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

of local concerns, local jurisdictions are not necessarily interested in being consistent with state and federal regulations. And federal and state agencies seem to have little incentive or desire to do regulatory battle with local governments, so local regulations often stand even though they are inconsistent or unreasonably burdensome.

• Regulators and those regulated are often confronted with very detailed and overspecific regulations that fail to address issues adequately or that result in inefficiency or excess cost. An example is a detailed prescription for an analytical procedure to determine the presence and evaluate the extent of a given pollutant, instead of a set of more general requirements that an acceptable procedure could meet. More general, performance-based criteria should be used to the greatest extent possible.

Workshop participants discussed the cost of waste management, and some cost tables were collected and compared. However, because the cost estimates and the underlying analyses were not developed in accord with a standard set of definitions and cost-accounting protocols, the reported costs vary greatly with institution and type of research being conducted. For example, on a total-cost basis, a survey conducted by the University of Texas of 12 different campuses throughout the United States found that costs ran from $1.6 to 3.4 million per year (average, $2.4 million).

Workshop participants suggested that there needs to be an overall analysis and digest of cost data, including a review of the causes for the recent steep cost increases, and development of consistent definitions for what should be included in cost calculations. Capability for benchmarking costs among research institutions would be helpful in controlling costs and reducing waste generation.

In dealing with the allocation of costs of waste disposal, university administrators face a number of difficulties. Researchers feel that because their grants already include reimbursement for overhead expenditures, they should not be assessed additional direct cost charges for waste management.3 From the university's point of view, environmental-management costs are steadily increasing. There are not only the obvious waste-disposal costs, but hidden costs in the labor and time of research-laboratory managers and researchers themselves.

Research institutions are taking action to manage their costs better. Some have begun to assess surcharges on purchased research materials based in part on their toxicity. Some have added direct charges for such identifiable costs as contractors' charges for