Labs and Environmental Regulations
What is the Problem?
Laboratories are workplaces where small amounts of chemicals are used in non-routine ways. Because of these characteristics, laboratories have unusual problems in assessing and controlling their impacts on the environment. These problems are compounded by the fact that federal, state and local regulations treat laboratories as though they were industrial facilities, subject to the same pollution control strategies and regulations as large scale users of hazardous chemicals.
In 1990, OSHA recognized the unusual nature of the laboratory workplace by promulgating the OSHA lab standard. Unfortunately, EPA regulations have not made this distinction between laboratories and other workplaces. There are several efforts proceeding across the U.S. to develop more reasonable alternatives to the environmental regulations which are currently being applied to laboratories. In general, these efforts focus on developing performance-oriented regulations, similar to the OSHA standard. Performance standards are regulations which specify the goals which management systems have to reach, rather than the method of reaching them.
Performance-based standards would allow laboratories to reach defined regulatory goals by using methods that are more appropriate for their facilities. These standards, which may take a year or so to develop, could eventually replace many of the prescriptive command-and-control regulatory interpretations that many in the lab community find excessive.
Performance-based standards have proven to be very efficient in allocating compliance resources to maximize the benefit to the environment. They appear to suit laboratories especially well because of the variety and variability of laboratory activities.
A variety of issues are involved in defining the optimum regulatory strategy for laboratories. These include:
Assessing the Environmental Impact of Labs:
A workshop organized by the University of Connecticut described these problems well in the context of enforcement actions. The Division of Chemical Health and Safety of the American Chemical Society hosted a workshop which explored related issues in more detail.
Some academic institutions have put together strong hazardous waste minimization programs. The waste minimization annual report from the University of Wyoming is a good example of a successful program and includes interesting waste generation numbers and trends.
Work on developing a regulatory scheme for laboratories has been proceeding through various avenues. Some of the issues that have been discussed include:
Hazardous waste management is not the only area in which the current regulatory approach to laboratories imposes an significant burden. Managing air pollution from laboratories, reporting on hazardous waste minimization efforts, and planning for hazardous material emergencies are all regulatory arenas in which the industrial model is ill-suited for application for laboratories. These areas will likely need to be addressed in the future.
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