Lab Pack Disposal 104: Should Your University Opt-In To Subpart K?
March 19, 2015
What is Subpart K?
It’s hard to believe that before 2008, there was no federal standard in place for the disposal of hazardous chemicals in academic labs. This did however change on December 1st of that year, with the addition of Subpart K to the Resource Recovery and Conservation Act (RCRA), the EPA’s plenary hazardous waste legislation.
In response to the unique challenge of laboratory chemical disposal facing universities, the EPA devised a different set of rules for eligible institutions. These rules changed the way academic entities dealt with their admittedly minute, yet ubiquitous toxic chemical waste in many ways.
Reminiscent of the tortuous titles of 18th century novels, the formal name of Subpart K is, “Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Colleges and Universities and Other Eligible Academic Entities Formally Affiliated with Colleges and Universities.”
What Does Subpart K Do for Eligible Academic Entities?
Formal name notwithstanding, Subpart K offers practical applications that make it especially invaluable for those universities which may have many laboratories on a single campus.
For one, it gives environmental health and safety (EHS) officers the ability to choose whether chemicals generated in one lab may be used in another lab. This can greatly reduce the amount of lab waste on campus.
Another waste minimization part of the rule provides “regulatory incentives” for laboratory clean-outs. The EPA correctly posits that academic institutions which regularly use lab packing procedures to dispose of their old, unused, and expired inventories of chemicals are safer overall.
According to the EPA, the rule also allows academic entities to choose where to make the hazardous waste determination either:
- In the lab before the waste is removed;
- At on on-site central accumulation area (CAA); or
- At an on-site or permitted or interim status treatment, storage, or disposal facility (TSDF).
Before, this determination was made by single individuals, researchers or even students, who may not have the proper training to make an informed decision.
Under Subpart K, non-laboratory hazardous waste does not have to be kept separate from chemical lab waste, making the bulk disposal of all on-site waste much easier.
Must All Academic Institutions Follow Subpart K?
If your lab has a chemical waste management system that has been effective before the addition of this rule to RCRA, understandably, you may not want to change your method. The EPA recognized this possibility, and made for Subpart K flexible: the alternative directives of this legislation are not mandatory.
Opt-Out of Hoarded Chemical Lab Waste
The accretion of toxic chemicals in school labs is unavoidable, but hoarding these chemicals on-site is not. To keep your lab safe, and in good regulatory standing, disposing of old chemicals with a complaint lab pack is essential.
This article is the 4th installment of a four-part series on chemical lab waste disposal in academic facilities. If you would like to learn more about lab decommissioning in an educational setting, please refer to our previous articles:
Lab Pack Disposal 101: Schools and Universities
Lab Pack Disposal 102: Regulation and Safety – What Can Go Wrong?
Lab Pack Disposal 103: Choosing the Best Lab Pack Company
To consult with an expert about disposing of your chemical lab waste or about RCRA Subpart K for your academic laboratory, give us a call today at 800-936-2311 or click here to email us.
Photo credit: Vancouver Island University via compfight