Meg McCarthy/DC/USEPA/US 

01/17/2007 03:03 PM	To

	aslesing@rdg.boehringer-ingelheim.com

	cc

	

	bcc

	Patricia Mercer/DC/USEPA/US@EPA; Kristin Fitzgerald/DC/USEPA/US@EPA;
James 

Michael/DC/USEPA/US@EPA

	Subject

	Follow-up Question on Boehringer Ingelheim's Comment

	

	

Arthur E. Slesinger

Executive Director, Environmental Affairs and Safety

Boehringer Ingelheim Pharmaceuticals Inc.

900 Ridgebury Rd

P.O. Box 368

Ridgefield, CT  06877-0368

Dear Mr. Slesinger:

 Thank you for your comments on EPA’s Proposed Rule: Subpart
K—Standards 

Applicable to Academic Laboratories (71 Federal Register 29712) on
behalf 

of Boehringer Ingelheim.

 In response to Boehringer Ingelheim’s comments (Docket Number 

EPA-HQ-RCRA-2003-0012-0118), EPA has a few follow-up questions.  On page
2 

of Boehringer Ingelheim’s comments, you indicate that institutional 

research laboratories are identical to the college and university 

laboratory environment.  EPA is very interested in any information and 

data that Boehringer Ingelheim can provide to help understand the 

similarities and differences between institutional research laboratories


and college and university laboratories, as described in the proposed 

rule.  For example, any information or data describing these
laboratories, 

their activities and their hazardous waste generation patterns would be 

beneficial to EPA in its development of the final rule.  What type of 

activities do these laboratories conduct?  Do their activities differ 

day-to-day or are they fairly routine and/or repetitive?  What types of 

hazardous wastes are generated at these laboratories?  In what amounts
are 

these wastes generated?  EPA would find it helpful if you could provide 

any answers, explanations or data relating to any of the above
questions.  

Additionally, what other types of laboratories exist at facilities such
as 

yours?  How does your facility differentiate between research
laboratories 

and other types of laboratories?  Finally, EPA would appreciate a timely


response to allow us to incorporate any information you may provide into


the decision-making process, as appropriate.   Please provide a response


by February 16, 2007.  If you are unable to provide a response by then, 

please contact us to let us know if and when you could provide a timely 

response.  

Any supporting information you provide to EPA will be made publicly 

available in the docket for the rulemaking, unless the information is 

claimed as Confidential Business Information (CBI).  Therefore, if you 

submit any information that you claim as CBI, clearly mark all of the 

information that you claim to be CBI.  Information so marked will not be


disclosed, except in accordance with procedures set forth in 40 CFR part


2.  Please do not fax any information claimed as CBI.  For additional 

information on how to submit CBI, refer to page 29713, of the May 23, 

2006, Federal Register, proposed rule for academic laboratories, or 

contact LaShan Haynes, the Office of Solid Waste CBI contact, at (703) 

605-0516, Haynes.LaShan@epa.gov.

Again, thank you for your comments on the proposed standards for
academic 

laboratories.  Please direct any questions or response to this letter to


any member of EPA’s labs team:  

Patricia Mercer, (703) 308-8408, Mercer.Patricia@epa.gov

Meg McCarthy, (703) 308-8653, McCarthy.Meg@epa.gov

Kristin Fitzgerald, (703) 308-8286, Fitzgerald.Kristin@epa.gov

*********************************

Meg McCarthy

US Environmental Protection Agency

Office of Solid Waste

Hazardous Waste Identification Division

703-308-8653

mccarthy.meg@epa.gov

*********************************

