> >Does anyone else do this or have any guidance for streamlining this process?
The question you ask is one of the reasons I worked (for ten years) to help the EPA decide to institute a rule specific to academic laboratories. According to https://www.epa.gov/hwgenerators/where-managing-hazardous-waste-academic-laboratories-rule-effect
Michigan has authorized the use of Subpart K in your state. This presents an opportunity for streamlining the waste determination process at your campus if it chooses to write an Environmental Management Plan as specific in this regulation.
Let me know if you have any questions about this.
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
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