Thank you for forwarding the responses. Please do NOT limit them to University Laboratories ONLY, many of us within the private laboratory research landscape encounter, and are limited by the same rules and for the exact same reasons. We are the ones absorbing your graduates into industries while addressing the very same issues from our perspectives, but without your exemptions.
I believe our perspectives are not only relevant, but exactly similar and I would like to see THAT considered by the Agency, since they excluded us last time.
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**med.cornell.edu] On Behalf Of Mary Beth Mulcahy
Sent: Thursday, February 11, 2016 7:09 PM
Subject: Re: [DCHAS-L] Inquiry on safety & hazardous waste compliance for universities
This list serve and personal email conversations have been fascinating on this topic. I'm going to send the responses off tonight, but I did want to say that the person making the inquiry was not (to my understanding) in a rule-making mode, but rather troubleshooting compliance issues in their region. That being said, the RCRA/laboratory history lesson the list serve provided I think will do a lot to shed light on the complexities universities face. Thanks so much for everyone's time.
On Wed, Feb 10, 2016 at 1:57 PM, Robin M. Izzo <rmizzo**At_Symbol_Here**princeton.edu> wrote:
I echo what Pete Reinhardt recommended. It would be helpful to understand the background of the person making the request. The EPA recently collected comments on its proposed changes to RCRA rules regarding hazardous waste, and these changes will affect colleges and universities. If this is someone who is working on that Generator Rule, then I recommend that he speak with representatives from DCHAS, CSHEMA and others. CSHEMA has reached out to EPA to suggest such a conversation. The people working on the new generator rules include individuals who are well aware of college and university issues, having worked with several of us before issuing Subpart K.
Robin M. Izzo
Environmental Health and Safety
Visit the EHS website at ehs.princeton.edu
Chapter 11 of the 2011 edition of Prudent Practices in the Laboratory (National Academies Press) has a thorough discussion of regulations and standards that apply to laboratories. Another good reference is the 2008 edition of the Environmental Compliance Guide for Colleges and Universities, published by APPA and CSHEMA. Also, the ACS Task Force on Laboratory Chemical and Waste Management published Laboratory Waste Management: A Guidebook. The second edition is published by Oxford Press.
Peter A. Reinhardt
Director, Office of Environmental Health & Safety
135 College St., Suite 100
New Haven, CT 06510-2411
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Mary Beth Mulcahy
Sent: Wednesday, February 10, 2016 2:30 PM
Subject: [DCHAS-L] Inquiry on safety & hazardous waste compliance for universities
All, I recently had a conversation with a colleague from EPA concerning hazardous waste compliance for universities, and in our conversation I offered to post an email from him on this list-serve to tap into its collective knowledge (see his email below).
"I am in the process of developing a hazardous waste compliance assistance program for colleges and universities (truly any post-secondary learning institution). Congress asked us [EPA] to regulate the management of hazardous waste through the Resource Conservation and Recovery Act (RCRA). We've routinely done inspections and regrettably find that universities tend to have numerous challenges with waste identification and management. I'm hoping your professional experience in both investigations and education (both as an educator and for the American Chemical Society) can help me find a more effective path than what we have pursued in the past."
So, ideas anyone?
One thing that struck me during the conversation was an article that I saw printed in JCHAS I think in 2010 that listed the numerous federal/state regulations a university was subject to. I remember being surprised by the number of requirements, and thought it would be insightful for this person as well. Despite searching my paper copies of JXHAS and JCHAS' search engine, I'm coming up empty. Any chance someone remembers an article like that?
I'll forward any posts on the topic.
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