Date: Wed, 31 May 2006 14:17:01 -0500
Reply-To: "Harrington, Rachel" <rachel.harrington**At_Symbol_Here**ROSALINDFRANKLIN.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Harrington, Rachel" <rachel.harrington**At_Symbol_Here**ROSALINDFRANKLIN.EDU>
Subject: Re: EPA Definition of Labs
Comments: To: Ralph Stuart
Comments: cc: Dave Milner
In-Reply-To: A<521C17AD-3B0D-4E16-B059-B52ACDCF87FD**At_Symbol_Here**>

I wholeheartedly agree that sticking to the OSHA definition would be the most effective in implementing a new RCRA standard for labs. Leaving out private and industrial labs would, in my opinion, be a HUGE oversight on their part. I have experience in both types of institutions and see no difference in the essential management while there will, of course, be nuances between each industry just as not every academic institution is the same. I participated in a stakeholders meeting in the summer of 2003 at the EPA headquarters in Chicago that was video broadcast from Washington with all the regions participating. Some of you may remember this and participated, as well. I was in industry at the time (I am now in academia) and industry was well represented at the meeting. I'm not sure where or when industry was dropped out of the scheme of things and had been unable to track the progress of this issue from the EPA website. I intend to comment on the lab definition as I consider limiting this rule to academic laboratories a grave oversight. I'm sure OSHA had no more experience with labs when the 1910.1450 was adopted than EPA has to date. Regards, Rachel Harrington Director, Office of EHS Rosalind Franklin University of Medicine and Science 3333 Green Bay Road North Chicago, IL 60064 847-578-3420 rachel.harrington**At_Symbol_Here** LIFE IN DISCOVERY -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Ralph Stuart Sent: Wednesday, May 31, 2006 1:53 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: [DCHAS-L] EPA Definition of Labs I'm beginning to get through the EPA proposed rule for academic lab waste and notice two the key questions involving the definition of labs. 1. EPA would like comment on whether the rule should be limited to academic labs. Specifically: In addition, EPA is seeking comment on whether to expand the scope of this alternative set of regulations to include other laboratories outside of colleges and universities that have similar hazardous waste generation patterns. For example, this could include government and private laboratories that generate large numbers of different waste streams, each in relatively small quantities that are stored and used in containers that can be easily manipulated by one person. Such an expansion in scope would not include production scale manufacturing laboratories, as they do not have the similar production patterns and unique circumstances that this rulemaking is intended to address. EPA is particularly interested in comments that provide data showing similarities or differences between college and university laboratories and laboratories at other institutions, with regard to hazardous waste generation patterns and challenges. Additionally, EPA seeks comments on whether such an expansion of scope might lead to unintended, adverse consequences for human health or the environment. The reason for this seems to be that EPA feels comfortable that it has a long history of working with academic labs but has less of a history of working with labs in other sectors. Personally, it's not clear to me why labs that meet the OSHA definition in the lab standard would be different in industry as opposed to academia. I wonder if anyone on the list has seen or experienced a large different in the style of labs between the two sectors that would suggest that a management plan approach to lab waste in industry would be less successful than in academia? I also wonder if anyone has suggestions about what kind of data would demonstrate the similarity or differences between academic and industrial labs? 2. The preamble to the rule says that the lab definition is specifically meant to include art studios, while excluding photo processing areas. The definition currently is: Laboratory means an area within a college or university where relatively small quantities of chemicals and other substances are used on a non-production basis for teaching or research purposes and are stored and used in containers that are easily manipulated by one person. An area where the same hazardous waste is routinely generated, such as photo processing, is not a laboratory. At UVM, we have many darkrooms interspersed among our labs and art studios and the implication of this statement is that we would have to have two separate systems side by side in the same building, which seems cumbersome at best. Do other campuses have similar concerns? It seems to me that both issues could be resolved by simply sticking to the OSHA definition of labs in delimiting the Universe of this rule. Thanks for any suggestions. - Ralph Ralph Stuart, CIH Environmental Safety Manager University of Vermont Environmental Safety Facility 667 Spear St. Burlington, VT 05405 rstuart**At_Symbol_Here** fax: (802)656-5407

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