Improve Environmental Performance in Academic Laboratories Managing Laboratory Hazardous Waste An Introduction to the Academic Laboratories Rule Subpart K ------- Subpart K Alternative Generator Regulations for Managing Hazardous Waste in Academic Laboratories The U.S. Environmental Protection Agency (EPA) added 40 CFR Part 262 Subpart Kto the Resource Conservation and Recovery Act (RCRA) hazardous waste generator regulations in December 2008. Subpart K provides standards for managing hazardous waste in academic laboratories at eligible academic entities as an alternative to the satellite accumulation area generator regulations. Subpart K protects public health and the environment by presenting alternative generator requirements better suited to the specific circumstances of teaching and research laboratories. The provisions of Subpart K will bring about safer management of hazardous waste in academic laboratories by: Requiring hazardous waste determinations to be made by trained professionals, rather than students Requiring hazardous waste to be removed from the laboratory every six months Allowing eligible academic entities the flexibility to decide when and where on-site hazardous waste determinations are made Offering incentives for removing from the laboratories old and expired chemicals that may pose risks Requiring the development of a Laboratory Management Plan, in which entities specify best waste management practices ------- Subpart K's Alternative Regulations Offer Significant Benefits For Participating States and Eligible Academic Entities Increased Laboratory Safety More accurate hazardous waste determinations by transferring the responsibility for making hazardous waste determinations to experts Requires training for students and laboratory workers • Laboratory clean-out incentives promote reduction of stockpiles of potentially dangerous old chemicals stored in laboratories • Time-driven removals ensure hazardous waste is removed from laboratories on a regular basis Required Laboratory Management Plan ensures safer laboratory practices and increased awareness of hazardous waste management ------- Subpart K's Alternative Regulations Offer Significant Benefits For Participating Eligible Academic Entities More Flexibility Choice of when and where on-site to make hazardous waste determinations Performance-based container management standards ensure safe storage and prevent leaks, spills, and emissions into the air while allowing for the following appropriate closed container exceptions: Venting is allowed when necessary for proper operation of laboratory equipment such as HPLCs Venting is allowed to avoid dangerous situations such as build-up of pressure Working containers may remain open until the end of a shift or procedure, whichever is first Efficiencies and Cost Savings Laboratories not required to count unused hazardous wastes generated during once-a-year laboratory clean-out toward generator status, which reduces episodic generation and lowers costs Thirty days allowed for once-a-year laboratory clean-out and no volume limit for clean-out materials On-site consolidation means less vendor time on-site and fewer partially full containers Increased laboratory safety leads to reduced liability and the potential for lower insurance rates ------- Eligible Academic Entities Colleges and universities Teaching hospitals owned by or formally affiliated with a college or university Non-profit research institutes owned by or formally affiliated with a college or university Subpart K applies to teaching, research, and some diagnostic laboratories, art studios, chemical stockrooms, and other laboratories owned by eligible academic entities. It does not apply to non-laboratory areas at eligible academic entities. Subpart K is an optional rule. States may choose whether to adopt Subpart K. Once a state adopts Subpart K, eligible academic entities in that state may opt into the Subpart K regulation or remain subject to the pre-existing generator standards (i.e., the satellite accumulation area regulations, 40 CFR 262.34(c)). Tailored for the Academic Laboratory Environment Subpart K is a new EPA generator regulation designed for the academic sector. It addresses the unique hazardous waste generation patterns of academic laboratories: Hundreds of different hazardous wastes that vary over time Small volumes of each waste Many points of generation Hazardous waste generated by students with high turnover, minimal training, and limited accountability ------- Take the next step toward improving environmental performance in your academic laboratories Visitwww.epa.gov/waste/hazard/generation/labwaste to find the final rule titled, "Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Eligible Academic Entities" Federal Register notice; December 1, 2008; 73 FR 72912 Code of Federal Regulations; 40 CFR Part 262 Subpart K The EPA Web site above also provides tools and resources for states and eligible academic entities that want to adopt and opt in to Subpart K. To learn if Subpart K is in effect in your state—and for assistance in implementing the new regulations in your academic laboratory— contact your state agency or the EPA Labs Team: Jessica Biegelson Kristin Fitzgerald biegelson.jessica@epa.gov fitzgerald.kristin@epa.gov 703.308.0026 703.308.8286 U.S. Environmental Protection Agency Office of Resource Conservation and Recovery Mail Code (5304P) 1200 Pennsylvania Avenue, NW Washington, DC 20460 www.epa.gov/waste/hazard/generation/labwaste EPA530-F-09-019 ------- |