Managing Hazardous Waste at Academic Laboratories Rulemaking
On December 1, 2008, EPA added a new subpart, subpart K, to the Resource Conservation and Recovery Act (RCRA) hazardous waste generator regulatory requirements in Title 40 of the Code of Federal Regulations (CFR) in Part 262. Subpart K is applicable to eligible academic entities, which are:
- colleges and universities, and
- teaching hospitals and nonprofit research institutes that are either owned by or formally affiliated with a college or university.
The rule establishes an optional, alternative set of regulations that allow eligible academic entities the flexibility to make hazardous waste determinations:
- in the laboratory;
- at an on-site central accumulation area; or
- at an on-site treatment, storage, or disposal facility (TSDF).
This rule also provides incentives for eligible academic entities to clean-out old and expired chemicals that may pose unnecessary risk. Further, this rule requires eligible academic entities that choose to manage their hazardous waste according to the rule to develop a Laboratory Management Plan. This is expected to result in safer laboratory practices and increased awareness of hazardous waste management.
Eligible academic entities may also choose not to follow the standards in this rule and remain subject to the pre-existing hazardous waste generator requirements.
EPA made six technical corrections to improve the clarity of the 2008 academic laboratories rule on December 20, 2010. These changes correct omissions, redundancies, and an obsolete reference in the 2008 rule.
This rulemaking was the culmination of many years of investigation and participation by EPA in efforts designed to better understand the challenges the academic community faces when managing hazardous waste in laboratories.
On May 23, 2006, EPA proposed a flexible and protective set of regulations that addressed the specific nature of hazardous waste generation and accumulation in college and university laboratories.
Prior to the proposed rule, EPA engaged in several efforts to facilitate improved reuse and recycling of chemicals in educational institutions and better waste management overall.
Pilot Project Led by the Howard Hughes Medical Institute
EPA participated in a collaborative, consensus-based project with the Howard Hughes Medical Institute (HHMI), 10 leading academic research institutions affiliated with HHMI, and state environmental agencies. Together these organizations developed a best practices approach for managing hazardous wastes in academic research institutions, which includes effective and practical approaches for stimulating additional reuse and recycling of chemicals. EPA issued a Report to Congress on this project in 2002.
- The 2002 Report to Congress
- May 30, 2002 Federal Register notice announcing the availability of the Report to Congress
- HHMI Laboratory Safety Program Exit
New England Universities Laboratories XL Project
Project XL, which stands for “eXcellence and Leadership,” was a national initiative that tests innovative ways of achieving better and more cost-effective public health and environmental protection. EPA's Region 1 is conducted The New England Universities Laboratories XL Project, which was designed to develop a more effective scheme for regulating university laboratories, to develop programs to enhance laboratory safety, and to illustrate better systems to manage laboratory environmental impacts.
1989 Report to Congress
In 1984, when the Hazardous and Solid Waste Amendments (HSWA) to RCRA were passed, Congress directed EPA to identify the problems associated with the management of hazardous wastes from educational institutions and to analyze the feasibility and availability of environmentally sound methods for its treatment, storage and disposal.
EPA developed several guidance documents to help college and university laboratories understand the set of requirements established by this rulemaking:
- Detailed Look at the Academic Laboratories Rule's Provisions
- Side-by-Side Comparison of Satellite Accumulation vs Academic Labs Rule
- How to Get Started with Subpart K
- How to Opt-into Academic Labs Rule Using Notification
- How to Do Container Labeling Under the Academic Laboratories Rulemaking (Subpart K)
- Lab Management Plan Brainstorming Worksheet
- Labs Rule Benefits