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If your University or college includes a maintenance department or has a laboratory, you probably have hazardous waste that needs to be dealt with. This waste must be properly stored, packaged, shipped, and disposed of in accordance with all local and national regulations.
In order to remain in compliance, your facility needs to have a comprehensive waste management plan that will keep your employees, students, and visitors safe, while safeguarding the environment in general. Compliance also helps to ensure that you and the school at large avoid any potential fines, penalties, or lawsuits, which can be severe.
01 / Common Types of Hazardous Waste in Education Systems
There are several common types of hazardous waste that colleges must store and dispose of, and we discuss some of these below.
Lab Packs
A lab pack is a container that is used to place other smaller containers of hazardous waste in for shipment and disposal. For colleges, this waste typically consists of unused, damaged, expired, or out-of-date chemicals. There are a number of regulations that must be followed when creating a lab pack, such as:
All of the chemicals that will be placed in the lab pack must be identified.
The chemicals must be segregated and packaged by type.
Any small vials should be placed in a larger container and then in absorbent material for further protection should the container break.
The lab pack must be packaged by a qualified individual because mistakes in the process could result in toxic fumes, fires, explosions, or other dangers.
The procedures for creating a lab pack can be complicated, but it is essential that these rules be followed to keep everyone safe and avoid regulation missteps and potential fines.
Miscellaneous Chemicals
There are a variety of chemicals commonly used at colleges and universities, and these must also be disposed of according to federal, state, and local regulations. Items, such as paint, waste oils, solvents, thinners, grounds keeping chemicals, and universal waste cannot simply be thrown in the trash. Your college needs to have a waste management plan that ensures these items are disposed of in accordance with regulations.
02 / RCRA Compliance for Colleges
RCRA compliance for colleges and universities is essential since they are subject to the Resource Conservation and Recovery Act (RCRA). However, the Environmental Protection Agency (EPA) did develop regulations intended to better suit teaching and research laboratories. More details about these regulations can be found in Title 40 of the Code of Federal Regulations, part 262, Subpart k. The regulations cover universities and colleges, as well as non-profit research institutes or teaching hospitals formally associated with or owned by a college or university.
According to subpart k:
Hazardous waste determinations must be made by trained professionals, not students.
Hazardous waste must be removed from the laboratory once every year.
Incentives are offered to the facilities for removing chemicals that are expired or old from the laboratories if they could present risks.
Eligible academic entities are given flexibility as to where and when to make their on-site waste determinations.
Facilities must make a Laboratory Management Plan that includes best waste management practices.
Facilities covered by subpart k are not required to follow its provisions if they follow existing generator regulations instead.
03 / Changes to Federal Regulations
Colleges should also be aware of a change to the hazardous waste regulations that could affect their waste management practices. The EPA has designated PFOA and PFOS as hazardous substances, and they are now included in the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). According to this regulation, if an entity releases a pound or more of these substances within a 24-hour period, they must be in compliance with CERCLA 103 and EPCRA 304 and their implementing regulations.
04 / Increases in Fines for Hazardous Waste
It is vital for colleges and universities to comply with regulations when using lab packs or handling any hazardous waste in order to keep everyone within the school safe. Additionally, careful compliance with hazardous waste regulations can help your facility to avoid severe penalties.
The EPA has increased its statutory civil penalties for 2024. The civil penalty for RCRA violations has increased to a maximum per day of $90,702 from $87,855. Penalties for other environmental statutes have increased as well. The maximum penalty per day for violating the Clean Water Act has increased to $66,712 from $64,618.
For the Clean Air Act, the penalty has increased to $57,617 per day from $55,808. Any of these penalties could be devastating for a college and show how important it is to have an effective university hazardous waste management plan that ensures your facility is following all regulations.
05 / Choose a Reliable Hazardous Waste Disposal Company to Avoid Fines and Penalties
If you’re a member of a university or college, it’s important to be aware of just how important it is to remain compliant with all regulations. Having an effective hazardous waste management plan that is easy for staff, students, and visitors to follow is key to staying safely within the confines of local and national regulation. This process however isn’t always easy to implement or maintain, particularly since regulations can frequently change. Keeping up with the latest regulations on a federal, state, and local level can be a significant task for administration.
A good way to ensure compliance with hazardous waste regulations is to work with an experienced waste disposal company. But it’s important to choose the right one, since your institution will be trusting this service provider in a high stakes regulatory environment. It’s important to look for a turnkey service that will handle the packing, labor, supplies, packing materials, paperwork, and more.
Robert Losurdo
President, COO
