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 (1986),
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).
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