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RCRA - Storage/Disposal Overview
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RCRA - Storage/Disposal Details 

In 1990, Congress passed the Pollution Prevention Act 42 U.S.C. 13101 and 13102 et seq. (1990). The act sets out the following National Policy:

The Congress hereby declares it to be the national policy of the United States that pollution should be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be recycled in an environmentally safe manner, whenever feasible; pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner.

In accordance with this policy, the Resource Conservation and Recovery Act (RCRA) requires generators of hazardous waste either to develop a formal program to minimize it or to make good faith efforts to reduce it. (What those efforts consist of depends on the generator’s status in terms of volume.) In addition, many states such as Massachusetts have issued state regulations mandating that facilities make efforts to reduce the use of toxic materials.

Laboratories have the potential to benefit in several ways from implementing comprehensive pollution prevention programs. The most immediate benefit is a reduction in operating expenses. By reducing the generator status of the lab through diminished waste volume, the laboratory lowers costs and also reduces the institution’s risk with regard to future environmental liabilities. A reduction in generator status further minimizes the effort required to comply with environmental regulations. These programs also represent good environmental stewardship and demonstrate good faith in complying with regulations. Finally, laboratories can help to protect their employees from potential harmful exposure by reducing the use of toxic materials and minimizing hazardous wastes.

Some of the key elements to setting up an effective program to minimize waste and reduce the use of toxic materials include the following:

  • Top Management Support - Top management support is critical, indicating to researchers and staff the importance of pollution prevention efforts.
  • Chemical Inventory - To assess where it might minimize chemical use or implement substitution, the lab first needs to know what chemicals it has, in what quantities and what they’re used for.
  • Waste Stream Analysis - The lab also needs to know the types of wastes it generates and how much of each.
  • Feasibility Analysis - Based on the chemical inventory and waste stream analysis, the lab needs to identify where toxic materials can be replaced or reduced, and where wastes can be eliminated, minimized or recycled. Click on Best Management Practices for recommendations.
  • Implementation of Selected Efforts - Based on the feasibility analysis, the lab should select those reduction opportunities that can produce the most benefit. Investment in special equipment, development of procedures and staff training may be required.
  • Results Evaluation - The lab should periodically evaluate the effectiveness of the program, make changes where necessary, and gradually expand implementation.

Additional information and links about pollution prevention activities can be found at the EPA’s Pollution Prevention Information Clearinghouse Resource List at :

http://www.epa.gov/opptintr/library/ppicdist.htm#Gen

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