What are EPA’s concerns, if any, about the proposed regulatory language?
Along with the technical aspects and resource demands of a rulemaking effort, EPA has questions for the C&U sector about federal and state enforceability in academic laboratories; proposed accumulation times during lab cleanouts (some feel 30 days may be too long); storage of incompatible chemicals (is not addressed in the proposed language and is a primary concern of EPA enforcement inspectors at C&U); and quid pro quo – some EPA representatives feel that the proposed language, while it does address historical inequities, should be accompanied by an increase in regulatory compliance requirements in other areas. Above all, OSW would like this rulemaking effort to resolve C&U Sector issues once and for all.
