SEPA
United States
Environmental Protection
Agency
Office of the Administrator
Washington, DC 20460
Mail Code 1807
EPA 100-R-00-036
January 2001
www.epa.gov/opei
Project XL Progress Report
New England Universities Laboratories
Major Milestones
In 1995, the U.S. Environmental Protection Agency (EPA) embarked on a series of innova-
tive initiatives in an effort to test new ways to achieve greater public health and environmental
protection at a more reasonable cost. Through Proj ect XL, which stands for excellence and
Leadership, EPA enters into specific proj ect agreements with public or private sector spon-
sors to test regulatory, policy, and procedural alternatives that will produce data and experi-
ences to help the Agency make improvements in the current system of environmental protec-
tion. The goal of Proj ect XL is to implement 50 proj ects that will test ways of producing
superior environmental performance with improved economic efficiencies, while increasing
public participation through active stakeholder processes. As of January 2001, EPA has
reached its goal of 5 0 proj ects in the implementation phase. EPA Proj ect XL Progress
Reports provide overviews of the status of XL proj ects that are implementing Final Proj ect
Agreements (FPAs). The progress reports are available on the Internet via EPAs Proj ect XL
Web site at http://www.epa.gov/Project XL. Hard copies may be obtained by contacting the
Office of Policy Economics and Innovation's (formerly the Office of Reinvention) Proj ect XL
general information number at 202-260-5754. Additional information on Proj ect XL is
available on the Web site or by contacting the general information number. The information
and data presented in the January 2001 Progress Report is current as of December 2000.
Background
Interested in promoting environmental regulations that reflect the unique situation of laborato-
ries and reducing the amount of chemical waste produced, a group of universities from
across New England formed the Laboratory Consortium for Environmental Excellence
(LCEE) in 1997. Later renamed the Campus Consortium for Environmental Excellence
(C2E2), the Consortium is a
not-for-profit corporation
whose member colleges,
universities, and research
organizations are interested in
promoting the continual im-
provement of environmental
management programs and
systems at academic institutions
and research organizations,
including the management and
New England
Universities
Laboratories
Massachusetts
Vermont
7
January 30, 1998
New England
Universities
Laboratories XL
Proposal Submitted
s
September 28, 1999
Final Project
Agreement
Signed
/
June 28, 2000
Baseline
Assessment
Completed
/
September 1, 2000
Boston College
Implements EMP
/
October 6, 2000
UMass-Boston
Implements EMP
/
December 28, 2000
Vermont DEC
approval of UVM
EMP
S
January 2001
UVM
Implements
EMP
7
Fall 2003
Final
Commitments
of FPA to
Be Met
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disposal of hazardous chemicals from campus laboratories. The New England Universities Laboratories XL
project was developed in conjunction with C2E2. The three participating universities, Boston College, the
University of Massachusetts-Boston (UMass-Boston), and the University of Vermont (UVM), are C2E2 mem-
bers. The XL proj ect is designed to pilot a more flexible, performance-based system for managing waste
generated in university laboratories. Performance-based systems focus on what is to be accomplished, not
prescribing how it will be done. This approach gives organizations the flexibility to adapt to different situations
and apply the most cost-effective approaches, while meeting the goals set.
The management of chemicals in university laboratories is primarily regulated by two Federal statutes: the
Occupational Safety and Health Act (OSHA), which regulates the use of chemicals within the lab, and the
Resource Conservation and Recovery Act (RCRA), which regulates their disposal. Laboratories generally use a
small amount of a wide variety of chemicals on an irregular basis, as opposed to a large amount of very few
chemicals used continuously that would be employed, for example, in a manufacturing facility. The Occupational
Safety Health Administration recognizes this difference and has in place performance-based standards specifi-
cally addressing laboratory conditions. The requirements of RCRA are less readily adapted to such a setting.
For example, RCRAs determination of when used chemicals are defined as "hazardous waste" is designed
primarily for an environment where large quantities of a small number of hazardous wastes are consistently
produced and is not adapted easily to the laboratory setting. In addition, while OSHA regulations specifically
address the handling and management of the types of chemicals used in laboratories, the management require-
ments for RCRA-defmed hazardous waste are more difficult to apply to the wide range of hazardous chemicals
used in laboratories.
Thus, university laboratories are essentially required to implement and track two parallel and not always consis-
tent chemical management systems within the laboratory setting. Under RCRA, laboratories must meet exter-
nally imposed requirements governing the management and handling of hazardous waste. Under OSHA, labora-
tories must comply with a performance-based, internally developed management system governing the manage-
ment and handling of "hazardous chemicals." The dual implementation of OSHA and RCRA regulations is
further complicated by the structure of university laboratories. With large numbers of laboratories within one
university, each producing small amounts of hazardous waste on an irregular basis, the overall management of
hazardous chemicals and hazardous waste becomes far more difficult. Additional complications arise from the
fact that the university laboratory setting is decentralized, diverse, and subj ect to the regular turnover of students
and researchers.
Boston College, with 14,000 students, has approximately 130 research and teaching laboratories and is classi-
fied as a small quantity generator (SQG) under RCRA. UMass-Boston, with 13,000 students, and UVM, with
10,000 students, are considered by EPA to be large quantity generators (LQG). UVM, which manages 538
labs, is considered a LQGby EPA because it generates more than 1,000 kilograms (2,200 pounds) of RCRA
hazardous waste in a single month. Under a different part of the regulation, UMass-Boston, with 144 labs, is
classified as an LQG because it surpasses the 1 kilogram (2.2 pound) per month threshold for generation of
acutely hazardous waste.
The Experiment
The Laboratory XL proj ect intends to facilitate the creation of an integrated and consistent regulatory atmo-
sphere for managing waste in laboratories. Under the proj ect the universities will be required to develop an
Environmental Management Plan (EMP) for chemical waste disposal similar to the OSHA-required Chemical
Hygiene Plan (CHP). This will enable some of the current RCRA hazardous waste regulations to more closely
reflect current OSHA regulations, reducing confusion and ambiguity within the university laboratory setting. As a
result of the harmonization of the OSHA CHP and the RCRA-oriented EMP, the new system will actively
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New England Universities Laboratories XL Project
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encourage chemical reuse and recycling, reduce costs, increase efficiency, and better educate laboratory profes-
sionals and researchers. In addition, the new system is expected to provide a better management approach for
laboratories and to result in increased pollution prevention while still ensuring protection of human health and the
environment.
The anticipated superior environmental benefits of the New England Universities Laboratories proj ect include:
increasing reuse and recycling of laboratory chemicals within the university by 10 percent, resulting in reduced
laboratory chemical waste disposal;
establishing a laboratory environmental management system for better management of chemicals and waste
between laboratories, resulting in cost and time savings for the university; and
increasing hazardous waste management awareness by expanding training in chemical management and
environmental education of laboratory workers, resulting in safer techniques in handling and storing laboratory
chemicals.
The Flexibility
As an incentive to achieve superior environmental performance at the participating universities, EPA's Office of
Solid Waste, the Massachusetts Department of Environmental Protection (MADEP), and the Vermont Depart-
ment of Environmental Conservation (VTDEC) are allowing for more flexible and cost-effective processes
under RCRA.
The statutory program, and the EPA office administering the program that is affecting the New England Univer-
sities Laboratories XL project is the RCRA program, administered by EPA's Office of Solid Waste.
Streamlining the Regulatory Process. A Laboratory Environmental Management Standard will be developed
by EPA and the participating universities that provides regulatory flexibility under RCRA for the implementation
of this XL proj ect. To enable this XL proj ect, flexibility for the universities' compliance with RCRA regulations
was addressed by a new site-specific rule for 40 CFR part 262, Subpart J, published by EPA in the September
28,1999, Federal Register. This rule created a pilot system for managing laboratory waste based on the actual
performance of the universities in reducing the amount of hazardous waste produced. The new subpart contains
a Laboratory Environmental Management Standard which defines criteria for the effective management of
laboratory waste and incorporates requirements detailing the organizational responsibilities and the training
requirements of each participating university laboratory through the development of an EMP.
Under the Environmental Management Standard, each university will create an EMP, modeled on OSHA's
CHP, that includes Minimum Performance Criteria. The Minimum Performance Criteria address the specific
requirements of RCRA that are being replaced and include provisions that address RCRA-type requirements,
such as labeling and container management. Further, the EMPs include enforceable procedures, responsibilities,
and practices that ensure that the Minimum Performance Criteria meet the requirements of the Laboratory
Environmental Management Standard. The regulatory flexibility is conditioned upon the universities' compliance
with the Minimum Performance Criteria in each laboratory.
The goals of the Laboratory EMP are to minimize the amount of hazardous waste created across the whole
university by shifting the focus of laboratory workers from waste disposal from a particular laboratory to the
potential for reuse in other laboratories and recycling those chemicals that are no longer needed. Further,
university Environmental Health and Safety (EHS) departments will broaden their scope from the current narrow
focus on waste pickup and handling issues to include pollution prevention and chemical substitution and reuse.
The resulting performance in hazardous waste disposal by the universities will exceed current RCRA program
requirements.
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Under Proj ect XL, Boston College, UMass-Boston, and UVM are provided with a temporary conditional
deferral from portions of RCRA regulations dealing with Hazardous Waste Determinations and Satellite Accu-
mulation Provisions.
State regulatory requirements in Massachusetts and Vermont parallel the Federal RCRA requirements for
hazardous waste, and therefore, state regulatory relief is addressed under this XL agreement.
Hazardous Waste Determination. Under the hazardous waste determination requirement of 40CFR 262.11,
determination as to whether or not a substance is a hazardous waste under RCRA definitions occurs in the
laboratory. As explained earlier, these decisions are often made by laboratory workers who do not have a
complete sense of the chemical needs of the entire university. As a result, the decision to label a chemical as a
hazardous waste is often premature and does not maximize the potential for reuse by other laboratories within
the university. This site-specific rule permits the hazardous waste determination to take place at a centralized
facility within each university, increasing the likelihood of reuse and recycling of materials. Under this XL proj ect,
the participating universities will be allowed to formally defer the hazardous waste determination from the
laboratory to a central on-site location. This should allow the universities' EHS professionals to more effectively
manage the laboratory waste at the institutional level and thus increase reuse and recycling opportunities.
Hazardous Waste Accumulation Time. The satellite accumulation provisions of RCRA, 40CFR 262.34(c)
require that hazardous waste in excess of 55 gallons be removed within three days of reaching the 55-gallon
limit. In the university setting, such a time constraint results in frequent, unplanned, and episodic pickups at
individual laboratories that are, in themselves, time consuming. Under the XL rule, the permissible time for waste
pickups is extended to 30 days. This flexibility allows for a more coordinated and efficient pickup and delivery
system that frees up staff time and resources, reducing the cost of waste collection. In addition, this change
allows for the development of infrastructure and training designed to increase waste minimization and an orga-
nized and coordinated campus-wide chemical reuse system. Regular inventories of laboratory chemicals and the
additional hazardous chemical training, including pollution prevention and environmental management practices,
received by laboratory workers will help ensure that chemicals stored within the laboratory do not pose addi-
tional risks to laboratory workers.
Promoting Innovation and System Change
Proj ect XL provides EPA with opportunities to test and implement approaches that protect the environment and
advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL proj ects are
helping to promote innovation and system change. The innovations and system changes emerging from the
Laboratory XL project are described below.
Alternative Regulatory Approaches to Encourage Hazardous Waste Recycling and Reuse. By offering
regulatory flexibility to the participating universities in conjunction with the Environmental Management Plans,
EPA and the state agencies will be able to evaluate the effectiveness of offering flexibility in hazardous waste
determination and temporary holding in order to encourage the more efficient utilization of hazardous waste at
the university level and to encourage recycling, reuse, and pollution prevention efforts. The universities have set
specific pollution prevention goals, including a 10 percent reduction in the overall amount of hazardous waste
generated from participating laboratories (from a baseline assessment conducted at the beginning of the proj ect)
and a 20 percent increase (from baseline, estimated to be less than 1 percent of all waste produced) in reuse of
laboratory waste over the life of the proj ect. The information that will be gained on environmental benefits and
cost savings experienced by Boston College, UMass-Boston, and UVM under Proj ect XL may be used by
EPA to develop a framework to address the potential transferability of this type of regulatory flexibility to
colleges and university laboratories nationwide.
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Development of a Performance-based Environmental Standard for University Laboratories. The project
is to be conducted over a period of four years, and performance is to be evaluated annually based on the
institution's reuse/redistribution of hazardous chemicals from laboratories, generation of hazardous waste,
management system audits, and laboratory worker environmental awareness surveys. In light of the environmen-
tal performance of the three universities and the lessons learned from this pilot proj ect, EPA, with stakeholder
input, will then determine whether to propose an environmental standard for laboratories. That standard would
serve as a national regulatory alternative to the current prescriptive RCRA standards, providing laboratories
more flexibility in meeting RCRA standards based on their actual performance in reducing waste and increasing
reuse and recycling opportunities.
Project Commitment Summary
This table and the environmental performance section that follows summarizes progress in meeting commitments
described in the Final Proj ect Agreement (FPA) for the universities.
Commitment
Status
Development of Baseline Assessment
Each university will conduct a baseline assessment of
current environmental performance, based on
representative data, within the first six months of the
effective date of the Final Rule with a report within
nine months.
The Baseline Assessment was completed on June
28, 2000.
Development of Laboratory EMP
EPA will promulgate a site-specific rule providing the
legal mechanism for piloting the new environmental
management system in the FPA.
The final rule was published in Federal Register,
September 28,1999.
Massachusetts will promulgate a state specific rule
that incorporates the terms of the Federal Rule within
18 months from the date that the Federal Rule is
finalized.
MADEP has issued a "Letter of Forbearance" as an
interim measure until a state-specific rule is finalized,
allowing the universities to proceed with the proj ect
with the increased regulatory flexibility.
Vermont will promulgate a state-specific rule within
the six month time period that the universities have to
develop the EMPs.
Revisions to the Vermont Hazardous Waste Man-
agement Regulation, became effective on March 28,
2000. Until the rule expires, September 20,2003,
UVM i s not subj ect to the requirements of Sections
7-202, 7-301, 7-303, 7-305(b), and 7-310 of the
Regulations.
Each university, working in collaboration with the
agencies, will develop a Laboratory EMP within six
months of the effective date of the FPA. This plan
will include policies, procedures, and practices
consistent with the Minimum Performance Criteria
and the Laboratory Environmental Management
System at 40 CFR part 262, subpart J.
Boston College is implementing an EMP as of
September 1,2000. UMass-Boston implemented
its EMP on October 6,2000. UVM's EMP was
approved in December 2000, and is being imple-
mented as of January 2001.
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Commitment | Status
Review by Project Signatories and Stakeholders
Upon completion, the written Laboratory EMPs will be
provided to the EPA, and the applicable state agency,
MADEP and VTDEC, for review and comment in order
to ensure that the requirements of the Laboratory Environ-
mental Management System have been met.
A copy of each university's Laboratory EMP will be
available to individual stakeholder groups, and the univer-
sity will consider the comments and input of such review-
ers in the revision of its EMP.
Draft EMPs were submitted and comments
provided in the first half of 2000. Final EMPs
were received in September, October, and
December 2000.
EMPs for the universities can be found at the
following web addresses:
UVM http://esf.uvm.edu/uvmemp
UMass-Boston http://omega.cc.umb.edu/
~ehs/ch em/ch emii.htm#B.6
Boston College http://www.bc.edu/ehs
Training and Information
Each university will provide to its Laboratory workers
initial training and information on the EMP and will con-
tinue such training throughout the life of this Laboratory XL
Project.
Training at Boston College and UMass-Boston
began in fall 2000. UVM will initiate training in
January 2001.
Project Implementation
Each university will provide written notification by certified
mail to the EPA and the relevant state agency at the time it
is prepared to implement its approved EMP. Up until such
written notification, RCRA regulations (or the equivalent
state regulations) will apply in full.
According to EMP requirements, each university will
define a list of "hazardous chemicals of concern" (HCOC)
and annually conduct a risk evaluation survey of these
chemicals in the laboratory. This list will be generated by
EHS professionals at each university based on regulatory
concerns, risk concerns, and potential chemical reactions.
Notification sent to EPA:
Boston College September 1, 2000
UMass-Boston October 6, 2000
UVM December 27, 2000 approval,
implementation expected January 200 1 .
HCOC list generated by each university in
spring 2000.
Risk evaluation survey completed spring 2000.
Monitoring, Reporting, and Evaluation
Each university will be responsible for collecting data and
monitoring its environmental performance using the Envi-
ronmental Performance Indicators (EPI's) selected for this
XL project, which will be reviewed by EPA and each
university's individual stakeholder groups. Each university
will also take appropriate steps to evaluate compliance
and address any nonconformance within its Laboratory
EMP within 12 months of the effective date of this FPA
The Proj ect will submit annual reports throughout the
duration of the project.
Monitoring began in Fall 2000. Quantitative
data to be collected spring 200 1 .
First annual status report update submitted
December 28, 2000. Additional Quantitative
Report to be submitted 2001 .
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Environmental Performance
This section summarizes progress in meeting the environmental performance described in the Final Proj ect
Agreement, the official agreement between EPA and the universities. Performance measures, as required by the
Laboratory Environmental Management Standard, are incorporated into each university's EMP. The universities
began implementing their EMPs in September and October 2000 and January 2001. This report details the
efforts of the universities to achieve the goals of superior environmental performance, which are broadly defined
in four categories: hazardous chemicals of concern inventory; laboratory waste reduction, reuse, and redistribu-
tion; environmental awareness survey; and costs of laboratory waste management.
Hazardous Chemicals of Concern Inventory. The Final Proj ect Agreement includes a requirement that each
university define a list of "hazardous chemicals of concern" (HCOC) and annually conduct a risk evaluation
survey of these chemicals in their laboratories. This inventory, which is beyond the requirements of RCRA, will
provide a baseline for assessing the impact of the XL proj ect. The list of HCOC will be generated by EHS
professionals at each university based on regulatory concerns, risk concerns, and potential chemical reactions.
Each university developed its own methodology for conducting the baseline HCOC risk assessment inventory.
UVM based its inventory on the requirements of the Superfund Amendments and Reauthorization Act (SARA)
Title in reporting. A variety of regulatory chemical lists were reviewed in 1990 to generate a list of approxi-
mately 400 hazardous chemicals considered to be of potential environmental or safely risk and likely to be
found at UVM. The list is distributed to laboratories every January, and the laboratories report the quantity of
each chemical on the list that is stored there on a daily basis, which are then rolled up into cumulative totals.
Boston College conducted a complete inventory of hazardous chemicals in the laboratories to establish its list of
HCOC. UMass-Boston conducts an annual inventory of chemicals, as required by the Boston Fire Department.
This list will be reviewed on an annual basis and updated to ensure it covers an appropriate breadth of hazard-
ous materials. The exact HCOC lists were developed on a university-by-university basis, because the types of
hazardous chemicals at a particular university vary with the type of research work performed there.
One goal of the proj ect is to ensure that the defined shelf life of each HCOC stored in the laboratories has not
been exceeded. This documented evaluation will enhance both waste and risk minimization efforts by identifying
and evaluating chemicals of concern and moving them out of the laboratories if they are beyond their suggested
shelf life. By providing regular and consistent data on chemicals and chemical storage, such surveys will support
university-wide chemical redistribution and/or the timely disposal of hazardous chemicals that are approaching
or have exceeded their shelf life. In addition, the survey will also document that HCOC that remain on the shelf
have recently been assessed for product integrity. Based on the experiences of UVM, laboratories conducting
annual inventories often discover and discard materials that have expired, resulting in improved housekeeping
and safer management of chemicals of concern. This may also result in increases in chemical waste generated by
laboratories around the time of the inventories for the first several years.
Laboratory Wastes Reduction, Reuse, and Redistribution. Because the current regulatory framework does
not easily support the reuse or redistribution of laboratory waste, it was the assumption of each of the universi-
ties that the institutional reuse/redistribution rate was less than 1 percent of waste generated from laboratories.
According to a 1996 survey of approximately 100 academic institutions by the Government Relations Commit-
tee of the Campus Safety, Health, and Environmental Management Division of the National Safety Council,
nearly 95 percent of respondents reported that they redistributed or recycled less than 1 percent of the hazard-
ous chemical waste otherwise destined for disposal. One of the goals of this XL project is to have a 20 percent
increase in reuse/redistribution of hazardous chemicals collected from labs over the life of the proj ect, and a
reduction in waste disposal of 10 percent due to better management and chemical reuse and recycling. The total
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quantity of laboratory waste generated at each university reflects the varying types of research conducted at the
different institutions, the different types and sizes of laboratory rooms, and the different approaches to waste
management (see Table below).
Reduction of Annual Generation of Laboratory Wastes
Baseline (1999)
Goal
Boston College
25,269 pounds
22,742 pounds
UMass-Boston
5, 585 pounds
5,027 pounds
UVM
3 6, 156 pounds
3 2, 549 pounds
Environmental Awareness Survey. The Environmental Awareness Survey developed for the Proj ect XL
baseline was a cooperative effort among the three universities. Although each university used a different sam-
pling technique, each participant responded to the same survey. The survey tested laboratory worker awareness
of the impact of laboratory chemicals on the natural environment and public health, the disposal regulations for
environmental waste, emergency response equipment available in the laboratory, and so forth. Under this XL
project, laboratory workers will receive enhanced hazardous chemical training with respect to laboratory waste,
pollution prevention, and the environmental management practices at the university. Survey scores over the term
of the proj ect are expected to reflect increased knowledge due to more comprehensive training and environ-
mental education and safer conditions for laboratory workers.
Costs of Laboratory Waste Management. The compliance costs of determining when chemical waste should
be defined as "hazardous," waste pickup, and disposal of waste are expected to decline over the life of this XL
proj ect. It is, however, likely that laboratory management costs in the first year of the proj ect (F Y 2001) may
increase due to training and labor costs associated with the implementation of the EMPs and increased labora-
tory cleanouts and disposal associated with the HCOC survey, periodic inspections, and increased awareness
of laboratory waste management.
Costs of Laboratory Waste Management (FY 2000)
Institution
Boston College
UMass-Boston
UVM
Total Cost
$122,612.00
$27,991.00
$258,960.00
Average Cost Per
Laboratory
$943.17
$194.28
$481.34
Stakeholder Participation
There has been both national and local stakeholder involvement in the development of the Laboratory Environ-
mental Management Standard and substantive elements of the FPA. The initial stakeholder group was a national
assembly of experts in laboratory chemical and environmental safely. The purpose of this group was twofold: (1)
to ensure that the Universities Laboratories XL Proposal reflected state-of-the-art thinking with regard to
controlling the potential impacts of laboratory chemicals and (2) to ensure that the Laboratory Environmental
Management Standard developed by the XL participants could over time reasonably apply to a broad spectrum
of colleges and universities.
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The development of the XL proj ect was discussed at two broader based national stakeholders' meetings
sponsored by LCEE (now C2E2). These meetings included representatives of different-sized colleges and
universities, non-governmental organizations, industry, and various branches of the EPA. People unable to attend
the national stakeholders' meetings were able to review the various drafts of the Laboratories XL Proposal on
the XL Home page on the World Wide Web and comment electronically through the Laboratories XL e-mail
listserv. Additionally, copies of the XL Proposal were mailed to individuals or organizations upon request. More
than 1 00 people reviewed the proposals in this way. In addition, local stakeholders, such as university faculty,
staff, and students, community stakeholders, and regulators with jurisdiction over laboratories have been in-
volved through local meetings, presentations, or reviewing the Laboratories XL Proposal to ensure protection of
laboratory worker and public health and safety under the proposed proj ect.
As this XL proj ect is implemented, the stakeholder involvement program will ensure that interested parties are
apprised of the status of proj ect implementation and that national and local stakeholders have access to informa-
tion sufficient to judge the success of this pilot, through local and campus newspapers, the Internet, and open
meetings.
Six-Month Outlook
The key focus areas for continued successful implementation of the FPA over the next six months will be the
following.
Continued implementation of the EMPs at Boston College, UMass-Boston, and UVM, including meeting the
Minimum Performance Criteria in the laboratories and implementing the laboratory inspection program.
Project Contacts
Thomas Balf, Proj ect Sponsor Primary Contact Nexus Environmental Partners (consultant),
Suzanne Howard, Boston College, (617)-552-0308.
Zehra Schneider-Graham, University of Massachusetts, Boston, (6 1 7)-287-5444.
Ralph Stuart, University of Vermont, (802)-656-5400.
Jim Miller, State of Massachusetts, Massachusetts Department of Environmental Protection,
(617)-292-5574.
Steve Simoes, State of Vermont, Department of Environmental Conservation, (802)-241-3878.
GinaSnyder,U.S.EPARegionl,(617)-918-1837.
Sherri Walker, U.S. EPA, Office of Policy, Economics, and Innovation, (202)-260-4295 .
Information Sources
The information sources used to develop this report include ( 1 ) the FPA for the New England Universities
Laboratories Proj ect, September 1999; (2) Proj ect XL Site Specific Rulemaking for University Laboratories,
Final Rule, published in the Federal Register September 28, 1 999; (3) Amendments to Vermont's Hazardous
Waste Management Regulations, March 2000; (4) Boston College's Draft Environmental Management Plan,
April 2000; and (5) New England Laboratories Proj ect XL Baseline Assessment, June 28, 2000. The informa-
tion sources are current through July 2000.
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Glossary
Baseline: The measure by which future environmental performance can be compared.
Chemical Hygiene Plan (CHP): A written program developed and implemented by the employer which sets
forth procedures, equipment, personal protective equipment and work practices that are capable of protecting
employees from the health hazards presented by hazardous chemicals used in the particular workplace and
meets the requirements as defined in 29 CFR1910.1450.
Environmental Management Plan (EMP): A written program developed and implemented by the university that
sets forth standards and procedures, responsibilities, pollution control equipment, performance criteria, re-
sources, and work practices that both protect human health and the environment from the hazards presented by
laboratory waste within a laboratory and between a laboratory and the hazardous waste accumulation area, and
satisfies the plan requirements defined elsewhere in this section. Certain requirements of this plan are satisfied
through the use of the Chemical Hygiene Plan, or equivalent, and other relevant plans, including a waste minimi-
zation plan. The elements of the EMP must be easily accessible, but may be integrated into existing plans,
incorporated as an attachment, or developed as a separate document.
Environmental Management System: An Environmental Management System allows an organization to assess
and control the environmental impact of its activities, products, or services. According to the International
Organization for Standardization, there are six key elements of an Environmental Management System: (1) an
environmental policy (an organization's statement of its intentions and commitment to environmental perfor-
mance); (2) planning (the analyses by the organization of the environmental impact of its operations); (3) imple-
mentation and operation (the development and putting into practice of processes that will bring about environ-
mental goals and objectives); (4) checking and corrective action (monitoring and measurement of environmental
indicators to ensure that goals and obj ectives are being met); (5) management review (review of the Environ-
mental Management System by the organization's top management to ensure its continuing suitability, adequacy,
and effectiveness); and (6) continual improvement.
Environmental Protection Agency (EPA): The Federal government agency charged with implementing U. S.
environmental laws and the sponsoring agency for XL proj ects.
Final Project Agreement (FPA): The FPA outlines the details of an XL project and each party's commitments.
The project's sponsors, EPA, state agencies, tribal governments, other regulators, and direct participant stake-
holders negotiate the FPA.
Hazardous Chemical of Concern (HCOC): A chemical that the organization has identified as having the potential
to be of significant risk to human health or the environment if not stored in accordance with procedures or
practices defined by the organization.
Hazardous Waste Accumulation Area: The on-site area at a university where the university will make a solid and
hazardous waste determination with respect to laboratory waste.
Laboratory: For the purpose of this proj ect, an area within a facility where the "laboratory use of hazardous
chemicals" occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a non-
production basis. The physical extent of individual laboratories within an organization will be defined by the
Environmental Management Plan. A laboratory may include more than a single room if the rooms are in the
same building and under the common supervision of a laboratory supervisor.
10
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Laboratory Environmental Management Standard: The defined requirements for preparation of Environmental
Management Plans and the inclusion of Minimum Performance Criteria within each EMP, as defined by 40 CFR
262SubpartJ.
Laboratory Waste: A hazardous chemical that results from laboratory scale activities and includes the following:
excess or unused hazardous chemicals that may or may not be reused outside their laboratory of origin; hazard-
ous chemicals determined to be RCRA hazardous waste as defined in 40 CFR Part 261; and hazardous
chemicals that will be determined not to be RCRA hazardous waste pursuant to 40 CFR 262.106.
Laboratory Worker: A person who is assigned to handle hazardous chemicals in the laboratory and may include
researchers, students, or technicians.
Large Quantity GeneratorPerson or facility which generates more than 2,200 pounds of hazardous waste
per month. In 1989, only 1 percent of more than 20,000 generators fell into this category. Those generators
produced nearly 97 percent of the nation's hazardous waste. These generators are subject to all requirements of
RCRA.
Non-compliance: For the purposes of this standard, activity, conduct, or work practices that do not conform to
the requirements of the Environmental Management Plan and applicable RCRA requirements.
Proj ect XL: A Federal program to conduct pilot proj ects that promote excellence and Leadership through
negotiated agreements with regulated parties.
Resource Conservation and Recovery Act (RCRA): RCRA gives EPA the authority to control the generation,
transportation, treatment, storage, and disposal of hazardous waste. RCRA also set forth a framework for the
management of nonhazardous waste. RCRA enables EPA to address environmental problems that could result
from underground tanks storing petroleum and other hazardous substances. RCRA focuses only on active and
future facilities and does not address abandoned sites.
Small Quantity Generator (SQG): Persons or facilities that produce 220 to 2,200 pounds per month of hazard-
ous waste. SQGs are required to keep more records than conditionally exempt generators. SQGs may include
automotive shops, dry cleaners, photographic developers, and a host of other small enterprises. SQGs comprise
by far the vast maj ority of hazardous waste generators.
Universities: For the purposes of this report, the following academic institutions: University of Vermont, Boston
College, and the University of Massachusetts Boston, which are participants in this Laboratory XL proj ect.
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