Campus Consortium for Environmental Excellence

Laboratory Regulatory Reform

Project XL
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RCRA and Labs
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The Current Regulatory Arena in Research Laboratories

  • Regulations are ever increasing and changing
  • EPA/RCRA regulations are typically written for industry based operations
  • Interpretation of RCRA varies among states and inspectors
  • Affect of large penalties and notices of noncompliance on institutions
  • Overlapping jurisdictions within laboratories
    • Federal: EPA, NRC, OSHA, DOT, NIH
    • State: DEP (MA), Building Codes, Fire Codes
    • Local: Fire Departments, Boards of Health

The Effect of Regulations on Research Laboratories

  • Constraints of Current System Affects:
    • On-site waste storage
    • Minimization
    • Treatment
  • The variety of regulations confuses laboratory workers
  • Increasing, overlapping and inconsistent interpretations adversely affects research and student education

The Costs of Waste Management

    Typically, hazardous waste management and disposal is the most significant cost in EH&S programs, although labs in colleges and universities in the US produce less than 1% of nation's waste Program costs continue to escalate due to:

    • Hidden Costs
    • Disposal Costs
    • Unique Wastes

University Laboratory Culture

    • Promulgation of OSHA?s performance based Laboratory Standard in 1990 had a large effect
    • There is significant "Public Interest" in laboratory operations
    • Technological advances serve to decrease exposure to human health and the environment by making better techniques available
    • Technological advances create constant change in the chemicals and equipment used
    • Greater acceptance of a safety culture in laboratories
    • Organizational management is decentralized

RCRA Reform Projects

    Revision of Prudent Practices in 1995

    "...the present volume responds to societal and technical developments that are driving significant change in the laboratory culture and laboratory operations relative to safety, health, and environmental protection."

    The Government-University-Industry Research Roundtable

    The Colorado Association of Academic and Research Laboratories is pursuing reinterpretation of hazardous waste regulations for laboratories in Colorado

    Colorado Department of Public Health and Environment document entitled ?Hazardous Waste Guidance: Satellite Accumulation for LQG?s of Hazardous Waste? - dated May 1997

    National Research Council and Duke University