How not to be a large quantity generator of hazardous waste

Colleges and universities use labpacks to dispose of much of their chemical waste. Excessive identification of material as acute hazardous waste or including the weight of containers and packing materials may raise the regulatory status of a program leading to additional paperwork and operational restrictions. Small and conditionally exempt small quantity generators will especially benefit from careful evaluation of suspected acute hazardous waste to avoid exceeding the one kilogram per calendar month limit that invokes large quantity generator rules. In addition, the extra effort required to measure net weight of hazardous waste generated and to exclude non-regulated waste from the total may keep a campus below the monthly quantity of non-acute hazardous waste that would subject the campus to increased regulation. Carefully using the letter of the rules to measure hazardous waste quantities should not affect decisions about proper management of chemical waste to protect public health and the environment. State rules may differ from the federal rules cited in this paper.