oversight

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)

         .                  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




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