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Lab Pack Disposal 102: Regulation and Safety – What Can Go Wrong?

February 10, 2015

Hazardous Waste and School Laboratories: the Lab Pack Connection

For schools and universities looking to dispose of their lab packs at the end of the year or semester, concerns may arise on the best and safest practices. This is wise when you take into consideration that the improper storage and disposal (or, more to the point, non-disposal) of lab pack chemicals can mean serious health hazards, hefty fines, and possibly legal action.

Typically, academic campuses are not thought of as being hazardous waste generators—and while university research laboratories only account for a small percentage of the hazardous waste produced each year in the United States—they are not exempt from such classification by the Environmental Protection Agency (EPA).

School and university labs can generate thousands of different hazardous chemicals, and these chemicals are all considered waste, even if only as a result of going unused. Dealing with these dangerous chemicals is not only a concern of safety, but also of regulation and law.

Related Article: Lab Pack Disposal 101: Schools and Universities

RCRA, CERCLA and Lab Packs

Laboratory chemicals and their generators are subject to two main EPA regulatory acts.

  • The Resource Conservation and Recovery Act (RCRA) requires generators, including those in educational field, to properly dispose of all chemical waste in a timely manner.
  • The CERCLA or “Superfund” Act of 1980, promulgates that generators must cleanup any waste dumps—regardless of the propriety of their practices during generation.

The EPA recommends lab packing as the only safe and compliant method of removing chemical waste from academic laboratories.

It is also wise to note that the Occupation Health and Safety Administration (OSHA) and the Department of Transportation (DOT) also have their own regulation governing the safe handling and shipment of hazardous chemical waste.

A Cautionary Tale of Three Universities: MIT, Yale, and Stanford

Legislation isn’t just an empty threat, either. Surprise inspections by federal or state agencies can occur at any time, no matter the type or size of generator. In 1998, the EPA conducted an inspection on the Cambridge campus of the Massachusetts Institute of Technology (MIT) and found violations in 56 of the 114 laboratories inside the prestigious university. Storing, handling, and labeling regulations of chemical waste were mostly the cause of these citations, but MIT was also given a violation for a lax spill response plan.

The school was cited several chemical waste-related violations—including transgressions against RCRA, the Clean Water Act, and the Clean Air Act—totaling $150,000 in fines. Luckily, no one was hurt from these potentially life-threatening violations, which could have resulted in criminal, not only civil, proceedings.

However, this inspection prompted MIT to initiate broad-ranging environmental and safety reforms, from the creation of training modules on handling chemical waste to increasing their use of recycled paper to 95%. But the fact remains that this mishap could have been prevented.

Similarly, other preventable laboratory chemical violations have occurred more recently at Yale and Stanford University, including citations for

  • improper storage,
  • mislabeled waste,
  • a lack of training chemical waste management training,
  • open containers of waste,
  • and mercury dumping.

Learning From Their Mistakes

Much can be learned from the mistakes of these generators. Training plays a crucial role in dealing with hazardous chemicals, and can go a long way in ensuring safety on campus and compliance with the law.

And the improper disposal of toxic chemicals, such as mercury, and storing out-of-date chemicals can be easily remedied by an experienced and trustworthy lab packing company.

The presence of trained chemists and an expedient cleanup crew during the lab pack can ensure that these chemicals will be treated to the EPA’s regulations, and also that no potentially-dangerous chemical reactions will occur in the process as well.

This article is the 2nd installment of a four-part series on chemical lab packing in academic facilities. If you would like more information on lab decommissioning in an educational setting, please refer our other articles:

Lab Pack Disposal 101: Schools and Universities

Lab Pack Disposal 103: Choosing the Best Lab Pack Company

Lab Pack Disposal 104: Should Your University Opt-In To Subpart K?

Don’t wait until it’s too late to properly deal with your school or university’s lab pack chemicals, prompt disposal is key. If you would like to learn more about the lab packing process, call us at 800-936-2311 or click here to email us.

Photo credit: Velovotee via compfight

Disposal of hazardous waste doesn’t have to be painful.