The Management and Cost of Laboratory Waste Associated with the Conduct of Research (1994)

Issue 4: What changes could be made in the conduct of research or the training of research personnel to improve management of mixed, chemical, radioactive, and biohazardous waste?

Issue 5: What possible regulatory or legislative policy mechanisms could be used to alleviate the regulatory constraints faced by laboratories (e.g., emphasize best practice under existing regulations, establish waivers within existing regulations, modify regulations)?

Issue 6: What are the appropriate mechanisms for considering the problems and possible policies and practices in response to them? Is the Roundtable the appropriate mechanism? If so, what approach should it use? If not, what other entities might be more appropriate?

These discussion of issues will be summarized in the following sections.

Some workshop participants found that research laboratories have several needs and characteristics different from those of other waste producers.

• The interdisciplinary nature and the ever-changing pattern of activity of many research laboratories result in the generation of small volumes of a wide variety of chemicals and minute amounts of various radioactive materials. Although some of the chemical wastes that come to a research laboratory's waste-handling area are commercial chemicals, most of the material generated consists of nonregulated chemicals. The situation is similar for radioactive materials.

• The wastes generated (particularly new chemicals) are often of unknown toxicity and hazard. That introduces considerable uncertainty as to the best method of disposal and sometimes makes it difficult to find any outlet. Some organizations opt for the most conservative method of disposal, a hazardous-waste incinerator, which is also the most expensive method.

• The 90-day disposal limit required by federal regulations poses another difficulty. Quantities of materials accumulate slowly and there might be no adequate disposal outlets for the material created so, it can be difficult or impossible to comply with the time limit and dispose of materials cost-effectively.

• The high rate of turnover in academic research laboratories as graduate students and postdoctoral personnel come and go often results in wastes that are not fully identified.

If the materials are nonregulated, nonexotic substances and there is some idea of their composition, a general characterization can be attempted; however, if the material is totally unknown, there might be additional costs for specialized characterization and disposal. For example, cylinders of unknown gas have to be sampled in such a way that the gas can be characterized, and a specialist might be needed to do it; this could increase the disposal cost greatly.

In summary, research laboratories are unique in the small quantities but varied nature of the waste substances that they produce. In particular, many new materials of unknown toxicity and hazard are created. That makes it difficult to dispose of chemicals in a cost-effective and timely manner. Some facilities have been forced to modify or limit the type of research that they conduct because of the difficulties involved in handling some of the waste generated as a result.¹ To alleviate the difficulties posed by the 90-day limit, some research facilities are going to the expense of obtaining a Resource Conservation and Recovery Act (RCRA) Part B permit so that they can continue to store materials beyond this limit.

Maintaining compliance with regulations is often difficult for laboratories. Environmental regulations, such as the RCRA, are written for manufacturing facilities and difficult to interpret for a laboratory.

In maintaining compliance, because of the large number of sources within a facility, it is sometimes very difficult to determine which source generated a particular waste. For example, if a facility exceeds a limit (such as a low pH or a metal concentration) at a sampling point in a waste stream, tracing the problem to the source can be expensive and time-consuming, if it is even possible.

Maintaining accurate reports is also difficult, inasmuch as researchers order their chemicals from many places. That makes it hard to keep accurate track of what is on site so that the health and safety staff can provide or obtain environmental-compliance information regarding particular chemicals. Records for radioactive materials almost invariably are better than those for chemicals because the regulatory requirements that apply to radioactive materials are more stringent.

Organizational management and operational incentives in university settings differ from those in manufacturing environments. The culture and structure in a university setting make effective dissemination and enforcement of regulations more difficult. In a university setting, each investigator is a small, independent enterprise, operating quasi-independently.

Some institutions are making efforts to improve their ability to comply with environmental regulations by conducting audits of the laboratories--not just once, but repeatedly in some cases--and developing chemical-tracking systems using bar codes that trace chemicals “ from cradle to grave” within a site.