The University of Iowa

SAFETYmatters - Recent EPA Hazardous Waste Compliance Inspection

On November 16th – 18th, the U.S. Environmental Protection Agency (EPA) conducted a hazardous waste management regulatory compliance inspection on the Main and UI Research (Oakdale) campuses.

Under the Resource Conservation Recovery Act (RCRA) congress gave EPA the authority to regulate hazardous waste disposal. EPA has defined what is hazardous waste, and how it must be managed. At The University of Iowa, the Environmental Health and Safety Office (EHS) has the responsibility for conducting management programs to ensure that hazardous waste is handled and disposed of in compliance with the regulations. The programs have established that waste generators accumulate waste in “satellite accumulation areas” that do not require permits. EHS operates an EPA permitted hazardous waste storage area.

EPA also has the authority to conduct unannounced inspections to determine regulatory compliance. An inspection is typically conducted annually on the Research campus and every five years on the Main campus. Inspections include a records review (shipping manifests, inventories, facility inspections, reports, and permit documents) and a walk-through inspection of waste generating, accumulation, and storage areas (labs, art studios, hospital and dental clinics, facilities and shops). EHS accompanies EPA inspectors during the visit.

During the November inspection EPA visited on the Research campus 11 labs in HLI and MTF, NADS, and FM shops. On the Main campus EPA visited 25 labs in CB, BB, SC, DSB, CPB, PHAR, and multiple buildings in CCOM. Shops at Cambus and FM were also reviewed. In the labs and facilities, the inspection made three findings of violations:

  • Failure to label one container with a hazardous waste. (Waste labels are available free of charge upon request by completing a Label Request Form.)
  • Failure to indicate the nature of hazards present on six containers. (Always check the appropriate hazard boxes on hazardous waste labels as soon as waste is added to a container.)
  • Failure to label a used oil container with the words used oil. (EPA regulations specifically require that used oil be identified by the words ‘used oil’.)

EHS has contacted staff in areas where findings were identified to make corrections. A response to the inspection explaining how non-compliance was addressed has been sent by EHS to EPA, and we are awaiting a reply. While EPA does have authority to take enforcement action including levying fines, it is not expected in this instance.