Deciding Whether to Opt into Subpart K
Posted on Fri, May 21, 2010 @ 01:32 PM
By Dave Williamson, Higher Education Account Manager
If the new Academic Lab Rule known as Subpart K is effective in your state and your institution is an eligible academic entity with laboratories, then you have the choice of opting into Subpart K. If you decide to opt in, your laboratory hazardous waste will fall under a new set of regulations. Before opting in make sure you have support from your institution's administration.
Many institutions have a couple EPA ID numbers for different parts of the campus. Under Subpart K each separate EPA ID has the option to opt in. It would make the job for the EH&S staff challenging to operate under different regulations for each EPA ID number, but it can be done.
A Lab Management Plan is required for institutions that adopt the academic lab. You must develop this in two parts. The first part is where you select options available to you under the rule. The second part is where you develop your own site specific best management practices for managing your laboratory hazardous waste in accordance with Subpart K.
One of the main benefits for opting in is the chance to reduce your generator status. Subpart K allows one lab clean out per year which does not count against your generator status. However, the waste still has to be reported.