NACUBO has long advocated for recognition of the differences between academic institutions and many other generators of hazardous waste in EPA rules.
As you have duly noted in the past that a “one-size-fits-all approach may not be optimal for such a diverse regulated community"...
Personnel Security Programs Meeting Report, 21-22 August 2013
Implementing the Revised Select Agents and Toxin Regulations Proceedings, 22-23 April 2013
International Science and Security Proceedings from the Meeting, 4-5 February 2013
A Discussion about Dual Use Review and Oversight at Research Institutions, September 13-14, 2012