Whats To Be Done? RCRAs Bad Fit for Labs

Though the waste classification regulations are tricky and in some cases impractical, its our job to know about them and apply them correctly. Let EPA know if you have a problem with how certain wastes are classified. But realized that regulatory changes are slow in coming.

LCEE and LRRTF support the concept of a laboratory process unit (LPU; a lab room or suite under the control of a single supervisor/principal investigator). They contend that only EHS personnel have the regulatory knowledge to properly classify RCRA waste and that waste should not be subject to RCRA until it leaves the LPU and is in the hands of EHS personnel.

Therefore, potentially hazardous waste must be put in an appropriate accumulation container that is in good condition, compatible with the waste, labeled, and less than the 55-gal and 1-qt limits applicable to satellite accumulation areas (SAAs). EPA does not require classification with all applicable waste ID numbers at the SAA; simple labeling such as Waste Solvent is acceptable.

Once EHS personnel pick up the waste, they must use information provided by lab staff to determine correct EPA hazardous waste numbers. Lab personnel must be trained to know what materials are likely hazardous wastes, as well as to segregate waste requiring special attention (PCBs, dioxins, radioactive materials, etc.), but EHS personnel are the ones who must be the experts in waste classification.

EPA has ruled that hazardous waste can be transported without a manifest on roads along the border of contiguous properties under the control of the same person (such as a university moving waste to a central accumulation point) but did not also address how one would then manifest the waste to the TSDF.

Campus-situated labs with more than one generator ID are advised to maintain a central accumulation point for each generator site. (Division of the campus does give them the advantage of having a potentially lower generator status.)

Normally, until all testing of a material in a test tube or vial is completed, it is considered a sample. When the researcher no longer needs the sample, place it in a suitable labeled waste container such as a 4 liter bottle. If a test tube contains hazardous waste, label it - at the SAA, simply Waste Extract or Hazardous Waste will do. There is no requirement for detailed labels at the SAA.

Once either limit is reached, the waste must be removed within three days. At least one state, however, Massachusetts, has adopted a policy stating that each SAA can use only one container at a time for each waste stream which, when full, must be moved to the accumulation area within three days. (Perhaps Massachusetts should reconsider its policy, since its inconsistent with federal rules, burdensome, and not based on a regulation.)

Lab staff should be aware that each lab room in which hazardous waste is generated should have an SAA and that hazardous waste should not be moved between rooms. (N.B: State regulators vary on this one; but better to be safe than sorry.)

An acceptable method of maintaining a closed container is to create a hole in the bottle cap or rubber stopper just large enough for the effluent tube. Aluminum foil or parafilm over the top may be frowned upon, but the latter method has not caused problems.

Of course, they must know enough to keep accumulation containers closed, in good condition and labeled, to segregate difficult wastes, and to give EHS personnel adequate information about the waste for proper classification. This can easily and briefly be incorporated into CHP training.

• treatment in accumulation containers as detailed in EPAs preamble dated March 24, 1986 (51 FR 10168);
• recycling (as in solvent distillation); and
• elementary neutralization (as in pH adjustment).

As part of a vital pollution prevention program, lab personnel should be encouraged to treat hazardous waste on-site in order to reduce toxicity and volume. Most states accept these treatment options, too; still as usually, check with your state first.