Beginning January 1, 2018 the University of Houston Main Campus will begin managing laboratory waste under 40 CFR 262 Subpart K: Managing Waste in Academic Laboratories. This change will reduce the University's risk of incurring serious violations under the Resource Conservation and Recovery Act for commonly accepted laboratory practices. This rule was created by the Environmental Protection Agency and adopted by the State of Texas in order to accommodate the unique aspects of generating unwanted materials in laboratories at colleges and universities. The rule requires colleges and universities that opt to manage their waste under this regulation to create and maintain a laboratory management plan that addresses certain required aspects. This laboratory management plan is the basis for the University's management of laboratory waste.
Coinciding with this change in waste management, EHLS has approved a new manual to replace the existing Hazardous Waste Manual. The new Regulated Waste Manual will address laboratory and non-laboratory wastes at the University that are regulated beyond those that cover refuse (general trash).
The major benefits of the adoption of this Laboratory Management Plan for laboratories on Main Campus are:
- Reduced liability for violations based on commonly accepted laboratory practices
- Reduced training burden through the provision of function-specific training
- Limited number of quantity-regulated wastes in laboratories (currently 124+, only 6 under this plan)
The major changes that laboratory staff will encounter are:
- New expanded labels with more room for contents and space to meet fire code rules requiring information to indicate hazards for emergency responders
- Development of Standard Operating Procedures (SOPs) to facilitate more consistent disposal rules for laboratories across campus
- Limits on the amount of time that a container can accumulate waste (a container can only accumulate waste 180 days before being removed from the laboratory
Implemented alongside this plan are other beneficial measures for laboratories including:
- Reusable containers (provided by EHLS) for holding large waste streams and the phase-out of metal solvent cans for waste accumulation
- Assistance in creating lab-specific printable labels for common waste streams, including hazard evaluation
- Written and updated guidance on what can (and cannot) be disposed of as refuse (general trash), as biological waste, and other waste streams
- EHLS approval of disposal SOPs to minimize sudden changes in practices
On this page you will find helpful documentation on the change, a presentation regarding on what the change means for labs, printable blank labels, and a repository for approved disposal procedures. EHLS will be reaching out by email to begin the onboarding process with laboratories that routinely generate waste, however all laboratories (even if waste is currently not handled by EHLS) must comply with the Laboratory Management Plan by June 30, 2018.