Investigating the “gray area” of hazardous waste management
The Environmental Health and Safety (EHS) program at TGen is tasked with properly disposing of chemical wastes produced by research laboratories, including determining if a waste is hazardous. The management and classification of hazardous wastes is governed by a federal regulation, the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA). However, since RCRA has a strict definition of what is considered hazardous, wastes that do not fall under this classification, but that still have other hazards, fall into a “gray area.” Through a combination of internal review, external sources, and case studies of two commonly-seen wastes, an investigation into the gray area was conducted, which provided more information and perspectives on the evaluation of non-RCRA wastes. This led to the development of educational materials for both EHS and laboratory staff use. These resources cover a variety of topics such as federal regulations, managing wastes from kits, and the waste determination process. The investigation ultimately explored the gray area of hazardous waste determination in order to better understand how to manage these wastes efficiently while safeguarding the surrounding community and environment.