Managing Hazardous Wastes Generated at School, Achademic and Educational Labs

Managing Hazardous Wastes Generated at School Labs, College, Educational Labs & Academic Laboratories

Subpart K is an optional, alternative set of regulations that allow eligible academic entities the flexibility to make hazardous waste determinations. The rule is applicable to eligible academic entities, such as, colleges and universities, and teaching hospitals and nonprofit research institutes that are either owned by or formally affiliated with a college or university.

The full text of the rule itself is found in Title 40 of the Code of Federal Regulations (CFR) in Part 262 .

Steps to implementing the 40 CFR Part 262 Subpart K Educational Lab Waste Rule

  1. Read the Federal Register, including the preamble (73 FR 72912; December 1, 2008), and review frequent questions and other implementation materials for additional information.
  2. Check out the resources availble from the EPA
    Frequently asked questions
  3. See this page about the rule
  4. Check eligibility. If you are interested in opting into Subpart K, you need to make sure that you are allowed to. You can only opt into Subpart K if your institution is an eligible academic entity. Make sure your institution is one (or more) of the following:
    1. College or university
    2. Teaching Hospital that is owned by or has a formal affiliation with a college or university
    3. Non-profit research institute that is owned by or has a formal affiliation with a college or
  5. Check your state. You also need to make sure the rule is effective in your state. See the bottom of this page. Even if your institution is an eligible academic entity, you can not operate under Subpart K unless your state has adopted the rule first or you are located in Iowa, Alaska, and the territories.
  6. Decide Whether to Opt into Subpart K
    If Subpart K is effective in your state and your institution is an eligible academic entity with laboratories, then you have the choice of opting into Subpart K. If your institution opts in, this means that you will manage your laboratory hazardous waste under this new set of regulations instead of the RCRA satellite accumulation area regulations that you currently operate under.
    This worksheet from the EPA may help you decide, and if you go ahead, to prepare. If the EPA link ceases working, use this link.
  7. Check internally - Before opting in, you should to consult with your administration/dean and maybe your legal counsel. You and your administration should decide together whether your institution will opt into Subpart K. You want to make sure you will have support to follow through with the transition.
  8. More than one lab? If your institution has more than one EPA Identification Number or more than one site, part of the decision about opting in will be to decide which sites will be opting in. When opting in, all the laboratories operating under the same EPA Identification Number (or on the same site) must opt in. Not all your sites have to opt in although it is probably in your best interest to have all the laboratories on a campus operating under the same system.

    Plan for the Transition to Subpart K

  9. Iidentify personnel that will be involved in planning and implementing Subpart K for your institution. For example, identify who will write your Laboratory Management Plan (LMP), and who will develop and conduct training for laboratory workers and students.
  10. Develop a timeline - Once your resources are identified, you can begin to develop a timeline for your institution's transition. Set a deadline for writing your LMP, and prepare a schedule for rolling out training to
    your laboratory personnel. Finally, identify a start date for when your institution will begin implementing Subpart K.
  11. Write the Laboratory Management Plan (LMP) for all your sites that will be opting in. You must develop an LMP with two parts. The first part is where you select options available to you under the rule. The second part is where you develop your own site‐specific best management practices for managing your laboratory hazardous waste in accordance with Subpart K. An LMP Brainstorming Worksheet is on EPA's website, listed above, under Implementation of Academic Laboratories Rulemaking.

    Taking the First Steps
  12. Training - Once your LMP is prepared, you can begin training your laboratory personnel, including laboratory workers (e.g., faculty, staff, technicians, post‐docs, etc.) and students on how to manage the laboratory hazardous waste. Everyone must be trained commensurate with their duties. This means that the more responsibility someone has for managing hazardous wastes generated in the laboratory, the more training that person should have.
  13. Submit your notification - When your laboratory personnel are trained and ready to implement Subpart K, the next step is to fill out and submit your notification (EPA's Site Identification Form, also called the 8700-12) to your State or Region that you will be operating under Subpart K. You must submit a separate notification for each site (each EPA Identification Number) that is opting into Subpart K.

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