- Links on this page
- Introduction
- Reference
- Your comments are important!
- Other useful links (not on this web site)
Introduction
The academic laboratories rule is a good rule with potential to provide significant benefits to many programs in our college and university sector. This is the first time since enactment of the RCRA rules in 1980 that EPA has made a serious effort to address the regulatory needs of our sector. We owe a vote of thanks to the team that shepherded the rule through the very complex and difficult—some would say arcane—EPA rulemaking process. Sadly, the agency operates in a litigious atmosphere in which it must judge success not by accolades, but by approximately equal attacks from both sides of an issue. The litigious atmosphere slows the rule-making process, among other problems.
Reference
Standards applicable to generators of hazardous waste; Subpart K—standards applicable to academic
laboratories; proposed rule 71FR29711–29752, May 23, 2006. Note: I have placed a
copy of the rule
in .pdf format on this web site.
The text is identical to the PDF document on the federal web site. However, I have tagged the document
for improved accessibility and highlighted the places
where the EPA specifically requested comments.
Your comments are important!
Note: The comment period closed in September, 2006 and EPA is now evaluating the comments. The following information and links may be useful to bring you up to speed on what has happened.
EPA will not offer another opportunity to comment on laboratory waste management anytime soon. The agency received many comments on the Labs Rule. This increases the likelihood that a final rule will be issued, but the timing is unpredictable and the agency rarely offers advance information.
While EPA originally intended to address issues that are not laboratory-specific through the Generator Initiative, we have learned that the Generator Initiative is likely to be delayed for an unknown length of time. Some of these unaddressed concerns are described on another page of this site and we continue to hope that EPA will address them.
If you are unfamiliar with the comment process, a page on this site describes EPA's internal process for reviewing comments and has suggestions for shaping comments.
Other useful links (not on this web site)
- Unfortunately, EPA has not released a compilation of the comments that it received. To access and
read the individual comments, go to
http://www.regulations.gov/fdmspublic/component/main
and use the following search criteria
- Search for: All documents (Open and Closed for Comment)
- Agency: Environmental Protection Agency
- Document type: Proposed Rules
- Keyword or ID: RCRA-2003-0012 (Enter as shown including the hyphens)
- CSHEMA comments are also posted on the CSHEMA web site Read the complete and final CSHEMA comments.
- Howard Hughes Medical Institute (HHMI) hosted, in early August, a meeting of campuses and state regulators who participated in the HHMI-sponsored ten campus demonstration project. The meeting focused primarily on the relationship of the proposed rule to the best practices, conclusions and recommendations developed by the demonstration project. The 2001 EPA report to Congress is on the EPA website. The 2000 HHMI report begins on the 21st page of the .pdf file.
- NACUBO has issued a bulletin on the academic laboratory waste rule.
- Government labs are also interested in the rule.
- American Chemical Society letter protesting limitation of rule to academic laboratories and a discussion of the rule in ES&T online.
- American Council on Education bulletin on the academic laboratory waste rule.
- An environmental law practice describes the rule.
