The Office of Environmental Safety needs your assistance to ensure that we do not incur violations for hazardous waste disposal at research laboratories. We highlight below the results of a recent inspection from the Environmental Protection Agency (EPA) and action items to assure a successful follow-up inspection by regulatory agencies. If this pertains to your research, please give this matter your attention.
On September 29, 2020, the U.S. Environmental Protection Agency (EPA), Region 4, and the Kentucky Division of Waste Management (KDWM) conducted Hazardous Waste Inspections at research laboratories within several building locations on the main campus. These inspections are unannounced and performed annually by the regulatory agencies. The September 2020 inspections resulted in the issuance of a formal Notice of Violation received on November 5, 2020.
It is expected that the EPA and KDWM will be conducting a follow-up inspection in the Spring of 2021 to verify that the identified violations have been satisfactorily addressed. This follow-up inspection will revisit the labs that had been cited in the Notice of Violation and will most assuredly visit a select number of new locations as well. If repeat violations are noted during the next inspection it is possible that they will yield fines and penalties to the University. Hazardous waste fines are gravity-based, and penalties range from $37,500 to $70,117 per day and per each identified violation.
A successful follow-up inspection by the regulatory agencies will depend upon diligence by the research community in observing, following and displaying compliance with all applicable environmental laws and regulations. We strongly encourage the use of self-inspections to ensure such compliance. Examples of some specific action items can be summarized in four areas including:
1. Knowledge. Personnel must be able to demonstrate knowledge of each one of the experiments, protocols, and/or activities conducted/performed in their laboratories including the type of waste these activities generate and the steps for proper disposal.
2. Training. All personnel must be up-to-date on their hazardous waste training requirements.
3. Operational. All containers must be properly labeled. This includes, but is not limited to, all containers containing product(s), regulated waste or non-regulated waste, reagents, etc. It is not acceptable to use abbreviations or chemical formulas when labeling. There should be no containers of unknown chemicals present in laboratories, non-regulated waste, reagents, etc. It is not acceptable to use abbreviations or chemical formulas when labeling. There should be no containers of unknown chemicals present in laboratories.
- All containers must be secured and segregated properly.
- All containers must be closed with a tight-fitting cap and in good condition.
- All containers must be in good condition (i.e., not dented, rusted, cracked, showing discoloration, signs of expansion etc.). This also includes all gas cylinders.
- All hazardous waste containers must be labeled with the words “Hazardous Waste” and the list of hazards.
Satellite Accumulation Area (SAA). Areas designated for hazardous waste accumulation are properly designated with SAA signage. This includes but is not limited to ensuring the area is free from any signs of spills or leaking containers.
Should you have any questions or concerns regarding compliance with hazardous waste regulations, please contact Maridely Loyselle, Assistant Director of the Environmental Management Department at Maridely.Loyselle@uky.edu or call (859) 562-3121.