Procedure 14:
Tracking Legal Requirements

Policy

The University's Environmental Safety Facility staff identify and track legal requirements applicable to laboratory wastes and their management. They will communicate relevant changes in these requirements to affected campus workers along with advice on possible implications for campus operations.

This will be done through:

• review of journals (such as Chemical Health and Safety);
• review of newsletters (such Laboratory Safety & Environmental Management);
• monitoring of applicable web sites and e-mail lists (such as EPA's news page and the Vermont Department of Environmental Conservation web site and the SAFETY e-mail list);
• by participating in the meetings of professional organizations (such as the Campus Consortium for Environmental Excellence); and
• through informal interactions with environmental agency representatives.

Laboratory personnel will stay current with the contents and goals of the Environmental Management Plan through the Environmental Safety Facility web site, updates provided during annual ESF campus laboratory audits, Project XL reports at the Environmental Council meetings, and through scheduled training sessions provided by the Environmental Safety Facility staff.

Plan

Who:

ESF staff are responsible for reviewing regulatory changes and assessing their potential effect on campus laboratory operations.

When:

Legal requirements will be reviewed on a continuing basis by ESF staff; reports on changes will be made as needed, but at least quarterly within the ESF staff.

Where:

Documents to be monitored include

• 40 CFR 261 (EPA RCRA regulations)
• Vermont DEC Hazardous Waste Regulations
• Burlington sewer use ordinance
• Laboratory Environmental Management Standard 40 CFR 262.10(j)
• Project XL Final Project Agreement
• Prudent Practices for Handling Hazardous Chemicals in the Laboratory - National Research Council
• Safety in Academic Chemistry Labs
• UVM Campus Hazardous Waste Contingency Plan
• University of Vermont Chemical Hygiene Plan
• University of Vermont Environmental Health and Safety Policy

Procedure

Record

The Environmental Safety Facility staff will maintain the Regulatory Tracking forms in a database which is available to the ESF staff, laboratory workers, campus facility planners and the general public for review.