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THE MANAGEMENT AND COST OF LABORATORY WASTE ASSOCIATED WITH THE CONDUCT OF RESEARCH: Report of a Workshop Research institutions have begun to make researchers sensitive to the potential environmental impacts of their work and to the costs of waste management through education programs, employment “signoff ” that states that they understand the environmental regulations of their employer, individual discussions with researchers as to how they can dispose of their wastes, staff newsletters that describe new regulations, teaching students that environmental considerations are part of research ethics, and general “selling” of the concept of good waste-management practices to individual researchers. Management mechanisms to improve the conduct of research include an internal “cradle-to-grave” chemical-tracking system, incentives and requirements to minimize wastes at the laboratory level, charging of violation costs to researchers so that they have an economic incentive to maintain good practices, changing to chemical-based accounting systems, bar-coding of all materials for tracing, adoption of miniaturized equipment to reduce amounts used, encouragement of complete use of purchased chemicals through an exchange mechanism, and regular laboratory inspections. In addition, developing good communication linkages with the community surrounding the institution helps to avoid public-relations problems before they occur. ISSUE 5: WHAT POSSIBLE REGULATORY OR LEGISLATIVE POLICY MECHANISMS COULD BE USED TO ALLEVIATE THE REGULATORY CONSTRAINTS FACED BY LABORATORIES (E.G., EMPHASIZE BEST PRACTICE UNDER EXISTING REGULATIONS, ESTABLISH WAIVERS WITHIN EXISTING REGULATIONS, MODIFY REGULATIONS)? A number of regulatory or legislative policy mechanisms were suggested that could alleviate the environmental regulatory constraints faced by laboratories. There was also some discussion as to the extent to which legislative versus regulatory help was needed. In general, it was felt that the current legislation did not necessarily need to be changed, but that regulatory changes or waivers would be needed for laboratories to function properly while meeting concerns about their environmental effects. The first discussion revolved around performance-based systems versus command-and-control-based regulations. In general, participants favored a more performance-based approach because of the unusual nature of research laboratories relative to the industrial facilities for which the regulations were written. In a performance-based system, for example, laboratories could develop their own standards of operation and regulations as long as they met an overall auditable standard set by a regulatory agency. That could probably be done without changing the related environmental statute. Whatever option is chosen by regulators or the research community, it needs to have external accountability and verification if the public is to have confidence in the results of the program. Another helpful addition would be in the form of small actions by EPA. These could include the development of specific definitions and perhaps laboratory-based modifications of the “key definitions ” (Table 1) related to how they should be applied to laboratories, review of EPA, Occupational Safety and Health Administration (OSHA), and Nuclear Regulatory Commission state rules for consistency or development of a consensus of
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THE MANAGEMENT AND COST OF LABORATORY WASTE ASSOCIATED WITH THE CONDUCT OF RESEARCH: Report of a Workshop all regulatory authorities on the interpretation of various rules for laboratory agencies, use of regulations based on national standards of practice (such as those being developed by the National Research Council Committee on Prudent Practices), and keeping regulation writers aware of laboratory needs. In addition, award programs for model laboratories such as the OSHA Star and EPA Energy Star programs would create incentives for laboratories to do better. Laboratories can undertake initiatives, such as the chemical industry 's Responsible Care program. A parallel initiative would include development of codes of practice for laboratories, working with the public so they better understand laboratory practices, and working with scientists and laboratory administrators so they can better understand the public 's concern. In addition, laboratories can communicate their needs to both legislative and regulatory bodies more fully so that the appropriate officials within these institutions are aware of the adverse impact of the current implementation mechanism of environmental regulations on research laboratories. Regular discussions among EPA, OSHA, Nuclear Regulatory Commission, and the research community are essential for ensuring that each understands the perceptions and concerns of the others. In some cases, representatives of state and local governments will need to be included.
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THE MANAGEMENT AND COST OF LABORATORY WASTE ASSOCIATED WITH THE CONDUCT OF RESEARCH: Report of a Workshop TABLE 1 RCRA Regulatory Interpretation Key Definition Issues for Labs “Operator in control of process” “At or near point of generation” WAA training requirements for researchers taking waste to 90-day area Unitary campus - “affiliates” operating on contiguous campus “Generator” entitled to rely on generator knowledge of waste Lab “waste water” vs. lab “waste” Experimental protocols as “treatment” Release reporting in labs Expired chemicals US/DOT Hazardous waste packaging - on-site roads with public access
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