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OSHA, Nuclear Regulatory Commission, Congress, and states the potential usefulness of such a mechanism.

Definitions and Implementation

One common problem that research laboratories face is that the definitions and regulations developed for industrial facilities often are not easily applied to laboratories.

For example, what is the laboratory site within a research institution where compliance with RCRA regulations is determined? Should it be within the laboratory at the end of the experiment. Might material instead be taken to a central location with more appropriate facilities as well as experts who know how to comply with RCRA requirements? For example, containers might instead be managed as they are now within OSHA regulations. First, the source of the material secured in a container is identified. Then it is treated as waste by dumping it down a drain or putting it in a waste disposal unit at the research laboratory. It becomes waste at the laboratory site, and is covered by RCRA regulations at that point; otherwise, it might be handled at the central location and that site becomes the focus of regulations. Some participants expressed the view that this basic implementation change in the regulation would alleviate a majority of the RCRA violations that laboratories experience and add no appreciable risk to the environment; if anything, the already-small risks would become smaller.

Definitions present another difficulty. A list of some of these problematic terms that need improved definitions is provided in Table 1. For example, one term on the list is “operator in control of the process for purposes of managing hazardous wastes.” Who is that in a laboratory setting? Is it the principal investigator who runs the laboratory suite? Is it limited to the laboratory room? Is it the senior research person on the experiment? Can it be a post-doctoral fellow? Is it the undergraduate who is in the laboratory at 3 a.m. when the waste is actually produced? The answer is important because it is the operator who is supposed to manage the waste and therefore be trained properly to handle this responsibility. Many questions regarding definitions are important because they can determine in many instances whether a violation of a regulation is deemed to have occurred.

GUIRR could conduct an additional workshop to develop definitions of terms for research laboratories and provide them to EPA, which could approve their use in a laboratory setting. Or research laboratories could use them in a petition for rule-making or for obtaining a letter of response from EPA on these interpretive issues.

Additional Suggestions

A number of the suggestions for action went beyond GUIRR's purview. Workshop participants were particularly pleased that the National Research Council Committee on the Study of Preledent Practices for Handling, Storage, and Disposal of Chemicals in Laboratories, was in the process of developing a model approach for the scientific community. Once the committee issues its report, laboratories will find it easier to work with the appropriate regulatory bodies.

In addition, participants felt that it would be helpful if associations of universities and university administrators raised these issues within the legislative process so that the



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