing Activity From the perspective of the trucking industry, the economic incentive to transport garbage out of the Northeast is very real: it turns otherwise empty miles into revenue miles, thereby reducing the need to recover all costs from revenue gained carrying goods (including food) into the Northeast. As we noted earlier, the demand for products carried into these communities by truck exceeds the demand for goods moving out of these areas. For example, the ICCreports that large food markets at loca- tions such as Hunts Point in New York City or one of the many super- market distribution centers scattered throughout the Northeast and Mid-Atlantic states receive hundreds of truckloads of food daily from Midwest producers. Once unloaded, the trucks may sit idle for days or even weeks waiting for a return load. Allowing trucks that carry food to haul garbage on return trips can also benefit the food purchaser. If trucking companies can earn revenue hauling garbage, competition among the companies may lead to lower costs for shipping food. Depending on market conditions, this may in turn lead to lower food prices for consumers. If trucking companies are legally restricted from earning revenue from hauling garbage, they will need to earn more revenues from transporting other commodities to stay in business. Such restrictions, therefore, might raise food shipping costs and food prices, although these price increases could be quite small. If certain trucks were dedicated to transporting a particular commodity exclusively-in this case garbage or food or both-society would have to expend more resources moving its commerce. Greater investment in dedicated truck and trailer capacity would be needed if the same trucks could not be used for multiple purposes. In addition, more total miles would be required to haul the same set of commodities, imposing the extra costs on society associated with faster highway deterioration, more traffic congestion, and more pollution. Economic and environmental factors have encouraged the long-haul Conclusions transport of garbage in multipurpose trucks from New York, Sew Jersey, and Pennsylvania. Multipurpose trucks also carry consumer goods and food into these areas. However, only limited, mostly anec- dotal, information exists on the extent that the same trucks carpmg garbage are subsequently used to carry food. To the extent that garbage can be safely cross-hauled with other commodities, it appears to be an economically viable business practice that provides a waste-disposal alternative for urban centers, a means to avoid “running empty” on return trips for truckers, and lower commodity and disposal costs co Page 82 GAO/BCED-W101 LIttIe Ir Known About Gubage/poad C-a Chapter 2 Long-Haul Trnnnport of Garbage-A Limited but Growing Activity consumers. As the number of multipurpose trucks engaged in long-haul garbage transport increases, to a large part because of the economic and environmental factors, the likelihood that food will be carried in the same trucks also increases. Page 33 GAO/WED-8Sl61 Little In Known About Gnrbageflood C-Hnuling Experts Do Not Know Potential Food ~ntamination Risks From Cross-Hauling Garbageand Food Both FDA and USLMhave general cleanliness standards applicable to vehi- cles used to transport food and certain other consumer goods. However, because no instances of transport-related contamination have been reported, FDAand USDAofficials said that these regulations, as applied, are limited to sensory-visual, smell, and touch-inspection. The two agencies, according to officials, focus their inspection resources in areas such as food preparation, where experience has shown that food con- tamination is most likely to occur. With regard to multipurpose trucks that haul garbage and other com- modities, the federal government does not require that (1) standard cleaning procedures be used before hauling food or (2) drivers keep records on the commodities they haul or trucks be identified in any way to focus attention on trucks that may need close scrutiny. A professor of food science at Pennsylvania State University, who supports banning the hauling of food after garbage in the same truck, testified that truck beds could harbor bacteria that current variable cleaning methods may not destroy. According to officials of the Centers for Disease Control (CDC)and National Institutes of Health (NIH), the two institutions have no knowl- edge of any documented contamination having occurred in the United States from transporting food in trucks that previously carried garbage. Using multipurpose trucks to carry garbage, according to these officials, is a relatively new activity; and detectable adverse health effects may not have emerged. In addition, no research has been performed to deter- mine microbial or chemical contamination that might remain in a vehicle after it has carried garbage or the risk of contamination to a subsequent load of food. Within the federal government, FDAand USDAare tasked with ensuring Limited Inspection of the wholesomeness of the nation’s food supply. Both agencies have spe- Trucks That cific regulations that apply to the conditions for transporting certain Transport Food foods. USIM and m officials informed us that they are aware of no instances of food contamination in the United States traced to food being transported in a truck that had carried garbage. FDAand USDArely extensively on the food industry to implement their regulations and ensure the safe transport of food. Page 34 GAO/ECED4Wl6l Little Ia Known About GarbageFood C=Hauling Chapter3 Experta Do Not Know Potential Food Contamination Risk.9From CrowHauling Garbageand Food Federal Inspection Tools USDA'SFood Safety and Inspection Service (FSIS)is responsible for the safe handling of meat and poultry products. FSISregulations include the following vehicle sanitation requirements. “...[T]he means of conveyanceshall be reasonably free of foreign matter (such as dust, dirt, rust, or other articles or residues), and free of chemical residues, SO that [a meat or poultry] product placed therein will not become adulterated. Such means of conveyance onto which [a meat or poultry] product is loaded...shall be subject to inspection.... The decision whether or not to inspect a means of conveyance in a spe- cific case, and the type and extent of such inspection, shall be at [FSIS’s] discretron and shall be adequateto determine if [a meat or poultry] product in such conveyance is, or when moved could become, adulterated.... Any means of conveyance found upon such inspectionto be in such condition that [a meat or poultry] product placed therein could become adulterated shall not be used until such condition that could cause adulteration is corrected....“’ FDA,an agency within HI-E, has a broad mandate under the Federal Food, Drug, and Cosmetic Act to ensure that food is produced and distributed under sanitary conditions and is safe to eat. The act specifically prohibits l the introduction, or delivery for introduction, into interstate commerce of any adulterated food; l the adulteration of any food in interstate commerce; and l the receipt in interstate commerce of adulterated food. A food is adulterated “if it has been prepared, packed, or held [in a truck, for example] under insanitary conditions whereby it may have become contaminated with filth or rendered injurious to health.” According to FDAtestimony, this means that, to become adulterated, a food does not actually have to be contaminated but only to have been held in an environment where it could become contaminated. FDA regula- tions that provide general guidance for food processors to prevent adul- teration stipulate that transportation of food be done under “conditions that will protect the food against physical, chemical, and microbial con- tamination, as well as against deterioration of the food and the container.” Both FSISand FDA inspectors rely on their senses of sight, smell, and touch to detect unsanitary conditions. The agencies’ officials agreed that such superficial inspections may not detect chemical contaminations and '9 C.F.R.Section325.1(c). Page 35 GAO/RCEDBO-161Little Ia Known About Garbageflood C-HauLine chapter 3 Experts Do Not Know Potential Food Contamination Risks From Cross-Hauling Garbageand Food would not detect microbial contamination. Inspectors do not collect sam- ples from truck floors and walls to test for chemical or bacterial resi- dues. Because inspectors do not document truck inspections, FDAand FSS officials were unable to tell us the number and frequency of truck inspections but said that not all trucks are inspected. They were also unable to tell us the number of trucks that their inspectors rejected as unclean for food transport but stated that they believed that number to be small. According to FDA and USDAofficials, it would be prohibitively expensive and not practicable to test a truck for every conceivable bacterial and chemical residue that might remain after it had carried garbage. Each truck tested would be idle for days or weeks waiting for results of countless, complex, costly tests with no assurance that all potential risk would be eliminated. These officials questioned whether the science even exists to test for every possible contaminant. They also noted that, even if a testing system could be devised, it may only result in a mar- ginal risk reduction. Both FDAand USDAofficials told us that their regulations allow inspec- tors to use their own judgement as to whether they should inspect the inside of a truck when visiting a food plant or warehouse. The officials contended that most food is now protected through wrappings and con- tainers that would isolate the food from contaminants during transport. Officials at both agencies told us that, because they have found no instances of contamination associated with cross-hauling food and gar- bage, they believe that the practice does not pose a serious contamina- tion risk and that current food inspection procedures are adequate. These officials said that FDAand FSISuse their inspection resources in areas such as food handling and preparation, where experience has shown them that contamination is likely to occur. Prompted by media reports that food might be transported in trucks that had carried garbage, both FDAand FSShave taken certain additional precautionary measures. For example, in June 1989, FSISissued a notice to its inspectors-in-charge at federally inspected meat and poultry plants, directing them to carefully inspect trucks at the loading docks and to advise plant managers and operators of the risks associated with cross-hauling. FSISalso sent letters to 22 transport company associations alerting them that cross-hauling meat or poultry with garbage presents risks of product adulteration and that the carrier could face penalties if adulteration occurred. FDAissued a notice to 100 food processing and Page 36 GAO/RCED-90-161Little [s Known About Garbage,Food CrowHauling chapter3 Experts Do Not Know Potential Food Contamination Risk.9From CroasHauling Garbageand Food distribution trade associations, in June 1989, alerting them of the cross- hauling of food and garbage and the potential risks of contamination. In March 1990, an FSISofficial testified before the Subcommittee on Sur- face Transportation, Senate Committee on Commerce, Science, and Transportation, that an ad hoc interdepartmental group, with represent- atives from FDA, USDA, EPA, MJT,and ICC, had been formed to evaluate the situation. While the group had not been able to develop an estimate of how widespread garbage/food cross-hauling is geographically or how often it occurs, it had determined that no confirmed incidents of adulter- ation of meat or poultry or other foodstuffs had been attributed to this practice, according to the official. Food Industry Inspection According to FDAand USDAofficials, they rely extensively on the food industry to self-regulate transportation activities to ensure the cleanli- Activities ness of the trucks used. However, no federal requirements exist stating that trucks used to carry garbage be so identified or that truck drivers document their previous loads, although such requirements could facili- tate food industry decisions about which trucks to use to transport food. Moreover, the food industry, like F’DAand USDA, also depends on a sen- sory inspection to determine if a truck is clean. An official from the National Food Processors Association, which repre- sents 600 companies that process, prepare, and package food, stated the food industry is not relying on the federal government to monitor gar- bage/food cross-hauling. Aware of the public’s perception that food gar- bage cross-hauling is undesirable and because the food industry 1s concerned about ensuring that the trucks it uses are clean many associ- ation members have issued warnings that they will not use trucking firms that allow their trucks to carry garbage. Representatives of food companies testified that they now require carriers to disclose the com- modities transported in previous loads and/or certify that the truck IS not used to haul garbage. According to representatives of the two large food processors we visited, they have quality control programs for inspecting every truck they use. One of the companies requires each trucking firm they do business with to sign a statement that the firm will not also haul garbage. No federal procedures exist for washing trucks, nor do regulations require trucks to be washed between loads, even between such seem- ingly incompatible loads as garbage and fresh produce. While some trucking firm owners testified that they clean their trucks after eac.h Page37 GAO,‘RCEB~101 Little Ie Known About Guba@/‘Food Clrw H~uUng chapter 3 Experts Do Not Know Potential Food Contamination Risks From CroesHauhg Garbageand Food load of garbage using steam or a high pressure cold water hose, a repre- sentative from the Owner-Operator Independent Drivers Association, Inc., testified that steam-cleaning a truck was the exception rather then the rule. This representative stated that frequent cleaning would be both an expensive and time-consuming proposition. The downtime and travel associated with going to a truck wash, waiting while the cleaning process goes on, and then driving to pick up the next load discourage truck washing on a regular basis. The professor of food science from Pennsylvania State University told us that metal truck beds can become scratched or etched, which would allow the harboring of bacteria. He also testified that a metal truck is more easily cleaned than one with a wooden body and it is easier to rid a truck of chemical substances than of bacteria, viruses, molds, and yeast, which multiply easily in the right conditions. Whether wooden or metal, according to his testimony, it is “impossible-or at least forbiddingly expensive-to make a garbage container compatible with food.” In his opinion, the effectiveness of truck cleaning is variable, and no research exists as to how trucks should be cleaned or sanitized. He also pointed out that plastic liners, which some transfer stations place in dry vans before loading compressed bundles of garbage, can tear and also provide conditions favorable to bacteria growth. As figure 3.1 depicts, a truck- load of loose garbage is a disgusting sight. Page 38 GAO/lK?ED-Wl61 Little b Known About Garbage/Food CrowHaulin~ ch8pter 3 Experta Do Not Know Potential Food Contamination Rhb From CmsbRanling Garbageand Foal Figure 3.1: Dry Van Hauling Loose Garbage I i . c Source: The Interstate Commerce Commission Page 39 GAO/lEED~161 Little Is Known About Garbage/Food CmeeHmling Chapter 3 Experts Do Not Know Potential Food Contamination Risks From Croes-Hauling Garbageand Food CDCmaintains nationwide surveillance of diseases through epidemiologic No Research on and laboratory investigations and data collection. CDC’Sinformation on Potential Food disease outbreaks usually comes from reports from other federal, state, Contamination From and local health agencies. However, the likelihood of an outbreak coming to the attention of health authorities is dependent on individ- Cross-Hauling uals’ and physicians’ awareness, their interest, and their motivation to Garbage, but Federal report a disease incident. In addition, CDC’S involvement is retrospec- tive-cuc would investigate the cause of an illness only after an out- Health Experts See break had occurred. The only circumstance in which CDCwould conduct Risk as Minimal bacterial or other contaminant tests on a truck would be if its surveil- lance identified a disease outbreak and its investigation pointed to the truck as the likely source of the outbreak. Clearly, garbage contains many harmful components. Disease-producing organisms, known as pathogens, include bacteria, viruses, molds, and yeasts that come from, among other things, decomposing food wastes, fecal matter in used disposable diapers, discarded syringes, and sickbed wastes. In addition, the insecticides, pesticides, cat litter, cleaning agents, and solvents, which may be found in garbage, contain toxic chemicals and poisons, many of which may cause acute or chronic health problems. According to CDC officials, the potential types of health effects from gar- bage/food cross-hauling would most likely be either bacterial type ill- ness, such as salmonella, or toxic chemical poisoning. CDCofficials acknowledge that CDCreceives reports of only a small fraction of the total number of outbreaks of foodborne disease and that the vast mqjority of outbreaks are never traced to their source of contamination. In a January 1989 report* on salmonella-a mqjor source of foodbome disease-cnc stated that only 1 percent of the actual number of salmo- nella cases were reported. In addition, CDCofficials told us that low-dose chemical poisoning is difficult to diagnose and often not reported to CDC. CDC’SDirector, Center for Environmental Health and Injury Control, told us that, even though reporting of foodbome illness is low, he is confi- dent that CDC’Ssurveillance system could detect a problem caused by cross-hauling garbage and then food from a small number of illnesses. He noted that he was not aware of any research to determine chemical or bacterial contaminants left in trucks that haul garbage and, although he did not rule out a potential health risk, he believed the risk to be ‘An Atlas of Salmonellain the United StatesSerotype-Specific Surveillance 1966-1986 DI\ won of Bacterial Diseases,Centerfor Infectious Diseases,Centersfor DiseaseControl, Jan 1989 Page 40 GAO/ECEMWl61 Little Is Known About Garbage/Food CrosHauling Chapter 3 Experts Do Not Know Potential Food Contamination Risks Prom Cross-Hauling Garbageand Food negligible. He said that the only situation that he might find objection- able would be the transport of bulk fresh produce after a load of pesti- cides in a truck that had not been cleaned out. He also noted that he, like many people, personally finds garbage/food cross-hauling aesthetically objectionable and, for that reason, he would favor a thorough cleaning with soap, water, and steam for such trucks before they carry food. The Director, Division of Safety, NIH, held similar views. He told us he was not aware of any incidents of illness from cross-hauling garbage and food. That, the Director told us, led him to believe that very little health risk occurs from using the same trucks to transport food and garbage. He noted that if a procedure were used to decontaminate the truck before it carried food, only a minimal risk, if any, would probably accrue from cross-hauling. Decontamination, according to the Director, could be accomplished by washing the truck out with a bleach solution, According to the federal health officials and our literature searches, no studies or reports have been conducted to determine the potential health risks of transporting food in the same trucks used to haul garbage. F’ur- thermore, according to officials from CDC,FDA, and USDA,garbage con- tains such a varied amount of potential contaminants that they would not know what items to test for. A separate, lengthy test is often needed to detect the presence of an individual contaminant, such as a chemical ingredient in a pesticide or a disease-carrying bacteria in a soiled dispos- able diaper. While federal health and food safety experts have found no instances of food contamination illness in the United States from transporting food in trucks that had previously carried garbage, food contamination has occurred from cross-hauling hazardous materials and food.” In 1987, EPA issued a study on the cross-hauling of hazardous and nonhazardous materials in trucks and the potential for conta.mi.nation.4 The study iden- tified 18 cases of transportation-related contamination of nonhazardous goods by hazardous material over a 30-year period. Six of the cases occurred in the United States. None of the incidents involved the trans- portation of municipal waste. Also, CDCofficials told us they were aware of four food contamination cases that occurred outside the United States “Crosshauling hazardous material and food is not illegal. However, as of May 1990, bills regulating, and in prescribedinstant prohibiting, such crmshauling were pending in both the Senate and the House of Representatives. 4”Study of Joint Use of Vehicles for Transportation of Hazardous and Nonhazardous Materials”” (EPA/640/01-87/04X, Apr. 1987). EPA concluded that insufficient information existed to recommend that specialsafeguardsbe taken to minimize threats to public health and the environment. Page 41 GAO/BcED9O-161Little Is Known About Garbage/F& Cross-Hauling Chapter 3 Experts Do Not Know Potential Food Conbmination Rlakn Prom Cmen-Eanling GarbageandFood when food came into contact with chemicals spilled in trucks. However, none of the four involved the transport of garbage and no similar problems have occurred in this country. In general, the food science professor from Pennsylvania State Univer- sity disagrees with federal health experts on the potential risks of gar- bage/food cross-hauling. He testified that the loading of dangerous wastes onto food trucks has the potential to contaminate food. He stated that objective, scientific, factual data could be generated to show the dangers of mixing garbage and food; however, no such studies have been conducted. Garbage has many potentially health-threatening components, ranging Conclusions from bacteria-laden used disposable diapers to cancer-causing chemicals in household pesticides. While federal health and food safety experts contend that the risk of food contamination from cross-hauling with gar- bage is relatively low, they lmow neither the extent nor nature of the potential health risks. Also, while federal regulations require safe food transport, federal agencies do not plan to use their available resources to implement the complex, expensive system that they believe would be necessary to test trucks for contaminants. Moreover, no research has been conducted to determine the potential for food contamination from transporting food in trucks used to haul garbage or the extent and nature of the health risks in the event of such contamination. We. along with the federal regulators and health experts, believe that current information is not adequate to rule out health risks in transporting food in these trucks. Food shippers who implement the federal regulations cannot be certain that the trucks they use are free of invisible bacterial or chemical resi- dues that may remain in a truck after it has hauled garbage. As a min- imum, the food industry needs better recordkeeping by truckers to identify commodities hauled in trucks and standards and guidehnes for truck cleaning if it is to provide reasonable assurance that food IS being safely transported. We recommend that the Secretary of Transportation take the stt’ps Recommendations needed, including seeking authorizing legislation if necessan. t I I develop regulations requiring that truckers maintain specific records 01’4Yjmmod- ities carried in trucks that carry food. This recordkeeping coultl tltblp food shippers identify trucks that may need more thorough m.slwy*tions Page 42 GAO/ECEDWl61 Little b Known Aboat Garbage Food 4 -Hauls Chapter 3 Experts Do Not Know Potential Food Contamination Risks From Cross-Hauling Garbageand Food and facilitate any future research that the Congress may require into the extent and nature of health risks. We also recommend that the Secretaries of Agriculture and Health and Human Services, in consultation with the Secretary of Transportation and the Administrator, EPA,develop standards and guidelines for truck cleaning. These measures would help minimize the potential risk of food contamination. Page 43 GAO/ECED-W161 Little b Known Mont Garbage/Food CroeeHauling Appendix I Major Contributors to This Report John W. Hill, Associate Director, (202) 755-6001 Resources, Ronnie E. Wood, Assistant Director Community, and J. Erin Ebzik, Assignment Manager M. Jane Hunt, Reports Analyst Economic Development Division, Washington, D.C. Richard A. McGeary, Regional Management Representative Philadelphia Regional William J. Gillies, Evaluator-in-Charge Office Paul C. Schwartzel, Staff Evaluator Regina L. Santucci, Staff Evaluator (242203) Page 44 GAO/RCEB~161 Little In Known About GahgedFood Cross-Hauling Y Requests for copies of GAO reports should be sent to: U.S. General Accounting Office Post Office Box 6015 Gaithersburg, Maryland 20877 Telephone 202-275-624 1 The first five copies of each report are free. Additional copies are $2.00 each. There is a 25% discount on orders for 100 or more copies mailed to a single address. ‘,?qy Orders must be prepaid by cash or by check or money order made out to the Superintendent of Documents.
Truck Transport: Little Is Known About Hauling Garbage and Food in the Same Vehicles
Published by the Government Accountability Office on 1990-06-28.
Below is a raw (and likely hideous) rendition of the original report. (PDF)