SecProbe.io

July 6, 2018
Devina Rankin
Chief Financial Officer
WASTE MANAGEMENT INC
1001 Fannin Street
Houston, Texas 77002
Re:WASTE MANAGEMENT INC
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 15, 2018
File No. 001-12154
Form 10-Q for the Fiscal Quarter Ended March 31, 2018
Filed April 23, 2018
File No. 001-12154
Dear Ms. Rankin:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-Q for the Period Ended March 31, 2018
Note 3. Debt, page 9
1.As of March 31, 2018, you had $2.2 billion of debt maturing within the next 12 months of
which $1.1 billion was classified as long-term because of your intent and ability to
refinance these borrowings on a long-term basis as supported by the forecasted available
capacity under your $2.25 billion revolving credit facility.  Given your disclosures on
page 10 indicate that there was unused and available credit capacity of only $629 million

 FirstName LastNameDevina Rankin
 Comapany NameWASTE MANAGEMENT INC
 July 6, 2018 Page 2
 FirstName LastName
Devina Rankin
WASTE MANAGEMENT INC
July 6, 2018
Page 2
as of March 31, 2018, please help us further understand how you determined that it was
appropriate to classify $1.1 billion as long-term debt.  Please provide us with your
analysis pursuant to ASC 470-10-45-12A through 45-20 as of March 31, 2018.
Liquidity and Capital Resources, page 40
2.We note that you reported a working capital deficit as of December 31, 2016, December
31, 2017, and March 31, 2018.  We also note that you are relying on the remaining
availability under your primary revolving credit facility to support your intent and ability
to refinance your short-term debt on a long-term basis as of March 31, 2018.  In this
regard, please expand your disclosures to address your consideration of both the working
capital deficit as well as the  availability under your credit agreements in determining that
your sources of cash will be sufficient to meet your cash and liquidity requirements over
the next twelve months.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Tracey McKoy, Staff Accountant at (202) 551-3772 or, in her absence
Nudrat Salik, Staff Accountant at (202) 551-3692 or, Terence O'Brien, Accounting Branch
Chief, at (202) 551-3355 with any questions.
Division of Corporation Finance
Office of Manufacturing and
Construction