Developing a Good Laboratory Management Plan

The problem is so prevalent at colleges and universities that EPA developed a regulatory option (new RCRA Subpart K), intended to encourage officials in charge of thousands of academic labs to periodically collect old, unneeded, or expired chemicals (legacy chemicals), determine whether these chemicals are hazardous, and properly manage their disposal.

If you are an eligible entity you must develop a laboratory management plan (LMP) to describe how you will meet the performance-based standards of the rule. The LMP is divided into two parts. Part I must contain two elements that are enforceable.
Part II must contain seven best practices addressing specific aspects of chemical management; entities may vary from the seven Part II elements without being subject to regulation. One LMP can cover multiple locations with multiple EPA ID numbers provided all locations covered by the LMP are owned by the same eligible academic entity.

Part I elements

1. Describe procedures for container labeling, including:

•     Identifying whether the eligible academic entity will use the term ‘‘unwanted material’’ or an “equally effective term” with the same meaning on the containers in the laboratory, and
•    Identifying the manner in which information that is “associated with the container” will be imparted.

2. Identify whether the unwanted material will be removed from the lab on a regular interval, not to exceed 6 months, or within 6 months of each container’s accumulation start date.

Part II elements

1. Describe the intended best practices for container labeling and management, including equipment such as high performance liquid chromatographs.
2. Describe the intended best practices for providing training for laboratory workers and students commensurate with their duties.
3. Describe the intended best practices for providing training to ensure safe on-site transfers of unwanted material and hazardous waste by trained professionals.
4. Describe the intended best practices for removing unwanted material from the laboratory, including development of a regular schedule and removals within 10 calendar days when maximum volumes are exceeded. Also describe the intended best practices for communicating that unwanted materials have exceeded their maximum volumes.
5. Describe the intended best practices for making hazardous waste determinations, including specifying the duties of the individuals involved in the process.
6. Describe the intended best practices for laboratory cleanouts.
7. Describe the intended best practices for emergency prevention, including procedures for emergency prevention, notification, and response; a list of chemicals that the eligible academic entity has, or is likely to have, that become more dangerous when they exceed their expiration date and/or as they degrade; procedures to safely dispose of chemicals that become more dangerous when they exceed their expiration date and/or as they degrade; and procedures for the timely characterization of unknown chemicals.

The academic entity must make its LMP available to laboratory workers, students, or any party at the institution who requests it. The LMP must also be reviewed and revised as needed.

Again, several of these elements—particularly those addressing chemicals that become more dangerous upon expiration and a regularly scheduled cleanout procedure—are recommended for businesses that have uncertainties about chemicals they have on-site.