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Associations Comment on Proposed Hazardous Waste Disposal Rules

NACUBO  has long advocated, along with others, for recognition of the differences between academic institutions and many other generators of hazardous waste in EPA rules. These efforts culminated in EPA’s adoption seven years ago of Subpart K of 40 CFR part 262. Unfortunately, many schools have been unable to take advantage of this alternative. The characteristics of hazardous waste generation at academic institutions that led to those rules remain relevant to the current NPRM. Colleges and universities tend to generate a large and ever-changing variety of hazardous wastes mostly in small quantities, from multiple facilities. The personnel involved are often faculty and students. Most higher education institutions have worked to build capable, professional dedicated environmental health and safety (EHS) staff to ensure regulatory compliance

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