Academic Laboratory Rule Gives Hazwaste Determination Options

EPA expects compliance with these provisions to result in safer laboratory practices and increased awareness of hazardous waste management.

Who is eligible—Colleges, universities, teaching hospitals, and nonprofit research institutes that are either owned by or formally affiliated with a college or university all have the option to follow the Academic Laboratory Rule.

Notification – An eligible academic entity must notify the appropriate EPA regional administrator in writing, using the RCRA Subtitle C Site Identification Form (EPA Form 8700-12), that it is electing to be subject to the requirements of the Academic Laboratory Rule for all the laboratories owned by the eligible academic entity under the same EPA ID Number. An eligible academic entity that is a CESQG and does not have an EPA ID Number must notify that it is electing to be subject to the requirements of the Academic Laboratory Rule for all the laboratories owned by the eligible academic entity that are on-site.

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LQGs and SQGs. An eligible academic entity that is either an LQG or an SQG must have a trained professional make the hazardous waste determination for unwanted material in any of the following areas:

• In the laboratory before the unwanted material is removed from the laboratory in accordance with 40 CFR 262.210
• Within 4 calendar days of arriving at an on-site central accumulation area in accordance with 40 CFR 262.211
• Within 4 calendar days of arriving at an on-site interim status or permitted TSDF in accordance with 40 CFR 262.212

A trained professional must accompany all hazardous waste that is transferred from the laboratory to the on-site central accumulation area or on-site TSDF.

CESQGs. An eligible academic entity that is a CESQG must ensure that a trained professional makes a hazardous waste determination for unwanted material in the laboratory before the unwanted material is removed from the laboratory in accordance with 40 CFR 262.210.

In the Laboratory

If an eligible academic entity makes the hazardous waste determination in the laboratory, it must have a trained professional make the hazardous waste determination before the unwanted material is removed from the laboratory.

If an unwanted material is a hazardous waste, the eligible academic entity must:

• Write the words "hazardous waste" on the container label that is affixed or attached to the container before the hazardous waste may be removed from the laboratory.
• Write the appropriate hazardous waste codes on the label that is associated with the container (or on the label that is affixed or attached to the container, if that is preferred) before the hazardous waste is transported off-site.
• Count the hazardous waste toward the eligible academic entity’s generator status, pursuant to 40 CFR 261.5(c) and (d), in the calendar month that the hazardous waste determination was made.

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When hazardous waste is removed from the laboratory:

• LQGs and SQGs must ensure it is taken directly from the laboratory to an on-site central accumulation area, or an on-site interim status or permitted TSDF, or transported off-site.
• CESQGs must ensure it is taken directly from the laboratory to any of the types of facilities listed in 40 CFR 261.5(f)(3) for acute hazardous waste, or 40 CFR 261.5(g)(3) for hazardous waste.

An unwanted material that is a hazardous waste is subject to all applicable hazardous waste regulations when it is removed from the laboratory.

See tomorrow’s Advisor for hazardous waste determination information at an on-site central accumulation area and an on-site TSDF under the Academic Laboratory Rule.