RCRA and Labs
LSEM RCRA interp
Current Reg Arena
UConn RCRA Workshop
Yale RCRA Inspection
|UVM XL Info
Development of a Laboratory EMP
Glassware Waste Project
Waste Min Project
Contacts and Info
LabWAM Priorities and Accomplishments
Fixing RCRA (Powerpoint)
Chemical Safety Levels
Kids in Labs (Powerpoint)
|The R&D NESHAP Development Process
Clean Air Act
|Pilot Schools' Draft EMP's
Environmental Management Standard
|University of Vermont
Lab Workers' FAQ's
The Rule, UVM docs
||Informatics||Green Bridge||Websites||LabXL Home|
On September 28, 1999, the Environmental Protection Agency (EPA), in conjunction with the Department of Environmental Protection (DEP), published the final rule "University Laboratories XL Project - Laboratory Environmental Management Standard," 40 CFR 262.100. See Appendix A. This new standard, which applies to laboratories meeting the definition of laboratory use of hazardous chemicals, is effective on __________ for Boston College Laboratories.
The guidelines specified in this Environmental Management Plan (EMP) identifies standards and procedures, responsibilities, pollution control, performance criteria, resources and work practices that both protect human health and the environment from the hazards presented by laboratory wastes. Many of the standards and procedures recommended in this plan are referred to in Boston Colleges Chemical Hygiene Plan (CHP).
Copies of this plan will be:
Requests for additional copies and questions regarding the EMP should be addressed to:
Director, Office of Environmental Health and Safety
St. Clements, Room 120
phone: (617) 552-0308
Boston Colleges Policies and Procedure Manual documents the function and responsibility of Environmental Health and Safety. This policy can be found on line at:
The College is also committed to the policies and procedures outlined in this EMP. Implementation of this program will be through the Office of Environmental Health and Safety, however, safe practices and compliance is everyones responsibility. Section 1.3 outlines relevant responsibilities to members of the college community.
The Administration of Boston College commits to providing the necessary resources for environmental protection while fostering intellectual development for its students, promoting insight and understanding for its research activities, and providing a safe, effective and efficient workplace for its faculty, staff, students and visitors.
The policies set forth in this EMP are applicable to all laboratory workers generating laboratory chemical waste. This includes faculty, staff, graduate students (ie. , teaching assistants, research assistants, laboratory assistants), undergraduate students, contractors and visitors at Boston College. Laboratory policies, however, cover only duties and tasks performed by laboratory workers while physically situated in BC laboratory facilities. Materials excluded from this plan include: radiological waste, biological waste, equipment, and photographic waste. These wastes are managed under separate Boston College plans.
The departments covered under this Plan include laboratories in Chemistry situated in the Merkert Chemistry Center; Physics and Biology situated in Higgins Hall; Psychology situated in McGuinn and Higgins Hall, and Geology & Geophysics situated in Devlin Hall.
Each department will maintain a list of faculty and their laboratories identified by room numbers. All of the lab rooms, under the administration of one faculty member situated in one building, may be considered "one laboratory" under this EMP. This shall be defined on the list provided by each department (Appendix B). A copy of this list should be forwarded to the Office of EH&S on an annual basis and or whenever a change occurs. Shared* laboratory spaces may not store laboratory waste, except as approved by the Office of Environmental Health and Safety and if listed on annual department list. Waste generated in shared spaces not approved for storage must be brought back to the researchers laboratory identified in the departmental list.
*Shared laboratory space is a room used for multiple research or academic interests that is not under the control of one person.
To fully implement policies, the assistance and cooperation of all Boston College faculty, staff and students is necessary. The following descriptions outline key roles and responsibilities involved in implementation and maintenance of this plan.
The EH&S Oversight Panel is comprised of senior level administrators to include the Financial Vice President and Treasurer, the Director of Buildings and Grounds, the Director of Research Administration, General Counsel, Director of Health Services, Director of Risk Management, Associate Director of University Housing, Associate Vice President of State and Community Relations, Chemistry Department Faculty, and the Director of Environmental Health and Safety. The Panels mission is to review and assist the Office of EH&S in developing, recommending and approving safety and enviornmental policies and management systems. The Panel will serve as an umbrella committee for other EH&S related committees on campus to ensure the Universitys compliance with federal, state and local regulations and best practices to safeguard members of the community and protect the environment.
In this, the Panel will review on an annual basis, activities and issues regarding the administration of this EMP.
The Office of EH&S reports to the Director of Buildings and Grounds at Boston College. The organizational chart for Boston College Administrators is in Appendix C. The Office of EH&S will oversee the Environmental Management Plan for Boston College and will:
Each department which generates laboratory waste is responsible for the implementation of the EMP within the laboratories under its administrative control. Each department will assign an individual or committee (department representative) to work with the Office of EH&S to:
The immediate supervisor of laboratory workers is responsible for coordinating with the designated departmental representative to implement the policies and procedures of the EMP. It is the responsibility of each laboratory supervisor to:
Laboratory workers are expected to:
The hazardous waste contractor servicing Boston College will perform the following duties in regards to this EMP:
Visitors of laboratories at Boston College who generate hazardous waste, and contractors who work in laboratories who need to be aware of this EMP observe University policies and procedures.
Appendix A, the Standard, lists all the Minimum Performance Criteria in section 262.104. Compliance with these standards will be checked when performing laboratory inspections. They include requirements on the following and will be discussed in relevant sections of this plan:
The University, through the Office of Environmental Health and Safety and departments covered under this plan, will review and update environmental objectives and targets important to the goals of the University, to student education and in support of research. These goals will be reviewed by the Environmental Health and Safety Oversight Panel.
On an annual basis, the Director of EH&S, or designee, will review legal requirements, lab inspection reports, reportable laboratory incidents, and other appropriate information (identified in Section 1.6) to set the upcoming years goals. The form listed in Appendix D will be utilized to set these goals. Once set, this form will be sent to departments covered under this plan for comment. The spring meeting of the EH&S Oversight Panel will review these goals and provide comment. The Director of EH&S, or designee, will then put these goals into action and disseminate information accordingly.
Some of the objectives may include:
For the first year of the pilot study, the goal will be to implement this EMP in laboratories at Boston College.
The Office of EH&S will identify and track legal requirements applicable to Laboratory Waste through the following means:
Lab workers will be updated with new information via the following means:
Periodic inspections will be performed by the Office of EH&S. These will consist of formal reviews of conformance with policies and procedures stated in this document. Inspections may occur during annual Chemical Hygiene Inspections. See EMP Laboratory Checklist in Appendix E. Inspections may be unannounced; however, the Office of EH&S will attempt to include faculty members during inspections of their work areas.
The completed checklist will be sent to the Principal Investigator or designee. Upon receipt, the PI will correct any issues, sign-off on the checklist and send a copy back to the Office of EH&S.
All affected laboratories will perform annual self reviews, using the EMP Checklist as a guideline, to ensure compliance with this Plan. These self-inspections will be reviewed by EH&S during periodic inspection.
Waste containers should be inspected and documented on the posted Waste Inspection Form every week. See Appendix F.
Weekly waste pick ups may also be a time to review compliance with the EMP. Boston Colleges hazardous waste service contractor will be responsible to alert the Office of EH&S and lab workers of non-compliance issues for corrective action.
Issues of non-conformance found in a laboratory that can be taken care of immediately shall be addressed at that time. This can be determined during routine inspections or during informal reviews.
The EMP checklist will be used during periodic EH&S inspections and will be forwarded to the principal investigator (PI) when complete. Upon receipt of the checklist, the PI, or designee will correct any issues of non-conformance and sign off on the form. A signed copy will be returned to EH&S. The Office of EH&S will then confirm corrective action taken.
EH&S will forward the checklist to the contractor and note items that should be reviewed. The contractor will note down on the checklist the action taken in the lab and drop off the form in the EH&S Office within 24 hours of being on site.
If the same issue is noted after the second inspection, and is considered significant in the professional judgement of EH&S staff or designee, the department head will also be notified in writing. If, after three inspections of a laboratory, the same significant issue exists, a report will be sent to the Dean of Arts and Sciences for further action, and the University Chemical Hygiene Committee.
In cases of imminent danger to life, health or the environment, the Director of EH&S, or designee, is authorized to order the cessation of hazardous activity until the danger from such a condition is abated or adequate measures have been taken.
Documents to be maintained in the Office of EH&S applicable to this program include:
Records to be maintained in Department Offices and or individual laboratories include:
Records will be kept for three years or in accordance with other legal requirements as they apply.
Proposed revisions to the EMP can be submitted to the Office of EH&S. EH&S will bring proposed revisions to the University Chemical Hygiene Committee for review and approval. Minor changes to the EMP can be made as necessary by the Office of EH&S.
The EMP will be kept updated on the EH&S web page. Laboratories will be advised of changes through the Lab Safety Newsletter or via interoffice memorandums.
This section will describe the process of determining a laboratory waste, labeling containers, storage of waste containers, allowable amounts of accumulated material and removal of waste containers from a laboratory.
A hazardous chemical that results from laboratory scale activities and includes the following: excess or unused hazardous chemicals that may or may not be reused; RCRA hazardous waste (see below) and chemicals determined not to be RCRA hazardous waste.
Laboratory waste must not result in the release of hazardous constituents into the land, air and water where such release is prohibited under federal law.
Chemical Hazardous Waste :
Under EPAs Hazardous waste statute, the Resource Conservation and Recovery Act (RCRA), a hazardous waste is defined as a "solid waste or combination of solid wastes, which because of its quantity, concentration, or chemical, or infectious characteristics may (1) cause or significantly contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness or (2) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of or otherwise managed." EPA also states a waste is hazardous if it is "ignitable, corrosive, reactive or toxic", or fits one of these lists: (1) Non-Specific Source Wastes (F Codes); (2) Discarded Commercial Chemical Products, Off-Specification Species, Container Residues and Spill Residues; (3) Acute Discarded Waste [in its original form](P Codes); (4) Toxic Discarded Waste [in its original form] (U Codes). Contact EH&S for lists.
Several individuals may determine when a material becomes a laboratory waste. This includes:
A material can be designated as laboratory waste when:
When a laboratory waste container is ready for removal, it will be removed and directly transported to the main accumulation area. Main accumulation areas are situated in Higgins Hall and Merkert Chemistry Center. Upon reaching the main accumulation area, the hazardous waste contractor or trained EH&S staff will determine if the laboratory waste will be reused, if it must be managed as RCRA hazardous waste, or is a non-hazardous waste.
Acute hazardous waste (or P-listed waste) is defined in 40 CFR 261.33 and 310 CMR 30.136. In the laboratory setting, this type of waste could be a commercial chemical product not yet used, remains from a spill, or the residue and the container of a P listed waste commercial product . The generic name(s) of the chemicals are shown on the list of acutely hazardous waste in Appendix G.
Laboratory workers will be responsible for ensuring that no more than 1 liter (one quart) of acutely hazardous laboratory waste is accumulated at one time in a lab. This may be checked when filling out the weekly Waste Inspection Form. The hazardous waste contractor will also check accumulated amounts of P-listed waste during weekly waste pick ups. Lastly, EH&Ss annual inspections will look at the accumulation of acutely hazardous waste in a laboratory. Once one liter of this material is accumulated, follow procedures for pick up of the waste material from the laboratory.
All laboratory waste must be labeled with:
If the container is too small to hold a label, then it shall be placed on a larger secondary container with a label. Printed labels can be obtained from the Office of EH&S, the department office or the hazardous waste service contractor.
Each lab may temporarily hold an aggregate of 208 liters (55 gallons) of laboratory waste and 1 liter (one quart) of acutely hazardous laboratory waste. Appropriate size containers for waste should be utilized.
Segregate hazardous chemical waste in containers according to chart in Appendix H. Store incompatible containers of laboratory waste in separate areas. See Figure One in the CHP for a list of incompatible chemicals. Also refer to reference material such as Prudent Practices in the Laboratory available in each department office.
Containers of waste must be securely closed with a cap, lid or funnel (with attached lid), etc. at all times except when wastes are being added to (including during in-line waste collection) or removed from the container. In line waste collection refers to any system that accumulates laboratory wastes automatically, periodically or continuously, and is associated with a chemical or instrumental operation in a laboratory. The following standards will apply to in-line waste collection:
Dated laboratory waste has 30 days to be directly transferred, by the contracted hazardous waste hauler, to the Universitys main accumulation area(s).
A hazardous waste service company is used to remove waste from laboratories and bring it to the main accumulation area. No laboratory workers can take laboratory waste to the main accumulation area, unless authorized by EH&S.
The service company will come on campus weekly to remove waste from the laboratories. Labs can sign up to have an automatic pick up, or drop off the Hazardous Waste Collection Form (Appendix I) in your department office, or call the Office of EH&S at 2-0308 for a pick up.
Use the following steps to have processed laboratory wastes removed:
Use the following steps to have virgin chemicals removed:
Follow the steps outlined above to remove waste from laboratories.
Refer to BCs Laboratory Guide for Renovations, Remodels, Moves, and Terminations
Refer to Section 2.0, Standard Operating Procedures, and 3.0, Control Measures in Boston Colleges Chemical Hygiene Plan which will include:
All laboratory chemicals will be transferred and moved in accordance with policies set in Boston Colleges Chemical Hygiene Plan. See Section 2.5.6 in the Chemical Hygiene Plan, Transport of Hazardous Chemicals.
Laboratory wastes will be moved by trained personnel, designated by EH&S personnel, following applicable regulatory guidelines to the main accumulation areas.
Procedures for laboratory workers for hazardous material emergency preparedness and response is covered in Boston Colleges Chemical Hygiene Plan, Section 2.6 "Emergency/Contingency Planning". Emergency contact information is also posted near or at laboratory phones.
Emergency response equipment (ie. spill kits to manage incidental spills) will be situated in each laboratory, labeled and stored with other safety equipment. Replenishment material is available in each department (contact Department Administrator), or in the Office of EH&S.
Laboratory waste spills, exposures and other incidents that trigger a reportable emergency or that require reporting under institutional policy will be investigated and documented using BCs Incident Report Form (Appendix J). Corrective actions to prevent future incidents will be recommended by the individual(s) investigating the incident to appropriate department head and or faculty in-charge.
In the event that an incident poses an actual or potential threat to human health or safety, the immediate evacuation of personnel in the affected area is required. If evacuation of the area around the campus is deemed necessary, Boston Colleges Emergency Coordinator will advise local authorities (i.e. fire, police) of the potential threat to human health and or the environment.
The Emergency Coordinator or any personnel who discovers a release or fire involving hazardous waste should activate the facility fire alarm and contact Boston College Police Department at their emergency number, 2-4444.
The on-scene Emergency Coordinator shall direct the evacuation until the Fire Department arrives.
EPAs definition of pollution prevention, or P2, include the following: P2 is source reduction and other practices that reduce or eliminate the creation of pollutants through the increased efficiency in the use of raw materials, energy, water or other resources, or the protection of natural resources by conservation.
The Office of EH&S will work with science faculty to promote pollution prevention activities. The goal is to decrease the amount of hazardous waste generated or reduce the toxicity of the waste generated in laboratories. Reduction lowers disposal costs, reduces hazards, reduces long-term liability and promotes a cleaner and healthier environment.
BCs hired hazardous waste hauler will also remain aware of potential pollution prevention opportunities and inform both EH&S and the faculty of these opportunities.
Pollution prevention opportunities will be evaluated during annual laboratory inspections conducted by EH&S. With the assistance of the hazardous waste hauler, EH&S will look at significant waste streams generated by the labs to determine which methods, as described below, can be used. The P2 Form in Appendix L will be used to measure and evaluate activities. At least one evaluation for pollution prevention will occur annually.
Success of P2 activities will be promoted to other laboratories and information disseminated via the EH&S website and the EH&S quarterly laboratory newsletter. Successful programs will noted on the EMP checklist.
Unopened or unused portions of chemicals can be redistributed to other laboratories. Prior to disposing of unused chemicals during lab clean-outs, moves, etc., check with other laboratories to see if they could use the material. If not, contact EH&S and these materials will be managed in the hazardous materials storage area in Higgins Hall. Therefore, prior to ordering new chemicals, check with EH&S to see if any of the surplus chemicals is what you are looking for, and you can have it for free.
End of process treatments can be incorporated into research protocols. This can include neutralization procedures or other standard practices outlined in many reference materials. End of process treatments can change a hazardous material to a less hazardous or non-hazardous material. One excellent book is the "Second Edition, Hazardous Laboratory Chemicals Disposal Guide" by Margaret-Ann Armour, CRC Press.
Rental of gas cylinders is the best approach. Determine if lecture size cylinders can also be rented. If not, ensure that one can return used cylinders back to the manufacturer for disposal.
Periodic inventories of chemical supplies, inventory control, and purchase of minimal quantities are all ways to manage chemicals in your area. Order smaller quantities of chemicals to ensure you use up chemicals before the expiration date, save money (if disposal of chemicals is needed), free up storage space and create less hazards in the event of a spill.
Use of micro-scale techniques or a decrease in the use of hazardous materials in research will reduce the amount of waste generated.
Use of non-hazardous and less toxic chemicals in your research is a safe and environmentally friendly way to reduce chemical hazardous waste.
Currently, Boston College recycles photofixing chemicals to reclaim silver.
Hazardous and non-hazardous waste should not be mixed. Follow guidelines in Appendix H on the proper segregation of hazardous waste to minimize costs and ensure best disposal practices.
Laboratory workers will be made aware of the above concepts to reduce waste generated during annual trainings.
Pollution prevention will be an environmental goal as described in section 1.5. The targeted decrease of waste generated is 10% over the life of the XL pilot study.
The American Chemical Societys Task Force on Laboratory Waste Management publishes a booklet entitled "Less is Better". To receive your free copy either contact the Office of EH&S at BC or contact: ACS, Dept. of Government Relations & Science Policy, 1155 16th St NW, Washington, DC 20036.
Two other excellent references include:
1. Laboratory Waste Management, A Guidebook written by the American Chemical Societys Task Force of Laboratory Waste Management.
2. Pollution Prevention and Waste Minimization in Laboratories by Peter A. Reinhardt, K.L. Leonard and P.C. Ashbrook, CRC Press.
Both of these books are available in the Office of EH&S in St. Clements Hall.
Proper management of chemical inventories can also help minimize laboratory waste streams. Each laboratory will be responsible to conduct an annual inventory of chemicals and ensure that all chemical containers are properly labeled and stored correctly.
For the first year of the pilot project a full inventory of all hazardous chemicals in each laboratory will be conducted. The Office of EH&S will assist in coordinating the inventory for the first year. In subsequent years, an assessment, by an ad-hoc laboratory committee, will be completed to determine if a full inventory is required annually thereafter. The assessment will be based upon a true risk of the chemical if not stored in accordance with defined practices and procedures.
Some items to take into consideration in conducting the survey will be:
If an issue is found with a chemical, or its container, during a survey, the laboratory will contact EH&S as soon as possible to determine what, if any, further action is warranted. EH&S will base their determination on best practices, professional expertise, the assistance of the hazardous waste contractor and local officials.
Boston College will provide laboratory workers with information and training so that they understand and can implement the elements of the Environmental Management Plan relevant to their responsibilities.
Trainings will be conducted in accordance with the same frequency as training for the Chemical Hygiene Plan. Currently this training is provided by the Office of EH&S in September and October, and again in January and February. Other information will be provided on an on going basis through informal discussions, newsletters, memorandums and publication of material on the EH&S web page.
Laboratory visitors, such as on-site contractors, visiting scientists, or environmental vendors, that require information and training under this EMP will be informed of the availability of this standard and be provided with the outline of the training program. Individuals responsible for a lab will provide this information to visitors. EH&S is available to conduct more intensive training for these groups.
Visitors will require information if they generate or handle waste chemical in a Boston College laboratory.
Acids - Inorganic & Pesticides
Acids - Organic & Photo Fixer
Bases - Alkaline & Photo Developer
Bases - Flammable & Photo - Other
Flammable Liquids & Reactives
High Hazard Peroxide Formers & Silica Gel
Mercury or any solutions containing Oil
Metals or Solutions Containing Oxidizers
Solvents-Non-halogenated organic Solvents-Halogenated
Water Reactive Compounds
Copyright © 2002 The Campus Consortium for Environmental Excellence |