Hazardous Waste Management

Taking Advantage of Laboratory Clean-Outs


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.

What Is a Laboratory Clean-Out?

This is an evaluation of the inventory of chemicals and other materials in a laboratory that are no longer needed or that have expired and the subsequent removal of those chemicals or other unwanted materials from the laboratory. A clean-out may occur for several reasons. It may be on a routine basis (e.g., at the end of a semester or academic year) or as a result of a renovation, relocation, or change in laboratory supervisor/occupant.

What it’s not. A regularly scheduled removal of unwanted material, as required by 40 CFR 262.208, does not qualify as a laboratory clean-out.

Big Benefits

According to EPA, benefits include:

  • Safer laboratories through reduced stockpile of legacy chemicals stored in laboratories
  • Opportunity to maintain normal generator status instead of becoming an LQG for the month
  • Reduced costs to the eligible academic entity

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More on the Laboratory Clean-Out

One time per 12-month period for each laboratory, an eligible academic entity may opt to conduct a laboratory clean-out that is subject to all the applicable requirements of the Academic Laboratory Rule, except that:

  • If the volume of unwanted material in the laboratory exceeds 55 gal (or 1 quart of reactive acutely hazardous unwanted material), the eligible academic entity is not required to remove all unwanted materials from the laboratory within 10 calendar days of exceeding 55 gal (or 1 quart of reactive acutely hazardous unwanted material), as required by 40 CFR 262.208. Instead, the eligible academic entity must remove all unwanted materials from the laboratory within 30 calendar days from the start of the laboratory clean-out.
  • For the purposes of on-site accumulation, an eligible academic entity is not required to count a hazardous waste that is an unused commercial chemical product (listed in 40 CFR 261, Subpart D or exhibiting one or more characteristics in 40 CFR 261, Subpart C) generated solely during the laboratory clean-out toward its hazardous waste generator status. An unwanted material that is generated before the beginning of the laboratory clean-out and is still in the laboratory at the time the laboratory clean-out commences must be counted toward hazardous waste generator status if it is determined to be hazardous waste.
  • For the purposes of off-site management, an eligible academic entity must count all its hazardous waste, regardless of whether the hazardous waste was counted toward generator status for the purposes of on-site generator accumulation, and if it generates more than 1 kg/month of acute hazardous waste or more than 100 kg/month of hazardous waste (i.e., the CESQG limits of 40 CFR 261.5), the hazardous waste is subject to all applicable hazardous waste regulations when it is transported off-site.
  • An eligible academic entity must document the activities of the laboratory clean-out. The documentation must, at a minimum, identify the laboratory being cleaned out, the date the laboratory clean-out begins and ends, and the volume of hazardous waste generated during the laboratory clean-out. The eligible academic entity must maintain the records for a period of 3 years from the date the clean-out ends.

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For all other laboratory clean-outs conducted during the same 12-month period, an eligible academic entity is subject to all the applicable requirements of the Academic Laboratory Rule, including, but not limited to:

  • The requirement to remove all unwanted materials from the laboratory within 10 calendar days of exceeding 55 gal (or 1 quart of reactive acutely hazardous unwanted material), as required by 40 CFR 262.208, and
  • The requirement to count all hazardous waste, including unused hazardous waste, generated during the laboratory clean-out toward its hazardous waste generator status.

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