The generation, storage and disposal of waste is one of the most challenging environmental regulatory compliance issues facing laboratories. Compared to many industrial facilities, academic labs tend to produce smaller amounts of a wider variety of waste types. Wastes must be collected, classified, labeled, stored, and disposed of in accordance with federal and often even stricter state regulations.
Hazardous and non-hazardous solid wastes are regulated at the federal level by the EPA under the Resource Conservation and Recovery Act (RCRA). Many states also have their own, sometimes more stringent, regulations. The overall intent of RCRA is to manage hazardous waste from generation to ultimate disposal. This "cradle to grave" approach has resulted in regulations governing hazardous waste generators, transporters, and treatment, storage, and disposal (TSD) facilities. Given that most university facilities do not themselves transport hazardous waste to an off-site hazardous waste disposal facility, treat hazardous waste, or operate a hazardous waste disposal facility, the regulations governing these activities are not addressed in the tour. More typically, your facility would generate, store the solid waste, hazardous waste--and, in some cases, biological waste, radioactive and mixed waste, and then have a contractor transport the waste off site for disposal. The specific hazardous waste management requirements a facility must follow depend on the facility's generator status and the types of waste it produces. In other words, the generator status of the college or university will determine the type of requirements individual departments may need to follow.
Radioactive wastes are regulated by the NRC. Mixed waste, waste that exhibits characteristics of both hazardous and radioactive waste, must be managed under both sets of regulations. There are very few federal regulations that currently address biological wastes, however most states and other local agencies have issued regulations regarding the disposal of biologically active material and medical wastes.
A listing of major RCRA requirements is presented below. The major elements of the hazardous waste storage and disposal regulations applicable to laboratories include the following:
- Waste Characterization
- Permitting
- Training
- Recordkeeping and Reporting
- Labeling
- Shipping
- Storage
- Emergency Preparedness and Response
- Source Reduction Strategy
Continue on through the expanded section of this activity to learn more about waste determination.