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Demystify: 

Date: Tue, 15 Aug 2006 11:48:53 -0400
Reply-To: esf**At_Symbol_Here**UVM.EDU
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Ralph Stuart <esf**At_Symbol_Here**UVM.EDU>
Subject: Academic Lab Waste Rule: Two easy steps...
Comments: To: lab-xl**At_Symbol_Here**list.uvm.edu

From: Reinhardt, Peter (Environment Health and Safety)
Sent: Tuesday, August 15, 2006 8:14 AM
Subject: Two easy steps...

And you thought you couldnít dance! Hereís an easy two-step:

1.  Read EPAís new lab waste rule and (ta-da!!) CSHEMAís final,  
submitted comment letter at http://www.cshema.org/committee/ 
Govtrelations/academiclabrule.htm
You donít have to read the preamble óthe rule is just the last few  
pages.

2.  Send an email to EPA at RCRA-docket**At_Symbol_Here**epamail.epa.gov THIS WEEK  
telling them what is most important to youówhat you like, donít like,  
or would like to see. If you like the CSHEMA comment letter, please  
let them know. CSHEMAís priorities are listed on pages 2-3 of the  
letter. Comments must be received before next Monday, 8/21.

Some things you might like about EPAís proposed rule:
∑ No more ìat or near the point of generationî or ìunder the control
of the operatorî
∑ You can make the waste determination just about anywhere youíd like
∑ You tell EPA how you will manage your lab waste in your Laboratory
Management Plan
∑ You donít count clean-out waste against your generator status
∑ No more ìcontainers must be closedî
∑ You have 30 days for big clean-outs (>55 gallons), instead of 3 days

And CSHEMA has suggested many improvements to the rule. We think EPA  
will listenóbut your comments are very important and will help! Many,  
many thanks to the several dozens of you who sent me suggestions on  
CSHEMA comment letteróall of the suggestions made the letter better.

Pete

Peter A. Reinhardt, Director
Department of Environment, Health & Safety
University of North Carolina
1120 Estes Drive Extension., CB# 1650
Chapel Hill, NC   27599-1650
http://ehs.unc.edu         pareinhardt**At_Symbol_Here**ehs.unc.edu
919-843-5913  Fax: 919-962-0227  Cell: 919-883-7027

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