Hazardous Waste Management in Academic Laboratories
The Standards Applicable to Generators of Hazardous Waste; Subpart K- Standards Applicable to Academic Laboratories was proposed in May of 2006 (71 FR 29712) and applies to college and university labs only. This rule is not applicable to industrial, medical, or hospital labs as defined in Subpart K. Additional areas common on college campuses are art studios, which are included, but not photography studios. The proposed rule is framed with performance based compliance standards and in comparison to the existing Satellite Accumulation Area (SAA) standards.
Current standards require RCRA trained individuals make the hazardous waste determination in the SAA or anytime hazardous waste is generated. The lab rule would allow for a RCRA trained individual to make the hazardous waste determination prior to “unwanted material” being removed from the lab. Further changes include that the hazardous waste determination can be made up to 4 calendar days after the “unwanted material” makes its way to the CAA (central accumulation area). “Unwanted material,” defined as used or unused chemicals and solutions that are determined to be hazardous, become subject to RCRA regulation upon removal from the laboratory.
Accumulation limits in the new lab rule are similar to current regulations. 55 gallons of unwanted material or 1 quart of “reactive acutely hazardous unwanted material” are allowed to be accumulated in a lab at one time. Acutely hazardous unwanted material that is reactive is categorized as P006, P009, P042, P065, P081, P112, and P122 unused chemicals. The accumulation time limit for all “unwanted materials” would be six months unless you exceed the quantities aforementioned, at which point you have 10 calendar days to remove the material from the laboratory.
Labeling standards published in the new lab rule would require the words “unwanted material” and sufficient information to alert emergency responders of the hazards associated with the contents. Additional requirements call for sufficient information on the label to allow a RCRA trained individual to make a hazardous waste determination. Finally the container label must denote the date accumulation begins.
These unwanted material containers must be properly managed to prevent leaks, spills, adverse chemical reactions, air emissions, or other dangerous situations. The contents must be compatible with the container and all containers in good condition.
One of the largest changes is the need for every facility to document a laboratory management plan (LMP). The LMP will describe the procedures for implementing the new lab rule standards. All entities seeking to follow the new lab standard have to notify their intent to comply with these standards.
The lab rule can benefit colleges/universities in several ways. The unwanted material in a lab doesn’t count towards your generator status until a hazardous waste determination is made. That determination would not be made until the material is removed from the lab. The task of making a correct waste determination can be put on a limited number of highly trained personnel, instead of hundreds of students and researchers doing the work in labs. This could reduce safety concerns with improper waste characterization and would help ensure accurate characterization for storage, packaging, treatment and/or disposal. This rule would help build comprehensive hazardous materials and hazardous waste management programs within college and university laboratories. Currently a program called Project XL is being implemented with these performance based standards. This project has helped to develop more effective procedures for regulating university laboratories, along with enhancing laboratory safety, and developing better systems to manage laboratory wastes. Partners include Boston College, University of Massachusetts Boston, University of Vermont, Environmental Protection Agency, Massachusetts Department of Environmental Protection, and the Vermont Agency of Natural Resources.
Current standards require RCRA trained individuals make the hazardous waste determination in the SAA or anytime hazardous waste is generated. The lab rule would allow for a RCRA trained individual to make the hazardous waste determination prior to “unwanted material” being removed from the lab. Further changes include that the hazardous waste determination can be made up to 4 calendar days after the “unwanted material” makes its way to the CAA (central accumulation area). “Unwanted material,” defined as used or unused chemicals and solutions that are determined to be hazardous, become subject to RCRA regulation upon removal from the laboratory.
Accumulation limits in the new lab rule are similar to current regulations. 55 gallons of unwanted material or 1 quart of “reactive acutely hazardous unwanted material” are allowed to be accumulated in a lab at one time. Acutely hazardous unwanted material that is reactive is categorized as P006, P009, P042, P065, P081, P112, and P122 unused chemicals. The accumulation time limit for all “unwanted materials” would be six months unless you exceed the quantities aforementioned, at which point you have 10 calendar days to remove the material from the laboratory.
Labeling standards published in the new lab rule would require the words “unwanted material” and sufficient information to alert emergency responders of the hazards associated with the contents. Additional requirements call for sufficient information on the label to allow a RCRA trained individual to make a hazardous waste determination. Finally the container label must denote the date accumulation begins.
These unwanted material containers must be properly managed to prevent leaks, spills, adverse chemical reactions, air emissions, or other dangerous situations. The contents must be compatible with the container and all containers in good condition.
One of the largest changes is the need for every facility to document a laboratory management plan (LMP). The LMP will describe the procedures for implementing the new lab rule standards. All entities seeking to follow the new lab standard have to notify their intent to comply with these standards.
The lab rule can benefit colleges/universities in several ways. The unwanted material in a lab doesn’t count towards your generator status until a hazardous waste determination is made. That determination would not be made until the material is removed from the lab. The task of making a correct waste determination can be put on a limited number of highly trained personnel, instead of hundreds of students and researchers doing the work in labs. This could reduce safety concerns with improper waste characterization and would help ensure accurate characterization for storage, packaging, treatment and/or disposal. This rule would help build comprehensive hazardous materials and hazardous waste management programs within college and university laboratories. Currently a program called Project XL is being implemented with these performance based standards. This project has helped to develop more effective procedures for regulating university laboratories, along with enhancing laboratory safety, and developing better systems to manage laboratory wastes. Partners include Boston College, University of Massachusetts Boston, University of Vermont, Environmental Protection Agency, Massachusetts Department of Environmental Protection, and the Vermont Agency of Natural Resources.
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