Hazardous Waste in Schools

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When you think of “Hazardous Waste”, the thought of leaking drums at an old manufacturing facility comes to mind.  Another common vision is people in white tyvek suits walking around a contaminated site with leaking drums.  The last thing that comes to mind as it pertains to “Hazardous Waste” is schools.  Did you know schools potentially could have the same hazardous waste concerns as manufacturing facilities?  They typically do not manufacture any products, however, hazardous waste can be generated by the types of classes being taught and/or routine activities such as cleaning and maintenance.

Almost all educational facilities with physical buildings, from grammar schools to colleges and universities, have hazardous waste concerns.  Although ‘Universal Wastes’, including batteries and fluorescent bulbs, are probably more common than hazardous waste in the schools, each must also deal with the more regulated hazardous waste. 

Some of the hazardous wastes in schools are generated from the types of classes at that particular school such as Biology and Chemistry.  Other hazardous wastes come from cleaning and daily maintenance of the buildings themselves.  These may include solvents for cleaning and corrosive boiler treatment chemicals.

The federal government recently adopted new regulations that could make it easier for schools to deal with their hazardous waste issues.  Subpart K of the Code of Federal Regulations (CFR) was written specifically for schools’ concerning their laboratory waste.  Schools now have the option to comply with Subpart K or to continue to be governed by the generator standards manufacturing facilities abide by (40 CFR, Part 262).  If chosen, Subpart K allows for longer accumulation times and more liberal hazardous waste determination methods.

For more guidance on the Subpart K regulations, or for an audit regarding your current hazardous waste program, contact Craig Gorczyca at EWMA (973-560-1400, x145 or craig.gorczyca@ewma.com).    

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