Managing Hazardous Wastes Generated at School, Achademic and Educational Labs
Managing Hazardous Wastes Generated at School Labs, College,
Educational Labs & Academic Laboratories
Subpart K is an
optional, alternative set of regulations that allow eligible
academic entities the flexibility to make hazardous waste
determinations. The rule is applicable to eligible academic
entities, such as, colleges and
universities, and teaching hospitals and nonprofit research
institutes that are either owned by or formally affiliated with a
college or university.
The full text of the rule itself is found in
Title 40 of the Code of Federal Regulations (CFR) in Part 262
.
Steps to implementing the 40 CFR Part 262 Subpart K Educational
Lab Waste Rule
- Read the Federal Register, including the preamble
(73 FR 72912; December 1, 2008), and review frequent questions
and other implementation materials for additional information.
-
Check out the resources availble from the EPA
Frequently asked questions
-
See this page about the rule
- Check eligibility. If you are interested in
opting into Subpart K, you need to make sure that you are
allowed to. You can only opt into Subpart K if your institution
is an eligible academic entity. Make sure your institution is
one (or more) of the following:
1. College or university
2. Teaching Hospital that is owned by or has a formal
affiliation with a college or university
3. Non-profit
research institute that is owned by or has a formal affiliation
with a college or
university
- Check your state. You also need to make
sure the rule is effective in your state. See the bottom of this page.
Even if your institution is an
eligible academic entity, you can not operate under Subpart K
unless your state has adopted the rule first or you are located
in Iowa, Alaska, and the territories.
- Decide Whether to Opt into Subpart K
If
Subpart K is effective in your state and your institution is an
eligible academic entity with laboratories, then you have the
choice of opting into Subpart K. If your institution opts in,
this means that you will manage your laboratory hazardous waste
under this new set of regulations instead of the RCRA satellite
accumulation area regulations that you currently operate under.
This worksheet from the EPA may help you decide, and if you
go ahead, to prepare. If the EPA link ceases working,
use this link.
- Check internally - Before opting in,
you should to consult with your administration/dean and maybe
your legal counsel. You and your administration should decide
together whether your institution will opt into Subpart K. You
want to make sure you will have support to follow through with
the transition.
- More than one lab? If your
institution has more than one EPA Identification Number or more
than one site, part of the decision about opting in will be to
decide which sites will be opting in. When opting in, all the
laboratories operating under the same EPA Identification Number
(or on the same site) must opt in. Not all your sites have to
opt in although it is probably in your best interest to have
all the laboratories on a campus operating under the same
system.
Plan for the Transition to Subpart K
- Iidentify personnel that will be involved
in planning and implementing Subpart K for your
institution. For example, identify who will write your
Laboratory Management Plan (LMP), and who will develop and
conduct training for laboratory workers and students.
- Develop a timeline - Once your
resources are identified, you can begin to develop a timeline
for your institution's transition. Set a deadline for writing
your LMP, and prepare a schedule for rolling out training to
your laboratory personnel. Finally, identify a start date for
when your institution will begin implementing Subpart K.
- Write the Laboratory Management Plan (LMP)
for all your sites that will be opting in. You must develop an
LMP with two parts. The first part is where you select options
available to you under the rule. The second part is where you
develop your own site‐specific best management practices for
managing your laboratory hazardous waste in accordance with
Subpart K. An LMP Brainstorming Worksheet is on EPA's
website, listed above, under Implementation of Academic
Laboratories Rulemaking.
Taking the First Steps
- Training - Once your LMP is prepared,
you can begin training your laboratory personnel, including
laboratory workers (e.g., faculty, staff, technicians,
post‐docs, etc.) and students on how to manage the laboratory
hazardous waste. Everyone must be trained commensurate with
their duties. This means that the more responsibility someone
has for managing hazardous wastes generated in the laboratory,
the more training that person should have.
- Submit your notification - When your
laboratory personnel are trained and ready to implement Subpart
K, the next step is to fill out and submit your notification
(EPA's Site Identification Form, also called the 8700-12) to
your State or Region that you will be operating under Subpart
K. You must submit a separate notification for each site (each
EPA Identification Number) that is opting into Subpart K.