Managing Hazardous Wastes Generated at School, Achademic and Educational Labs

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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.

What does the rule do?

The rule establishes an optional, alternative set of regulations that allow eligible academic entities the flexibility to make hazardous waste determinations:

• in the laboratory;
• at an on-site central accumulation area; or
• at an on-site treatment, storage, or disposal facility (TSDF).

What are typical lab wastes? Click here to see a desciption.

Goal of this rule

This rule also provides incentives for eligible academic entities to clean-out old and expired chemicals that may pose unnecessary risk. Further, this rule requires eligible academic entities that choose to manage their hazardous waste according to the rule to develop a Laboratory Management Plan. This is expected to result in safer laboratory practices and increased awareness of hazardous waste management.

Eligible academic entities may also choose not to follow the standards in this rule and remain subject to the pre-existing hazardous waste generator requirements.

Who is eligible

Eligible Academic Entities are

• Colleges and universities
• Teaching hospitals owned by or formally affiliated with a college or university
• Non-profit research institutes owned by or formally affiliated with a college or university

Subpart K applies to teaching, research, and some diagnostic laboratories, art studios, chemical stockrooms, and other laboratories owned by eligible academic entities. It does not apply to non-laboratory areas at eligible academic entities.

Subpart K is an optional rule.

States may choose whether to adopt Subpart K. Once a state adopts Subpart K, eligible academic entities in that state may opt into the Subpart K regulation or remain subject to the pre-existing generator standards (i.e., the satellite accumulation area regulations, 40 CFR 262.34(c)).

Requirements (general)

• Training of Laboratory Personnel
• EHS or Vendor Makes the hazardous waste determinations
• Move wastes out in a timely manner at predetermined frequencies
• Unwanted materials must be consolidated on-site
• Labs must cleanout periodically
• Requires development of a Lab Management Plan (LMP)

You can see the full rule here, 40 CFR Part 262, Subpart K.

For a page about the steps to comply with this rule, click here.

Benefits of using this rule.

In the EPA's eyes, here is a comparison of the new requirements:

• Greater awareness in laboratory
• Safer laboratories ?
• Better compliance
• More accurate HW determinations since it is done closest to where it was created.
• Options of where and when to make the HW determination allows the institution to tailor rule to its labs
• Encourages better planning ?
• Improves lab safety because HW must be removed on a routine basis
• Fewer partially full containers reduces costs ?
• Vendors spending less time on-site reduces costs
• Safer laboratories through reduced stockpile of legacy chemicals stored in laboratories ?
• Opportunity to maintain normal generator status instead of becoming an LQG for the month ?
• Reduced costs to eligible academic entity
• Provides flexibility for how to comply with the performance based standards of the rule

Where is the rule in effect?

The chart below the map lists the state or U.S. territory, a link to the state's regulations if applicable, and whether the state has adopted or been authorized for the rule.

State or Territory	Link to State Regulations	Adopted the Rule	Authorized for the Rule
Federal Tribes (uses Federal Regulations )		Administered by appropriate EPA Region
Alabama	Alabama Regulations (PDF) (1072 pp, 337 MB)	Yes	No
Alaska (uses Federal Regulations)		Administered by EPA Region 10
American Samoa (uses Federal Regulations )		Administered by EPA Region 9
Arizona	Arizona Regulations	Yes	No
Arkansas	Arkansas Regulations (PDF) (827 pp, 30 MB)	Yes	Yes
California		No	No
Colorado		No	No
Connecticut		No	No
Delaware		No	No
District of Columbia		No	No
Florida	Florida Regulations (20 pp, 956 K)	Yes	Yes
Georgia	Georgia Regulations	Yes	Yes
Guam		No	No
Hawaii		No	No
Idaho	Idaho Regulations (PDF) (12 pp, 113 K)	Yes	Yes
Illinois	Illinois Regulations	Yes	No
Indiana	Indiana Regulations (PDF) (2 pp, 12 K)	Yes	Yes
Iowa (uses Federal Regulations )		Administered by EPA Region 7
Kansas		No	No
Kentucky		No	No
Louisiana		No	No
Maine		No	No
Maryland		No	No
Massachusetts		No	No
Michigan	Michigan Regulations (258 pp, 605 K)	Yes	Yes
Minnesota		No	No
Mississippi	Mississippi Regulations	Yes	No
Missouri		Yes	No
Montana	Montana Regulations	Yes	No
Nebraska		No	No
Nevada		No	No
New Hampshire		No	No
New Jersey	New Jersey Regulations (PDF) (161 pp, 684 K)	Yes	No
New Mexico		No	No
New York		No	No
North Carolina	North Carolina Regulations	Yes	Yes
North Dakota	North Dakota Regulations	Yes	No
Northern Mariana Islands (uses Federal Regulations )		Administered by EPA Region 9
Ohio	Ohio Regulations	Yes	No
Oklahoma	Oklahoma Regulations (PDF) (28 pp, 74 K)	Yes	Yes
Oregon		No	No
Pennsylvania	Pennsylvania Regulations	Yes	No
Puerto Rico (uses Federal Regulations and Puerto Rico Regulations)		No	No
Rhode Island		No	No
South Carolina	South Carolina Regulations	Yes	No
South Dakota	South Dakota Regulations	Yes	Yes
Tennessee		Yes	No
Texas	Texas Regulations	Yes	Yes
U.S. Virgin Islands (uses Federal Regulations )		Administered by EPA Region 2
Utah	Utah Regulations	Yes	No
Vermont	Vermont Regulations (PDF) (27 pp, 88 K) see Section 7-109(b)(4) on page 1-24	Yes	Yes
Virginia	Virginia Regulations	Yes	Yes
Washington	Washington Regulations	Yes	No
West Virginia	West Virginia Regulations	Yes	No
Wisconsin		No	No
Wyoming	Wyoming Regulations	Yes	No

Notes About Table:

• Adoptions and authorization status listed above are as of April 15, 2013.

Related:

Lab pack wastes