United States
Environmental Protection
Agency
Office Of Small Business
Ombudsman
(2131)
EPA 233-B-98-001
July 1998
c/EPA
Environmental
Management Guide For
Small Laboratories
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ENVIRONMENTAL MANAGEMENT GUIDE
for
SMALL LABORATORIES
Office of Small Business Ombudsman
U.S. Environmental Protection Agency
Washington, D.C. 20460
July 1998
11
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NOTICE
This document has been prepared to assist those responsible for administering or improving
environmental management programs at small laboratories. To do this, the document outlines
management and Federal regulatory issues for small laboratory environmental management, but does not
prescribe in detail all required factors and considerations. For example, many important state and local
requirements are not addressed.
The U.S. Environmental Protection Agency (EPA) does not make any guarantee or assume any liability
with respect to the use of any information or recommendations contained in this document It is
recommended that users of this document requiring additional information or advice consult a qualified
professional.
m
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ACKNOWLEDGEMENT
This document was prepared by PRIZM Inc. for the Office of Small Business Ombudsman (OSBO),
U.S. Environmental Protection Agency (EPA). Ms. Karen V. Brown, the Small Business Ombudsman,
was the Project Officer. Key authors were: Frank J. Priznar, PRIZM Inc. and Cynthia L. Salisbury,
Potytek Development Corporation. Important guidance was provided by: numerous EPA staff in
headquarters, regions, and lab facilities, notably Howard O. Wilson, OARM/SHEMD, Bob Rose,
EPA/OSBO, and David J. Carver, OSWER. Also providing valuable review and comments were:
Kathryn D. Wagner, Ph.D., Laboratory Safety & Environmental Management; members of the American
Chemical Society's Task Force on Laboratory Waste Management; Clete Lewis, REM, Quest
Diagnostics Inc.; Thomas Shelley, CHO, Cornell University; Barbara J. Weaver, CIH, Lancaster
Laboratories; K. Leigh Leonard, University of Wisconsin System; David Armstrong, Roche Bioscience;
and Ralph Stuart, CIH, University of Vermont. The authors would also like to thank over fifty experts
who responded to PRT7IM Inc.'s request for review by way of the "Safety" and "Lab XL" listservs
hosted by the University of Vermont. Your suggestions and assistance were greatly appreciated.
SUGGESTED IMPROVEMENTS
Although every reasonable effort was made to make this document useful to small laboratories, it is
recognized that improvements are always possible. Also, over time, environmental requirements and
recommendations may change. Comments and suggested improvements on this document are welcome.
Please direct these to:
Office of Small Business Ombudsman
U.S. Environmental Protection Agency
MC2131
401 M Street, SW
Washington, DC 20460
IV
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TABLE OF CONTENTS
1.0 INTRODUCTION . 1
2.0 KEY ENVIRONMENTAL MANAGEMENT ISSUES .~~_ 3
2.1 ENVIRONMENTAL MANAGEMENT SYSTEMS . 3
2.2 AIREMISSIONS _5
2.2.1 Regulatory Considerations 5
2.2.2 Identifying and Quantifying Air Emissions.... 6
2.2.3 Air Emissions Program Checklist 8
2.3 WATER DISCHARGES 9
2.3.1 Regulatory Considerations ~9
2.3.2 Hazardous Waste Mixed with Domestic Sewage 11
2.3.3 Neutralization 11
2.3.4 Spill Containment ..12
2.3.5 Water Discharge Checklist „ 13
2.4 HAZARDOUS AND NON-HAZARDOUS WASTES 14
2.4.1 Regulatory Considerations 14
2.4.2 Mixtures of Chemical Wastes 19
2.4.3 Detennining Generator Status 19
2.4.4 Hazardous Waste Accumulation hi the Laboratory 20
2.4.5 Storage Requirements for Chemicals and Wastes 22
2.4.6 Hazardous Waste Manifests and Related RCRA Provisions 25
2.4.7 Medical and Infectious Wastes 26
2.4.8 Multi-hazardous Wastes 26
2.4.9 Sealed Radioactive Sources 27
2.4.10 General Hazardous Waste Recycling and Disposal Considerations „ 28
2.4.11 Nonhazardous Waste - ,.~28
2.4.12 Hazardous Waste Management Checklist — 29
2.5 POLLUTION PREVENTION AND WASTE MINIMIZATION „ 31
2.5.1 In-Lab Treatment Of Hazardous Waste ~ 33
2.5.2 Pollution Prevention and Waste Minimization Checklist — 34
3.0 ADDITIONAL ENVIRONMENTAL MANAGEMENT ISSUES 35
3.1 HAZARDOUS SUBSTANCE RELEASES ~- 35
3.2 EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW « 36
3.3 PESTICIDES — 36
3.4 DRINKING WATER 36
3.5 TOXIC SUBSTANCES 37
3.6 UNDERGROUND STORAGE TANKS 38
4.0 RELIABLE RESOURCES — 39
4.1 PUBLICATIONS 39
4.2 PRIVATE ORGANIZATIONS 40
4.3 GOVERNMENT RESOURCE CENTERS ~ 40
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4.4 INTERNET SITES 41
4.4.1 Government Agencies 41
4.4.2 Other 41
4.5 HOTLINES 42
4.6 WASTE EXCHANGES 42
4.7 U.S. EPA REGIONAL OFFICES 43
4.8 STATE SMALL BUSINESS ASSISTANCE PROGRAMS 44
VI
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1.0 INTRODUCTION
This document provides information designed to help staff in small labs better understand their
responsibility for good environmental management. Its purpose is to assist in development and
implementation of environmental management programs which meet important Federal regulatory
requirements. It is important to understand that for small lab programs to be fully responsive, the
information provided here must be supplemented by knowledge of state and local regulations. This
guide is designed to be a good starting source.
Environmental management issues associated with small laboratories present a unique challenge. This
challenge stems from the fact that most of today's environmental management requirements are based on
regulations which were designed for relatively simple processes in manufacturing (e.g. printing) and
services (e.g. dry cleaning) entities. Small lab operations, in general, are very different from those in
manufacturing and services as the following table indicates. The uniqueness of small lab operations
means that traditional approaches to environmental management, which may work well with other
operations, need careful consideration, and possibly adjustment, to work well.
WHAT MAKES LABS DIFFERENT?
Factor
Number of Chemicals Used
Quantity of Chemicals Used
Variability in Operations
Staff Education/Knowledge of Chemicals
Centralized Management Control
Manufacturing/Services
Low
High
Low
Mixed
High
Small Laboratories
High
Low
High
High
Mixed
With a focus on environmental management and emphasis on chemicals, it is important to understand
that some critical related areas are not addressed by this document. For example, safety and health
requirements administered by the Occupational Safety and Health Administration (OSHA) are not
addressed nor are requirements for transporting hazardous materials (e.g. samples, supplies), which are
implemented by the U. S. Department of Transportation (DOT). Both are very important to small labs.
Also, neither the hazards of biologically-active nor radioactive materials are fully addressed in this
document. However, Section 4.0 indicates reliable sources of information that should be helpful in these
areas.
For the purpose of this document, a "small laboratory" is one that has no full-time position in
environmental management. In small labs, environmental management is most likely a shared
responsibility or administered by part-time staff or through collateral duty. Given this definition, most
labs probably fall into this "small laboratory" category and will benefit from this document Of course,
many large labs, should benefit from the information contained in this document as well. However,
large labs are likely to have additional environmental management responsibility that is not fully
addressed here. Air emissions management is one example where large labs, especially those involved
in research and development, may have additional responsibility.
Environmental Management Guide fcr SBttO Libs
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Small labs are diverse in their settings and operations. Some small labs are affiliated with a larger
organization, while others are independent operations. Given widespread use of the word "lab" many
types of small labs exist; a few are listed below.
TYPICAL SMALL LAB TYPES
Independent
Contract Research in the Healthcare, Chemical, Natural Resources, Energy, or
Manufacturing Industry
Commercial Testing Labs in the Environmental, Material Science, Healthcare,
Industrial Hygiene, Food, and Engineering Sectors
Affiliated
Teaching and Research Labs in Academia
Hospital Labs
Quality Assurance Labs in Manufacturing
Forensic Labs
Water and Wastewater Plant Labs
Government Research and Testing Labs
Research and Development Labs
All of these small lab types should benefit from the information in this Guide.
The remainder of this document is organized into three additional sections.
• Section 2.0 Key Environmental Management Issues - Presents information on: (1) environmental
management systems; (2) the three most likely areas of environmental management risk, air
emissions, water discharges, and waste management; and (3) pollution prevention.
• Section 3.0 Additional Environmental Management Issues - Presents information on important, but
less common areas needing environmental management improvement in labs.
• Section 4.0 Reliable References - Lists additional information sources on small lab environmental,
health, and safety management.
Environmental Management Guide for Small Labs
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2.0 KEY ENVIRONMENTAL MANAGEMENT ISSUES
The environmental management issues presented in this section are considered "key" because they
either: (1) represent traditional areas with the most environmental management risk for small labs, or:
(2) are perceived to offer the greatest opportunity for improvement. Key environmental risk areas are
those related to air emissions, water discharges, and waste management. Key opportunities for
improvement are in environmental management systems and also in pollution prevention.
2.1 ENVIRONMENTAL MANAGEMENT SYSTEMS
Like any other important business activity in a small lab, environmental issues must be carefully
managed. For example, other management systems occurring in small labs may address quality, finance,
human resources, or safety. The collection of activities undertaken to ensure that environmental issues
are managed is called an environmental management system/tEMS). 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; and
• Integrate environmental objectives into overall business objectives.
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.
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.
The following elements are typically considered evidence of an effective EMS. Much of what is needed
in many small labs may already be in place.
Environmental Management Guide for Small Ltbs
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ELEMENTS OF AN ENVIRONMENTAL MANAGEMENT SYSTEM
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, and local regulations.
Implementation
Establish roles and responsibilities and provide resources.
Provide training to employees on their environmental responsibilities.
Institute processes for communicating both internally and externally
environmental management issues.
Develop written procedures and policies and ensure that documentation is
in place.
Identify potential emergencies and develop procedures for prevention and
response.
Quality Control
Monitor key activities and track performance.
Identify and correct problems.
Keep adequate records of EMS performance.
Conduct periodic environmental management systems 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 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. However, because the EMS
process encourages continual improvement, 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,
which is an advantage because management and staff are motivated to spend time and resources wisely
and an EMS promotes and sustains efficiency.
Environmental Management Guide for Small Labs
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2.2 AIR EMISSIONS
Often, air emissions from small labs are subject to little or no regulation. Still, responsible lab staff
should still take steps to minimize emissions because even small unregulated amounts of pollutants can
be harmful to the environment. The good management practices presented in Section 2.5 should be
helpful for minimizing quantities of air pollutants emitted from small labs.
This section presents information on applicable regulation at the Federal level. It is important to
carefully review both state and local regulations for applicability. Some states have looked closely at
labs as air pollution sources, but many have not.
2.2.1 Regulatory Considerations
Overview
The Clean Air Act Amendments of 1990 established broad-reaching programs dealing with issues such
as auto emission standards, alternative fuels, and stratospheric ozone. But perhaps of greatest potential
concern to laboratories, is in Section 112 addressing hazardous air pollutants (HAPs). Currently, 188
pollutants are listed as hazardous under Section 112 which also directs EPA to designate industry
"source categories." HAP emission standards for many source categories have been developed and more
are being added. Source categories include major industrial types (e.g., pharmaceutical manufacturing,
synthetic organic chemical manufacturing) at which laboratories are often present. Interestingly,
Congress also directed EPA to consider listing "research or laboratory facilities" as its own source
category (CAA 112(c)(7)). EPA has not yet made a listing determination; but listing research or
laboratory facilities as a separate source category would impact only very large stand-alone laboratory
facilities which qualify as "major sources." Major sources are those with the potential-to-emit 10 tons
per year of any single HAP or 25 tons per year of a combination of HAPs.
Although small laboratories are unlikely to meet EPA's definition of major source, they routinely emit
air pollutants from fume hood stacks and vents and are often regulated by state air pollution control
regulations. In some instances, small laboratories may be regulated under a state program because they
are located in facilities with heating/cooling plants or pilot plants that are already regulated under a state
program. Sometimes these operations qualify the entire site as a major source and, therefore, the small
laboratory can be subject to these additional regulations.
Permits
State air pollution control regulations usually mandate that air pollution sources and control devices
require permits to "construct" and permits to "operate." Laboratories may need to obtain permits for air
pollution emissions, but state regulations governing permits for emissions from laboratory fume hoods
vary drastically. Many states clearly exempt laboratory emissions from permitting requirements, while
other states have no special exemption for laboratories. Further, some states have developed special
registration requirements for lab fume hoods. Permits may also be required for air pollutant emissions
from facility heating equipment such as boilers. Permits are typically required for the operation of
boilers with heat input capacities equal to or exceeding 1 million Btu/hour; however, some states require
permits for smaller boilers. Also, sources such as incinerators and paint spray booths, will most likely
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be subject to air permitting requirements. Environmental staff in small labs need to carefully review
their state's permitting requirements to determine if on-site air pollution sources require permits.
Other Potentially Important Air Pollution Control Regulations
In addition to the routine lab and building management operations which may be impacted by air
pollution control regulations, labs may encounter the following non-routine or less common operations
that will trigger air pollution control regulations:
• Demolition, renovation, and removal of asbestos-containing materials (ACMs) in existing structures
on-site may be subject to the National Emission Standards for Hazardous Air Pollutants (NESHAPs).
NESHAPs for asbestos are contained in 40 Code of Federal Regulations (CFR) Part 61, Subpart M,
and in applicable state air pollution control regulations. Note that these requirements may change
over time.
• Industrial facilities (e.g., chemical production plants, metal smelters, and manufacturing operations)
often face stringent air pollution control regulations such as limitations on pollutant emissions,
periodic or continuous emission monitoring, and installation of air pollution control equipment.
Laboratories that are part of a large industrial facility may be subject to these more detailed
requirements and will need to coordinate with the facility environmental, health, and safety staff.
• Pursuant to the Clean Air Act Amendments of 1990 (CAAA), EPA developed regulations that limit
emissions of ozone-depleting chemicals such as chlorofluorocarbons (CFCs) and
hydrochlorofluorocarbons (HCFCs). EPA regulations prohibit venting and require recycling of
CFCs and HCFCs during the servicing, repair and disposal of air conditioning equipment, and
require service personnel to be trained and certified by EPA or an EPA-approved organization.
Owing to the CAAA and the Montreal Protocol, the production of CFCs was banned as of December
31,1995. Some Heating Ventilation and Air Conditioning equipment may have needed to be
upgraded or replaced to comply with phase-out schedules. Certain laboratory uses of CFCs have
been permitted beyond the phase-out deadline since the Montreal Protocol, since EPA has declared
laboratory analytical uses of CFCs to be an "essential use" in certain specific lab analyses.
• In response to the CAAA, EPA has developed regulations that establish requirements to prevent or
respond to accidental releases of extremely hazardous air pollutants. Facilities storing above
threshold quantities of extremely hazardous air pollutants will have to identify the possible hazards
and develop risk management plans. Certain substances deemed extremely hazardous air pollutants
may be present in labs (e.g., ammonia, chlorine, ethylene oxide, and vinyl chloride). However, EPA
generally excludes chemicals stored in labs from the requirements (59 FR 4478, Jan. 31,1994)
because of small quantities stored.
2.2.2 Identifying and Quantifying Air Emissions
Air emissions of chemicals result from routine and non-routine lab operations. Examples of lab
operations that result in air emissions of chemicals include:
• Exhaust from fume hoods, chemical storage cabinets and rooms;
• Breakage, spills, and leaks;
• Bench-top operations; and
• Glassware cleaning and rinsing.
In small labs, chemicals may seem to be everywhere so it is important to have an inventory to understand
6 Environmental Management Guide for Small Labs
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and control their use. Although it may be difficult to maintain, an inventory is also important for
identifying and quantifying potential air emissions.
Accurately quantifying small lab air emissions is very difficult. For example:
• Some non-routine lab processes may have little or no records on chemical usage.
• Chemicals can change phase in the course of laboratory work. A liquid can become a part of a solid
or a solid reactant can become a volatile gas.
• Researchers may purchase and use chemicals that are outside of a centralized management system.
• Chemical volatility varies with temperature and pressure.
However, it is important to estimate maximum emission potential to understand if regulatory thresholds
are likely to be exceeded. One way to estimate maximum air emission potential is based upon a simple
mass balance model such as the one following. This model relies on accounting for all possible uses of
the chemical so that the remainder, that can not be accounted for, is the maximum amount potentially
emitted to the air.
MAXIMUM SMALL LAB AIR EMISSION CALCULATION
For a specific air volatile chemical, fill in quantities known or estimated.
Description
(A) Amount of unused chemical in inventory today.
(B) Amount of same unused chemical in a previous inventory. Note: A long period
of time (i.e. one year) between (A) and (B) may yield more accurate results.
(C ) Subtract (A) from (B). This is the difference in inventory over the time period.
(D ) Amount of chemical purchased and received in the time period covered by the
inventory records used in (A) and (B).
(E) Add (C ) and (D). This is the amount that needs to be accounted for.
(F) Amount of chemical still in use in solutions and mixtures.
(G) Amount of chemical disposed of as waste (all forms).
(H) Amount (non-waste), shipped off-site, or other off premise use.
Subtract (F) through (H) from (E).
This is the maximum amount potentially emitted to the air from the lab over
the period of time between (A) and (B). Compare to regulatory thresholds.
Quantity
A second approach centers upon evaluating a specific lab process instead of the entire lab. This
approach will be easier and more reliable in labs where analyses are routine. For example, suppose a
routine test mass balance calculation repetitively indicates a 10% "loss" of a chemical. "Loss" means
the chemical is not part of the product or the solid waste stream. Thus, it may be assumed to be emitted
to the air. This percentage can then be used to estimate the total mass of chemical potentially emitted by
multiplying the loss per test by the total number of tests.
Although it might seem like an overwhelming task to make a calculation for all chemicals in a lab, this is
probably not necessary. To start, the most air volatile and commonly used chemicals, such as organic
solvents, should be addressed as well as any especially hazardous or stringently regulated chemicals.
Thus, after making calculations for a small subset of chemicals, lab staff should have a good
Environmental MuHgemeM Guide fcr
Ute
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understanding of potential air emissions. Quantifying air emissions is important because it can help: (1)
determine lab status for permitting and regulatory compliance issues; and (2) identify and prioritize
pollution prevention activities.
Air Emissions Program Checklist
The following checklist of actions will help small labs achieve and maintain a good air emissions
program. Completing all of these actions does not necessarily mean all regulatory compliance
requirements have been met. It is important to get updated information from Federal, state, and local
authorities.
SMALL LAB AIR EMISSIONS PROGRAM CHECKLIST
Action
1.
2.
3.
4.
5.
6.
7.
8.
9.
If lab operations result in air emissions make sure they been
identified, measured, and documented.
Determine and record any changes in emission levels since the
last inventory.
Maintain an up-to-date site plan or blueprint showing all existing
sources of ear contaminants.
If the lab emits air contaminants to the outdoor atmosphere
(through stacks, vents, exhausts), make sure that a plan approval,
operating permit, or exemption was obtained and documented if
required.
If an air emission permit is needed:
• Ensure that all of the lab's permits to operate sources of air
emissions are up-to-date, and
• Ensure that there is a system for timely renewal of air
permits and associated fees.
Regularly observe and document emissions from emission points
to determine whether smoke or odors are produced.
If air emission control devices exist, ensure that inspections and
maintenance (e.g., checking for belts) are performed on a regular
basis.
Ensure that chemical (including waste) containers are not left
open on bench-tops or in fume hoods. Containers should be kept
closed to eliminate fugitive emissions and evaporative losses.
Maintain current copies of state and local air emission
regulations.
Notes
\
Environmental Management Guide for Small Labs
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2.3 WATER DISCHARGES
As a convenient way to dispose of chemical lab waste, sink drains can be very tempting. Good
laboratory practices, however, discourage disposal of chemicals in this manner since it may result in fire,
chemical reactions, and corrosion within the plumbing system. In addition, drain disposal of chemicals
may cause pH upsets and other environmental problems at the wastewater treatment plant
Consequently, Federal, state, and local regulations stipulate both acceptable, and prohibited, pollutants
for discharge. This section reviews regulatory requirements, and indicates how laboratory staff can
responsibly manage water discharges.
2.3.1 Regulatory Considerations
Overview
The primary objective of the Clean Water Act, as amended in 1972, is to limit uncontrolled discharge of
pollutants to the nation's navigable waterways. To achieve this objective, EPA introduced several
regulatory programs, many of which are implemented and enforced on a state and local leveL Since
most laboratories probably discharge wastewater to publicly-owned treatment works (POTWs), the first
subsection following addresses this subject. Subsequently, other relevant sections of the Clean Water
Act will be briefly discussed.
Discharges to POTWs
Where laboratories discharge wastewater to a POTW, lab staff must consider Federal, state and local
water pollution control regulations before discharging pollutants down the drain. Regulations governing
wastewater discharges to a POTW are sometimes referred to as "pretreatment standards," meaning mat
some wastes must be treated before being discharged to comply with the standards. The National
Pretreatment Standards, found in 40 CFR Part 403.5 contain standards prohibiting all users from
discharging the pollutants listed here into a sewer system.
• Flammable or explosive pollutants including, but not limited to, waste streams with a closed cap
flash point of <140°F.
• Pollutants which will cause corrosive structural damage to the POTW, but in no case discharges with
pH lower than 5.0, unless the POTW is specifically designed to accommodate such discharges.
• Solid or viscous pollutants that may cause an obstruction of flow in the POTW.
• Pollutants capable of releasing fumes or vapors in sufficient quantities to detrimentally affect the
safety and health of treatment works personnel.
• Pollutants, including oxygen demanding pollutants (high biological oxygen demand), at a
concentration and flow which may cause interference with the POTW.
• Wastewater with sufficient heat to inhibit biological activity in the POTW (must not exceed 104°F at
the POTW).
• Petroleum, oil, non-biodegradable cutting oil, or products of mineral oil origin in amounts that wffl
cause interference or pass through.
Several states have imposed pretreatment standards that are more stringent man the Federal standards.
Additionally, most POTWs have local sewer ordinances which usually set even more stringent
Environmental Mamgema* Guide for Saal Ute
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standards. Local sewer ordinances typically set discharge limits for metals, biological oxygen demand,
and various organic pollutants. Many of these ordinances specify that an increase in the use of water in
order to dilute pollutants to achieve compliance with the above limits is prohibited. Also, local
ordinances often require "industrial users," as defined in the ordinance, to obtain discharge permits from
die local wastewater authority. It is important to become familiar with the standards in state and local
jurisdictions before discharging any substances to the sewer.
If, after careful consideration, small lab management determines that limited drain disposal of
nonhazardous substances is acceptable, the following general guidelines should be followed:
• Use drain disposal only if the drain system flows to a wastewater treatment plant and not into a septic
tank system or a storm water sewer system that flows directly into surface water. Note: Dye tracing
can easily be done on all drains leading out of a laboratory to ensure that discharges affected by
Federal, state, or local regulations go to the appropriate location (e.g., POTW).
• Make sure that the substances being disposed of are compatible with each other and with the piping
system.
• Discharge only those compounds that are soluble in water such as aqueous solutions that are readily
biodegrade and/or of low-toxicity solutions without metals that can make the sludge toxic.
National Pollutant Discharge Elimination System
Laboratories that discharge wastewater to surface water are likely to require a National Pollutant
Discharge Elimination System (NPDES) permit. NPDES programs are usually maintained and enforced
by state water pollution control agencies. Even effluents such as non-contact cooling water are often
subject to NPDES requirements. Laboratories with their own wastewater treatment system that
discharges to a nearby lake or stream would be subject to NPDES requirements.
In the early 1990s, EPA implemented a program requiring NPDES permits for storm water runoff. In
general, offices and the associated parking areas are not included by NPDES storm water requirements.
However, some light industrial activities, such as outside storage of materials, may cause NPDES storm
water runoff requirements to apply. Check with appropriate wastewater authorities to be sure.
Septic System
In most areas, laboratories no longer discharge wastewater to septic systems. Where public sewer
systems are available, septic systems may be prohibited. Laboratory managers in facilities that discharge
wastewater to a septic system, should caution all personnel that any pollutant discharged down the drain
has the potential to contaminate the environment. Facilities discharging to septic systems may be
required to obtain a permit for discharge to ground water.
Reportable Discharges of Oil and Hazardous Substances
Discharges of oil to a navigable waterway that cause a sheen or discoloration of the surface of the water
must be reported to the National Response Center (NEC: 800/424-8802) or the U.S. Coast Guard (40
CFR 110). Navigable waters are defined broadly by EPA and include most lakes, rivers and streams.
Discharges of hazardous substances, as designated hi 40 CFR 116, to navigable waterways must be
reported if they exceed the reportable quantities established in 40 CFR 117. Any person in charge of a
vessel or an onshore facility shall, as soon as he/she has knowledge of any discharge of a designated
hazardous substance, immediately notify the appropriate agency of the discharge.
10 Environmental Management Guide for Small Labs
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Spill Prevention. Control and Countermeasure (SPCC)
In accordance with 40 CFR 112, an SPCC plan is required of facilities storing oil, which due to then-
location, could reasonably be expected to discharge oil in harmful quantities to navigable waters. SPCC
requirements apply to facilities storing more than 42,000 gallons of oil underground, 1320 gallons total
above ground, or any single container above ground exceeding 660 gallons. For example, SPCC
planning activities would likely be triggered for a lab having an outdoor, aboveground beating oil tank
with a capacity of 1,000 gallons.
It is important to remember that many water discharge regulations that affect laboratories are
implemented and enforced at the state and local level; therefore, regulations will vary from state to state
and sometimes by localities within a state. Whether you are connected to a septic system, on-site
wastewater treatment system, or local publicly owned treatment works (POTW) will also determine the
specific regulations that you must follow, so be sure to check with your local wastewater authority.
2.3.2 Hazardous Waste Mixed with Domestic Sewage
In most cases, lab staff should avoid discharging regulated hazardous waste down the drain (see Section
2.4 for the Federal regulatory definition of hazardous waste) even though EPA's hazardous waste
management regulations excludes from the definition of hazardous waste any wastes mixed with
domestic sewage that enters a POTW (40 CFR 261.4(a)(l)). Generally, any laboratory mat discharges
down the drain more than 15 kg of hazardous waste per month (40 CFR 403.12(p)(2)), or acutely
hazardous waste in any amount, is required to notify the EPA Regional Office, the state hazardous waste
authorities, and the POTW of such discharges. (Check with local authorities first) Notification usually
must include the following information.
• Name of the hazardous constituents contained in the wastes.
• Estimates of the masses and concentrations of constituents in the waste-stream discharges during that
calendar month.
• Estimate of the masses of such constituents which may be expected to be discharged during the
following twelve month period.
Although it may be allowed, discharging limited amounts of hazardous waste with domestic sewage may
not always be an environmentally sound choice.
Lab staff should never allow hazardous waste discharges to drains leading to septic tanks or storm
sewers.
2.3.3 Neutralization
In most states, it is acceptable to neutralize acid and caustic solutions and then dispose the neutralized
solution down the drain if there are no other hazardous characteristics. Check with state and local
authorities first however. Where it is permissible, it is important that only elementary neutralization is
occurring and that it is under a Resource Conservation and Recovery Act (RCRA) exemption for
hazardous waste treatment without a permit. Non-exempted treatment, without a RCRA permit, is a
serious RCRA violation. A neutralized solution should have a final pH value between 6 and 9 (check
11
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with your local POTW to make sure this pH range meets their requirements). Although many labs are
equipped with neutralization tanks, problems can result from their usage. For example, a limestone chip
bed is commonly used as a passive in-line acid neutralization system. In theory, these systems should
work but they often do not in practice because: (1) they are flow dependent; and (2) system maintenance
(e.g., cleaning) is often neglected. Also, limestone, though an aid for neutralizing acid discharges, is not
helpful in neutralizing caustic discharges. In general, it is not wise to rely on an in-line system until its
effectiveness has been proven and can be monitored.
23.4 Spill Containment
A discussion of water discharge would not be complete without mentioning spill containment. The
need for spill protection applies to all areas where materials can be potentially damaging to the POTW or
enter storm water systems. The following are some suggestions to prevent spills from entering drains.
• Floor drains should be eliminated from new construction. Where floor drains presently exist, they
should be covered with properly fitting drain covers. Note that a lack of floor drains may make it
more difficult to test emergency showers.
• Fume hood cup sinks should be guarded or closed off. If the sink does not need to be used, then it
should be sealed off. If the sink must remain in service, it can be protected from spills by installing a
perimeter guard ring. A simple cup sink guard can be made by encircling it with a line of non-
reactive caulk.
• Have spill kits available where required (e.g., by SPCC plans) or where spills are likely to enter
drains. Make sure appropriate spill kits are available. For example, there are special kits for acids,
caustics, organics, and mercury. They are not interchangable.
12 Environmental Management Guide for Small Labs
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2.3.5 Water Discharge Checklist
The following checklist of actions will help small labs achieve and maintain a good water discharge
program. Completing all of these actions does not necessarily mean all regulatory compliance
requirements have been met. It is important to get updated information from Federal, state, and local
regulators.
SMALL LAB WATER DISCHARGE PROGRAM CHECKLIST
Action
To evaluate or improve the lab water discharge program,
ensure that:
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
The discharge meets with general pretreatment prohibitions for:
• Fire or explosion hazards.
• Corrosivity.
• Viscous obstructions which could plug sewer.
• Sludge discharges.
• Heat sufficient to inhibit biological activities (> 104°F).
The POTW is aware of the discharge.
The lab has a sewer use discharge permit or letter of
acknowledgment from the POTW.
The lab has a copy of the POTW's sewer use discharge
requirements.
There a system in place to routinely monitor the discharge to the
POTW.
If samples are taken:
• They are handled by a certified sampling/analytical lab.
• Proper sample containers, preservation techniques, holding
times, and quality control are used.
• There is a designated employee responsible for making sure
that sampling is performed according to permit requirements.
• Sampling results are reviewed and compared with permit
requirements. Ensure that deviations noted and investigated.
• Reports are maintained on site for three years.
All laboratory personnel have been trained to understand the types
of pollutants prohibited from discharge to the POTW.
Direct discharges to surface water are permitted.
Discharges to on-site waste disposal systems are permitted.
Copies of state and local water pollution regulations are available.
Notes
Note: Actions 1-7 are for discharges to POTWs.
13
Environmental Mmgenaft Grife for Stott Lite
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2.4 HAZARDOUS AND NON-HAZARDOUS WASTES
Managing the generation and disposal of hazardous and nonhazardous wastes is one of the most difficult
environmental management challenges for staff in small labs. Common issues to address include
classification, storage, labeling, treatment, and disposal of laboratory wastes as well as identifying
opportunities to minimize the generation of wastes. This section will review these areas and indicate
some practical ways to help manage waste. Only the Federal requirements, which set forth minimum
requirements, are outlined here. It is important to check with relevant state and local authorities to find
out if there are any stricter regulations or requirements which apply. Often there are.
2.4.1 Regulatory Considerations
Overview
The Resource Conservation and Recovery Act (RCRA), enacted in 1976, was written to provide "cradle
to grave" tracking of hazardous waste. Pursuant to RCRA, EPA developed hazardous waste
management regulations applicable to generators and treatment, storage and disposal facilities (TSDFs).
In 1984, Congress expanded the scope of RCRA with passage of the Hazardous and Solid Waste
Amendments (HSWA). HSWA allowed EPA to pass regulations governing small quantity hazardous
waste generators (SQGS; those generating <1,000 kg hazardous waste/month). Therefore, HSWA had a
substantial impact on small labs. Through RCRA and HSWA, EPA developed regulatory programs for
hazardous waste and nonhazardous waste.
Most laboratories routinely generate hazardous waste and, therefore, are subject to RCRA hazardous
waste management regulations (40 CFR Parts 260 to 270). As hazardous waste generators, laboratories
are subject to requirements governing waste classification and, depending on quantities generated, waste
accumulation, disposal, recordkeeping, and emergency preparedness.
State Delegation
EPA has delegated authority to implement and enforce hazardous waste management programs to states
with regulations that are at least as stringent as EPA's hazardous waste regulations. Still, it is important
to keep up with the EPA regulations since EPA regularly publishes new hazardous waste management
regulations that are enforceable in the states even though they may not yet be included in a given state's
hazardous waste regulations.
Hazardous Waste Defined
EPA defines hazardous waste in 40 CFR 261. In order for a waste to be hazardous waste it must meet
the EPA definition of "solid waste," since hazardous waste is considered a subset of solid waste. The
term "solid waste" is used very broadly in RCRA and refers to both nonhazardous and hazardous waste
including not only solids, but also liquids, semi-solids, sludges, and compressed gases. A solid waste
determination depends on the type of material and how it will be recycled or disposed of. Therefore,
chemicals from a laboratory may or may not be a solid waste, depending on their final disposition.
Certain solid wastes are considered hazardous wastes since they may cause an increase in mortality or
illness or pose substantial hazard to human health or the environment when improperly managed. A
waste is considered hazardous if it is: (1) listed on one of the lists of hazardous wastes; or (2) it exhibits
14 Environmental Management Guide for Small Labs
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one or more of the four hazardous characteristics. Listed and characteristic hazardous wastes are
identified using codes consisting of one letter followed by three digits. For listed wastes, the first letter
in the code corresponds to the list designation (e.g., F-List, P-List, U-List, K-List). The first letter in the
codes of characteristic wastes is D. Generators must identify their wastes with all applicable codes;
therefore, it is common for several codes to be associated with a single waste container.
To determine if a waste is a regulated hazardous waste, generators can use either knowledge or testing
(40 CFR 262.11). Wastes such as expired chemical stocks will not require testing to determine if they
are hazardous waste; rather, knowledge of the chemicals' origins and characteristics can be applied in the
determination. (Note: Material Safety Data Sheets (MSDSs) can be useful for this purpose).
Listed Wastes
There are four lists of hazardous wastes. To determine if a waste is listed, one must have knowledge of
the waste's origin. The lists are described briefly below, but complete copies of the hazardous waste lists
are included in 40 CFR 261.
• F-List [40 CFR 261.311 - The F-list (F001-F039), frequently referred to as the non-specific
source list, contains spent solvents, electroplating wastes, wastes related to the production or
treatment of chlorinated hydrocarbons, wood preserving wastes, and certain landfill leachates.
Spent solvents on the F-list are designated by the codes F001, F002, F003, F004 and F005. The
F001 code only applies to certain chlorinated solvents used hi degreasing operations. Spent
solvents represented by the codes F002 through F005 are presented alphabetically in a table on
the next page. Often, laboratories generate F-listed spent solvents. For example, in an organic
prep lab, listed solvents such as methylene chloride and carbon disulfide are used in the
extraction processes: methylene chloride wastes (e.g., waste extracts) are denoted by the code
F002, and carbon disulfide wastes are denoted by the code F005. Note that mere is a special
"ignitability" provision for some of these wastes. This provision states that if a F-listed waste
was originally listed for ignitability (solely), and that waste is no longer ignitable, then the waste
is no longer a listed hazardous waste.
• K-List T40 CFR 261.321 - The K-list, frequently referred to as the specific source list, contains
solid hazardous wastes from certain industries including, but not limited to, chemical
manufacturing, ink formulating, petroleum refineries and metal smelting. Laboratories may
generate K-listed waste if they accept waste samples from a K-listed industrial process.
• P-List T40 CFR 261.33(eYI - The P-list applies to unused, discarded, commercial chemical
products with a sole-active ingredient on the P-list. In laboratories, the P-list is often assigned to
expired chemicals or unused chemicals that are thought to be contaminated. For example, a
container of carbon disulfide, that for some reason is thought to be contaminated, would be
disposed of as P022 waste. The P-list can also be applied to discarded chemical solutions that
were made hi the laboratory in lieu of purchasing a commercial product For example, excess
(e.g., unused) Aldrin standard that was prepared in the laboratory (e.g., in methanol) would be
disposed of as P004 waste if Aldrin was the sole-active ingredient (methanol is not "active" in
this case). The P-list is not applied to waste standards with several active ingredients (&£., a
mixed pesticide standard), but only to waste standards with a sole-active ingredient P-listed
wastes are acutely hazardous wastes. To avoid generation of unnecessary quantities of P-listed
waste, all P-listed waste should be segregated from other hazardous waste.
is
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F-LISTED SOLVENTS
Solvent
Acetone
Benzene
n-Butyl Alcohol
Carbon Disulfide
Carbon Tetrachloride
Chlorobenzene
Chlorinated Fluorocarbons
Cresols
Cresylic Acid
Cyclohexanone
2-Ethoxyethanol
Ethyl Acetate
Ethyl Benzene
Ethyl Ether
Isobutanol
Methanol
Methylene Chloride
Methyl Ethyl Ketone
Methyl Isobutyl Ketone
Nitrobenzene
2-Nitropropane
ortho-Dichlorobenzene
Pyridine
Tetrachloroethylene
1,1,1 -Trichloroethane
1,1,2-Trichloroethane
Trichloroethylene
1 , 1 ,2-Trichloro- 1 ,2,2-Trifluoroethane
Trichlorofluoromethane
Toluene
Xylene
F-Code
F003
F005
F003
F005
F001
F002
F001
F004
F004
F003
F005
F003
F003
F003
F005
F003
F002
F005
F003
F004
F005
F002
F005
F002
F002
F002
F002 J
F002
F002
F005
F003
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Environmental Management Guide for Small Labs
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• U-List [40 CFR 261.33(f)1 - The U-list applies to unused, discarded, commercial chemical
products that contain a sole-active ingredient that appears on the U-list In laboratories, the U-4ist
is often assigned to expired chemicals or unused chemicals that are thought to be contaminated.
For example, a container of methylene chloride, that for some reason is thought to be
contaminated, would be disposed of as U080 waste. [Note: Actually dichloromethane, not its
synonym methylene chloride appears on the U-list. When reviewing the P- and U-lists, one most
carefully check for synonyms.] Unlike the P-list, which have been identified as acute hazardous
wastes, the U-listed wastes have been identified as toxic wastes.
• State Listed Wastes - State hazardous waste regulators often add wastes, such as waste oils and
polychlorinated biphenyls, to their state lists of hazardous wastes.
Characteristic Wastes
There are four hazardous waste characteristics: ignitability, corrosivity, reactivity and toxicity.
Generators may use testing or knowledge to determine if their waste exhibits one or more of the
characteristics. Below are key descriptors of each characteristic. Actual definitions can be found in the
CFR at the citations given.
• Ignitability F40 CFR 261.211 - Ignitable wastes, denoted by the code DOO1, are generally liquids
with flash points below 60°C (140°F). Non-chlorinated solvent wastes are usually ignitable
wastes. (Note: These solvent wastes may also be F-listed.) A non-liquid is considered ignitable
if it is capable of causing fire through friction, absorption of moisture, or spontaneous chemical
changes, and burns in a manner that creates a hazard.
• Corrosivitv [40 CFR 261.221 - Corrosive wastes, denoted by the code D002, are generally
aqueous solutions with a pH 2 < or > 12.5.
• Reactivity [40 CFR 261.231 - Reactive wastes, denoted by the code D003, are those wastes that
are generally unstable, explosive, capable of detonation when heated under confinement, or react
violently with water. Also, wastes are reactive if they generate toxic cyanide or sulfide fumes
when subjected to pH between 2 and 12.5.
• Toxicitv T40 CFR 261.241 - Toxic wastes, denoted by the codes D004 through D043, are certain
wastes containing the regulated constituents shown in the table on the next page. To determine if
wastes are toxic, they are subjected to the toxicity characteristic leaching procedure (TCLP). ft
should be noted that some states now require other metals to be analyzed under TCLP. As
indicated throughout this document, you must check with your state agency to see if mere are any
additional requirements. TCLP identifies wastes that are likely to leach hazardous concentrations
of regulated constituents in simulated landfill conditions. Wastes leaching contaminants above
the regulated concentrations exhibit the toxicity characteristic and must be assigned the
appropriate EPA hazardous waste code. Liquid wastes (e.g., containing less man 0.5% filterable
solids) exhibit the toxicity characteristic if the waste itself contains contaminants above me
regulated levels (the TCLP does not need to be performed).
17
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EPA TOXICITY CHARACTERISTIC CONSTITUENTS
EPA ID Number
D004
D005
D018
D006
D019
D020
D021
D022
D007
D023
D024
D025
D026
D016
D027
D028
D029
D030
D012
D031
D032
D033
D034
D008
D013
D009
0014
D035
D036
D037
D038
D010
D011
D039
D015
D040
D041
D042
D017
D043
Regulated Constituent
Arsenic
Barium
Benzene
Cadmium
Carbon tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
o-Cresol
m-Crsol
p-Cresol
Cresol (total)
2,4-D
1 ,4-Dichlorobenzene
1 ,2-Dichloroethane
1,1-Dichloroethylene
2,4-DinitrotoIuene
Endrin
Heptachlor (and its epoxide)
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-TP (Silvex)
Vinyl chloride
Regulatory Level (mg/1)
5.0
100.0
0.5
1.0
0.5
0.03
100.0
6.0
5.0
200.0
200.0
200.0
200.0
10.0
7.5
0.5
0.7
0.13
0.02
0.008
0.13
0.5
3.0
5.0
0.4
0.2
10.0
200.0
2.0
100.0
5.0
1.0
5.0
0.7
0.5
0.5
400.0
2.0
1.0
0.2
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Environmental Management Guide for Small Labs
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Exclusions
Certain substances are excluded from the regulatory definitions of solid and hazardous wastes. For
example, household waste (no matter how hazardous) is excluded from the regulatory definition of
hazardous waste. Three exclusions that are particularly important to many laboratories are highlighted
below:
• Wastewater - Under the Federal RCRA regulations, mixtures of untreated sanitary waste and
other (i.e. hazardous) waste discharged to a publicly-owned treatment works (POTW) are
excluded from the definition of solid waste and, therefore, not regulated hazardous waste (40
CFR Part 261.4(a)). This exemption also applies to on-site waste water treatment systems
with an NPDES permit. The discharges are subject to stringent water pollution control
requirements instead of hazardous waste requirements (see Section 2.3.2).
• Samples - Samples that are sent to the laboratory for analyses are not considered regulated
waste while awaiting testing, while stored after testing for a specific purpose, or while being
transported back to the sample collector (40 CFR 261.4(d)). For example, samples are not yet
waste if QC of analytical results has not been completed and re-testing may be necessary.
Once a sample is no longer being held for a specific purpose, then it must be managed as
waste, and hazardous waste if appropriate (e.g., if it is listed or displays a characteristic).
• Empty Containers - Empty containers that once held hazardous materials are not regulated as
hazardous waste if they meet the definition of "empty." A container is empty if all waste has
been removed (e.g., by pouring or pumping) and less than one inch of residue remains on me
bottom of container. Containers that held acutely hazardous waste are considered empty only
after being triple rinsed with a solvent capable of removing the acutely hazardous waste
residue. The solvent rinsate then must be managed as acutely hazardous waste.
2.4.2 Mixtures of Chemical Wastes
It is not uncommon for laboratories to generate waste streams that contain several chemicals mixed
together. If this is the case, there are additional rules that affect treatment, storage, and disposal
practices. It is important to understand that a mixture of a hazardous waste and a nonhazardous waste is
hazardous if the mixture exhibits the above noted characteristics and/or if the hazardous waste
component is a listed hazardous waste. Dilution is not allowed as treatment.
2.4.3 Determining Generator Status
If lab wastes are found on any of the hazardous waste lists or exhibit any of the characteristics mentioned
previously, the waste is considered hazardous and must be stored, treated or otherwise managed in
accordance with the requirements specified in RCRA. Once wastes are determined to be hazardous, it is
necessary to quantify the amount of hazardous waste generated per month.
Hazardous waste generators are subject to varying requirements depending on how much hazardous
waste they generate monthly. Under the Federal rules, there are three classes of generators: large
quantity generators (LQGs), small quantity generators (SQGs), and conditionally-exempt small quantity
generators (CESQGs). Often, states define generator status differently and set more stringent
19 Environmental Management Guide for Small Labs
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requirements, especially upon SQGs and CESQGs. Therefore, it is imperative that lab staff understand
state generator requirements.
SQGs and LQGs must obtain EPA generator identification numbers. Hazardous waste must be labeled,
stored, and disposed of in accordance with state hazardous waste regulations. Organizations generating
less than 100 kilograms of hazardous waste per month are CESQGs and are subject to very minimal
regulation (in most states).
The table on the next page presents an overview of generator status requirements mat apply to
laboratories depending upon their generator status.
2.4.4 Hazardous Waste Accumulation in the Laboratory
Storage requirements for hazardous waste are specified under Federal (RCRA) and state requirements.
At a minimum, lab staff should be aware of the following Federal regulations. The quantity and type of
waste generated will determine what specific requirements need to be followed. Hazardous waste
accumulating in laboratories are usually considered to be in "satellite accumulation areas" and are
subject to minimal regulatory requirements (262.34(c)). Satellite accumulation areas must be at or near
the process that generates the waste and under the control of the operator of that process. Generators
may accumulate up to 55 gallons of hazardous waste, or 1 quart of acutely hazardous waste, at a satellite
accumulation area. If the waste is moved to a nearby room, then it is not considered in satellite
accumulation and is subject to more stringent requirements. Waste in satellite accumulation areas must
be managed as discussed below:
• All hazardous waste containers in the laboratory must be kept closed during storage except when it is
necessary to add or remove waste. Evaporation of wastes in fume hoods is prohibited.
• Federal satellite area rules only require labels listing the container's contents, but many states require
that the contents, the hazard and the actual words, "Hazardous Waste," be on the container. Prudent
practice would be to mark all hazardous waste containers in the laboratory with the words
"Hazardous Waste" and other words that identify the containers' contents (e.g., "waste hexane with
trace pesticide contamination").
• Hazardous waste must be stored in containers that are in good condition and are compatible with the
wastes they contain.
20 BiUiiiHMH|fn|gf Management fiiiutr- fhr Small 1 atn
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RCRA REQUIREMENTS FOR LABS AS A FUNCTION OF GENERATOR STATUS*
Requirement (40CFR)
Waste Determination
(262.11)
Generation Rate Limits
(261. 5 and 262.34)
Accumulation Quantity Limit w/o
Permit
(261.5 and 262.34)
Accumulation Time
(261.S and 262.34)
EPA ID Number
(262.12)
Mark Containers with Start Date
(262.34)
Mark Containers "Hazardous Waste"
(262.34(a))
Air Emission Standards 40 CFR 26S
SubpartCC
Satellite Accumulation
(26234(c))
Use Manifests
(262,SubpartB)
Exception Reporting (262.42)
Biennial Report (262.41)
Contingency Plan (265, Subpart D)
RCRA Personnel Training (262.34
and 265.16)
Storage Requirements (without
permit) (262.34 tad 265)
Recordkeeping Requirements
(262.40)
Waste "Designated Facility"
Land Disposal Restrictions
(268.7)
CESQG»»
Applicable
< 100 kg/mo
not to exceed 1 ,000 kg at any time
not to exceed 1 kg acute at any time
No limit
Not required***; possible state
requirement
Not applicable
Not applicable
Not applicable
Not applicable
Not required***; possible state
requirement
Not required
Not required
Not required, but OSHA (29 CFR
1910.38) requires emergency
planning
Not required, but recommended
None, but OSHA regulations under
29 CFR 1910, Sobpaits H and N.
apply, particularly 29 CFR 1910.106
Waste determinations and generation
log required (notification of regulated
waste activity, training records,
manifests, and land disposal
restriction notifications
recommended)
state-approved or RCRA permitted
facility or legitimate recycler
Possible state requirement
SQG
Applicable
100-1,000 kg/mo
not to exceed 6,000 kg at any time
180 days, or 270 if waste is to be
transported over 200 miles.
Required
Applicable
Applicable
Not applicable
Applicable
Required
Required after 45 days
Not required; possible state
requirement
Basic planning required in
accordance with the standards in
262.34(dX4) and (5) and 265,
Subpart C as well as OSHA
regulations
Basic training required by
262.34(dX5Xui)
Compliance with technical standards
in Part 265, Subparts I and J; for
containers and tanks is required by
262.34(dX2) and (3) and OSHA
regulations
Notification of regulated waste
activity, waste determinations,
generation log, manifests, land
disposal restriction notifications,
exception reports, and
correspondence with local emergency
responders (written contingency plan,
weekly container inspection &
periodic equipment maintenance logs,
and RCRA training records
recommended)
RCRA-permitted facility or legitimate
recycler
Applicable
LOG
Applicable
1,000 kg/mo or greater
No limit
90 days
Required
Applicable
Applicable
Applicable
Applicable
Required
Required after 35 days
Required
Full written plan in accordance with
265 Subpart D, is required by
262.34(a)(4) and OSHA regulations
Full compliance with the training
requirements in 265.16 is required by
262.34(a)(4)
Compliance with technical standards
in Part 265, Subparts I, J, W, and
DD, is required by 262.34(a)(l) and
OSHA regulations
Notification of regulated waste
activity, waste determinations,
generation log, manifests, land
disposal restriction notifications,
exception reports, biennial reports,
correspondence with local emergency
responders, RCRA training records,
and written contingency plan required
(weekly container inspection is
required & periodic equipment
maintenance logs is recommended)
RCRA-permitted facility or legitimate
recycler
Applicable
* From Laboratory Safety A Environmental Management,Vo\. 5, No. 6.
** As of January 1.1998, landfills accepting CESQG waste must be in compliance with portions of 40 CFR Part 258.
*** Although these hems are not legally required under RCRA, most transporters and TSDFs will not handle hazardous waste without them.
21
Environmental Management Guide for Small Labs
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• Up to 55 gallons of hazardous waste, or 1 quart of acutely hazardous waste, may be stored at each
satellite accumulation area. Note: Although EPA regulations allow up to 55 gallons of hazardous
waste to be stored at each satellite accumulation area, this is often not a safe practice. Also,
standards such as those specified by the National Fire Protection Association (e.g., NFPA 45) limit
the quantities of flammable materials that can be stored in one laboratory room. Therefore, lab staff
should limit the quantity of hazardous waste permitted to be stored hi each room to a more
reasonable quantity (e.g., five gallons).
Once hazardous waste leaves the satellite accumulation areas and enters a different location, referred to
herein as a central accumulation area, additional regulations take effect.
Hazardous Waste in a Designated Accumulation Area
Once hazardous waste leaves the satellite accumulation areas and enters a different location, referred to
herein as an accumulation area, it is subject to more stringent management standards.
When waste leaves the satellite accumulation area, "the clock starts." From this date, a laboratory must
ship the waste off-site to a permitted hazardous waste treatment, storage or disposal facility (TSDF)
within 90,180, or 270 days depending on its generator status and distance from the TSDF. If waste is
not sent off-site within the required time frame, then the laboratory is subject to fines and in some cases
very cumbersome and costly RCRA storage permit requirements.
All waste containers entering an accumulation area must be clearly marked with the date they entered the
area. All containers must be clearly marked "Hazardous Waste."
The following emergency equipment must be maintained at the accumulation area and periodically
tested to ensure it is in working order:
• A communications device or alarm system capable of informing facility personnel and local
emergency response authorities in the event of an emergency;
• A portable fire extinguisher, spill control equipment, and decontamination equipment; and
• Water at adequate volume and pressure to supply water hose streams, or foam producing
equipment, or automatic sprinklers.
Waste containers must be arranged in the accumulation area so that there is adequate aisle space to allow
for the flow of emergency personnel and equipment. Incompatible wastes must be separated to the
extent possible using distance, benns, or containment pans. The area must be inspected weekly for all
waste containers hi the shed for leaks and deterioration on a weekly basis.
2.4.5 Storage Requirements for Chemicals and Wastes
Laboratory staff should ensure that both hazardous wastes and stock chemicals are stored properly in
order to prevent spills and uncontrolled reactions. Chemicals should be segregated according to
chemical classes. For example, acids should be kept separate from bases, oxidizers from organics, and
cyanides from acids. The table on the next page provides additional examples of segregation principles
for various chemical classes.
22 Environmental Management Guide for Small Labs
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PARTIAL LIST OF INCOMPATIBLE CHEMICALS (REACTIVE HAZARDS)*
Substances in the left hand column should be stored and handled so that they cannot accidentally contact corresponding
substances in the right hand column.
Acetic acid
Acetic anhydride
Acetone
Acetylene
Alkali and alkaline earth metals, such as
sodium, potassium, lithium, magnesium,
calcium, powdcced aluminum
Ammonia (anhydrous)
Ammonium nitrate
Aniline
Bromine
Calcium oxide
Carbon, activated
Chlorates
Chromic acid and chromium trioxide
Chlorine
Chlorine dioxide
Copper
Fluorine
Hydrazine
Hydrocarbons (benzene, butane,
propane, gasoline, turpentine, etc.)
Hydrocyanic acid
Hydrofluoric acid (anhydrous)
Hydrogen fluoride
Hydrogen peroxide
Hydrogen sulfide
Iodine
Mercury
Nitric acid (concentrated)
Nitroparaffins
Oxalic acid
Oxygen
Perchloric acid
Peroxides, organic
Phosphorus (white)
Phosphorus pentoxide
Potassium chlorate
Potassium permanganate
Silver and silver salts
Sodium
Sodium rutnte
Sodium peroxide
Sulfaricacid
Chromic acid, nitric acid, peroxides, permanganates
Hydroxyl-containing compounds such as ethylene glycol, perchloric acid
Concentrated nitric and snUuric acid mixtures, hydrogen peroxide
Chlorine, bromine, copper, silver, fluorine, mercury
Carbon dioxide, carbon tetrachloride, other chlorinated hydrocarbons (also prohibit the use of water, roam, and dry dy™*"'
extinguishers on fires involving these materials— dry sand should be employed)
Mercury, chlorine, calcium hypochlorite, iodine, bromine, hydrogen fluoride
Acids, metal powders, flammable liquids, chlorates, nitrites, sulfur, finery divided organics, combustibles
Nitric acid, hydrogen peroxide
Ammonia, acetylene, butadiene, butane, other petroleum gases, sodium carbide, turpentine, benzene, finely divided meals
Water
Calcium hypochlorite, other oxidants
Ammonium salts, acids, metal powders, sulfur, finely divided organics, combustibles
Acetic acid, naphthalene, camphor, glycerol, turpentine, benzene, finely divided metals
Ammonia, acetylene, butadiene, butane, other petroleum gases, hydrogen, sodium carbide, turpentine, benzene, finely divided meaJs
Ammonia, methane, phosphine, hydrogen sulfide
Acetylene, hydrogen peroxide
Isolate from everything
Hydrogen peroxide, nitric acid, and other oxidant
Fluorine, chlorine, bromine, chromic acid, peroxides
Nitric acid, alkalis
Ammonia (aqueous or anhydrous)
Copper, chromium, iron, most metals or their salts, any flammable liquid, combustible matmah, aniline, mttomrmmir
Fuming nitric acid, oxidizing gases
Acetylene, ammonia (anhydrous or aqueous)
Acetylene, tulminic acid, ammonia
Acetic acid, acetone, alcohol, aniline, chromic acid, hydrocyanic aci
nitratable substances
Inorganic bases, amines
Silver and mercury and their salts
Oils, grease, hydrogen, flammable liquids, solids, gases
Acetic anhydride, bismuth and its alloys, alcohol, paper, wood, grease, oils (an organics)
Acids (organic or mineral), also avoid friction, store cold)
Air, oxygen
Alcohols, strong bases, water
Acids (see also chlorates)
Glycerol, ethylene glycol, benzaldehyde, sulfuric acid
Acetylene, oxalic acid, tartaric acid, fulminic acid, * ammonium compounds
See alkali metals (above)
AtiMnp*mnn mtrstc BDQ other m n iiipnmtt% suits
Any oxidizable substance, such as ethanol, methanol, glacial acetic
ethylene glycol, ethyl acetate, methyl acetate, furfural
Chlorates, perchlorates, permanganates
* From Prudent Practices in the Laboratory, Handling and Disposal of Chemicals, National Academy Press, 199S.
23
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Laboratories that use highly reactive chemicals should take measures to ensure that these substances are
handled properly. Due to the volatile and explosive nature of this class of chemicals, it warrants special
attention. The following guidelines should be followed when using and storing highly reactive
substances:
• Consider the storage requirements of each highly reactive chemical prior to purchase and make sure
that staff are trained to store it safely.
• Obtain and review the Material Safety Data Sheet or other chemical safety information to ensure that
staff are aware of the hazards and storage requirements.
• Purchase small quantities of the chemical that staff will need for the short term. Try not to exceed a
three month supply.
• Label, date, and inventory all highly reactive materials as soon as they are received. If staff must
transfer the chemical from its original container into another container, make sure it is labeled with
the name of the chemical, and the words DANGER! HIGHLY REACTIVE MATERIAL. Note:
OSHA may require special labels disclosing all hazards on repackaged containers.
• Do not open a container of highly reactive material that is past its expiration date.
• Do not open a liquid organic peroxide or peroxide former (e.g., picric acid) if crystals or a precipitate
are present
• Segregate the following highly reactive materials:
— Oxidizing agents from reducing agents and combustibles.
— Powerful reducing agents from readily reducible substrates.
— Acids from reducing agents.
• Store highly reactive liquids in trays large enough to hold the contents of the bottles.
• Store peroxidizable materials away from heat and light.
• Do not use metal spatulas to handle peroxides because contamination by metals can lead to explosive
decomposition. Use ceramic, Teflon®, or wooden spatulas.
• Avoid friction, grinding, and all forms of impact near peroxides, especially solid peroxides and
diazomethane solution (used in methylation of some pesticides). Glass containers that have screw-
cap lids or glass stoppers should not be used. Instead, use polyethylene bottles with screw-cap lids.
• Store materials that react vigorously with water away from possible contact with water.
• Store thermally unstable materials in a refrigerator. Use a refrigerator with these safety features:
— Alarm to warn when temperature is too high.
— Spark-proof controls on the outside.
— Magnetic, locked door.
• Store liquid organic peroxides at the lowest possible temperature consistent with the solubility or
freezing point Liquid peroxides are particularly sensitive during phase changes.
• Inspect and test peroxide-forming chemicals periodically.
• Store containers in cabinets that are designed to hold that type of waste.
24 Environmental Management Guide for Small Labs
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2.4.6 Hazardous Waste Manifests and Related RCRA Provisions
Hazardous Waste Manifests
In accordance with 40 CFR 262, all hazardous waste shipments being sent off-site to be managed at a
TSDF must be accompanied by hazardous waste manifests. Wastes may only be manifested to
appropriate designated facilities, such as permitted TSDF or a recycler. Often, manifests are completed
by a hazardous waste contractor. However, laboratory personnel must review the manifest to ensure it is
completed accurately and sign the manifest certifying that it is accurate. The designated TSDF must sign
the manifest and send a copy to the laboratory within 30 to 45 days (depending upon your generator
status) of the waste shipment. If a signed copy is not received by the laboratory within the appropriate
time frame, the laboratory is subject to exception reporting requirements in 40 CFR 262.42. Note: As of
August 12,1997, labs in campus settings (i.e. labs in multiple buildings located on contiguous properties
divided by roads) the Military Munitions Rule (62 FR 6621) exempted some RCRA manifest
requirements. Specifically, to allow generators to consolidate waste in a central accumulation area, EPA
now allows transportation of hazardous waste on public or private right-of-ways, or along the border of
contiguous properties under the control of the same person without a manifest
Land Disposal Restriction (LDR) Notices
EPA regulations require that nearly all hazardous waste be treated prior to land disposal (40 CFR 268).
Hazardous waste generators are required to notify the receiving TSDF when they ship land disposal
restricted wastes. LDR notices accompany the hazardous waste manifest and include the generator's
identification number, the appropriate treatment standards, and the accompanying manifest number.
Training
Lab staff should be trained annually in hazardous waste management and emergency procedures relevant
to their positions. Other staff may need to be trained in proper building evacuation procedures in me
event of an emergency. The training must teach personnel to perform their duties in a way mat ensures
compliance with hazardous waste management regulations. Obviously, since hazardous waste
management responsibilities differ for various staff, so do training requirements. RCRA training
regulations also require that hazardous waste generators maintain written job titles and descriptions for
all employees with positions relating to hazardous waste management. Lab staff who pack hazardous
waste for transport or prepare and/or sign manifests must be trained in accordance with DOT regulations.
Also, OSHA's Lab Standard (29 CFR 1900.1450) requires a plan, including training, addressing lab staff
who work with chemical hazards. Oddly, though, not all labs (e.g., QA labs in manufacturing) are
included.
Reporting and Record-keeping
Generators must file EPA Form 8700-12 (Notification of Hazardous Waste Activity) with their state
hazardous waste agency to obtain an EPA identification number. Generators should retain a copy of mis
form. In addition, generators must also retain weekly inspection logs for the accumulation area, data
relating to hazardous waste determination, training records, job descriptions, hazardous waste manifests,
and LDR notices. Many laboratories (especially SQGs and LQGs) are subject to annual reporting
requirements imposed by their state hazardous waste agency.
25
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2.4.7 Medical and Infectious Wastes
In addition to generating chemical waste, laboratories that perform biological and medical research may
also generate medical and infectious waste. Although there are no Federal EPA requirements for the
management and disposal of medical waste (other than regulations for medical waste incinerators and
chemical treatment systems) most states do define and regulate this waste stream. Medical waste is
generally defined as any solid waste generated in the diagnosis, treatment, immunization of human
beings or animals, in related research, or in the production or testing of "biologicals" including cultures
and stocks, human blood and blood products, human pathological wastes, sharps, animal waste, and
wastes from isolated patients.
It is important to consult with the state office of environmental management to obtain the current
requirements in the lab location. Additionally, it is important to understand that other Federal agencies
such as DOT, OSHA, and the Nuclear Regulatory Commission (NRC) have regulations that address
various aspects of medical waste management. Information on how to contact these agencies for more
information are in Section 4.0.
Proper management ensures that infectious waste is handled in accordance with established procedures
from the time of generation through treatment of the waste. The following elements of an infectious
waste management program should be in place to reduce exposure to employees and the public:
• Segregate infectious waste from the general trash.
• Use the universal biological hazard symbol on infectious waste containers.
• Select the packaging material that is appropriate for the type of waste handled:
— Plastic bags for solid or semisolid infectious waste.
— Puncture resistant containers for sharps.
— Bottles, flasks, or tanks for liquids.
• Use packaging that maintains its integrity during storage and transportation.
• Do not compact infectious waste or packaged infectious waste before treatment.
• Minimize storage time.
• Select the most appropriate treatment option for your waste. Consider steam sterilization,
incineration, thermal inactivation, and chemical disinfection. Note that in most cases, it is acceptable
to discharge blood and blood products to the sanitary sewer, but check first with your local POTW.
• Contact state and local authorities to identify approved treatment disposal options.
An effective infectious waste program not only protects workers and the environment, it can also lead to
cost savings from waste reduction or prevention.
2A.S Multi-hazardous Wastes
Laboratories may generate waste streams that contain a combination of chemical, biological, or
radioactive substances. Multi-hazardous wastes are defined as those that contain both chemical and
biological hazardous substances, while "mixed wastes" will contain radioactive, chemical, and/or
biological hazardous substances. Any waste-stream that presents more than one type of hazard requires
special management consideration because the selected treatment technology appropriate for one type of
26 Environmental Management Guide for Small Labs
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waste may not be appropriate for the other types. Some examples of laboratory mixed wastes include:
• Used flammable (e.g., toluene) liquid scintillation cocktails.
• Phenol-chloroform mixtures from extraction of radiolabeled nucleic acids.
• Aqueous solutions containing chloroform and radioactive material typically found in solutions
generated by the neutralization of radioactive trichloracetic acid solutions.
• Certain gel electrophoresis waste (e.g., methanol or acetic acid containing radionuclides).
• Lead contaminated with radioactivity.
To minimize the generation of multi-hazardous waste streams, consider the following points:
• Use pollution prevention strategies to reduce multi-hazardous waste to a waste mat presents a single
hazard. By taking measures to limit the types of hazard in a specific waste-stream the waste may be
managed by standards methods only for that category.
• When possible select a single management option. Some waste management methods are
appropriate for more than one waste hazard. For example low-level radioactive animal tissue
(radioactive-biological waste) can often be incinerated on-site in compliance with NRC regulations,
which may be a satisfactory disposal option for both the radioactive and the biological characteristics
of the waste. Some multi-hazardous waste can be disposed of safely in the sanitary sewer when
allowed by the local POTW (see Section 2.4).
The problems presented by managing mixed wastes can be reduced by applying waste minimization
techniques such as:
• Substitution of nonignitable liquid scintillation fluid (LSF) for toluene-based LSF to reduce a
chemical-radioactive waste to a radioactive waste.
• Substitution of shorter half-life radionuclides such as Pfor Pand I for I to shorten the
hazard period.
• Use of 2.5 mL scintillation vials (minivials) instead of 10 mL vials to reduce waste scintillation fluid.
• Elimination of the methanol/acetic acid and radioactive mixed hazards in gel electrophoresis work by
skipping the gel fixing step if it is not required.
• Prevention of radioactive contamination of lead by lining lead containers with disposable plastic or
by using alternative shielding materials.
2.4.9 Sealed Radioactive Sources
Sealed radioactive sources are commonly used in measuring devices and other laboratory
instrumentation. For example, gas chromatographs use 63 Nickel and static eliminators use 21° Polonium.
Leakage and proper disposal are infrequent, but major concerns associated with radioactive sealed
sources. Leak tests are required for beta and gamma sources emitting 100 microcuries or greater and for
alpha sources that emit 10 microcuries or greater. Leak tests should be conducted every six months.
This can be accomplished by wiping the source with a filter paper or a medical swab and men sending it
to a certified testing lab. Consideration should also be given to the proper disposal method for
radioactive sealed sources. When taking the equipment out of service, it is advisable to follow the
manufacturers instructions. Generally, manufacturers advise returning the equipment to mem and they
hi turn, will dispose of the radioactive source. The manufacturer should be your first contact to learn
about handling, shipping and disposal options prior to shipment.
27 EnvirowK^MaiagcflKiK Gufcfe tor Saal Labs
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2.4.10 General Hazardous Waste Recycling and Disposal Considerations
Once specific waste streams and quantities have been determined, it is important to decide on the best
recycling or disposal method for that waste. Reputable hazardous waste transporters or hazardous waste
management facilities can provide advice on the options that are most cost-effective and
environmentally preferred to specific situations. Note, however, that it is always the generator's
responsibility to understand and be in compliance with the regulations. Typical disposal options for
chemical wastes include incineration for toxic materials, and landfill for nonhazardous materials.
Hazardous waste transporters can also assist labs meet DOT shipping and RCRA transportation
requirements and help prepare hazardous waste manifest forms.
Because laboratory wastes typically include a diverse array of chemicals in small quantities, they present
special disposal concerns. In general, chemicals can either be consolidated into bulk waste streams that
meet specific characteristics or "lab-packed." The term "lab-pack" describes the most common method
for packaging small quantities of laboratory waste. Small containers of compatible waste materials are
placed intact into a larger packaging unit, usually a steel or fiber drum that contains an absorbent
material, such as vermiculite, to cushion the containers and absorb spilled or leaked waste. An inventory
is made as the containers are added to the drum. The drum is then sealed and a copy of the inventory
sheet is attached to the drum. The drum is then shipped off-site for disposal accompanied by a
Hazardous Waste Manifest.
There are advantages and disadvantages to lab-packing. This packaging method eliminates the need to
transfer wastes and also reduces the occurrence of dangerous reactions resulting from mixing
incompatible materials. However, this method is often the most expensive. The decision to consolidate
or lab-pack should be made by those who are knowledgeable about the makeup of each waste stream and
in consultation with the selected hazardous waste contractor. Note that only individuals who have
successfully completed DOT "Hazmat" training can prepare lab-packs.
2.4.11 Nonhazardous Waste
In addition to hazardous waste, RCRA regulates nonhazardous waste, sometimes simply referred to as
solid waste. Solid waste disposal facilities typically must be permitted by a state agency and must meet
certain design and operating requirements. Most laboratory facilities arrange to have solid waste hauled
to a permitted waste disposal facility (e.g., landfill or incinerator). On-site landfills or incinerators are
stringently regulated by state agencies governing waste management and, in the case of incinerators, air
pollution control.
Many state and local regulations include requirements for segregating and recycling certain materials
(e.g., glass, newspapers, aluminum). Laboratory managers should ensure that personnel comply with
local recycling codes.
28 Environmental Management Guide for Small Labs
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2.4.12 Hazardous Waste Management Checklist
The following checklist of actions will help small labs achieve and maintain a good hazardous waste
management program. Completing all of these actions does not necessarily mean all regulatory
compliance requirements have been met. It is important to get updated and more complete information
from Federal, state and local authorities.
HAZARDOUS WASTE MANAGEMENT PROGRAM CHECKLIST
Action
If it has been determined that the lab generates hazardous waste, ensure that:
Notes
Hazardous Waste Identification
1. Waste has been properly characterized to determine that (1) it is hazardous
waste and (2) proper EPA identification code numbers have been assigned.
Generator Status
2. The facility has a system to determine generation rate and quantity of
hazardous waste accumulated on-site and uses this data to ascertain generator
status
3. If required (e.g., SQG or LQG), the facility has an EPA identification number.
*? ^ . -. . Satellite. Accumulation
4. Each satellite accumulation area (SAA) is at or near the point of waste
generation for each waste and is under the control of the operator of the
process that generated the waste.
5. Waste containers are labeled "Hazardous Waste" and/or with words to
indicate their contents.
6. Waste containers are kept closed and are in good condition.
7. Wastes are compatible with containers.
8. Wastes in any given SAA do not exceed 55 gallons of hazardous waste or one
quart of acutely hazardous waste.
Central Accumulation Area
9. Every hazardous waste container is marked "Hazardous Waste" and with its
accumulation start date.
10. Waste is stored <90 days for LQGs and <1 80 days for SQGs, or 270 days if
transported more than 200 miles.
11. Incompatible wastes and/or materials are separated or protected by physical
means (wall, cabinet).
12. Internal communications equipment is available (e.g., two-way radio,
telephone).
13. Floor drains are covered to prevent a spill from entering a drain.
14. Fire extinguishers and a water supply are available.
15. Decontamination equipment is available (emergency shower, eyewash).
16. Aisle spaces are unobstructed.
17. Containers are inspected for leakage and/or corrosion at least weekly and
inspections are recorded.
18. The storage area provides secondary containment.
19. Personal safety equipment is available and usable.
20. Ignitable and reactive wastes are handled and stored in a manner to prevent
fires and/or explosives.
21. Containers are arranged on shelving so that the heavy containers are on the
lower shelves and smaller containers on higher shelves.
29
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22. Shelving supporting hazardous wastes is in good condition and sturdy enough
to support the load.
; HazarBoBi Waste Disposal
23. Any hazardous waste treated or disposed on-site (e.g., neutralized and/or
discharged down the drain) is done so in accordance with all applicable
regulations.
24. Any hazardous waste leaving the site is sent to an appropriately permitted
TSDF.
25. The hazardous waste transporter/broker is licensed, insured and reputable.
26. Employees responsible for shipping hazardous waste have been trained in
accordance with DOT regulations.
- :• ;Recordkeepmg and Reporting
21. The following records are retained on-site for at least three years:
• Manifests
• Waste analyses results
• Inspection records
• Training records
• Land disposal restrictions notifications
29. Hazardous waste manifests, signed by the transporter and designated TSDF,
have been received by the facility within the appropriate time period (e.g., 35
days for LQG and 60 days for SQG).
, . Emergency Preparedness
29. An emergency coordinator who is familiar with response procedures at the
facility has been designated and is on site or on call at all times.
30. Emergency phone numbers (Fire Department, Police Department and Local
Hospital) have been posted.
3 1 . The Fire Department is aware of the types and quantities of hazardous
materials stored in the facility.
32. For LQGs, a written contingency program has been developed and distributed.
33. Spill cleanup materials and equipment (e.g., absorbents, neutralizes, and
personal protective equipment) are available.
•••.'•.,-.'•/.. . _ . _
-Management System
34. Copies of current Federal, state and local hazardous waste management
regulations are available.
35. An individual has been designated to manage hazardous waste at the facility
(e.g., tracking, accumulation, disposal, minimization and recordkeeping).
36. A formal training program (e.g., waste management, emergency response) is in
place.
31. A system to track the quantities of chemicals and hazardous wastes on-site is
in place.
38. The laboratory has investigated and, where feasible, implemented pollution
prevention opportunities.
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2.5 POLLUTION PREVENTION AND WASTE MINIMIZATION
Pollution prevention 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. Pollution prevention
applies not only to the management of all types of waste, but also to the management of releases to air,
water, and land. Some common pollution prevention practices include equipment or process
modifications, reformulation, substitution with less toxic materials, and inventory control procedures.
EPA has developed a hierarchy for waste management alternatives which lists source reduction as the
preferred option, followed by on-site and off-site recycling, treatment, and land disposal.
Implementing a comprehensive pollution prevention 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, and it also may reduce potential environmental liabilities and help
protect the environment.
Laboratories 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 in which processes
can change. This section presents proven pollution prevention opportunities applicable to laboratory
operations. The information contained in this section is not exhaustive, but serves as a resource to help
lab staff begin or expand a pollution prevention program.
There are various methods you can employ to minimize the generation of hazardous wastes. To be
effective, a pollution prevention 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 laboratory and 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 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
i
Pollution prevention and waste minimization opportunities in use at labs are listed below.
• Establish a centralized purchasing program to ensure full utilization of chemical products,
• Order reagent chemicals only in amounts needed.
• Maintain a limited inventory of chemicals on hand so that chemicals do not expire or deteriorate and
necessitate disposal.
31 EoviroomeotalMuiageaat Guid
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• Only mix what is needed.
• Rotate chemical stock.
• Develop a running inventory of unused chemicals for use by other departments.
• Reduce or eliminate the use of highly toxic chemicals in laboratory experiments.
• Centralize the waste management function to better track waste generation rates and management
costs.
• Establish waste minimization goals.
• Educate staff on the benefits of waste minimization.
• Perform routine self-audits and pollution prevention opportunity assessments.
• Scale down experiments/procedures by using smaller labware and chemical quantities.
• Increase use of instrumentation that requires less reagents or smaller or fewer samples.
• Include hi the experiment plan the reaction work-up-steps that deactivate hazardous materials or
reduce toxicity.
• Treat or destroy hazardous waste products as the last step in experiments. Be careful, a RCRA
permit may be needed.
• Complete reactions to eliminate hazardous waste.
• Reuse/recycle spent solvents.
• Recover metal from catalyst.
• Use procedures to recover metallic mercury. Note that except for physical separations, most mercury
procedures are not safe at lab scale and won't work well in small batches.
• Recover silver from silver chloride residue waste.
• Investigate silver recovery or recycling with an outside vendor for photo processing wastes.
• Investigate mercury recovery and recycling with outside vendor.
• Keep individual hazardous waste streams segregated: segregate hazardous from nonhazardous,
segregate recyclable waste from non-recyclable waste.
• Assure that the identity of all chemicals and wastes is clearly marked on all containers.
• Use less solvent to rinse equipment. For example, rinse several times with small volumes of solvent,
rather than using only one or two rinses with larger volumes.
• Use citrus based solvents instead of xylene.
• Use biodegradable aqueous or detergent cleaners instead of chemical cleaners.
• Substitute red liquid thermometers for mercury thermometers where possible.
• Use biodegradable scintillation cocktail.
• Seek alternatives to phenol extractions.
• Review the use of highly toxic, carcinogenic, reactive, or mutagenic materials to determine if safer
alternatives are feasible.
• Review procedures periodically to determine if quantities of chemicals and/or chemical waste could
be reduced.
• Develop experiments in teaching labs that can use the same waste containers from week to week or
that use less and fewer chemicals while still relaying concepts to the class.
• When preparing a new protocol, consider the lands and amounts of waste products and see how they
can be reduced or eliminated.
• Examine your waste/excess chemicals to determine if there are other uses within your organization
before discarding.
• Consider using computer simulation/modeling to replace wet chemistry.
32 Environmental Management Guide for Small Labs
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• Use solid phase extractions instead of column chromatography.
• When solvent is used for cleaning purposes, use spent solvent for initial cleaning and fresh solvent
for final cleaning.
• When cleaning substrates or other materials by dipping, process multiple items in one day.
• Store and reuse developer in photo labs.
• Polymerize epoxy waste to a safe solid.
• Consider using solid-phase extractions for organics.
• Reuse hexane (or other solvent) after rotary evaporation.
• Keep containers closed except when in use.
2.5.1 In-Lab Treatment Of Hazardous Waste
Although not pollution prevention or waste minimization, there are many benefits to undertaking
appropriate waste treatment techniques in the lab. Generators of hazardous wastes may treat their wastes
on-site provided they treat in tanks and containers, and they are not conducting thermal treatment. If it is
acceptable to incorporate treatment steps, suitable options for waste minimization (e.g., In-lab treatment)
should be considered when planning experiments. Often steps can be added at the end of the experiment
or procedure to eliminate hazardous byproducts and wastes. Some typical examples include oxidizing
organic chemicals with sodium hypochlorite to produce nonhazardous waste, using phase separation of
organics from aqueous solutions and liquids from solids. Other in-lab treatment methods include
precipitation of toxic metals, oxidation of inorganic cyanides and sulfides, and treatment of organic
peroxides and hydro-peroxides. Ideally, every laboratory procedure should be reviewed to determine
whether acceptable waste treatment steps should be developed and included. Some specific
recommendations include:
• Destroy ethidium bromide using NaNOi and hydrophosphorus acid.
• Treat sulfur and phosphorus wastes with bleach before disposal.
• Treat organolithium waste with water or ethanol.
• Consider including detoxification and/or waste neutralization steps in lab experiments.
33 EnviroomenolManigeiaatGtttie for SteB Lite
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2^5.2 Pollution Prevention and Waste Minimization Checklist
There are many opportunities for preventing pollution and minimizing waste in small labs. Acting on
these usually results in cost savings. The following short list is designed to help a small lab begin or
expand a pollution prevention and waste minimization program.
POLLUTION PREVENTION AND WASTE MINIMIZATION CHECKLIST
Action
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Offer unused chemicals to other departments or organizations
before disposing as a hazardous waste.
Contact suppliers to determine if they will accept unused
materials (e.g., compressed gases).
Mix compatible wastes together to reduce costs associated with
shipping multiple containers. (Note: Its imperative to be certain
the wastes are compatible. If unsure, don't do it.)
Scale down experiments or production batches by using smaller
sized labware and quantities of chemicals.
Consider reaction work-up steps that deactivate hazardous
materials for each procedure.
Reduce the amount of solvent needed to rinse equipment.
Use terpene or citrus based cleaners to replace organic solvents
like acetones.
Reuse or recycle spent solvents when feasible, before disposing.
Identify less hazardous chemicals identified as substitutes for
hazardous chemicals.
Substitute red liquid thermometers for mercury ones.
Develop and implement a laboratory pollution prevention
program.
Notes
Note: On May 28,1993, EPA published its Interim Guidance to Hazardous Waste Generators on the
Elements of a Waste Minimization Program (58 FR 31114). In this guidance, EPA stated that an
effective waste minimization program should include each of the general elements: top
management support; characterization of waste generation; periodic waste minimization
assessments; cost allocation system; technology transfer; and program evaluation. Also, EPA
emphasized the need for each generator to have a written waste minimization plan.
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3.0 ADDITIONAL ENVIRONMENTAL MANAGEMENT ISSUES
The following section describe areas of environmental management responsibility mat are important, but
do not affect all small laboratories. Information is provided to make lab staff aware of these issues. If
relevant, additional information should be sought from the references listed in the next chapter.
3.1 HAZARDOUS SUBSTANCE RELEASES
In 1980, Congress passed the Comprehensive Environmental Response, Compensation and Liability Act
(CERCLA) in response to the growing concern about releases of hazardous substances to the
environment. CERCLA was intended to provide for response to, and cleanup of, environmental
problems not adequately addressed by other environmental statutes. Under CERCLA, provisions were
made to establish a trust fund to finance environmental cleanups — this resulted in CERCLA's nickname
"Superfund."
CERCLA has been amended over ten times since its passage hi 1980. Two important amendments are
the Superfund Amendments and Reauthorization Act (SARA) of 1986 (see next section), and the
Pollution Prevention Act of 1990.
Past Disposal Areas
The primary purpose of CERCLA is to provide for liability, compensation, cleanup, and emergency
response for hazardous substances released to the environment. If lab personnel discover or have
knowledge of an area that may be contaminated with hazardous substances (e.g., an abandoned landfill),
they should consult with environmental professionals prior to disturbing the area. Such areas may
require historical investigation and environmental sampling and analyses.
Releases of Hazardous Substances
EPA has designated hazardous substances and established reportable quantities (RQs) for releases (40
CFR 302) of these substances. The regulation mandates notification of a National Response Center
(NRC) for releases of hazardous substances in quantities exceeding the associated RQ. It is unlikely that
RQs of hazardous substances will be present at most small laboratories. However, lab managers should
be familiar with the substances and RQs listed in 40 CFR 302 to make then* own determination. If
hazardous substances are present on-site in quantities exceeding the RQs, then lab staff should be
prepared to make the required notifications in the event of a regulated release.
Pollution Prevention
In 1990, Congress passed the Pollution Prevention Act as an amendment to CERCLA. The act sets a
priority for preventing pollution at the source over recycling, treatment, or disposal of waste. Since
1990, EPA has examined its regulations to ensure that they encourage pollution prevention. Many states
have developed regulations requiring businesses to establish pollution prevention programs. Pollution
prevention can be achieved by substituting nonhazardous products for hazardous products, improving
operating practices to reduce the quantity of hazardous substances consumed, and educating employees
as to the benefits of pollution prevention.
35
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EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW
The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 is actually Title m of
the Superfund Amendments and Reauthorization Act (SARA) which was mentioned previously (Section
3.1). EPCRA allows individuals access to information regarding chemicals used and emitted in their
communities. Laboratories storing hazardous substances above regulatory thresholds are required to
participate in the local emergency planning process.
Emergency Planning and Notification
In 40 CFR 355, EPA codified a list of extremely hazardous substances and associated threshold planning
quantities (TPQs). Labs storing extremely hazardous substances in amounts exceeding the TPQs must
notify state and local emergency response authorities and participate in the community's emergency
planning process. Lab management should review and compare inventories of chemicals on site with
EPA's list extremely hazardous substances to determine if these substances are present in amounts
exceeding the TPQs.
Inventory and Material Safety Data Sheet (MSDS) Reporting
EPCRA establishes reporting requirements that provide the public with important information on
hazardous chemicals hi their community (40 CFR 370). Specifically, laboratories storing chemicals may
be required to submit material safety data sheets (MSDSs) and inventories of the chemicals on site to the
state and local emergency response authorities (e.g., the local fire department). Submissions are only
required for hazardous substances present in amounts exceeding 10,000 pounds and extremely hazardous
substances present in amounts exceeding their TPQs or 500 pounds (whichever is less).
33 PESTICIDES
The Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) was originally enacted in 1948, then
amended substantially hi 1972 and amended again in 1988 and 1996. The aim of the statute is primarily
to safeguard public health and the environment against misuse of pesticides. Before being sold,
distributed, transported, used or stored hi the U.S., pesticides must be registered by EPA. Laboratories
may be subject to FIFRA regulations if storing, applying, or disposing of pesticides. Pesticides used and
stored on-site must be managed in accordance with label directions (40 CFR 162). Pesticide storage
areas should be well-ventilated, secure, and away from food and beverages (40 CFR 165). Pesticides
and pesticide containers should be disposed of in accordance with 40 CFR 165 and, if appropriate,
hazardous waste regulations. Finally, laboratories testing pesticides in support of the registration process
are subject to FEFRA Good Laboratory Practice Standards (40 CFR 160). Additionally, chemicals being
used to treat medical waste must be registered under FIFRA if they make any antimicrobial claims.
3A DRINKING WATER
The Safe Drinking Water Act, as amended, establishes national drinking water standards applicable to
public drinking water systems. Generally the standards apply to municipalities operating a public
drinking water system. However, a laboratory with an on-site drinking water system (e.g., on-site wells)
that has 15 or more service connections and supplies water to an average of at least 25 people daily, at
36 Environmental Management Guide for Small Labs
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least 60 days per year is operating a "public water system" as defined by EPA. Laboratories operating a
public water system face stringent sampling and analyses requirements specified in 40 GFR 141 and
their state regulations.
3.5 TOXIC SUBSTANCES
Under the Toxic Substances Control Act (TSCA) of 1976 (40 CFR 720.36), EPA is given broad
authority to issue regulations designed to gather health/safety and exposure data on, require testing of,
and control exposure(s) and/or use(s) of, new and existing industrial chemical substances and mixtures.
(Drugs, cosmetics, foods and food additives, pesticides and nuclear medicine are exempt from TSCA
coverage and are subject to control under other Federal statutes). All laboratories, including "small"
laboratories, must adhere to the TSCA Good Laboratory Practice Standards (TSCA GLPS) found at 40
CFR 792 when performing studies relating to health effects, environmental effects and chemical fate
testing issued under Section 4 of TSCA.
Using its authority provided under TSCA, EPA has implemented stringent requirements pertaining to
polychlorinated biphenyls (PCBs). In laboratories, PCBs can often be found in samples, microscopy
fluids, standards, electrical equipment (e.g., transformers, ballasts), or hydraulic systems. PCB-
containing equipment and materials must be labeled, stored and disposed of in accordance with EPA's
PCB management requirements in 40 CFR 761. Although PCB-contaming ballasts (such as those found
in fluorescent lights) may still be in service, most PCB transformers were to have been removed from
service or retrofilled with a non-PCB oil by October 1991. Facilities with more than 45 kg (99.4 Ib.) of
PCB containing materials (not just waste) on site, at any time during the calendar year, must prepare an
"annual document" as described in 40 CFR 761.180.
Wastes containing PCBs are regulated by the EPA in 40 CFR Part 761. Many laboratories generate PCB
wastes including liquid and solid excess samples, solvents containing PCBs (e.g., extracts) and
standards. Wastes containing 50 ppm PCBs are regulated under TSCA. However, EPA interprets me 50
ppm to apply to the "starting concentration" of the PCB material if any dilution took place. Therefore, if
a 10 ppm PCB solution is prepared from a 1000 ppm standard >50 ppm, then upon disposal me 10 ppm
solution must be managed as if it contains over 50 ppin PCBs. Obviously, this interpretation further
confuses the management of PCB laboratory wastes. It is important to segregate PCB waste from other
lab wastes since management of PCB wastes is complex and disposal of PCB regulated waste is
especially costly.
In many states, the management of PCB laboratory wastes is especially complex since they are often
subject to both EPA's TSCA regulations and state hazardous waste regulations. PCB wastes are not
regulated as a hazardous waste under the Federal RCRA regulations. PCB waste generators must be
sure to comply with the following PCB management requirements:
• Generators of PCB waste must submit a "Notification of PCB Activity," EPA Form 7710-53, to
EPA's Office of Toxic Substances (40 CFR 761.205).
• PCB waste containers and entrances to PCB waste storage areas must be marked with a PCB
warning label (40 CFR 761.40).
• PCB waste containers must be marked with the date the waste was first generated [40 CFR
761.65(c)(8)]. PCB waste containers hi the laboratory must be marked with the date the first drop of
37 Bnviroomei^MuiagaaeniGtade for Sanl Lite
-------
waste enters the container. [Note: If the waste is also hazardous waste, this date will probably differ
from the hazardous waste accumulation start date.]
• PCB waste containers must be inspected for leaks every 30 days [40 CFR 761.65(c)(5)]; even if the
containers are stored in the laboratory. The inspections should be documented in a log book.
• PCB wastes must be placed in special containers as required by 40 CFR 761.65(c)(6).
• PCB wastes must be stored in an area with a roof, walls and an impervious floor with six-inch
curbing and a containment capacity equal to twice the volume of the largest PCB container or 25%
of the total volume of all the PCB containers, whichever is greater [40 CFR 761.65(b)].
PCB waste must be incinerated within one year from the date the waste was generated [40 CFR
761.65(a)]. To be sure the disposal facility has adequate time to incinerate wastes, all PCB wastes
should be shipped off-site within nine months of generation. PCB waste shipments must be
accompanied by a waste manifest.
There are also TSCA regulations applicable to laboratory analysis of asbestos. Regulations applicable to
asbestos sampling and analysis are 40 CFR 763, Subparts E and G (Subpart E, 783.87(a)(b); 763.90(i),
Appendix A, Appendix E; Subpart G, 763.121(f), Appendix A.) TSCA also specifies requirements
applicable to the importation of chemicals.
3.6 UNDERGROUND STORAGE TANKS
Underground storage tanks (USTs) are stringently regulated by state environmental agencies and
sometimes also by local fire departments. State and local UST regulations are often more stringent than
EPA's regulations which are contained in 40 CFR 280. State and local authorities must be aware of the
presence of USTs on site. USTs were required to have leak detection devices no later than December
1993 and corrosion protection and spill/overfill prevention are required to be operable by December
1998. Newly installed USTs are required to be equipped with corrosion protection, automatic release
detection, and overfill prevention devices. Most USTs must be leak tested annually and product in the
tanks must be inventoried regularly. In some areas, where both storage of heating oil in UST's and use
is in the same location, exemption from regulation may apply. Regardless, USTs that contain heating oil
should be leak tested regularly since they are just as likely to cause environmental impairment as
regulated USTs.
Presently, above ground storage tanks (ASTs) are only regulated by EPA under the Clean Water Act if
they have the potential to release oil to navigable water ways. Many state environmental agencies and
local fire departments have developed regulations applicable to nearly all ASTs.
38 Environmental Management Guide for Small Labs
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4.0 RELIABLE RESOURCES
Of the numerous sources of information on environmental management, the following list provides
information most relevant to small lab environmental programs. Included are reference materials,
organizations, world wide web (www) site addresses, toll-free hotlines, waste exchanges, governmental
resource centers, EPA Regional Offices, and state Small Business Assistance Programs. In addition, lab
staff should consult with the relevant state and/or local agencies for specific questions regarding air
emissions and hazardous waste management, and contact the local POTW for information regarding
wastewater discharge issues.
4.1 PUBLICATIONS
Topic
Comprehensive Lab EHS
Coverage
Environmental Management
Systems
Source
Chemical Safety
Pollution Prevention
Laboratory Safety & Environmental Management (LS&EM). A
newsletter published by PRIZIM Inc. covering the full spectrum of
lab environmental, health, and safety issues. 316 E. Diamond Avenue,
Gaithersburg, MD 20877.
Environmental Management Systems: An Implementation Guide
for Small and Medium- Sized Organizations. EPA 832-B-96-007,
November 1996.
Environmental Management in Healthcare Facilities. K.G.
Wagner, Ph.D. (ed). W.B. Saunders Co. 1998.
Prudent Practices in the Lab: Handling and Disposal of
Chemicals. National Research Council, National Academy Press,
Washington, DC. 1995.
Chemical Health & Safety. A journal published by the American
Chemical Society, Washington, DC 20036.
Chemical Safety in the Laboratory. Stephen K. Hall, CRC Press,
Inc. 1994.
Pollution Prevention and Waste Minimization in Laboratories. P.
A. Reinhardt, K. Leigh Leonard, and P. C. Ashbrook, CRC Press, Inc.
1996.
Facility Pollution Prevention Guide. EPA/RREL Publication
EPA/600/92/088. May 1992.
EPA Guide to Pollution Prevention - Research and Educational
Institutions. EPA/RREL Publication, EPA/625/7-90/010. June
1990.
39
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Safety • Handbook of Laboratory Safety. K. A. Furr, Ph.D. (Ed.). CRC
Press. 1996.
• Laboratory Waste Management - A Guidebook. American
Chemical Society, Washington, DC. 1994.
Waste Management • Hazardous Laboratory Chemicals Disposal Guide. M. Armour,
2^ Edition, CRC Press, Inc; 1996.
• Destruction of Hazardous Chemicals in the Laboratory. G. Lunn,
and E. B Sansone, John Wiley & Sons. 1992.
• Step-by-Step Guide to Better Laboratory Management Practices.
Publication No. 97-431, Washington State Department of Ecology,
Hazardous Waste and Toxics Reduction Program. July 1997.
Department of Ecology, Publications Distribution Center, P.O. Box
47600, Olympia, WA 98504-7600).
• RCRA Orientation Manual. EPA 530-R-98-004.
4.2 PRIVATE ORGANIZATIONS
American Chemical Society, 1155 16th Street, NW, Washington, DC 20036. 202-872-4600.
Offers journals, training, and information on lab waste management and chemical health and safety.
American Institute for Pollution Prevention, 1616 P Street, Suite 100, Washington, DC 20036.
202-797-6567.
American Institute of Chemical Engineers' Center for Chemical Process Safety, 345 East 47th Street,
New York, NY 10017. 292-705-7319.
National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02269. 617-770-3000.
Develops and offers standards on flammable chemical storage in labs.
PRIZIM Inc. sponsors national and regional meetings and training titled, "Laboratory Safety &
Environmental Management (LS&EM)," publishes the LS&EM newsletter, and offers environmental,
health, and safety management consulting services for laboratories. 316 E. Diamond Avenue, Suite 201,
Gaithersburg, MD 20877. 301-840-9316.
43 GOVERNMENT RESOURCE CENTERS
U.S. EPA Small Business Ombudsman Clearinghouse/Hotline, 401 M Street, SW, Washington, DC
20460. 1-800-368-5888.
Helps private citizens and small businesses with questions on all program aspects within EPA.
EPA National Center for Environmental Publications and Information. 1-800-490-9198.
Provides access and information about EPA publications.
40 Environmental Management Guide for Small Labs
-------
U.S. Department of Health and Human Services, Public Health Service, Centers for Disease Control and
Prevention, National Institute for Occupational Health and Safety (NIOSH). NIOSH 1-800-356-4674.
Provides information about occupational safety and health issues.
U.S. Environmental Protection Agency (U.S. EPA) Clean Air Technology Center (CATC), U.S. EPA,
Research Triangle Park, NC 27711. 919-541-0800. World Wide Web (www) Home Page:
http://www.epa.gov/ttn/catc.
Serves as a resource on all areas of emerging and existing air pollution prevention and control
technologies.
U.S. EPA Pollution Prevention Information Clearinghouse, 401 M Street, SW, Washington, DC 20460.
202-260-1023. E-mail: PPIC@epamail.epa.gov.
Provides a library and electronic bulletin board dedicated to information on pollution prevention.
U.S. Nuclear Regulatory Commission, One White Flint North, 11555 Rockville Pike, Rockville, MD
20852-2738. 301-415-7000. http://www.nrc.gov/
4.4 INTERNET SITES
4.4.1 Government Agencies
U.S. Environmental Protection Agency: http://www.epa.gov. Also see http://www.epa.gov/ttm/nelac
for information on environmental lab business opportunities.
U.S. Environmental Protection Agency Small Business Ombudsman: http://www.epa.gov/sbo/. Also see
the Small Business Environmental Home Page: http://www.smallbiz-enviroweb.org/
U. S. Department of Labor, Occupational Health and Safety Administration (OSHA): http://www.osha-
slc.gov
U. S. Department of Health and Human Services, Public Health Service, Centers for Disease Control
and Prevention (CDC), National Institute for Occupational Safety and Health (NIOSH):
http://www.cdc.gov/niosh/homepage.html
4.4.2 Other
These listservs can be helpful for solving unique problems. All have lab oriented participants.
• SAFETY list. A general discussion of environmental, health, and safety. Contact Ralph Stuart at the
University of Vermont (email: rstuart@esf.uvm.edu) for information on how to subscribe,
• LAB-XL. A discussion of performance oriented environmental regulation of laboratories. Contact
Ralph Stuart at the University of Vermont (email: rstuart@esf.uvm.edu) for information on how to
subscribe.
41 Envirotunenttl Managonent &»te fee SanB ljrt>s
-------
The National Association of Chemical Hygiene Officers (NACHO) list. Participants discuss all
aspects of laboratory chemical hygiene. Contact Dr. Jim Kaufman at the Laboratory Safety
Workshop (email: Labsafe@aol.com) for information on how to subscribe.
HOTLINES
EPA Small Business Ombudsman Hotline: 1-800-368-5888
Provides environmental management assistance information to small businesses, including labs.
EPA RCRA Hotline: 1-800-424-9346; (703) 412-9810
Provides information related to hazardous waste regulations and Resource Conservation and Recovery
Act (RCRA), Superfund-related matters.
TSCA Hotline: 202-554-1404
Provides information concerning the Toxic Substances Control Act (TSCA)-related regulations and
policies.
CHEMTREC: 1-800-262-8200
The Chemical Transportation Emergency Center provides technical information related to chemical
exposure, spills, leaks, and fires, including Material Safety Data Sheets (MSDS).
Department of Transportation: 1 -800-467-4922
Provides information on matters related to the U.S. Department of Transportation (DOT) hazardous
materials transportation regulations.
National Response Center: 1-800-424-8802
For reporting spills of hazardous substances.
OSHA: 1-800-321-6742
Provides information regarding matters related to the Occupational Health and Safety Administration
(OSHA) programs and standards.
4.6 WASTE EXCHANGES
Northeast Industrial Exchange Southern Waste Information Exchange
90 Presidential Plaza P.O. Box 6487
Syracuse, NY 13202 Tallahassee, FL 32313
(315)422-6572 (904)644-5516
42 Environmental Management Guide for Small Labs
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California Waste Exchange
Department of Health Services
Toxic Substances Control Division
Alternative Technology & Policy Development Section
714 P Street
Sacramento, CA 95814
(916) 324-1807
4.7 U.S. EPA REGIONAL OFFICES
Region 1 (VT, NH, ME, MA, CT, RI)
John F. Kennedy Federal Building
Boston, MA 02203-0001
(617) 565-3420
Region 2 (NY, NJ, PR, VI)
290 Broadway
New York, NY 10007-1866
(212) 637-3000
Region 3 (PA, DE, MD, WV, VA)
841 Chestnut Street
Philadelphia, PA 19107
(215) 566-5000
Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
61 Forsyth Street
Atlanta, GA 30303
(404) 562-9900
Region 5 (WI, MN, MI, IL, IN, OH)
77 West Jackson Boulevard
Chicago, EL 60604-3507
(312) 353-2000
Region 6 (NM, OK, AR, LA, TX)
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 655-6444
Region 7 (NE, KS, MO, IA)
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-7000
Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2466
(303) 312-6302
Region 9 (CA, NV, AZ, HI)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305
Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206) 553-1200
43
Environmental Muagoaeat GuMe fbr Sanl Lite
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4.8 STATE SMALL BUSINESS ASSISTANCE PROGRAMS
Small Business Ombudsman (SBO) and Small Business Assistance Program (SB AP) offices are located
in each state. These are an excellent and free source of environmental management assistance. These
sources are also familiar with local environmental requirements.
OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Blake Roper, Ombudsman
Administrative Division
Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
334-213-4308
334-213-4399
800-533-2336 (national)
rbr@adem.state.al.ns
James Moore
Air Division
Department of Environmental Management
P.O. Box 301463
Montgomery, AL 36130-1463
334-271-7861
334-271-7950 (F)
800-533-2336 (national)
David Wigglesworth
Small Business Advocate
AKDEC
555 Cordova Street
Anchorage, AK 99501
907-269-7582
907-269-7600 (F)
800-510-2332 (state)
dwiggles@envircon.state.ak.us
Scott Lyfle
Small Business Assistance
AKDEC
555 Cordove Street
Anchorage, AK 99501
907-269-7571
907-269-7600 (F)
800-510-2332 (state)
slytle@envircon.state.ak.us
Dual role SBO and SBAP
Gregory Workman
AZ DEQ - Compliance Assistance
3033 N. Central Avenue
Phoenix, AZ 85012
602-207-4337
602-207-4872 (F)
800-234-5677 (state)
workman.gregory@ev.state.az.us
Richard Polito
Maricopa County SBEAP
1001 N. Central, Suite 200
Phoenix, AZ 85004
602-506-5102
602-506-6669 (F)
rpolito@estrp.maricopa.gov
Robert Graham
Department of Pollution Control & Ecology
P.O. Box 8913
Little Rock, AR 72219-8913
501-682-0708
501-682-0707 (F)
888-233-0326 (national)
grahamr@adeq.state.ar.us
44
Environmental Management Guide for Small Labs
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
James Schoning
Small Business Ombudsman
California EPA
Air Resources Board
2020 L Street
P.O. Box 2815
Sacramento, CA 95814
916-323-6791
916-323-2393 (F)
800-272-4572 (state)
Peter Venturini
California EPA
Air Resources Board
Stationary Source
2020 L Street
P.O. Box 2815
^Sacramento, CA 95814
916-445-0650
916-327-7212 (F)
La Ronda Bowen
Public Advisor
South Coast Air Management District
Small Business Assistance Office
21865 E. Copley Drive
Diamond Bar, CA 91765
909-396-3235
909-396-3335 (F)
800-388-2121 (national)
Ibowen @ aqmd.gov
Natalia Porche
SCAQMD/SBAP
21865 E. Copley Drive
Diamond Bar, CA 91765
909-396-3218
909-396-3335 (F)
800-388-2121 (national)
Cathy Heald
CDPHE
OCS-INF-A1
4300 Cherry Creek Drive, South
Denver, CO 80246-1530
303-692-2034
303-691-1979 (F)
800-886-7689 (state)
cathy.heald@state.co.us
Nick Melliadis
CDPHE
APCD/55/B-1
4300 Cherry Creek Drive, South
Denver, CO 80246-1530
303-692-3175
303-782-5493 (F)
800-333-7798 (national)
nick.melliadis@state.co.us
Tracy Babbidge, Ombudsman
Small Business Assistance Program
Department of Environmental Protection
79 Elm Street
Hartford, CT 06106-5127
860-424-3382
860-424-4063 (F)
800-760-7036 (state)
tracy.babbidge@po.state.ct.us
Glen Daraskevich
Small Business Assistance
Department of Environmental Protection
Environmental Quality Division
79 Elm Street
Hartford, CT 06106-5127
860-424-3545
860-424-4063 (F)
800-760-7036 (state)
glen.daraskevich@po.state.ctus
George Petitgout
Small Business Ombudsman
DEDNRC
P.O. Box 1401
Dover, DE 19903
302-739-6400
302-739-6242 (F)
gpetitgout@dnrec.state.de.us
George Petitgout
Dual Role as SBAP Director
45
Environmental
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Carol Baker
Air Quality Division
EHA/Department of Health
2100 Martin Lather King Avenue, SE
Washington, DC 20020
202-645-6093 x3082
202-645-6102 (F)
Olivia Achuko
Air Quality Division
EHA/Department of Health
2100 Martin Luther King Avenue, SE
Washington, DC 20020
202-645-6093 x3071
202-645-6102 (F)
Elsa Bishop
Small Business Ombudsman
Department of Environmental Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
904-488-0114
904-922-6979 (F)
800-722-7457 (state)
bishop_e@dep.state.fl.us
Currently dual role as SBAP Principal and Small Business
Ombudsman
Tom Ledew
FLSBAP-MS5505
Dept of Env. Protection
2600 Blair Stone Road
Tallahassee, FL 32399-2400
Marvin Lowry
GASBAP
4244 International Parkway, Suite 120
Atlanta, GA 30354
404-362-2656
404-363-7100 (F)
marvin_lowery@mail.dnr.state.ga.us
Anita Dorsey-Word
GASBAP
4244 International Parkway, Suite 136
Atlanta, GA 30354
404-362-4842
404-363-7100 (F)
anita_dorsey-word@mail.dnr.state.ga.us
Robert Tarn
HI Department of Health
Clean Air Branch
919 Ala Moana Boulevard
Honolulu, ffl 96814
808-586-4200
808-586-4359 (F)
Doug McRoberts
IDDEQ/PL&E
statehouse Mail
1410 North Hilton
Boise, ID 83706
208-373-0497
208-373-0169 (F)
dmcrober@deq.state.id.us
Donald Squires
Illinois EPA/DAPC
Small Business Ombudsman
2200 Churchill Road
P.O. Box 19276
Springfield, EL 62794-9276
217-785-1625
217-782-9039 (F)
888-372-1996 (state)
epa813@epa.state.il.us
Mark Enstrom
Illinois Department of Commerce
and Community Affairs
520 East Adams
Springfield, EL 62701
217-524-0169
217-785-6328 (F)
800-252-3998 (state)
menstrom@commerce.state.il.us
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Environmental Management Guide for Small Labs
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Maggie McShane
IDEM/OBR
100 N. Senate
P.O. Box 6015
Indianapolis, IN 46206-6015
317-232-8598
317-232-6647 (F)
800-451-6027 (state)
Cheri Storms
IDEM/OPP & TA/VOC
100 N. Senate, Room 1320
P.O. Box 6015
Indianapolis, IN 46206-6015
317-233-1041
317-233-5627 (F)
800-451-6027
cstor@opn.dem.state.in.us
Linda King
IA Department of Development
Small Business Liaison
200 E. Grand Street
DesMoines,IA 50309
515-242-4761
515-242-4749 (F)
800-358-5510 (state)
lking@ided.state.ia.us
John Konefes
IA Waste Reduction Center
University of Northern Iowa
1005 Technology Parkway
Cedar Falls, IA 50614-0185
319-268-3733 (F)
319-273-8905
800-422-3109 (state)
konefes@uni.edu
Janet Neff
Environmental Ombudsman
Office of Pollution Prevention
KS DH&E
Forbes Field, Building 283
Topeka,KS 66620
913-296-0669
913-291-3266 (F)
800-357-6087 (national)
Frank Orzulak, Director
Continuing Education Building
University of Kansas
Lawrence, KS 66045
785-864-3978
785-864-5827 (F)
800-578-8898 (state)
forzulak@falcon.cc.ukans.edu
Rose Marie Wilmoth
Air Quality Representative
Office of Commissioner
Department for Environmental Protection
14 Reilly Road
Frankfort, KY 40601
502-564-2150, x!28
502-564-4245 (F)
800-926-8111 (national)
wnmoth@nrdep.nr.state.ky .us
Gregg C. Copley, Director
Kentucky Business Environmental Assistance Program
Gatton College of Business and Economics
University of Kentucky
Lexington, KY 40506-0034
606-257-1131
606-323-1907 (F)
800-562-2327 (national)
gccopll @pop.uky.edu
Jim Friloux, Small Business Ombudsman
LADEQ
P.O. Box 82263
Baton Rouge, LA 70804
504-765-0735
504-765-0746 (F)
800-259-2890 (state)
jim_f@deq.state.la.us
Dick Lehr
LA Department of Environmental
Quality (Air)
7290 Bluebonnet
P.O. Box 82135
Baton Rouge, LA 70884-2135
504-765-2453
504-765-0921 (F)
800-259-2890 (state)
richard_l ©deq.state Ja.us
47
Environmental Mantgenteit Gwte tor Small Ute
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Ron Dyer
Department of Environmental Protection
Office of Innovation and Assistance
Station 17
state House
Augusta, ME 04333
207-287-4152
207-287-2814 (F)
800-789-9802 (state)
ron.e.dyer@state.me.us
Brian Kavanah
Department of Environmental Protection
Office of Innovation and Assistance
Station 17
state House
Augusta, ME 04333
207-287-6188
207-287-2814 (F)
800-789-9802 (state)
John Mitchell
MD Department of the Environment
Office of Community Assistance
2500 Broening Highway
Baltimore, MD 21224
410-631-3003
410-631-3936 (F)
800-633-6101, x3003 (state)
George Frantz
Executive Office of Environmental Affairs
Office of Technical Assistance/#2109
100 Cambridge Street
Boston, MA 02202
617-727-3260 x631
617-727-3827 (F)
george.frantz@state.ma.us
Dana Cole
MI Jobs Commission
Victor Center, 4th Floor
201 N. Washington
Lansing, MI 48913
517-335-1847
517-335-0198 (F)
Dave Fiedler
MDEQ Environmental Assistance Division
P.O. Box 30457
Lansing, MI 48909
517-373-0607
517-335-4729 (F)
800-662-9278 (national)
Charlie Kennedy
MPCA/OEA
520 Lafayette Road
SLPaul,MN 55155-4194
612-297-8615
612-297-8324 (F)
800-985-4247 (state)
Troy Johnson
SBAP Coordinator
Air Quality Division
MN Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155
612-296-7767
612-297-7709 (F)
800-657-3938 (state)
troy.johnson@pca.state.mn.us
Jesse Thompson
Small Business Ombudsman
MSDEQ
P.O. Box 10385
Jackson, MS 39289-0385
601-961-5171
601-961-5742 (F)
800-725-6112 (national)
48
Environmental Management Guide for Small Labs
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Brad Ketcher
state of Missouri
Office of the Governor
P.O. Box 720
Jefferson City, MO 65102
573-751-3222
573-751-1495 (F)
Byron Shaw, Jr.
DNR Technical Assistance Program
Jefferson state Office Building
Box 176
Jefferson City, MO 65102
573-526-5352
573-526-5808 (F)
800-361-4827 (national)
Mark Lambrecht
Department of Environmental Quality
Small Business Ombudsman
1520 E. 6th Avenue
Helena, MT 59620
406-444-2960
406-444-6836 (F)
800-433-8773 (national)
malambracht@mt.gov
Warren Norton
Department of Environmental Quality
Air Quality Division
1520 E. 6th Avenue
Helena, MT 59620
406-444-5281
406-444-1499 (F)
800-433-8773 (national)
Dan Eddinger
Public Advocate
Department of Environmental Quality
P.O. Box 98922
Lincoln, NE 68509-8922
402-471-3413
402-471-2909 (F)
edh@nccibm.rtpnc.epa.gov
Dan Eddinger
Dual Role as Ombudsman and SBAP Principal
Marcia Manley
Small Business Ombudsman
NV Department of Environmental Protection
333 West Nyle Lane
Carson City, NV 89706-0851
702-687-4670, x3162
702-687-5856 (F)
800-992-0900, x4670 (state)
mmanley @ ndep.carson-city .nv.us
Janet Goodman
Small Business Program Manager
NV Department of Environmental Protection
333 West Nyle Lane
Carson City, NV 89706-0851
702-687-4670, x3164
702-687-5856 (F)
800-992-0900, x4670 (state)
Rudolph Cartier
Dual Role as Ombudsman and SBAP Principal
Rudolph Cartier
Air Resources Division
Department of Environmental Services
64 North Main Street, 2nd Floor
Concord, NH 03301-2033
603-271-1379
603-271-1381 (F)
800-837-0656 (state)
cartier@desarsb.mr.com
49
Environmental Management Gunk for Small 1
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
John Serkies
Office of Business Advocacy
Department of Commerce and Economic Development
20 West state Street
CN823
Trenton, NJ 08625-0823
609-633-7308
609-777-3106 (F)
800-643-6090 (national)
jserkies@commerce.state.nj.us
Chuck McCarty
Pollution Prevention-Permit Coordinator
SBAP
NJDEPE
P.O. Box 423
Trenton, NJ 08625-0423
609-292-3600
609-777-1330 (F)
cmccarty@dep.state.nj.us
Robert Horwitz
NMED/AQB
Harold Runnels Building
P.O. Box 26110
Santa Fe,NM 87502
505-827-9685
505-827-0045 (F)
800-810-7227 (national)
Cecilia Williams
MM ED/AQB
Harold Runnels Building
P.O. Box 26110
Santa Fe,NM 87502
505-827-0042
505-827-0045 (F)
800-810-7227 (national)
TriaCase
Supervisor, Division of Small Business
Environmental Ombudsman Unit
Empire state Development, 32nd Floor
633 3rd Avenue
New York, NY 10017
212-803-2282
212-803-2309 (F)
800-782-8369, x!57 (national)
tcase@empire.state.ny.us
Marian Mudar
Environmental Program Manager
NYS Environmental Faciliites Corporation
50 Wolf Road, Room 598
Albany, NY 12205
518-457-9135
518-485-8494 (F)
800-780-7227 (state only)
mudar@nysesc.org
Edyth McKinney
Office of the Small Business Ombudsman
Department of Environment, Health, and Natural
Resources
P.O. Box 29583
Raleigh, NC 27626
919-733-0823
919-715-6794 (F)
800-829-4841 (national)
edytne_mckinney @ owr.ehnr.state.nc.us
Fin Johnson
Office of Small Business Ombudsman
Department of Environment, Health and Natural Resources
P.O. Box 29583
Raleigh, NC 27626
919-733-0824
919-715-6794 (F)
800-829-4841 (national)
fm_johnson@owr.ehnr.state.nc.us
Jeff Burgess
ND SDH&CL
P.O. Box 5520
Bismark,ND 58506
701-328-5153
701-328-5200 (F)
800-755-1625 (state)
Tom Bachman
ND SDH&CL
Division of Environmental Engineering
P.O. Box 5520
Bismark,ND 58506
701-328-5188
701-328-5200 (F)
800-755-1625 (state)
SO
Environmental Management Guide for Small Labs
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Mark Shanahan
Clean Air Resource Center
50 West Broad Street, Room 1901
Columbus, OH 43215-5985
614-728-3540
614-752-9188 (F)
800-225-5051 (state)
mark.shanahan@aqda.state.oh.us
Rick Carleski
Ohio EPA
Division of Air Pollution
1600 Watermark Drive
Columbus, OH 43215
614-728-1742
614-644-3681 (F)
rick.carleski@epa.state.oh.us
Steve Thompson
Deputy Executive Director
Department of Environmental Quality
1000 NE 10th Street
Oklahoma City, OK 73117-1212
405-271-8056
405-271-8425 (F)
Alwin Ning
Small Business Program
Department of Environmental Quality
1000 NE 10th Street
Oklahoma City, OK 73117-1212
405-271-1400
405-271-1317 (F)
800-869-1400 (national)
Paul Burnet
ORDEQ
811SW 6th Avenue
Portland, OR 97204-1390
503-229-5776
503-229-6945 (F)
800-452-4011 (state)
Jill Inahara
ORDEQ
Air Quality Division
811SW 6th Avenue
Portland, OR 97204
503-229-6147
503-229-5675 (F)
800-452-4011 (state)
Greg Czarnecki
Office of P2 & Compliance Assistance
PADEP
RCSOB, 13th Floor
P.O. Box 8772
Harrisburg, PA 17105-8468
717-772-8951
717-783-2703 (F)
Scott Kepner
Bureau of Air Quality Control
PADEP
P.O. Box 8468
Harrisburg, PA 17105-8468
717-787-1663
717-772-2303 (F)
Kepner.Scott@al .dep.state.pa.us
Tomas DeLeon
Administrator, Commercial Development Administration
Office
P.O. Box 4275
San Juan, PR 00902
787-724-1451
787-722-8477 (F)
Maria Rivera
PREQB - SBAP
HC-91, Box 9197
VegaAlta,PR 00692-9607
787-767-8025, x296
787-756-5906 (F)
Roger Greene
RI Department of Environmental Management
235 Promenade Street
Providence, RI 02908
401-277-2771
401-277-4546 (F)
Pam Annarummo
RI Department of Environmental Management
235 Promenade Street
Providence, RI 02908
401-222-6822, x7204
401-277-3810 (F)
800-253-2674 (state)
Environmental Management Guide for SMB Labs
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Donna H. Gulledge, SBO
SC Department of Health & Environmental Control
2600 Bull Street
Columbia, SC 29201
803-734-5909
803-734-9196 (F)
800-819-9001 (national)
gulleddh@columb30.dhec.state.sc.us ,
Rose Stancil
SBAP Technical Engineer Assistant
Department of Health & Environmental Control
2600 Bull Street
Columbia, SC 29201
803-734-2765
803-734-9196 (F)
stancirr @ columb30.dhec.state.sc.us
Joe D. Nadenicek
Small Business Ombudsman
Department of Environment & Natural Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501
605-773-3151
605-773-6035 (F)
800-438-3367 (state)
Bryan Gustafson
Department of Environment & Natural Resources
Joe Foss Building
523 East Capitol
Pierre, SD 57501
605-773-3351
605-773-6035 (F)
Ernest Blankenship
TN Department of Environment & Conservation
L&C Tower, 8th Floor
401 Church Street
Nashville, TN 37243-1551
615-532-0731
615-532-0614 (F)
eblankenship@mail.state.tn.us
Linda Sadler
Small Business Assistance Program
L&C Annex, 8th Floor
401 Church Street
Nashville, TN 37243-1551
615-532-0779
615-532-0614 (F)
800-734-3619 (national)
lsadler@mail.state.tn.us
Tamra Shae-Oatman
Small Business Advocate
TX NRCC (Mail Code 106)
P.O. Box 13087
Austin, TX 78711-3087
512-239-1062
512-239-1065 (F)
800-447-2827 (national)
toatman@smtpgate.tnrcc.state.tx.us
Stephanie Bernkopf
UT Department of Environmental Quality
Office of the Small Business Ombudsman
168 North 1950 West
Salt Lake City, UT 84114-4810
801-536-4479
801-536-4099 (F)
sbernkop@deq.state.ut.us
Frances Bernards
UT Department of Environmental Quality
Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
801-536-4056
801-536-4099 (F)
800-270-4440 (state)
fbernard@deq.state.uLus
52
Environmental Management Guide for Small Labs
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Judy Mirro
VT Environmental Assistance Division
Laundry Building
103 South Main Street
Waterbury, VT 05671
802-241-3745
802-241-3273 (F)
800-974-9559 (state)
John Daniel, Air Division Director
VA Department of Environmental Quality
P.O. Box 10009
Richmond, VA 23240
804-698-4311
804-698-4510 (F)
800-592-5482 (state)
Richard Rasraussen
Manager, Small Business Assistance Program
VA Department of Environmental Quality
P.O. Box 10009
Richmond, VA 23240
804-698-4394
804-698-4510 (F)
800-592-5482 (state)
rgrasmusse@deq.state.va.us
Dual role SBO/SBAP Principal.
Marylyn A. Stapleton
VI Department of Planning & Natural Resources
Division of Environmental Protection
8000 Nisky Center, Suite 231
Charlotte Amalie, St. Thomas, VI 00802
340-777-4577
340-774-5416 (F)
Leighton Pratt
Department of Ecology
P.O. Box 47600
Olympia, WA 98504-7600
360-407-7018
360-407-6802 (F)
Bernard Brady
WA Department of Ecology
Air Quality Program
P.O. Box 48600
Olympia, WA 98504-7600
360-407-6803
360-407-6802 (F)
bbra461 @ecy .wa.gov
Kenneth Shaw
Small Business Ombudsman
WV Office of Ah- Quality
1558 Washington Street, SE
Charleston, WV 25311
304-558-1218
304-558-1222 (F)
800-982-2474 (state)
Fred Durham
WV Office of Air Quality
1558 Washington Street, SE
Charleston, WV 25311
304-558-1217
304-558-1222 (F)
800-982-2474 (state)
Hampton Rothwell
Small Business Ombudsman
Department of Development
WISBAP, 6th Floor
201 West Washington Avenue
Madison, WI 53703
608-267-0313
608-267-0436 (F)
800-435-7287 (national)
hrothwell@commerce.state.wi.us
Pam Christenson
Technical Assistance Director
Department of Commerce
WISBAP, 6th Floor
201 West Washington Avenue
Madison, WI 53703
608-267-9214
608-267-0436 (F)
800-435-7287 (national)
pchristenson@commerce.state.wi.us
53
Environmental MungeoKOt Guide ft* SanB Late
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OMBUDSMAN
SMALL BUSINESS ASSISTANCE PROGRAM
Dan dark
Department of Environmental Quality
OA/Small Business Ombudsman
122 W. 25th Street
Cheyenne, WY 82002
307-777-7388
307-777-3773 (F)
^missc. state, wy.us
Charles Raffelson
Department of Environmental Quality
Division of Air Quality
122 W. 25th Street
Cheyenne, WY 82002
307-777-7347
307-777-5616 (F)
craffe@missc.state.wy.us
54
Environmental Management Guide for Small Labs
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