I wholeheartedly agree that sticking to the OSHA definition would be the
most effective in implementing a new RCRA standard for labs.  Leaving
out private and industrial labs would, in my opinion, be a HUGE
oversight on their part.  I have experience in both types of
institutions and see no difference in the essential management while
there will, of course, be nuances between each industry just as not
every academic institution is the same.  

I participated in a stakeholders meeting in the summer of 2003 at the
EPA headquarters in Chicago that was video broadcast from Washington
with all the regions participating. Some of you may remember this and
participated, as well. I was in industry at the time (I am now in
academia) and industry was well represented at the meeting.  I'm not
sure where or when industry was dropped out of the scheme of things and
had been unable to track the progress of this issue from the EPA
website.

I intend to comment on the lab definition as I consider limiting this
rule to academic laboratories a grave oversight.  I'm sure OSHA had no
more experience with labs when the 1910.1450 was adopted than EPA has to
date. 

Regards, 

Rachel Harrington
Director, Office of EHS
Rosalind Franklin University of Medicine and Science
3333  Green Bay Road
North Chicago, IL  60064
847-578-3420
rachel.harrington**At_Symbol_Here**rosalindfranklin.edu

LIFE IN DISCOVERY

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Ralph Stuart
Sent: Wednesday, May 31, 2006 1:53 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] EPA Definition of Labs

I'm beginning to get through the EPA proposed rule for academic lab  
waste and notice two the key questions involving the definition of labs.

1. EPA would like comment on whether the rule should be limited to  
academic labs. Specifically:

In addition, EPA is seeking comment on whether to expand the scope
of this alternative set of regulations to include other laboratories
outside of colleges and universities that have similar hazardous waste
generation patterns. For example, this could include government and
private laboratories that generate large numbers of different waste
streams, each in relatively small quantities that are stored and used
in containers that can be easily manipulated by one person. Such an
expansion in scope would not include production scale manufacturing
laboratories, as they do not have the similar production patterns and
unique circumstances that this rulemaking is intended to address. EPA
is particularly interested in comments that provide data showing
similarities or differences between college and university laboratories
and laboratories at other institutions, with regard to hazardous waste
generation patterns and challenges. Additionally, EPA seeks comments on
whether such an expansion of scope might lead to unintended, adverse
consequences for human health or the environment.

The reason for this seems to be that EPA feels comfortable that it  
has a long history of working with academic labs but has less of a  
history of working with labs in other sectors.

Personally, it's not clear to me why labs that meet the OSHA  
definition in the lab standard would be different in industry as  
opposed to academia. I wonder if anyone on the list has seen or  
experienced a large different in the style of labs between the two  
sectors that would suggest that a management plan approach to lab  
waste in industry would be less successful than in academia? I also  
wonder if anyone has suggestions about what kind of data would  
demonstrate the similarity or differences between academic and  
industrial labs?

2. The preamble to the rule says that the lab definition is  
specifically meant to include art studios, while excluding photo  
processing areas. The definition currently is:
Laboratory means an area within a college or university where
relatively small quantities of chemicals and other substances are used
on a non-production basis for teaching or research purposes and are
stored and used in containers that are easily manipulated by one
person. An area where the same hazardous waste is routinely generated,
such as photo processing, is not a laboratory.

At UVM, we have many darkrooms interspersed among our labs and art  
studios and the implication of this statement is that we would have  
to have two separate systems side by side in the same building, which  
seems cumbersome at best. Do other campuses have similar concerns?

It seems to me that both issues could be resolved by simply sticking  
to the OSHA definition of labs in delimiting the Universe of this rule.

Thanks for any suggestions.

- Ralph

Ralph Stuart, CIH
Environmental Safety Manager
University of Vermont
Environmental Safety Facility
667 Spear St. Burlington, VT  05405

rstuart**At_Symbol_Here**uvm.edu
fax: (802)656-5407

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