From: Ralph Stuart <rstuartcih**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Inquiry on safety & hazardous waste compliance for universities
Date: Sun, 14 Feb 2016 13:30:54 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: B40A9C94-3FB7-48BE-BDDA-BD47A6E0E2F0**At_Symbol_Here**
In-Reply-To <006a01d16598$a3eeb6e0$ebcc24a0$**At_Symbol_Here**>

>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.

I don't agree that these reasons are why Subpart K has not been a wild success. It does work well in simplifying RCRA requirements in labs in those states where it is allowed (about half of the country) and on campuses where the waste management program is willing to develop an overall plan for the management of lab waste. I think that the development of this plan is what is referred to as "even more requirements" above.

The advantages of Subpart K are:
- It moves away from the industrial model of large amounts of a limited number of waste streams to recognize a diverse, diffuse set of waste streams;
- It moves the "point of generation" of the waste out of the laboratory, so that lab staff do not have to understand RCRA requirements such as waste codes, etc. The overall campus plan provides a mechanism for equivalent environmental protections.
- It takes away the need to create a separate system for non-RCRA and RCRA chemical wastes; since many toxic chemicals are in use in labs that aren't on the RCRA lists, parallel systems create confusion when they require different labelling systems, etc.

The primary disadvantage of Subpart K that I have heard about is the fact that people well-versed in RCRA regulations don't like to have to think outside of that box. But as last fall's proposed generator rules changes showed, the "point of generation" question is going to continue to persist and become more problematic for labs if the RCRA model remains the same there.

- Ralph

Ralph Stuart, CIH

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