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THE MANAGEMENT AND COST OF LABORATORY WASTE ASSOCIATED WITH THE CONDUCT OF RESEARCH: Report of a Workshop ISSUE 6: WHAT ARE THE APPROPRIATE MECHANISMS FOR CONSIDERING THE PROBLEMS AND POSSIBLE POLICIES AND PRACTICES IN RESPONSE TO THEM? IS THE ROUNDTABLE THE APPROPRIATE MECHANISM? IF SO, WHAT APPROACH SHOULD IT USE? IF NOT, WHAT OTHER ENTITIES MIGHT BE MORE APPROPRIATE? Workshop participants discussed various actions that could be taken by universities, industry, and government to alleviate the difficulties that research laboratories are facing relative to waste management. Federal Demonstration Project Nine years ago, GUIRR was responsible for initiating the Federal Demonstration Project (FDP)4 in which some 50 universities were chosen competitively to work cooperatively with 10 federal research agencies to test the ability to make the administration of research grants more flexible in several ways, including allowing investigators to manage project budgets and time lines without prior approval of agency officials. Although there were difficulties along the way and the project took a great deal of time and energy to put together, a sufficient amount of confidence was built up after the program was demonstrated by National Science Foundation, National Institutes of Health, and other agencies that further demonstration projects are being conducted. Could the same thing be done for laboratory waste-management? One option would be to develop and implement a demonstration project in which selected institutions would comply with performance-based rules, rather than command and control rules, for their laboratories. That would require institutions to develop laboratory-management practices that would meet a predetermined performance based standard. Representatives of several institutions at the workshop volunteered to be part of such a project. The benefit of a demonstration project is that it does not require global acceptance of the rule, but rather is a trial run to determine whether all the interested parties feel comfortable with selected laboratories operating under the selected conditions. A demonstration project also could serve as a learning experience to evaluate how a performance-based system could be properly implemented. An effort under way in Congress would develop a mechanism for demonstration projects within the current environmental statutes. Some participants believed that some of the current statutes already permit the ability to conduct a demonstration project. GUIRR could serve as a forum to provide a detailed analysis of the characteristics of such a demonstration project and how it might be implemented and to indicate to EPA, 4 The FDP is designed to improve the management of federally funded research. The goal is to enhance research productivity without compromising the stewardship of public funds by eliminating unnecessary administrative procedures and streamlining those necessary to ensure accountability. By freeing researchers from some of the burden of paperwork, efficient research-administration systems enable investigators to spend more of their time doing science and engineering. And through streamlining and standardizing of administrative procedures, wasteful bureaucratic accretion is constrained. The net effect is greater value for the public's investment in science.
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THE MANAGEMENT AND COST OF LABORATORY WASTE ASSOCIATED WITH THE CONDUCT OF RESEARCH: Report of a Workshop OSHA, Nuclear Regulatory Commission, Congress, and states the potential usefulness of such a mechanism. Definitions and Implementation One common problem that research laboratories face is that the definitions and regulations developed for industrial facilities often are not easily applied to laboratories. For example, what is the laboratory site within a research institution where compliance with RCRA regulations is determined? Should it be within the laboratory at the end of the experiment. Might material instead be taken to a central location with more appropriate facilities as well as experts who know how to comply with RCRA requirements? For example, containers might instead be managed as they are now within OSHA regulations. First, the source of the material secured in a container is identified. Then it is treated as waste by dumping it down a drain or putting it in a waste disposal unit at the research laboratory. It becomes waste at the laboratory site, and is covered by RCRA regulations at that point; otherwise, it might be handled at the central location and that site becomes the focus of regulations. Some participants expressed the view that this basic implementation change in the regulation would alleviate a majority of the RCRA violations that laboratories experience and add no appreciable risk to the environment; if anything, the already-small risks would become smaller. Definitions present another difficulty. A list of some of these problematic terms that need improved definitions is provided in Table 1. For example, one term on the list is “operator in control of the process for purposes of managing hazardous wastes.” Who is that in a laboratory setting? Is it the principal investigator who runs the laboratory suite? Is it limited to the laboratory room? Is it the senior research person on the experiment? Can it be a post-doctoral fellow? Is it the undergraduate who is in the laboratory at 3 a.m. when the waste is actually produced? The answer is important because it is the operator who is supposed to manage the waste and therefore be trained properly to handle this responsibility. Many questions regarding definitions are important because they can determine in many instances whether a violation of a regulation is deemed to have occurred. GUIRR could conduct an additional workshop to develop definitions of terms for research laboratories and provide them to EPA, which could approve their use in a laboratory setting. Or research laboratories could use them in a petition for rule-making or for obtaining a letter of response from EPA on these interpretive issues. Additional Suggestions A number of the suggestions for action went beyond GUIRR's purview. Workshop participants were particularly pleased that the National Research Council Committee on the Study of Preledent Practices for Handling, Storage, and Disposal of Chemicals in Laboratories, was in the process of developing a model approach for the scientific community. Once the committee issues its report, laboratories will find it easier to work with the appropriate regulatory bodies. In addition, participants felt that it would be helpful if associations of universities and university administrators raised these issues within the legislative process so that the
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