As someone who has served for 35 years on the ACS task force group on RCRA, I have witnessed at least five initiatives within EPA to address laboratory waste issues. For 35 years, ACS has recognized the difficulty laboratories have had in complying with these regulations and has tried continually to educate EPA and Congress on these issues. In each case, information was provided, study was done, and then… nothing. The problems associated with proper waste identification and management are not solely due to insufficient training and communication; they also go to the heart of the regulatory requirements. The RCRA regulations were designed for industrial facilities with industrial quantities of hazardous waste. Laboratories have always been an afterthought when considering if these requirements are fair or workable. Each time ACS has provided comments, attended hearings, or met with Congressional or EPA staff, our issues have largely fallen on deaf ears. EPA priorities change, Agency work groups are abandoned, and nothing is accomplished.
While a waste compliance assistance program is a worthy goal, perhaps it is time to finally address the problems laboratories have complying with regulations which were not designed for laboratory operations. If the regulations worked in a lab setting, this would not be an issue. The technical expertise and resources to develop sound waste management programs are there in a university setting. What is not there is the regulatory flexibility needed to make these programs work effectively.
Russ Phifer
Russ Phifer
WC Environmental, LLC
1085C Andrew Drive
West Chester, PA 19380
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Cell - 610-322-0657
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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
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.ESubject: [DCHAS-L] Inquiry on safety & hazardous waste compliance for univesetrsities
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."
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.
Thanks,
Mary Beth
