Why would a college or university want to continue to operate under the existing regulations?
EPA recognizes that hazardous waste management operations vary widely among campuses and some colleges and universities have developed programs that have proven to be successful, and thus may be reluctant to change from the regulation under which they are currently operating. Therefore, Subpart K is an optional, alternative set of requirements to the existing generator regulations at 262.11 and 262.34(c). Those colleges or universities that choose to continue to manage their laboratory hazardous waste under the current hazardous waste regulations may do so. Colleges or universities that would like the additional flexibility of Subpart K may choose to manage their laboratory hazardous waste according to this new set of generator regulations. Subpart K was developed with performance-based standards in part to account for the diversity among college and university operations and practices, curricula, and goals. The term “performance-based standards” means a flexible approach that will all
