From: Russ Phifer <rphifer**At_Symbol_Here**WCENVIRONMENTAL.COM>
Subject: Re: [DCHAS-L] Inquiry on safety & hazardous waste compliance for universities
Date: Fri, 12 Feb 2016 08:24:02 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 006a01d16598$a3eeb6e0$ebcc24a0$**At_Symbol_Here**

Chris - Subpart K is still in place; however, it has not been successful since it placed even more requirements on academic laboratories and also cut the allowable time for satellite accumulation from one year to six months. It also failed to address university concerns that more time was needed on large campuses for waste to be moved from laboratories to central accumulation at the end of a semester.



Russ Phifer, Executive Director

National Registry of Certified Chemists

125 Rose Ann Lane

West Grove, Pennsylvania 19390


800-858-6273 FAX





From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Kohler, Christopher E
Sent: Thursday, February 11, 2016 8:59 PM
Subject: Re: [DCHAS-L] Inquiry on safety & hazardous waste compliance for universities


HI Mary Beth,


Sorry if this has already been answered, but unless it been repealed, I belive "Subpart K" provides alternatives to RCRA waste disposal specifically for colleges and universities.




Sent from my Verizon Wireless 4G LTE smartphone



-------- Original message --------

From: Mary Beth Mulcahy <mulcahy.marybeth**At_Symbol_Here**GMAIL.COM>

Date: 2/10/2016 2:37 PM (GMT-05:00)


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.


Mary Beth

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