Date: Tue, 15 Aug 2006 11:48:53 -0400
Reply-To: esf**At_Symbol_Here**UVM.EDU
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Ralph Stuart <esf**At_Symbol_Here**UVM.EDU>
Subject: Academic Lab Waste Rule: Two easy steps...
Comments: To: lab-xl**At_Symbol_Here**

From: Reinhardt, Peter (Environment Health and Safety)
Sent: Tuesday, August 15, 2006 8:14 AM
Subject: Two easy steps...

And you thought you couldn’t dance! Here’s an easy two-step:

1.  Read EPA’s new lab waste rule and (ta-da!!) CSHEMA’s final,  
submitted comment letter at 
You don’t have to read the preamble —the rule is just the last few  

2.  Send an email to EPA at RCRA-docket**At_Symbol_Here** THIS WEEK  
telling them what is most important to you—what you like, don’t like,  
or would like to see. If you like the CSHEMA comment letter, please  
let them know. CSHEMA’s priorities are listed on pages 2-3 of the  
letter. Comments must be received before next Monday, 8/21.

Some things you might like about EPA’s proposed rule:
· No more “at or near the point of generation” or “under the control
of the operator”
· You can make the waste determination just about anywhere you’d like
· You tell EPA how you will manage your lab waste in your Laboratory
Management Plan
· You don’t count clean-out waste against your generator status
· No more “containers must be closed”
· You have 30 days for big clean-outs (>55 gallons), instead of 3 days

And CSHEMA has suggested many improvements to the rule. We think EPA  
will listen—but your comments are very important and will help! Many,  
many thanks to the several dozens of you who sent me suggestions on  
CSHEMA comment letter—all of the suggestions made the letter better.


Peter A. Reinhardt, Director
Department of Environment, Health & Safety
University of North Carolina
1120 Estes Drive Extension., CB# 1650
Chapel Hill, NC   27599-1650         pareinhardt**At_Symbol_Here**
919-843-5913  Fax: 919-962-0227  Cell: 919-883-7027

Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.