Hazardous Waste Management

On-Site Accumulation and Following the Academic Laboratory Rule


Yesterday we told you about hazardous waste determinations in the laboratory under the Academic Laboratory Rule.  Here’s what you need to know about the requirements of on-site accumulation areas and TSDFs.

At an On-Site Central Accumulation Area

If an eligible academic entity makes the hazardous waste determination at an on-site central accumulation area, all unwanted material removed from the laboratory must be taken directly from the laboratory to the on-site central accumulation area and:

  • The unwanted material becomes subject to the generator accumulation regulations of 40 CFR 262.34(a) for LQGs or 40 CFR 262.34(d) for SQGs as soon as it arrives in the central accumulation area, except for the "hazardous waste" labeling requirements of 40 CFR 262.34(a)(3).
  • A trained professional must determine if the unwanted material is a hazardous waste within 4 calendar days of the unwanted materials’ arrival at the on-site central accumulation area.

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If the unwanted material is a hazardous waste, the eligible academic entity must (40 CFR 262.211(e)):

  • Write the words "hazardous waste" on the container label that is affixed or attached to the container, within 4 calendar days of arriving at the on-site central accumulation area and before the hazardous waste is removed from the on-site central accumulation area.
  • Write the appropriate hazardous waste codes on the container label that is associated with the container (or on the label that is affixed or attached to the container, if that is preferred) before the hazardous waste is treated or disposed on-site or transported off-site.
  • Count the hazardous waste toward the eligible academic entity’s generator status, pursuant to 40 CFR 261.5(c) and (d), in the calendar month that the hazardous waste determination was made.
  • Manage the hazardous waste according to all applicable hazardous waste regulations.

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At an On-Site TSDF

If an eligible academic entity makes the hazardous waste determination at an on-site interim status or permitted TSDF, all unwanted material removed from the laboratory must be taken directly from the laboratory to the on-site TSDF and:

  • The unwanted material becomes subject to the eligible academic entity’s hazardous waste permit or interim status as soon as it arrives in the TSDF.
  • A trained professional must determine if the unwanted material is a hazardous waste within 4 calendar days of the unwanted material’s arrival at the on-site TSDF.
  • If the unwanted material is a hazardous waste, the eligible academic entity must (40 CFR 262.212(e)):
  • Write the words "hazardous waste" on the container label that is affixed or attached to the container, within 4 calendar days of arriving at the on-site TSDF and before the hazardous waste may be removed from the on-site TSDF.
  • Write the appropriate hazardous waste codes on the container label that is associated with the container (or on the label that is affixed or attached to the container, if that is preferred) before the hazardous waste may be treated or disposed of on-site or transported off-site.
  • Count the hazardous waste toward the eligible academic entity’s generator status, pursuant to 40 CFR 261.5(c) and (d), in the calendar month that the hazardous waste determination was made.

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