5 responses I received about my posting yesterday. I hope that it's ok that I forward people's names and comments along to the list to help others think through the issues. If I prefer I not do this, please let me know if the e-mail you send to me. - Ralph From: "William Parks"
Date: May 31, 2006 5:11:15 PM EDT Subject: Re: [DCHAS-L] EPA Definition of Labs The single biggest difference between academic labs and labs in general industry, as I understand it, are that academic labs do not have employees - they have students, and of course, faculty and staff which are employees. EPA and OSHA have no real differences in waste management, waste streams, etc., that being said, in practice waste photo processing solution, while not as flammable as Karl Fischer solvent, is still flammable, but not usually stored in waste or bulk quantities of Karl Fischer solvent. Beyond that, the only real waste management practice to remember is the 90 day storage limit. EPA also regulates TSDF's. Bill Parks R.P.I.H. CHEMPHYXX 877/402-6609 **Providing sound Occupational Safety and Health, Industrial Hygiene, and Environmental services and solutions** ==== From: ACTSNYC**At_Symbol_Here**cs.com Date: May 31, 2006 5:19:00 PM EDT To: rstuart**At_Symbol_Here**uvm.edu Subject: Re: [DCHAS-L] EPA Definition of Labs I don't know what they mean by "relatively small quantities of chemicals." The art studios I see such as ceramics, printmaking, metalwork, foundry, etc., etc., buy stuff in pretty hefty quantities. Ceramics areas are likely to have RCRA regulated chemicals like barium carbonate in 100# sacks, and buy silica- containing dry clay, tack, and other minerals by the pallet. The printmakers buy solvents in 5 and even 55 gallon drums. I can't imagine an art foundry being treated as a laboratory. Big art painting studios will also have flammable storage cabinets full to the brim. I guess, despite my schedule, I'd better submit some comments, too. Especially, if there is any assumption that the university art faculty is chemically sophisticated. This is why I always recommend that universities put their art departments under hazcom if they can. These faculty need regular training, simple rules, etc. Monona Rossol == From: "Linda Waller" Date: May 31, 2006 5:32:04 PM EDT Subject: Re: [DCHAS-L] EPA Definition of Labs Ralph, Being from a small campus with CESQG status, these regulations are of definite interest to me. On your point #1, I would agree with you that with the few labs I have seen outside of academics that fit the lab standard definition, the EPA rules would seem to apply there also. As far as #2, I have the exact same issue with our photography waste. Actually, we collect it in the arts and sciences as there are scientists doing their own photography for their research processes. As all of the work for photography is done for teaching and/or research purposes, it seems to me to fit the lab definition EPA is looking at, even though the waste collected is still the same fixer/ developer solution. Thus, I find this to be a bit of a dilemma as we would be fulfilling both the definition and the exception... Of course, as a CESQG, I still have room to work with the photography waste, but this will not simplify the applications at the university level if I have to track both systems (lab and general industry). If the EPA is truly trying to help the academic arena comply and meet standards, it seems to me that this specific exception will not be adding to the clarifications needed. Linda Linda Waller NNU Safety Office liwaller**At_Symbol_Here**nnu.edu (208) 467-8833 == From: David Bunzow Date: May 31, 2006 5:39:09 PM EDT Subject: Re: [DCHAS-L] EPA Definition of Labs Having worked in labs both in industry and academia, the reluctance to include non-academic labs could be either a familiarity/trust issue or that other labs may also be associated with non-lab situations within the same facility and subject to existing RCRA regulations (as will be the case for academic photo "labs" that are being excluded in this proposal). I would prefer to see adoption and application of a definition for "laboratory" without the qualifier "academic". Perhaps the number and type of labs that would need to be included prevents this from being realistic, but the OSHA 29CFR1910.1450 definition is a good starting point. Of course, there's no mileage to be gained when OSHA and EPA use the same definitions and criteria... I intend to comment (with a touch more eloquence and focus) before the end of the comment period as well. Regards, David -- David A. Bunzow CET; CHMM; CHO; REM Associate Director; Facilities and Operations Advanced Technology Prototyping Manager UAF Office of Electronic Miniaturization Wells Fargo Bank Facility; Suite 300 P.O. Box 758090 Fairbanks, AK 99775-8090 Phone: 907-455-2006 (office) 907-590-0120 (cell) E-Mail: fndb**At_Symbol_Here**uaf.edu URL: www.silicontundra.org From: "Russ Phifer" Date: June 1, 2006 7:30:26 AM EDT Subject: RE: EPA Definition of Labs As someone who has managed laboratory wastes from several hundred industrial, academic & governmental labs for the past 30 years, I believe I can address this issue with some degree of personal experience. First of all, there is no significant difference in what is generated between these different types of laboratories or even how they are managed on-site; the difference is in, as EPA puts it, "generation patterns". Schools tend to accumulate their "routine" waste on a periodic basis roughly coinciding with semester breaks. Industrial & governmental labs generate on a more steady basis. While it is clear that ANY effort to address the problems directly associated with lab waste (too numerous to mention)is a positive step, at least one of the proposed regulations (days a lab can exceed maximum volume)was really designed just for academic labs. Industrial R&D labs typically can move waste more quickly, largely because they don't have every lab on their site all wanting or needing their wastes moved at once. On the other hand, industrial & governmental labs could clearly benefit from having the waste determination made at the central accumulation area, and there is no logical reason why this should be limited to academic facilities. As for other aspects of the proposed standard, I applaud the requirement for training, but don't understand why the training recordkeeping requirement apparently applies only to large quantity generators (262.207(1). Does this mean SQGs don't have to train their workers or students, or just that they don't have to document any training? The fact is, larger generators tend to have more money, more hazardous waste personnel, larger safety departments, and better management systems in place to start with. Isn't there a far greater chance of something going wrong (incompatible waste, improper labeling, improper classification) in a smaller facility with fewer (or no) trained personnel? I believe it should be manditory that any facility taking advantage of the flexibility provided under this regulation have properly trained personnel and be able to document their training. Further, some specific minimum training requirements should be developed and included either as an appendix to the standard or as part of a Laboratory Management Plan submitted to EPA or at least maintained by the generator. An additional concern is that under the proposed standard, training and instruction can be provided by "Instruction by the professor/manager before or during an experiment" (262.207(e) (1). Shouldn't there be a requirement that this individual be properly trained?? There is nothing in the standard that indicates the trainer has to be a "RCRA-Trained Individual" or that the formal classroom training, electronic/written training, on-the-job training, or written or oral exam alternatives has to be managed by a RCRA- Trained Individual. Those are my main concerns and the ones I will address individually as well as through the ACS Task Force on Laboratory Environment, Health & Safety and it's joint comments. Russ Phifer WC Environmental, LLC PO Box 1718, 1085C Andrew Drive West Chester, PA 19380 610-696-9220 ext. 12 /610-344-7519 fax rphifer**At_Symbol_Here**glasmesh.com
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