October 30, 1998

Ms. Joan Ferber, Regulations Coordinator
Environmental Analysis and Regulations Section
Department of Toxic Substances Control
400 P Street, 4th Floor
P. O. Box 806
Sacramento, CA 95812-0806

RE: Proposed Regulations
Research Laboratory Wastes Exemption Regulations and AB 1089 Regulations
Department Reference Number: R-97-30

Dear Ms. Ferber:

We wish to thank DTSC and the Office of Pollution Prevention and Technology Development for its work in developing regulations that take into account the realities of laboratory research. We appreciate your responsiveness to the University's concerns and your efforts to make the SB 14 program more workable. With the research lab waste exemption, many of our campuses will be under the threshold and fall out of the SB 14 requirements altogether.

The original intent of SB 14 was clearly aimed at industry, which has a large volume of a few waste streams. The hazardous waste produced at universities is typically generated from small volumes of a large number of hazardous materials, used in a variety of experimental processes. However, due to SB 14, all of our campuses have instituted waste minimization procedures that will continue to be implemented. These procedures have had economic rewards for us as well as environmental ones. Some examples of measures already in place are:

Administrative

1. Management commitment
2. Making waste minimization a campus policy
3. Chemical exchange programs
4. Chemical inventory
5. On-site chemical waste tracking
6. Chemical waste recharge
7. Educational programs
8. Information exchanges

Laboratory

1. Introducing microscale procedures for use in experiments, thereby reducing volume (most chemistry lab textbooks are prepared for microscale).
2. Modifying experiments so that the end result can be used as the starting product for another experiment.
3. Chemical substitution.
4. Replacing mercury thermometers with digital ones.
5. Reusing spent solvents for the initial rinse when cleaning glassware; using fresh solvent only for the final rinse.

Facilities

1. Use of water-based paints and cutting fluids
2. Recycling pesticide rinse water

The University will continue to look for opportunities to reduce hazardous waste, due to the economic incentives as well as environmental consciousness. Again, we want to thank you for your efforts.

Sincerely,



David Belk
Director
Environmental Protection Services

Cc: Assistant Vice President Bocchicchio
Executive Assistant Pacult
Environment, Health and Safety Directors
Hazardous Waste Managers
Coordinator Oseroff