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BYU and Subpart K. Alfredo Chandia Risk Management Brigham Young University Provo, 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.

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byu and subpart k

BYU and Subpart K

Alfredo Chandia

Risk Management

Brigham Young University

Provo, Utah

brigham young university
Brigham Young University
  • Located in Provo, Utah
slide3

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.
slide4

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
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 overview1
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
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
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
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
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
slide14

Purpose of labels

    • Aid First Responders
    • Aid laboratory users in where to put their unwanted lab material
slide15

ID #57

  • Unique Container Label
    • Constituents (Waste Profiles)
    • Date created (important for “Rolling 6 months” collection)
    • Generator’s contact information
    • Additional information
slide18

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
slide19

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
slide20

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.)
slide21

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
slide22

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 laboratory
    • All cleanouts will be documented (lab id, date started/ended, volume generated, etc.) and the records kept for 3 years