Problem Description. Reasons for Request for Regulatory Flexibility 1. Hazardous Waste Determination [40 CFR 262.11] The Universities have found, and their stakeholder group has confirmed, that hazardous waste determination may be made prematurely in the laboratories and may be a barrier to the reuse, recycling and redistribution of laboratory waste throughout the institution. This is attributable to the finding that once researchers and graduate students no longer have use for an individual laboratory waste, they are seldom aware of the reuse and recycling opportunities available in other laboratories. Thus, they are prone to call even reusable materials “hazardous waste.” The result is that a certain quantity of reusable material is unnecessarily disposed of every year. In fact, under the current OSHA/RCRA 1Such performance-based systems applicable to hazardous materials in laboratories have been developed and successfully implemented by the National Institutes of Health for biohazards, the Nuclear Regulatory Commission for nuclear hazards and OSHA for workplace hazards. For example, under OSHA’s performance-based Laboratory Standard, management of hazardous materials in the laboratory is principally regulated by means of a written Chemical Hygiene Plan as required under 29 CFR 1910.1450, which is developed by each organization in accordance with the criteria set forth in the standard. scheme, a 1996 survey revealed that less than 1% of laboratory waste is currently reused by university laboratories.
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