The committee recommends that federal, state, and local lawmakers and regulators strive for conformity and consistency in the regulations that affect laboratories.
If disposal of multihazardous waste is to be accomplished safely and cost effectively, regulations affecting its individual components should not conflict, and the regulatory framework should be based on risk priority. For example, health and safety considerations may sometimes demand that greater emphasis be given to one component of the total chemical, biological, and radiological toxicity, while existing regulations would require equal emphasis for all components. This situation arises, for example, with mixtures containing trace amounts of radioactive material in which the major health and safety risk is associated with a chemical or biological component.
The committee recommends that the U.S. Nuclear Regulatory Commission and the Environmental Protection Agency establish de minimis levels for radionuclides, below which laboratory waste can be disposed of without regard to radioactivity.
The committee recommends that the Environmental Protection Agency encourage safe disposal of chemical-radioactive (mixed) waste materials with short half-lives by excluding the decay-in-storage period from the current 90-day limitation on storage of hazardous waste.
Requirements for multiple EPA identification numbers for a single campus create an unnecessary administrative burden.
The committee recommends that the Environmental Protection Agency allow the use of one EPA identification number for all chemical waste generated on a single campus of an educational institution.
Complete safety procedures for an institution must incorporate emergency planning and must recognize the role of external agencies. It is essential that emergency procedures be developed that will minimize risk to personnel and allow emergency response workers to function effectively. Clear lines of communication must be maintained. In addition, local regulations affecting laboratories should be oriented toward reduction of risk. Federal law, for example, specifically exempts laboratories from detailed reporting of every chemical stored in a facility, enabling a reporting system focused on those chemicals that would pose the greatest risks in an emergency.
The committee recommends that laboratory personnel, in cooperation with the institutional health and safety structure, establish ongoing relationships and clear lines of communication with emergency response teams.
The committee recommends that emergency response regulations require inventory information only on those containers with chemicals in quantities large enough to pose a significant risk to personnel or the environment in the case of an emergency release or fire.
Small colleges and high schools often do not have an environmental health and safety office or the resources to manage laboratory waste. Teachers are thus left to shoulder the burden of waste disposal, and their attention can be diverted from core science teaching as a result.
In order to support the teaching of laboratory courses in small colleges and high schools, the committee recommends a careful review of current record-keeping requirements to avoid excessive burdens on teachers at small institutions.
Prudent management of chemicals is important for a variety of environmental, social, and economic reasons. Manufacturers and suppliers of chemicals play a central role in these efforts because they manage the commercial flow of chemicals and have responsibility for the procedures by which chemicals are packaged and shipped. Uniform identification of chemicals by manufacturers and suppliers could help to reduce risks in the storage, use, and disposal of chemicals, improve the management of chemicals in the laboratory, and enhance emergency response preparedness.
The committee recommends that chemical suppliers adopt a uniform bar code identification system that would facilitate establishment and maintenance of laboratory chemical inventory and tracking systems.
The committee recommends that all laboratory chemicals be labeled with the date of manufacture.
The committee recommends that chemical suppliers adopt uniform color coding and bar coding for compressed gas cylinders.
The policies and practices of commercial manufacturers and suppliers of laboratory chemicals directly affect the management of chemicals in the laboratory, especially the ability to practice effective pollution-prevention techniques such as source reduction and recycling-reuse-recovery. The costs and risks associ-