UriHed Environmental PrQ*££tif>n Agency How to Get Started Under Subpart K Taking it Step by Step Learning Curve The first thing you want to do is learn as much as you can about Subpart K, so you can make informed decisions. We recommend that you read the Federal Register, including the preamble (73 FR 72912; December 1, 2008), and review frequent questions and other implementation materials for additional information. All of these materials are available on EPA's website: If you are interested in opting into Subpart K, you need to make sure that you are allowed to. You can only opt into Subpart K if your institution is an eligible academic entity. Make sure your institution is one (or more) of the following: 1. College or university 2. Teaching Hospital that is owned by or has a formal affiliation with a college or university 3. Non-profit research institute that is owned by or has a formal affiliation with a college or You also need to make sure the rule is effective in your state. Even if your institution is an eligible academic entity, you can not operate under Subpart K unless your state has adopted the rule first or you are located in Iowa, Alaska, and the territories. Decide Whether to Opt into Subpart K If Subpart K is effective in your state and your institution is an eligible academic entity with laboratories, then you have the choice of opting into Subpart K. If your institution opts in, this means that you will manage your laboratory hazardous waste under this new set of regulations instead of the RCRA satellite accumulation area regulations that you currently operate under. Before opting in, you should to consult with your administration/dean and maybe your legal counsel. You and your administration should decide together whether your institution will opt into Subpart K. You want to make sure you will have support to follow through with the transition. If your institution has more than one EPA Identification Number or more than one site, part of the decision about opting in will be to decide which sites will be opting in. When opting in, all the laboratories operating under the same EPA Identification Number (or on the same site) must opt in. Not all your sites have to opt in - although it is probably in your best interest to have all the laboratories on a campus operating under the same system. http://www.epa.gov/waste/hazard/generation/labwaste university ------- Plan for the Transition to Subpart K Next, identify personnel that will be involved in planning and implementing Subpart K for your institution. For example, identify who will write your Laboratory Management Plan (LMP), and who will develop and conduct training for laboratory workers and students. Once your resources are identified, you can begin to develop a timeline for your institution's transition. Set a deadline for writing your LMP, and prepare a schedule for rolling out training to your laboratory personnel. Finally, identify a start date for when your institution will begin implementing Subpart K. Write the Laboratory Management Plan (LMP) for all your sites that will be opting in. You must develop an LMP with two parts. The first part is where you select options available to you under the rule. The second part is where you develop your own site-specific best management practices for managing your laboratory hazardous waste in accordance with Subpart K. An "LMP Brainstorming Worksheet" is on EPA's website, listed above, under "Implementation of Academic Laboratories Rulemaking." Taking the First Steps Once your LMP is prepared, you can begin training your laboratory personnel, including laboratory workers (e.g., faculty, staff, technicians, post-docs, etc.) and students on how to manage the laboratory hazardous waste. Everyone must be trained "commensurate with their duties." This means that the more responsibility someone has for managing hazardous wastes generated in the laboratory, the more training that person should have. When your laboratory personnel are trained and ready to implement Subpart K, the next step is to fill out and submit your notification (EPA's Site Identification Form, also called the 8700-12) to your State or Region that you will be operating under Subpart K. You must submit a separate notification for each site (each EPA Identification Number) that is opting into Subpart K. You are ready to implement Subpart K in your laboratories This document is for planning purposes only and does not constitute, replace or change the regulations Unhed etatss Envirprimprrfal Agency ------- |