681 
Dumping Act when at sea. NACOA concluded that waste disposal regulated 
by this medium-by-medium approach (land, air, or water) has been 
responsible for shifting the risk posed by individual classes of wastes 
to the medium of least regulation rather than to the medium of least 
risk. The existing approach, through which the importance of possible 
impacts on land, air, water, people, and living and non-living resources 
are assessed separately by medium and not compared, is not working well 
and does not promise better results in the future. 
Valid resource management must not only review the major catagories 
of alternatives for sewage sludge management (e.g., land application, 
incineration, ocean dumping, etc.), but has to critically review each 
option indepth for suboptions. For instance, nearshore ocean dumping 
may be economically more advantageous than offshore dumping, however, 
the offshore environmental advantages may outweigh inshore economic 
advantages. It is our belief, that in many cases, the ocean has been 
used and may unfortunately continue to be as the waste disposal medium 
of last resort. Therefore, there is a need and responsibility, to 
predict the potential effects of using the ocean for waste disposal. 
National marine pollution programs must transform from an archaeological 
approach to an anticipatory approach--programs, that influence the 
future instead of documenting the past. As with other waste m terial 
control strategies, sewage sludge management must emphasize control of 
the type and volume of pollutants entering the sludge from other sources, 
and their subsequent recycling at the source. 
In the past five years, more information has become available on 
both environmental effects of sewage sludge disposal and on alternatives 
to ocean dumping. Additional information is also available on the 
integrated effects of pollution and natural factors in other coastal 
environments. Some changes in pollution rates of the Bight have also 
occurred recently; for instance, greater amounts of sewage sludge are 
being dumped and even greater rates of sludge production are projected 
in the future. Recent findings in these areas are incorporated in this 
assessment. 
11-267 O—82——44 
