Campus Consortium for Environmental Excellence

Univ of Connecticut RCRA Workshop

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

On April 17, 1998, the Univ of Connecticut hosted a seminar on Hazardous Waste Management for Colleges and Universities.

Speakers were recruited nationally and included:

Laboratory Hazardous Chemical Waste Regulations
David Monz, Principal, Updike, Kelly and Spellacy,
Hartford and New Haven, Connecticut

Yale RCRA Inspection and Supplemental Environmental Projects
Elan Gandsman, Director, Environmental Health and Safety,
Yale University, New Haven, Connecticut

Stanford RCRA Inspection and Compliance Assistance Program
Lawrence Gibbs, Associate Vice Provost, Environmental Health
and Safety, Stanford University, Stanford, California

University of Louisville RCRA Inspection and EPA Inspector Training Program,
Cheri Hildreth, Director, Environmental Health
and Safety, University of Louisville, Louisville, Kentucky

Financial Impacts of RCRA Noncompliance,
James Main,
Assistant Vice Chancellor for Business and Finance, University of
Nebraska at Lincoln

Reduction of Hazardous Chemical Waste from Teaching
George H. Wahl, Jr., Professor of Chemistry, North
Carolina State University, Raleigh, North Carolina

Advantages of Microscale Experimentation in Teaching and
Research Laboratories,
Kenneth Williamson, Professor of Chemistry,
Mount Holyoke College, South Hadley, Massachusetts

Below are notes from Ralph Stuart of the University of Vermont.

Notable Items from the University of Connecticut SEP RCRA seminar

1. In New England and California, the regulatory model of waste in labs is moving towards the assumption that all laboratory materials are hazardous and are waste from the minute they exit the chemical process within the lab. This is established by regulation in California and the trend observed in consent order settlements of violations in New England. This model is counter to the XL model and to de facto interpretations (by EHS departments and regulators alike) in the rest of the country. This split raises significant parity issues between laboratory institutions.

2. Yale's web based hazardous waste course is available for around $5000; this is cheaper than than adapting Stanford's for local use. Howard Hughes Medical Institute is developing a set of lab safety web courses that are likely to be free. The trend is web based training materials are becoming more cheaply available fast.

3. In addition to the physical characteristics of laboratory work (small quantities, large varieties, processes change rapidly with time, shifting and diverse population performing the work) that makes the RCRA model of process units producing wastes a poor fit, laboratories have special cultural challenges that result from their social role in meeting a strict RCRA interpretation:

" The institutional administration is focused on information and creativity, not production, safety and compliance.
" Safety culture needs to be formed as a partnership between labs and administration, because technical expertise is not shared by upper levels of the administration.
" The EHS Department is the bridge between social and physical environment of the laboratories and the expectations of the general public.
" Learning in academia is based on education, not on training.
" In academia, there is extensive reliance on weak links (for example, teaching assistants) in the supervisory chain, in order to provide development opportunities.
" Interaction with hazards is part of the education process.
" Academia works with adolescents and other inexperienced populations; these populations are the most likely to create compliance problems (statistics).

3. The Stanford response to these cultural problems: the Compliance Assistance Program - multi-regulatory visits by ehs staff to check compliance issues.
Bi-weekly non-police visits to detect problems for referral to professional. Requires 4 people for 700 labs. Stanford has weekly visits by county hazmat inspectors.

4. Some institutions are regularly inspected over several year period without problems before a major finding of violations happen.

5. UNeb spent $600,000 for SEP from $2.2 M training for high school, fire department, colleges, police departments. As a result, the Univ of Nebraska has developed a hot list of chemicals for its purchasing, and receiving program

6. A formal seminar on the research process for regulators is probably necessary to bridge the gap between regulatory expectations and research reality. Include: information about difference between education and training, the scientific process, a lab tour.