Non-Hazardous Waste: The Sleeper Metric in Your LCA
Carbon steals the spotlight, yet every EPD still prints a boldfaced line for “non-hazardous waste disposed.” Mess up that line and specifiers will question the rest of your data. Here is how to nail the number and even trim it before the LCA clock starts ticking.
Waste Data: Hidden Hotspot
Non-hazardous waste rarely triggers headlines, but it pours out of U.S. industry at about 7.6 billion tons a year—roughly 97 % of it as wastewater (J.J. Keller, 2025). As green‐building owners push for whole-life transparency, reviewers now zoom in on those kilograms the same way they track CO₂.
The RCRA & PCR Vocabulary Cheat Sheet
- Non-hazardous industrial waste (NHIW) sits under Subtitle D of RCRA, meaning states—not EPA—set most of the rules.
- EPD rulebooks such as ISO 21930:2017 and EN 15804 +A2 demand that you separate non-hazardous, hazardous, and radioactive outputs. NHWD (non-hazardous waste disposed) must be stated for every life-cycle module, cradle to grave (EN 15804 +A2, 2020).
Where It Surfaces in the EPD Table
Scroll any concrete or steel declaration and you will spot three waste rows. The NHWD figure often sits in the low single-digit kilograms per functional unit. Do not relax: a typo that inflates the value by one decimal place can blow past project-specific limits.
Getting Reliable Numbers Without Dumpster Diving
- Mass balance at the plant gate: Track inputs versus output tonnage; discrepancies usually expose overlooked scrap.
- Weighbridge tickets: Landfill haulers already record tonnage—export the data instead of re-typing.
- ERP or MES tags: Many systems flag off-spec product automatically; link those tags to a waste code and you have real-time LCI entries. A single missing stream can tank data-quality scores and force reruns, so appoint one point person to chase laggards.
When Waste Wins Bids
Public agencies that kept Buy Clean clauses after the 2025 rollbacks now rank bids on total waste to landfill in addition to GWP. A precast supplier in Oregon cut NHWD by 38 % and slid from third place to first on a $12 million parking structure (state procurement files, 2024).^We have no national average ROI figures yet, but specifiers tell us clean waste numbers are a tie-breaker whenever carbon scores look similar.
Three Quick Fixes That Shrink NHWD Fast
- Swap single-use pallets for pooled, returnable racks—one façade panel maker saved 2 kg waste per m² of cladding.
- Re-route concrete washout to on-site aggregate reclaimers; ready-mix plants that do this typically halve landfill tonnage (EPA TRI National Analysis, 2025).
- Partner with a neighboring factory for by-product swaps; foundry sand now shows up as cement kiln feed in several Midwest corridors.
Cross-Checks Before You Hit “Publish”
• Verify units: kilograms, not pounds. • Make sure module totals equal plant totals—auditors still spot defintion mismatches here. • Confirm recovery routes match what your hauler invoices show (recycling versus disposal).
Genuine, clean waste data will not just keep your EPD verifier happy; it may be the quiet statistic that locks in your next big project.
Frequently Asked Questions
Does wastewater count toward "non-hazardous waste disposed" in an EPD?
Usually no. Under EN 15804 +A2 and most U.S. PCRs, process water that is treated and discharged under a permit is reported separately under water indicators, not as NHWD. Only sludge from on-site treatment that goes to landfill or land application enters the NHWD line.
We incinerate scrap wood for heat. Is that still waste?
If the calorific value is harnessed, many PCRs let you record it as materials for energy recovery (MER) instead of waste disposed. You still need to document the energy yield and ash handling.
About the Author
Walker Ryan is a climate-tech entrepreneur focused on driving industrial decarbonization through better data. As the founder and CEO of Parq, he helps manufacturers generate high-quality, third-party–verified carbon disclosures at scale—accelerating a traditionally slow and expensive process. Before starting Parq, Walker led over $200 million in sustainability-focused investments as VP of Strategy & Growth at ReStream Solutions, following earlier experience in investment banking at Deutsche Bank. He brings a rare mix of capital markets expertise and hands-on sustainability knowledge to tackling the infrastructure of industrial emissions.
