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On 1 December 2008, the United States Environmental Protection Agency added new hazardous waste determination and accumulation provisions to RCRA to provide an alternative compliance scenario for academic generators. This rulemaking established a new Subpart K to 40 CFR 262. The Agency''s intent was to help academic laboratories better manage their hazardous waste, in part by providing greater flexibility regarding: (1) the timing of hazardous waste determinations, (2) on-site waste consolidation, (3) lab clean-outs, and (4) record-keeping. Since its passage, relatively few large research-oriented universities have opted into the Subpart K system. This paper focuses on the approach taken by The University of North Carolina-Chapel Hill to evaluate the pros and cons of Subpart K, assess the impacts on its established Part B hazardous waste management process, and explain the decision reached by the University''s Department of Environmental Health and Safety to not opt into Subpart K at this time. Because Subpart K is favorable for certain academic hazardous waste generators, this decision may be reconsidered in the event the rulemaking is revised in the future. [Copyright &y& Elsevier]

The Resource Conservation and Recovery Act was passed by the US Congress in 1976; the law charged the Environmental Protection Agency with developing regulations to control the disposal of hazardous wastes from “cradle to grave”. These RCRA regulations went into effect on November 19, 1980. The ensuing 30 years have seen dramatic changes in how waste is managed both at the generator''s site and in terms of ultimate disposal. This paper will look at those changes and grades the overall progress that has been made to reduce improper disposal of hazardous chemical wastes. [Copyright &y& Elsevier]