This section of the tour deals primarily with the generation and management of hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA).
One of the most challenging environmental regulatory compliance issues facing laboratories is the generation, storage and disposal of waste. Compared to many industrial facilities, medical labs tend to produce smaller amounts of a wider variety of waste types. All of these wastes must be collected, classified, labeled, stored and disposed of, and these activities must be handled in accordance with federal regulations--and often even stricter state and local regulations.
Typically, medically laboratories generate, store and dispose of solid and hazardous waste--and, in some cases, radioactive and mixed waste. Radioactive wastes are regulated by the NRC. Mixed waste--that is, waste that exhibits characteristics of both hazardous and radioactive waste--must be managed under both NRC and RCRA regulations.
Although most states and other local agencies have issued regulations regarding the disposal of medical and infectious wastes, there are very few federal regulations that do so. You'll find coverage of these issues in their own section of the tour.
At the federal level, hazardous and non-hazardous solid waste is regulated by the EPA under the RCRA, whose overall intent is to manage this waste from generation to ultimate disposal. This "cradle-to-grave" approach has resulted in regulations governing hazardous waste generators, transporters and TSD (treatment, storage and disposal) 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 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.
As you may know, the federal Resource Conservation and Recovery Act (RCRA) and the implementing federal regulations at 40 CFR Parts 260-272 govern hazardous waste management. Many states also have their own, sometimes more stringent, regulations. Not only is hazardous waste management one of the most common environmental issues at college and university campuses, but the specific requirements for hazardous waste (RCRA) are so numerous, the tour has, as appropriate, split the content into three areas as follows:
- RCRA (Storage/Disposal)
- RCRA (Recordkeeping)
- RCRA (Training/Other)
Continue further along the tour and learn more about RCRA storage/disposal requirements.