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Testing laboratories represent a diversified industry sector composed of firms that perform a variety of acoustic, vibration, thermal, destructive, and other testing and quality inspection services for a wide range of clients.
The primary environmental concern of most labs is hazardous waste. Existing federal and state hazardous waste regulations were designed primarily for industrial settings and are, in certain aspects, difficult to apply to academic teaching and research laboratories. The challenge for these academic laboratories is that they typically use a small amount of a large variety of chemicals on a sporadic basis.
Toxic substances can also be a concern. Certain certifications must accompany chemicals imported into or exported out of the United States. This Toxic Substance Control Act (TSCA) requirement applies to all imports or exports of the chemicals. This requirement also extends to research and laboratory samples. The certification rules apply if your campus imports or exports chemicals for any purpose.
Research activities may be exempt from TSCA rules pertaining to significant new use rules (SNUR) and premanufacturing notice (PMN) or may be subject to fewer demands than manufacturing. In some cases, as long as the institution meets the safety and recordkeeping requirements in 40 CFR 720.36 and 720.78, chemicals created in small amounts for research are exempt from TSCA reporting. However, if your company produces chemicals commercially, more extensive TSCA requirements apply.
The presence of certain volumes of chemicals onsite may trigger Community Right-to-Know reporting requirements.
Disposal of chemicals down drains leading to water treatment facilities may be subject to National Pollutant Discharge Elimination System (NPDES) permitting requirements.