Yesterday we talked about general container management and labeling requirements under the Academic Laboratory Rule. Here’s what you’ve got to do when it’s time to get rid of those containers.
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Scheduled Removal
An eligible academic entity must either remove all containers of unwanted material from each laboratory on a regular interval, not to exceed 6 months, or remove containers of unwanted material from each laboratory within 6 months of each container’s accumulation start date. The eligible academic entity must specify in its Laboratory Management Plan (LMP) which of these two procedures it will follow for removing unwanted material from its laboratories and develop a schedule for regular removals of unwanted material from its laboratories.
Yes, there’s a plan requirement too–more on the LMP below.
Removing Containers When Volumes are Exceeded
If a laboratory accumulates a total volume of unwanted material (including reactive acutely hazardous unwanted material) in excess of 55 gal before the regularly scheduled removal, the eligible academic entity must ensure that all containers of unwanted material in the laboratory (including reactive acutely hazardous unwanted material):
- Are marked 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) with the date that 55 gal is exceeded
- Are removed from the laboratory within 10 calendar days of the date that 55 gal was exceeded, or at the next regularly scheduled removal, whichever comes first
- If a laboratory accumulates more than 1 quart of reactive acutely hazardous unwanted material before the regularly scheduled removal, the eligible academic entity must ensure that all containers of reactive acutely hazardous unwanted material:
- Are marked 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) with the date that 1 quart is exceeded.
- Are removed from the laboratory within 10 calendar days of the date that 1 quart was exceeded, or at the next regularly scheduled removal, whichever comes first.
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Drafting a Laboratory Management Plan
An eligible academic entity must develop and retain a written LMP. The LMP is a site-specific document that describes how the eligible academic entity will manage unwanted materials in compliance with the Academic Laboratory Rule. An eligible academic entity may write one LMP for all the laboratories owned by the eligible academic entity that have opted into the Academic Laboratory Rule, even if the laboratories are located at sites with different EPA ID Numbers.
The LMP must describe how a college or university will meet the required standards for:
- Container management and labeling;
- Training of laboratory workers, other appropriate faculty, and environmental health and safety personnel, commensurate with their duties;
- Instructing students;
- Ensuring safe movement of the unwanted materials from the laboratory to an on-site central accumulation area; an on-site interim status/permitted TSDF; or an off-site interim status/permitted TSDF; and
- Conducting laboratory clean-outs, if the eligible academic entity chooses to conduct these events.
What About Training?
An eligible academic entity must provide training to all individuals working in a laboratory at the eligible academic entity. Training for laboratory workers and students must be commensurate with their duties so they understand the requirements of the Academic Laboratory Rule and can implement them. An eligible academic entity can provide training for laboratory workers and students in a variety of ways, including any of the following:
- Instruction by the professor or laboratory manager before or during an experiment
- Formal classroom training
- Electronic/written training
- On-the-job training
- Written or oral exams
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An eligible academic entity that is an LQG must maintain documentation demonstrating training for all laboratory workers that is sufficient to determine whether laboratory workers have been trained. Examples of training documentation can include:
- Sign-in/attendance sheets for training sessions
- Syllabus for training session
- Certificate of training completion
- Test results
A trained professional must accompany the transfer of unwanted material and hazardous waste when the unwanted material and hazardous waste is removed from the laboratory, and make the hazardous waste determination for unwanted material.