From: Ralph Stuart <rstuartcih**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Inquiry on safety & hazardous waste compliance for universities
Date: Wed, 10 Feb 2016 15:00:22 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 1861FB6D-2D02-42B0-9343-B070218B08C8**At_Symbol_Here**

> We"ve routinely done inspections and regrettably find that universities tend to have numerous challenges with waste identification and management.

In the comments the ACS has filed with EPA over the years in a variety of venues, we have identified the nature of these challenges to be related to the regulatory model that RCRA is based on, particularly with regard to those issues rather than the lack of compliance assistance from the federal EPA. See
for our most recent statement on this issue.

As EPA acknowledged with the promulgation of Subpart K of RCRA, the laboratory, as well as other aspects of the academic environment presents many situations that do not fit into the EPA's regulatory model. In my opinion, a hazardous waste compliance assistance program that does not address the issues raised in the Subpart K preamble is unlikely to gain much traction with the audience identified for this effort.

Let me know if you have any questions about this.

- Ralph

Ralph Stuart, CIH

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