Overview
Laboratory worker responsibilities – Overview
- Proper labeling
- Compatible containers
- Closed containers
- Proper storage location
- Observance of quantity limitations
- Disposed via EHS
- Special requirements for RAM waste related to Radiation Safety regulations
- Enforcement discretion
Both City and East Campus are operated as Large Quantity Generator (LQG) sites. As a LQG, hazardous waste regulations require that facility personnel receive training that makes them competent to perform their hazardous waste related duties. This includes the ability to make a waste determination, proper handling of waste chemicals, actions to take in an emergency, and other like topics. Obviously, it would be impossible to train every faculty, staff, and student to attain this level of competency. Therefore, Colleges and Universities have successfully argued that laboratories are Satellite Accumulation Areas and that the real waste management functions are conducted by EHS staff, not laboratory workers.
While the regulatory agencies have recognized this approach as legitimate and legal, they do expect a certain level of performance by laboratory staff. That primarily boils down to appropriate container labeling and management while the waste is in the laboratory. Laboratory personnel are expected to properly label waste containers, use collection containers that are compatible with the content, keep the container closed, refrain from illegal disposal methods, and limit the quantity of waste that is accumulated.
Seems simple, right? Well, the basis for these requirements and how they are implemented are a bit more complex than it would appear. This portion of the training will give you the information on the nuances of each of these requirements and how to apply the information learned in a laboratory audit. Radiation Protection regulations contain requirements relative to radioactive waste. If the radioactive waste also contains constituents that are regulated under the hazardous waste rules, then we have a dually-regulated material. During this training, we’ll cover the requirements for radioactive waste.
It is important to recognize that the interpretation of the hazardous waste rules varies tremendously from EPA region to EPA region, State to State, and inspector to inspector. So, unfortunately compliance with the rules can be a bit of a moving target, and there will be times that we have to adjust our management practices and instructions. We refer to this as “enforcement discretion,” and such discretion is not in our control. So, as you’ll see as we progress through this section of the training, there are some things that fall into a “gray” area.
Listed in the overview are areas that auditors should be able to assess.
Citations and Related Resources