Campus Consortium for Environmental Excellence

RCRA and Labs

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

The most pressing regulatory concern for laboratories for most laboratories is compliance with hazardous waste regulations promulgated under the Resource Conservation and Recovery Act (RCRA). The application of RCRA to hazardous materials in laboratories has been a source of controversy for many years. This controversy reached new levels in 1993 and 1994, when RCRA inspections at Stanford and Yale resulted in 5- and 6-figure fines. The Stanford case resulted in the development of a Laboratory Regulatory Reform Task Force, which worked hard to develop a clearer sense of the regulatory challenges facing labs.

This controversy has heightened in 1999, when EPA Region I, Region II and Region III, announced enforcement iniatives aimed at higher education, the site of many laboratories.

This pressure has resulted in various efforts to reform these regulations as they apply to laboratories. These efforts include:

Laboratory Regulatory Reform Efforts

The California Laboratory Regulatory Reform Task Force

In 1995, after a hazardous waste inspection at Stanford University resulted in fines of over $1 million, a statewide task force was appointed to review the laboratory regulatory situation in California. This group consisted of representative of academic and industrial labs and state regulators. They issued a report with 14 recommendations for regulatory reform, to which the state Department of Toxic Substances Control responded.

American Chemical Society LabWAM

The American Chemical Society has had a Task Force of Laboratory Waste Management for several years. In concert with the ACS Government Relations and Science Policy Department, it has been active in a number of areas. Peter Reinhardt of the University of Wisconsin is the chair of this task force and had prepared a summary of its Priorities and Accomplishments. In addition, the Task Force provided comments on California LRRTF Reports.

Project XL

Project XL is one of the EPAs programs for reinventing its regulations to be more responsive to the parties it regulates. With regard to laboratory use of hazardous materials, the New England-based Laboratory Consortium for Environmental Excellence (LCEE) is pursuing the development of a Project XL to apply to the application of RCRA regulations to laboratories. The ground rules for Project XL and the LCEEs work is described here.

Colorado Satellite Accumulation Rules

One of the gray zones involved in laboratory waste handling from a regulatory perspective is When is a material a waste?. The State of Colorado has an interpretation of the waste generating process which allows the waste generator to define the boundaries of the waste process. This would help answer this question in laboratory settings.