> > Is this something that has come off the tails of the recent incidents at UCLA, Texas Tech and TAMU? > To some extent. It's more trying to figure out what the context of the google reports of lab hazmat events each day represent. >The reality is many organizations, especially in universities, do not have a true lab registration program or process. That was an ongoing struggle in the Lab XL effort that led to the Subpart K rule; just counting "labs" at a specific institution such as ours. After today's suggestion, I did look at the preamble of the rule and it appears that the EPA didn't want to take this question on either. They did include the number of large quantity generators in academia, but they didn't get more specific than that as far as I can see. - Ralph Ralph Stuart, CIH Environmental Safety Manager University of Vermont Environmental Safety Facility 667 Spear St. Burlington, VT 05405 rstuart**At_Symbol_Here**uvm.edu
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