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!