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Government Relations Lessons Learned
Transcript of Government Relations Lessons Learned
Into the Meat Grinder...
College and University sector meets several times
Strategies for rulemaking and/or letters of interpretation
The Joys of RCRA
How are EPA hazardous waste regulations incompatible with labs...let us count the ways...
October 21, 1976
- Congress passes RCRA
If you like sausage and respect the law, you shouldn't watch either one of them being made.
~ Otto von Bismark
The Rulemaking Process
Some government relations lessons from the development of Subpart K
I am not Ralph Stuart
(in case you did not notice)
The Tao of Ralph
October 22, 1976 -
Academia and labs complain that it's not a good fit.
We Need Change
Letter of interpretation
Exempt labs from certain rules
New rules for labs
National Research Council
Mismatch between regulations and laboratory practices
Congress authorizes EPA to make change to regulations for higher education institutions
EPA proposes guidance to clarify regulatory requirements for academic labs
Government - University - Industry Research Roundtable (GUIRR)
California Laboratory Reform Task Force
ACS LabWAM report to EPA
Prudent Practices for Disposal of Chemicals from Laboratories
ACS Committee on Chemical Safety creates Task Force on Laboratory Waste Management (LabWAM)
Still active today as CCS
Safety Advisory Panel (SAP)
Requests performance-based standards
13 Recommendations, including request for performance-based standards
This follows very specific recommendations and proposals in 1990, 1992, and 1996
National Research Council Committee on Prudent Practices for Handling, Storage and Disposal of Chemicals in Laboratories
Project XL Begins: eXcellence in Leadership
Howard Hughes Medical Institute (HHMI) Consensus Best Practices
Report to U.S. Congress at the request of the House and Senate Committee on Appropriations
Evaluating the Consensus Best Practices Developed through the HHMI's Collaboratorive Hazardous Waste Management Demonstration Project and the Need for Regulatory Changes to Carry Out Project Recommendations
2002: An Audience with the EPA
American Council on Education (ACE)
Association of Higher Education Facilities Officers (APPA)
Campus Safety Health and Environmental Management Association (CSHEMA) -
National Association of College and University Business Officers (NACUBO)
Meet with Assistant Administrator Marianne Horinko and her staff
EPA recognizes colleges and universities as a special sector
College and University Sector Strategy
Office of Solid Waste and Emergency Response
Office of Policy, Economics and Innovation
Enforcement and Compliance Assurance
2006 Meeting with Office of Management and Budget
Lots of good things
Many missed opportunities
~ 20 states adopted Subpart K
Unknown number of schools opted in
Notice of Proposed Rulemaking for Hazardous Waste Generator Improvement
Many proposed changes will be a challenge for laboratories.
EPA says...this is not for you, you have the Lab Rule
Expect rulemaking before the elections
...the conversations will continue....
Lessons Learned from Lab XL and Subpart K
Regulations are downstream of the legislation
Primary driver is to meet the intent of the authorizing law.
Regulators expect unpleasant side effects to occur
Saying it's inconvenient or expensive is "whining"
The Affected Community has to Self-Organize
Technical Considerations and Administrative Realities
Each agency has its own administrative opportunities and challenges based on their political history and fortunes
Strictly technical arguments will be self-limiting
Example: OSHA and EPA - different perspectives on same chemical issue
Patience and Persistence is Required
Start discussions and planning before a crisis hits.
It may take a crisis for the change to occur, but a ready answer is more likely to be picked up when the crisis hits.
The larger the fraction of the regulated community, the better - don't want to develop individual regulations for every possible sector
Having several organizations involved in the discussions is helpful even if only one or two take the lead
2002 Report to Congress
EPA recognizes academic research institutions have difficulty complying with...RCRA regulations due largely to their industry-oriented framework. Therefore, EPA supports developing effective alternatives for safely managing hazardous wastes in academic research institutions that meet standards for protection of human health and the environment.
Not just for rulemaking