Campus Consortium for Environmental Excellence


DTSC Response, part 2

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
UVM XL Info
Development of a Laboratory EMP
Glassware Waste Project
Waste Min Project
Contacts and Info
RCRA
LabWAM Priorities and Accomplishments
Background Information

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

Enforcement
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
EMP
Environmental Management Standard
University of Vermont
EMP
Lab Workers' FAQ's
The Rule, UVM docs
Baseline Report
Informatics Green Bridge Websites LabXL Home

3. Treatment in the Laboratory

Issue: Should bench top treatment be excluded from permitting?

Task Force Interpretation of the Existing DTSC Regulations: The Reform Task Force refers to DTSC's "'Draft' Fact Sheet on Handling of Hazardous Waste at Laboratories" as an appropriate mechanism for bench top treatment.

DTSC Response to the Task Force Interpretation: The "Fact Sheet on Handling of Hazardous Waste at Laboratories" is a draft at this time, however, we acknowledge that substantial agreement between DTSC and the Reform Task Force exists on this subject. Under certain conditions, existing laws allow certified labs, educational labs, and Quality Assurance/Quality Controlled labs to conduct onsite treatment without a permit.

Task Force Recommendation: The Reform Task Force recommends that bench top treatment within the LPU not be subject to regulation if it is conducted in compliance with the conditions below: