Are the major concerns of small colleges being addressed by the rulemaking effort?
Small college representatives participated in drafting CC’s regulatory language. While many small colleges support the proposal, they note that the language does not completely address their main concerns about RCRA, such as episodic generation and multiple EPA ID numbers/contiguous property issues. Small college representatives are particularly troubled by P-list rules, which disproportionately impact college laboratories that are much more likely to have small quantities of esoteric chemicals compared to industry. Industry typically has either large amounts of P-listed chemicals or none at all. The one-kilogram limit, which kicks small quantity laboratory generators into large quantity generator status, is a major burden to small colleges and universities. The CC has told the OSW that these are major concerns for the sector, but to date, the OSW has said that these concerns are not unique to the C&U sector and must be addressed under their broader RCRA initiative. The CC will continu
