Guide to Managing Wastes for Laboratories: 
Section 2: Management In Labs

This guide was originally prepared by the U.S. EPA to provide information about small chemical laboratory environmental issues. EHSO has updated and revised it to make it more useful. Click here for the printable pdf version of the SMALL LABORATORY GUIDE  (814K) Be sure to ALSO see this page on OSHA lab standards and requirements !!!

2.1 Environmental Management Systems

Like any other important business activity in a small lab, environmental issues must be carefully managed. For example, important business activities occurring in small labs address quality, finance, human resources, or safety and have appropriate management systems.

What is an EMS?

The collection of activities undertaken to ensure that environmental issues are managed is called an environmental management system (EMS). An EMS is essential to:

  • Consistently comply with environmental laws and regulations;
  • Improve overall environmental performance;
  • Address environmental liability from current or past practices;
  • Maximize the investment, no matter how small, in environmental affairs;
  • Integrate environmental objectives into overall business objectives; and
  • Provide for an environmentally safe workplace.

Interest in environmental protection is growing steadily so small labs, like other organizations, may be increasingly challenged to demonstrate commitment to the environment. Implementing an EMS can help in a number of ways.

Why is an EMS Important?

First, an EMS makes good business sense. By identifying the causes of environmental problems, and then eliminating them, an EMS can help save money. The following questions demonstrate the point:
Is it better to conduct chemical analyses right the first time or perform a lot of re-work later?
Is it cheaper to prevent a spill in the first place or clean it up afterwards?
Is it more cost-effective to prevent pollution or to manage it after it has been generated?

Second, an EMS can be an investment in the long-term viability of a small lab. An EMS helps the organization become more focused and, therefore, more effective in achieving environmental goals. This, typically, will result in higher staff job satisfaction and productivity. It also will help attract and retain new customers. More and more often, it is becoming necessary to prove a lab has an EMS to satisfy contract or other business terms.

Elements of an EMS

Policy

  • Develop an Environmental Policy that describes the lab organization's commitment to the environment.
  • Use this policy as a framework for planning and implementation.

Planning

  • Formulate objectives in line with the policy.
  • Plan actions to achieve objectives.
  • Ensure plan is in compliance with Federal, state, tribal and local regulations.

Implementation

  • Establish roles and responsibilities and provide resources.
  • Provide training to employees on their environmental responsibilities.
  • Institute processes for communicating both internal and external environmental management issues.
  • Develop written procedures and policies and ensure that documentation is maintained.
  • Identify potential emergencies and develop procedures for prevention and response.

Quality Assurance and Control

  • Monitor key activities and track performance.
  • Identify and correct problems.
  • Keep adequate records of EMS performance.
  • Conduct periodic environmental management system audits to verify that the EMS is operating as intended.

Management Review

  • Periodically review the EMS to evaluate overall program
    effectiveness and institute improvements where needed.
  • Annually review objectives to determine whether the lab is meeting
    them. Set new targets as needed.

Chances are that most small labs have already committed to a quality or safety program. In fact, much of what is needed in many small labs may already be in place. In these cases, it is useful to think of an EMS as a value-added component to these existing programs.

When first establishing an EMS, the process can seem overwhelming. Because the EMS process encourages continual improvement, however, it doesn't matter how complete an EMS is, or isn't. It is important to get started now.

Small labs have some advantages over larger labs for establishing an EMS. For example, lines of communication are generally shorter, organizational structures are less complex, people perform multiple functions, and access to management is simpler. Also, time and

resources are more scarce. This means management and staff are often motivated to spend time and resources wisely. An EMS helps promote and sustain such efficiency.

EMS Standards and Registration

Many lab organizations have already committed to quality certifications such as the International Organization for Standardization (ISO) Total Quality Management Standard, ISO 9000. A number of organizations and countries have developed similar "quality" standards devoted to EMS. One such standard is ISO 14001. A lab can review its organization against a standard such as ISO 14001 to identify gaps and opportunities for improvement in its EMS. If the lab meets all the required elements of the standard, the lab can "self-declare"
conformance. Alternatively, the lab can go through a third-party "registration" process. Some customers may require a third party review. Regardless of whether the lab pursues formal registration or self-declares, the assessment and adjustment of the lab's operations using a standard such as ISO 14001 is likely to improve lab environmental management.

ISO 14001 and other EMS standards should not be confused with lab certification and accreditation programs that demonstrate compliance with industry or government process or sample analysis protocols. Examples of these accreditations include EPA's National Environmental Laboratory Accreditation Program (NELAP) and the National Institutes of Standards and Testing (NIST) accreditation process for asbestos analysis. A properly designed EMS will consider conformance with such accreditation programs as a system objective but will go beyond the lab analysis process to consider all environmental aspects of the lab.

2.2 Pollution Prevention and Waste Minimization

Pollution prevention (P2) and waste minimization are terms that refer to practices that reduce or eliminate the amount and/or toxicity of pollutants which would have entered any waste stream or that would have been released into the environment prior to recycling, treatment, or disposal. P2 applies not only to the management of all types of waste, but also to the management of releases to air, water, and land. These practices are cross cutting and can be adopted in many environmental program areas.

The United States Congress issued national expectations for P2 in the Pollution Prevention Act of 1990. The U.S. Environmental Protection Agency (EPA) has developed a hierarchy for waste management alternatives that lists source reduction as the preferred option, followed by on-site and off-site recycling, treatment, and land disposal. The P2 approach is most effective if encouraged at the highest level of the lab organization and integrated into the organization's EMS. Some common P2 practices include equipment or process modifications, reformulation, substitution with less toxic materials, and inventory control procedures.

Implementing a P2 Program

Implementing a comprehensive P2 program can benefit a lab organization in a number of ways. It may cut expenses by reducing waste treatment and disposal costs, raw material purchases, and other operating costs. It may also reduce potential environmental liabilities and help protect the environment.

Labs have unique waste disposal issues that are different from manufacturing operations because of the broad variety and small quantities of chemicals used and the rapid frequency with which processes can change. There are various methods lab personnel can employ to minimize the generation of hazardous wastes. To be effective, a P2 program should include the key elements outlined below:

1. Obtain Management Support. Top management should instill and foster support by communicating the importance for such a program to staff. Management participation and compliance with the program is critical to its success.

2. Conduct a Waste Stream Assessment. Evaluate each waste stream from every process to generate ideas and options for reducing waste.

3. Conduct a Feasibility Analysis. This will help prioritize the order in which waste minimization options are selected and carried out. When performing a feasibility analysis, consider regulatory issues, costs, staffing, space requirements, and company policies.

4. Implement the Selected P2 or Waste Minimization Options.
Develop and disseminate a memo or policy to educate and train staff
who will ultimately be involved in performing and/or implementing the
selected options.

5. Evaluate the Program. Periodically evaluate the program's performance to determine overall effectiveness. Then implement recommended changes for improvement.

P2 and Waste Minimization Opportunities

There are a variety of P2 and waste minimization opportunities that may be available to small labs. Specific examples are provided in each of the key environmental management issue subsections provided in Section 3 of this Guide.

2.3 Environmental Training

A critical element for the successful implementation of a lab EMS is the development and implementation of an environmental training program. Employees at small labs may encounter various types of hazards chemical, physical, biological and radiological. A comprehensive training program provides:

  • Employees with information to conduct their jobs in a safe manner;
  • A process to assure compliance with regulatory-based training requirements; and
  • A mechanism to: demonstrate management's commitment to improved environmental
    performance; communicate corporate environmental policies and goals; and elevate the
    environmental awareness of staff.

Developing and implementing a comprehensive environmental training program can be a daunting task when one considers the dozens of environmental, health and safety training classes that may be required for a lab. OSHA has developed voluntary training guidelines to assist employers in identifying and providing a training program. The guidelines consist of seven steps that follow the EMS process of planning, implementing, and measuring performance:

Developing the Training Program

1. Perform a Needs Assessment. Determine what training, if any is necessary, to meet the training program objectives. Training is generally required when there are new or transferred employees, changes in programs or procedures, new regulations or requirements, new equipment or materials, needs for improved performance, or simply to meet a periodic regulatory requirement.

2. Design the Training Program. Design a program that includes:

  • Establishing training goals and objectives (e.g., education on specific lab procedures,
    compliance with regulation,general awareness, etc.); and
  • Determining effective training methods (e.g., case studies, video, practical exercises) and trainers.

3. Develop the Training Content. Prepare training courses and materials to meet the program goals and objectives. The materials may include commercially available products, training developed and presented by a contractor or developed internally.

4. Conduct the Training. Execute the training program.

5. Evaluate the Training Effectiveness . Assess individual training class effectiveness and the overall effectiveness of the training program to ensure that it is meeting the course/program goals.

6. Recordkeeping and Monitoring. Maintain records of student evaluations, tests, and attendance rosters.

7. Improve the Training Program . Based on the results of evaluations, revise the training classes and program to correct deficiencies.

Required Training

Lab personnel are subject to a variety of EPA, OSHA, DOT and Nuclear Regulatory Commission (NRC) training requirements. Requirements include hazard communication, chemical hygiene and hazardous waste training to name a few.

2.4 Information Management and Recordkeeping

"Buried in paperwork" is a term that is easily understood by environmental managers at small labs. The amount of environmental information that must be managed can be daunting. Consider the variety of information sources presented in the following figure.
 



Implementation Guide for the Code of Environmental Management Principles for Federal Agencies;
Appendix A, Model Office/Facility Environmental Program


Maintaining accurate, up-to-date, and easily retrievable records of environmental management activities is essential for reducing future liability (e.g., fines for regulatory non-compliance, costly cleanup costs), facilitating inspections (internal and external), and responding to customer and other inquiries and information requests. Many environmental laws and regulations require comprehensive documentation to assure compliance and for regulatory agency reporting. Each reporting requirement has unique agencies to work with, reporting periods and submission dates, data reporting formats and record retention times. Documentation requirements are also required to demonstrate conformance with EMS standards such as ISO 14001. Many of these are described in the key environmental management issue subsections provided in Section 3 of the Guide.

Like most elements of a quality EMS, a good information and documentation management system should be designed to meet the specific needs of the small lab. The system should address not only regulatory reports but also such information as key regulations, guidance documents and other environmental management publications. The recordkeeping system should never rely on undocumented processes set up and maintained exclusively by a single individual. Inevitably, the individual is gone when key documents are needed and, therefore, cannot easily be retrieved.

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