Campus Consortium for Environmental Excellence


Environmental Management Standard

with links to UMB documents

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
UVM XL Info
Development of a Laboratory EMP
Glassware Waste Project
Waste Min Project
Contacts and Info
RCRA
LabWAM Priorities and Accomplishments
Background Information

Fixing RCRA (Powerpoint)
Chemical Safety Levels
Kids in Labs (Powerpoint)
California
Colorado

Enforcement
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
EMP
Environmental Management Standard
University of Vermont
EMP
Lab Workers' FAQ's
The Rule, UVM docs
Baseline Report
Informatics Green Bridge Websites LabXL Home

Sec. 262.104 What are the minimum performance criteria?

The Minimum Performance Criteria that each University must meet in managing its Laboratory Waste are:

(a) Each University must label all laboratory waste with the general hazard class and either the words "laboratory waste'' or with the chemical name of the contents. If the container is too small to hold a label, the label must be placed on a secondary container. UMB EMP

(b) Each University may temporarily hold up to 55 gallons of laboratory waste or one quart of acutely hazardous laboratory waste, or weight equivalent, in each laboratory, but upon reaching these thresholds, each University must mark that laboratory waste with the date when this threshold requirement was met (by dating the container(s) or secondary container(s)). UMB EMP

(c) Each university must remove all of the dated laboratory waste from the laboratory for delivery to a location identified in paragraph (i) of this section within 30 days of reaching the threshold amount identified in paragraph (b) of this section. UMB EMP

(d) In no event shall the excess laboratory waste that a laboratory temporarily holds before dated laboratory waste is removed exceed an additional 55 gallons of laboratory waste (or one additional quart of acutely hazardous laboratory waste). No more than 110 gallons of laboratory waste total (or no more than two quarts of acutely hazardous laboratory waste total) may be temporarily held in a laboratory at any one time. Excess laboratory waste must be dated and removed in accordance with the requirements of paragraphs (b) and (c) of this section. UMB EMP

(e) Containers of laboratory wastes must be:UMB EMP

    (1) Closed at all times except when wastes are being added to (including during in-line waste collection) or removed from the container;

    (2) Maintained in good condition and stored in the laboratory in a manner to avoid leaks;

    (3) Compatible with their contents to avoid reactions between the waste and its container; and must be made of, or lined with, materials which are compatible with the laboratory wastes to be temporarily held in the laboratory so that the container is not impaired; and

    (4) Inspected regularly (at least annually) to ensure that they meet requirements for container management.

(f) The management of 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.

(g) The requirements for emergency response are: UMB EMP

    (1) Each University must post notification procedures, location of emergency response equipment to be used by laboratory workers and evacuation procedures;

    (2) Emergency response equipment and procedures for emergency response must be appropriate to the hazards in the laboratory such that hazards to human health and the environment will be minimized in the event of an emergency;

    (3) In the event of a fire, explosion or other release of laboratory waste which could threaten human health or the environment, the laboratory worker must follow the notification procedures under paragraph (g)(1) of this section.

(h) Each University must investigate, document, and take actions to correct and prevent future incidents of hazardous chemical spills, exposures and other incidents that trigger a reportable emergency or that require reporting under paragraph (g) of this section. UMB EMP

(i) Each University may only transfer laboratory wastes from a laboratory:

    (1) directly to an on-site designated hazardous waste accumulation area. Notwithstanding 40 CFR 263.10(a), each University must comply with requirements for transporters set forth in 40 CFR 263.30 and 263.31 in the event of a discharge of laboratory waste en route from a laboratory to an on-site hazardous waste accumulation area; or UMB EMP

    (2) to a treatment, storage or disposal (TSD) facility permitted to handle the waste under 40 CFR part 270 or in interim status under 40 CFR parts 265 and 270 (or authorized to handle the waste by a state with a hazardous waste management program approved under 40 CFR part 271) if it is determined in the laboratory by the individuals identified in Sec. 262.105(b)(3) to be responsible for waste management decisions that the waste is a hazardous waste and that it is prudent to transfer it directly to a treatment, storage, and disposal facility rather than an on-site accumulation area. UMB EMP

(j) Each University must ensure that laboratory workers receive training and are provided with information so that they can implement and comply with these Minimum Performance Criteria. UMB EMP

Sec. 262.105 What must be included in the laboratory environmental management plan?

(a) Each University must include specific measures it will take to protect human health and the environment from hazards associated with the management of laboratory wastes and from the reuse, recycling or disposal of such materials outside the laboratory. CH/EM PLAN VII

(b) Each University must write, implement and comply with an Environmental Management Plan that includes the following:

    (1) The specific procedures to assure compliance with each of the Minimum Performance Criteria set forth in Sec. 262.104. CH/EM PLAN VII

    (2) An environmental policy, or environmental, health and safety policy, signed by the University's senior management, which must include commitments to regulatory compliance, waste minimization, risk reduction and continual improvement of the environmental management system. EHS MANUAL 1.1

    (3) A description of roles and responsibilities for the implementation and maintenance of the Laboratory Environmental Management Plan. CH/EM PLAN III.A

    (4) A system for identifying and tracking legal and other requirements applicable to laboratory waste, including the procedures for providing updates to laboratory supervisors. CH/EM PLAN III.A.2

    (5) Criteria for the identification of physical and chemical hazards and the control measures to reduce the potential for releases of laboratory wastes to the environment, including engineering controls, the use of personal protective equipment and hygiene practices, containment strategies and other control measures. CH/EM PLAN III.B.2

    (6) A pollution prevention plan, including, but not limited to, roles and responsibilities, training, pollution prevention activities, and performance review. IN PROCESS

    (7) A system for conducting and updating annual surveys of hazardous chemicals of concern and procedures for identifying acutely hazardous laboratory waste.CH/EM PLAN III.B.8

    (8) The procedures for conducting laboratory clean-outs with regard to the safe management and disposal of laboratory wastes. CH/EM PLAN VII.F / EHS MANUAL 1.4

    (9) The criteria that laboratory workers must comply with for managing, containing and labeling laboratory wastes, including: an evaluation of the need for and the use of any special containers or labeling circumstances, and the use of laboratory wastes secondary containers including packaging, bottles, or test tube racks.CH/EM PLAN VII.C

    (10) The procedures relevant to the safe and timely removal of laboratory wastes from the laboratory.CH/EM PLAN VII.E

    (11) The emergency preparedness and response procedures to be implemented for laboratory waste. EHS MANUAL1.2

    (12) Provisions for information dissemination and training, provided for in paragraph (d) of this section.CH/EM PLAN III.5

    (13) The procedures for the development and approval of changes to the Environmental Management Plan.CH/EM PLAN III.A.1

    (14) The procedures and work practices for safely transferring or moving laboratory wastes from a laboratory to a location identified in Sec. 262.104(i).CH/EM PLAN III.B.7

    (15) The procedures for regularly inspecting a laboratory to assess conformance with the requirements of the Environmental Management Plan.CH/EM PLAN III.B.6

    (16) The procedures for the identification of environmental management plan noncompliance, and the assignment of responsibility, timelines and corrective actions to prevent their reoccurrence.CH/EM PLAN III.B.6

    (17) The record keeping requirements to document conformance with this Plan.CH/EM PLAN III.B.6

(c) Organizational responsibilities for each university.

Each University must:

(1) Develop and oversee implementation of its Laboratory Environmental Management Plan.

(2) Identify the following:

    (i) Annual environmental objectives and targets; IN PROCESS

    (ii) Those laboratories covered by the requirements of the Laboratory Environmental Management Plan.CH/EM PLAN III.A.6

(3) Assign roles and responsibilities for the effective implementation of the Environmental Management Plan.CH/EM PLAN III.A

(4) Determine whether laboratory wastes are solid wastes under RCRA and, if so, whether they are hazardous.CH/EM PLAN VII.A.1

(5) Develop, implement, and maintain:

    (i) Policies, procedures and practices governing its compliance with the Environmental Management Plan and applicable federal and state hazardous waste regulations.CH/EM PLAN III.A

    (ii) Procedures to monitor and measure relevant conformance and environmental performance data for the purpose of supporting continual improvement of the Environmental Management Plan.CH/EM PLAN III.A.1

    (iii) Policies and procedures for managing environmental documents and records applicable to this Environmental Management Standard.CH/EM PLAN III.A.2

(6) Ensure that:

    (i) Its Environmental Management Plan is available to laboratory workers, vendors, employee representatives, visitors, on-site contractors, and upon request, to governmental representatives.CH/EM PLAN III.A.5

    (ii) Personnel designated by each University to handle laboratory wastes and RCRA hazardous waste receive appropriate training.CH/EM PLAN III.B.5

    (iii) The Environmental Management Plan is reviewed at least annually by senior management to ensure its continuing suitability, adequacy and effectiveness. The reviews may include, but not be limited to, a consideration of monitoring and measuring information, Laboratory Environmental Management Standard performance data, assessment and audit results and other relevant information and data.CH/EM PLAN III.A.1

(d) What are the Information and Training Requirements for Each University?

(1) Each University must ensure that laboratory workers receive training and are provided with the information to understand and implement the elements of each University's Environmental Management Plan that are relevant to the laboratory workers' responsibilities.CH/EM PLAN III.B.5

(2) When must each University ensure that laboratory workers receive training and information?CH/EM PLAN III.B.5

    (i) Each University must provide the information to each laboratory worker when he/she is first assigned to a work area where laboratory wastes may be generated.

    (ii) Each University must ensure that each laboratory worker has had training within six months of when he/she is first assigned to a work area where laboratory wastes may be generated. Each University must retrain a laboratory worker when a laboratory waste poses a new or unique hazard for which the laboratory worker has not received prior training and as frequently as needed to maintain knowledge of the procedures of the Environmental Management Plan.

(3) Each University must provide an outline of training and specify who is to receive training in its Environmental Management Plan.CH/EM PLAN III.B.5

(4) Each University must ensure that laboratory workers are informed of:

    (i) The contents of this Subpart and the Laboratory Environmental Management Plan(s) for the laboratory(ies) in which they will be performing work;

    (ii) The location and availability of the Environmental Management Plan;

    (iii) Emergency response measures applicable to laboratories;

    (iv) Signs and indicators of a hazardous substance release;

    (v) The location and availability of known reference materials relevant to implementation of the Environmental Management Plan; and

    (vi) Environmental training requirements applicable to laboratory workers.

(5) Each University must ensure that Laboratory workers have received training in:

    (i) Methods and observations that may be used to detect the presence or release of a hazardous substance;

    (ii) The chemical and physical hazards associated with laboratory wastes in their work area;

    (iii) The relevant measures a laboratory worker can take to protect human health and the environment; and

    (iv) Details of the Environmental Management Plan sufficient to ensure they manage laboratory waste in accordance with the requirements of this Subpart.

(6) Requirements pertaining to Laboratory visitors:

    (i) Laboratory visitors, such as on-site contractors or environmental vendors, that require information and training under this standard must be identified in the Environmental Management Plan.

    (ii) Laboratory visitors identified in the Environmental Management Plan must be informed of the existence and location of the Environmental Management Plan.

    (iii) Laboratory visitors identified in the Environmental Management Plan must be informed of relevant policies, procedures or work practices to ensure compliance with the requirements of the Environmental Management Plan.

(7) Each University must define methods of providing objective evidence and records of training and information dissemination in its Environmental Management Plan.