Campus Consortium for Environmental Excellence

LabWAM Priorities and Accomplishments

Project XL
Final Rule

2001 Progress
2002 Progress

Final Project Agreement
Final Agreement
XL Stakeholders
Leighton Letter
Regulatory Relief
XL Rule

Legal Aspects
RCRA and Labs
LSEM RCRA interp
Minimizing Costs
Current Reg Arena
UConn RCRA Workshop
Yale RCRA Inspection
Development of a Laboratory EMP
Glassware Waste Project
Waste Min Project
Contacts and Info
LabWAM Priorities and Accomplishments
Background Information

Fixing RCRA (Powerpoint)
Chemical Safety Levels
Kids in Labs (Powerpoint)

Region 1
Region 2

Region 3
The R&D NESHAP Development Process
Clean Air Act

Pilot Schools' Draft EMP's

EPA Midterm Report

Boston College
BC Plan
BC Standards
UMASS Boston
Environmental Management Standard
University of Vermont
Lab Workers' FAQ's
The Rule, UVM docs
Baseline Report
Informatics Green Bridge Websites LabXL Home

American Chemical Society's Task Force on Laboratory Waste Management (LabWAM)

prepared by

This file is also available in Adobe PDF format, which is easier to read and print than the HTML version at this link

LabWAM Accomplishments in Concert
with ACS Department of Government Relations and Science Policy

List of Objectives:
1: Guidance to Labs 2: Treatment Permits
3: Waste Accumulation Time Limits 4: EPA ID Numbers
5: Pollution Prevention in Labs 6: Mixed Waste
7: Appropriate Environmental Regulations 8: Waste-Related Issues
LabWAM Objective 1:
Provide waste management and compliance guidance to laboratories
What's the Problem? What's LabWAM done about it? What's Happening Now?
RCRA is the nation's most complex environmental law. It was written for industrial processes, so laboratory compliance is very difficult. Published
RCRA & Laboratories
The Waste Management Manual for Laboratory Personnel
(1990) and
Laboratory Waste Management: A Guidebook (1994).

Symposia/poster sessions at ACS National Meetings (1982, 1985, 1986, 1989, 1990, 1994, 1995) and many Regional Meetings.

Free distribution of booklets via GRASP, sale of Guidebook through ACS Books.

Possible future project: brief LabWAM regulatory guides, "About RCRA and Labs," on sewer disposal, satellite accumulation, chemical treatment, etc.

LabWAM Objective 2:
Reduce permitting burden for laboratory waste treatment
What's the Problem? What's LabWAM done about it? What's Happening Now?
Treatment minimizes waste, is efficient and has been a traditional way of safely disposing of chemical waste. Most labs do not have the required permit and cannot afford one. 1990: Drafted proposal for Laboratory Waste Minimization that includes these LabWAM objectives 2, 3 and 4.
1990: GRASP coordinated the formation of the Laboratory Waste Coalition.
1992: Proposal included in RCRA amendments, which did not pass Congress.
1993: Prominent Members of Congress urged EPA Administrator Browner to consider the proposal within EPA's existing legal authority.
1994: Congress asks EPA to consider the proposal as part of VA, HUD, and Independent Agencies FY1995 Appropriations Act (P.L. 103-327).

ACS submitted comments in favor of the PIT recommendations to right.

July 1996: EPA's Permits Improvement Team (PIT) recommends that "OSW should establish a general permit boilerplate and promote the use of general permits for non-commercial storage or treatment facilities, including, for example, laboratories."

On hold:EPA indicated that LabWAM would be invited to help draft the permit boilerplate.

LabWAM Objective 3:
Extend waste accumulation time limits
What's the Problem? What's LabWAM done about it? What's Happening Now?
The 90 day limit for large quantity generators prevents the accumulation of sufficient quantities for cost effective waste minimization and shipment See Objective 2 July 1996: PIT recommendation to "extend the generator storage time frames from 90 to 270 days for laboratories as part of regulatory re-invention."
LabWAM Objective 4:
Allow a single EPA IDnumber for contiguous university campuses
What's the Problem? What's LabWAM done about it? What's Happening Now?
EPA requires an ID number for every city block and costly recordkeeping of waste transport from each block. See Objective 2

Plus ACS submitted comments in favor of the EPA proposal, right.

November 1995: EPA proposes redefinition of "On-Site."

Final rule, issued December 1996, allows transport between contiguous sites without a manifest, but still requires separate I.D. numbers for each site.

LabWAM Objective 5:
Encourage pollution prevention (P2) and waste minimization in laboratories
What's the Problem? What's LabWAM done about it? What's Happening Now?
There have been few resources and little guidance that is specific to laboratories.

Inventory management is difficult with many small amounts; surplus chemicals contribute to the wastestream.

Published Less is Better in 1985, revised in 1993;
P2 Symposium (1982) and chemical inventory poster session (1995) at ACS National Meetings.
Free distribution of Less is Better.
LabWAM Objective 6:
Help laboratories manage mixed waste and reduce their risk of noncompliance
What's the Problem? What's LabWAM done about it? What's Happening Now?
Mixed waste is both radioactive and chemically hazardous. For some laboratory mixed waste, there are no commercial disposal options - partly due to its small volume and unique characteristics. EPA requires an expensive permit for treatment and storage; most labs do not have one. The Nuclear Regulatory Commission (NRC) has set release concentrations for only a few types of ultra-low level laboratory wastes. 1996: Meet with EPA's Mixed Waste Team to discuss issues and raise awareness of the problem. PIT recommendations will help.
Prepare LabWAM position White Paper to refine objectives.

Meet again with EPA.

DivCHAS & DivNucC&T co-sponsored mixed/multihazardous waste symposium for Boston ACS National Meeting in August 1998. Collaborate with Health Physics and International Isotope Societies.

LabWAM Objective 7:
Advocate for appropriate environmental regulations for laboratories
What's the Problem? What's LabWAM done about it? What's Happening Now?
Environmental laws and EPA rules are written for industrial processes. Because laboratories are uniquely different, industrial regulations are often unduly burdensome and inefficient.

Alternatively, performance-based regulations, such as OSHA¹s Laboratory Standard, appear to be an exemplary model for laboratory regulation. Laboratories are a small voice in the rulemaking process.

GRASP has commented on proposed laws and regulations that would cover laboratory waste, air emissions and wastewaters. Meet with EPA to explore national Project XL for labs.

Support, when appropriate:
EPA Region I Project XL laboratory initiative.
California, December 1996: ACS commented in support of regulatory reform recommendations, including performance-based standards.

On hold: draft model Laboratory Environmental Management Plan

LabWAM Objective 8:
Waste-Related Laboratory Issues
What's the Problem? What's LabWAM done about it? What's Happening Now?
A. EPA and states have begun to regulate air emissions from laboratories.

B. Laboratory spills create waste and are increasingly disruptive and costly.

C. Lessons from recent large EPA fines at universities in Region I and California have not been learned by most other institutions. Academia is less aware of environmental requirements, and autonomous faculty are unaware of their compliance responsibilities. Improvements are necessary for other LabWAM objectives to succeed.

A. ACS supported the³equitable treatment² of labs language in the 1990 Clean Air Act, and has commented to EPA in April 1991, and again on EPA proposed air emission rules (noted below) for laboratories and R&D.

B. Published ACS Guide for Chemical Spill Response Planning in Laboratories in 1995.

A. August 1995: EPA proposes allowing separation of R&D and Major Part 70 Sources. May 1997: EPA proposes listing R&D as a Part 63 HAP source.
On hold: writing a Reducing Lab Air Emissions brochure.

B. DivCHAS co-sponsored lab spill symposium for Boston ACS National Meeting in August 1998.

C. On hold: proposed article to raise awareness of institutional leaders/research directors via collaboration with other organizations (such as NACUBO).