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    Note: Items with a bullet are individual pages. Items without bullets are subtopics on a page.

• Home page
  • Site policies
  • About the author
  • Five easy steps to manage your generator status
    • Identify hazardous waste correctly
      • Flow chart
    • Identify acute hazardous waste correctly
      • Acute RCRA waste quiz
      • Acute RCRA waste quiz for Internet Explorer 6 and lower browser
    • Measure amounts correctly
  • How and why to comment on proposed rules
  • Treatment of regulated waste in laboratories—safe and necessary
    • When is it essential to do treatment in laboratories?
    • Is chemical waste treatment different from other chemistry?
    • Do laboratory people need special RCRA training to perform treatment in labs?
    • Must treatment reduce hazards?
    • How practical is waste treatment in laboratories?
    • Should regulators allow treatment in laboratories?
    • How can the safety and effectiveness of chemical waste treatment be measured?
    • What treatments are prohibited?
    • Should EPA regulate the lab safety aspects of waste treatment processes?
  • Chemical waste training for laboratories
    • Introduction
    • Background—Is the inspector there to help you? You may be surprised!
    • What are the objectives of RCRA training?
    • How similar are OSHA and RCRA training requirements?
    • What are the shortcomings of current training requirements? How can they be addressed?
    • Is there a fundamental difference between safety and compliance training for laboratories?
    • What training should individuals receive?
    • Can/Should RCRA and OSHA training requirements be harmonized?
    • A different approach to training
    • Training a diverse audience
    • Chemical waste training outline for laboratory workers
    • Students and volunteers
    • How can training be delivered?
    • How can training be measured?
    • Summary
    • Accessible alternative versions
      • Linearized version—Table 1, Chemical waste training
      • Linearized version—Table 2, Chemical waste training
  • The role of enforcement policy in changing the regulatory climate
  • Problems with the Military Munitions Rule and possible solutions
    • Introduction—Military munitions rule
    • The Military Munitions Rule and contiguous property
    • “Almost but not quite” contiguous
    • The ten day transfer limit
    • Conclusions
  • Building performance oriented chemical waste rules
    • Introduction—Performance oriented rules
    • The benefits of regulations and inspections
    • Performance oriented regulations
    • Guidelines for performance oriented regulation
    • Example goal analysis
    • Fundamental goals of hazardous waste management
    • Performance criteria
    • Applying performance oriented approaches to existing regulations
    • Written plans
    • An alternative to written plans
    • Sample placards
    • Accessible alternative versions
      • Text version—Figure 1, Performance oriented rules
      • Text version—Figure 2, Performance oriented rules
      • Text version—Figure 3, Performance oriented rules
      • Text version—Figure 4, Performance oriented rules
      • Text version—Figure 5, Performance oriented rules
      • Text version—Figure 6, Performance oriented rules
      • Linearized version—Table 1, Performance oriented rules
      • Linearized version—Table 2, Performance oriented rules
  • Preliminary information about proposed RCRA labs rule for higher education
  • Important issues remaining for colleges, universities and other research institutions
    • Problems that EPA can repair by regulatory changes
      • The military munitions rule and multiple ID numbers
      • Consolidation from separate sites to a 90-day facility
      • Improved service to K–12 sites
      • Reform of P and U lists
      • Episodic generation and time limits
      • Flexible accumulation times for small quantities
      • Deregulation of ¹⁴C and ³H waste that is not LSC
      • Training
      • LDR paperwork
      • Clarify how to handle wastes generated during field work
      • Simplify and clarify requirement for arrangements with local authorities
    • Problems that federal regulatory change cannot address
      • Variations in state and local regulations
      • Varying interpretations of rules
    • Problems that the C/U sector can address by education
      • Correctly identifying acute hazardous waste
      • Correctly identifying other RCRA waste
      • Measure net weights to avoid overstating labpack waste quantities

Rev. 27 Mar 2007, 1700
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