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sediments, and there is movement toward banning sewage sludge disposal soon. 



The direction taken by the international community through the London Convention and 

 the United States through passage of the Ocean Dumping Ban Act is clear: the eventual 

 elimination of waste dumping at sea. 



In addition to the London Convention's prohibitions, the MARPOL convention 

 (International Convention on the Prevention of Pollution from Ships) regulates waste dumping 

 at sea. As mentioned above, it, along with the London Convention and MPRSA, prohibits ocean 

 dumping of persistent synthetics, which raises questions about the legal ability to dump 

 synthetically bagged wastes in the sea. 



Both U.S. and international law have moved away from the ocean as a waste repository. 

 By and large, the wastes contemplated for a new deep ocean dumping regime cannot be legally 

 dumped at sea. Starting a new ocean dumping industry would also run completely counter to 

 U.S. and international waste disposal policies. 



2. Embarking on a new at-sea waste dumping protocol is completely inconsistent with U.S. 

 waste management policies. 



Waste dumping in the deep ocean would run counter to established waste management 

 policies for the following reasons: 



A. deep ocean dumping would act as an enormous disincentive for waste 

 prevention, recycling and reuse. 



B. waste disposal on the seafloor hundreds or thousands of miles offshore in 

 depths of water over three miles deep would make waste monitoring incredibly 

 difficult, while making waste retrieval and site clean-up nearly impossible. 



C. beginning a new deep ocean practice would divert limited Federal funds from 

 the development of technologies that solve waste problems, not just move them 

 around. 



D. scattering bags of wastes across the ocean floor would leave a legacy of waste 

 for our grandchildren and great-grandchildren to grapple with. 



Waste Policy Has Shifted To Prevention, Recycling And Reuse 



The first preferred action in the waste management hierarchy is prevention, followed by 

 recycling and reusing wastes. Ocean dumping is a throw-back to an out-of-sight, out-of-mind 

 outlook on waste management. As history has shown, as long as the oceans have been available 

 for waste dumping, preferred activities such its waste prevention and reuse have languished. 

 While the oceans received sewage sludge, little effort was made to determine environmentally 

 safe ways of decontaminating and disposing of sludge. When the Ocean Dumping Ban Act 

 passed in 1988, states and municipalities were forced to develop alternatives. As we've closed 



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