BYU and Subpart KAlfredo ChandiaRisk ManagementBrigham Young UniversityProvo, Utah
Brigham Young University
Located in Provo, Utah
Private University founded in 1875 and is affiliated with the Church of Jesus Christ of Latter Day Saints. It offers BS, MS and PhD degrees.
Undergraduate body of approximately 30K students.
Some interesting facts about BYU: Approximately 70% of students speaks a second
language (numbering 107 languages in total) . . . Fluently!
55 languages are taught on campus BYU Ballroom Dance Company has won the US National
Formation Dance Championship every year since 1982
Ice Cream is now cheaper on campus than in 1950 (if you adjust for inflation)
BYU’s Waste Operations as of May 2013 Overview
Generator makes request for waste pickup via our web page or via phone
We collect from the laboratory and bring the material to our central accumulation area (90-Day Area)
If regulated, we assign waste codes
We prepare waste for shipment
Ship waste via vendors
BYU’s Waste Operations as of May 2013 Overview
BYU’s Container Management
We provide containers to generators for collection
We give unique IDs to each container
Each container ID is tracked online
Each container has an online log sheet
Each container is associated with a waste stream
We bulk our waste
We reuse containers
Subpart K
40 CFR 262 Subpart K - Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material for Laboratories Owned by Eligible Academic Entities
Effective on December 2008
Volunteer program
Effective in Utah
Why did we adopt Subpart K at BYU?
Utah Department of Environmental Quality Inspection
in March 2011
From UDEQ’s letter dated 5/23/2011
“Subpart K of 40 CFR 262 provides standards for managing hazardous waste in academic laboratories as an alternative to the satellite accumulation area generators regulation. Subpart K may better suit the University’s specific circumstances of managing waste from teaching and research laboratories.”
BYU’s Situation – Discussion
We have been operating under a scheme that resembled the Subpart K model
UDEQ has been aware of it and not said too much about it.
Our regulators are aware the SAA model doesn’t fit the academic environment
It was time to adopt Subpart K
We finally decided to adopt the regulation
Adopting Subpart K
Looked into the regulation itself
Watched the training EPA offers online
Looked at other schools
Met with University of Utah to get their input (already working under Subpart K)
Developed our Laboratory Management Plan (LMP)
Development of Laboratory workers’ online training
Approval by BYU’s Academic Safety Committee
Signature of our Administrative Vice President
Submittal of Form 8700-12 to Utah Department of Environmental Quality
Changes to our Operations (Academic Side)
Labels
Purpose of labels Aid First Responders
Aid laboratory users in where to put their unwanted lab material
Unique Container Label
Constituents (Waste Profiles) Date created (important for “Rolling 6 months”
collection) Generator’s contact information Additional information
ID #57
Webpage Content Update
Training
Delivered online (and tracked) for all “Laboratory Workers” (PIs & student workers)
“Commensurate with their duties” Initial training and every two years thereafter “Fail proof” training Must have training completed to request unwanted
lab material pickup Consulted with Faculty and Staff for best format
Trained Professionals at BYU: Professional staff oversee all unwanted lab material
management Student employees work under the direct
supervision of professional staff Training:
40-Hour HAZWOPER Training RCRA Regulations Training DOT Training Biological Waste Management Training Radiological Training Truck Driving Training In-House Training in Waste Container Management
Database Chemical Compatibility Training Other training as needed
Container Management
Labels (already discussed) Good laboratory practices for using and handling
containers We gave ourselves up to 10 calendar days to pick
up the container(s) on our Laboratory Management Plan. Internally, we gave ourselves up to 3 business days.
All containers will be removed every 6 months (from start of accumulation date)
We will automatically remove the container 30 days before its’ 6 month due date
It can be removed for other reasons as well (full, project ends, 90%full, etc.)
Container Management
Use of working containers < 2 gallons of less May be open till the end shift or until full (whichever is
first) Hazardous Waste Determination
Done by us at our Central Accumulation Area BYU’s Chemicals Management Building
Made the determination within 4 days Move some chemicals (unused chemicals) to BYU’s chemical
redistribution program
Lab Cleanouts It doesn’t help us on our generator status It gives us flexibility on how we manage cleanout We have 30 days
We have BIG lab moves = cleanouts
John A.Widtsoe Building Life Science Building (no official name yet)
Once a year per laboratoryAll cleanouts will be documented (lab id, date
started/ended, volume generated, etc.) and the records kept for 3 years
Questions, Comments, Discussion, Etc.
See you next year in Park City, Utah!
