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Transitioning to the Academic Laboratory Waste Rule

Beginning on January 1, 2018 the University is transitioning to the Academic Laboratory Waste Rules as found in title 40 of the Code of Federal Regulations (CFR) Part 262 Sub Part K.  In the past, the University has followed the Satellite Accumulation Area requirements as found in 40 CFR Part 262 for waste generators.  These rules applied to all generators of EPA defined hazardous waste, which laboratories frequently generate, across all industries.   The adoption of these college/university specific rules was a collaborative effort between the Environmental Protection Agency and the Campus Health, Safety and Environmental Management Association (CSHEMA). The goal was to better manage and safely dispose of wastes generated on campus in a timely manner. It was finalized by EPA several years ago and has slowly been adopted in the various states.

Now as a laboratory waste generator you may be wondering what this new rule means to me.  The good news is that it should make disposal easier.  Most of the current EHLS Rules for lab waste are still in force.  Generators most still collect, label, store and request a waste pick-up in a timely manner.  There 2 major changes under the new rules.  The first change is the label requirements. The new labels will say “unwanted material” and they will larger than the previous hazardous labels.  This was done to allow the lab waste generators to add more information on the label such as hazards (flammable, corrosive etc.) and add different constituents of mixtures.  This information is very important to EHLS personnel in preparing waste for ultimate off- site disposal but probably is not of interest to the waste generator.  Therefore, with new labels lab personnel identify waste in much greater detail than in the past.  The other major change is waste container will no longer be able to accumulate indefinitely until the reach a certain quantity. Under the lab waste rule containers of waste can only accumulate for 6 months and then a request to move them must be submitted.  Therefore, EHLS will be periodically checking with generators about waste accumulations time limits.  The thinking behind the rule was that academic labs frequently store chemicals for long periods, which cause problems such as expired chemicals and excessive load of flammable of combustible chemicals. Under this rule, lab users will be compelled to remove any waste containers older than 6 months as well as check their chemical inventory and get rid any other chemicals they no longer need.  EPA felt that excessive chemical storage for long durations was a major hazard in college/university labs regardless if there was a release or spill.  CSHEMA agreed and the rule was worked over many months of meetings and comments.

Now EHLS stands ready to assist the waste generators in transitioning to the new rule.  Please see guidance documents under the Waste tab of this web page for further information.