12/07/06

Meeting with Association of Independent Research Institutes (AIRI)
Representatives

Attendees:

EPA/OSW:

Betsy Devlin

James Michael

Trisha Mercer

Kristin Fitzgerald

Meg McCarthy

Rachel Alford

Lewis-Burke Associates, LLC (representing AIRI):

Donna Dean

Hollie Stephenson

Representatives for the Association of Independent Research Institutes
met with EPA Office of Solid Waste management and staff to reiterate
their comments on the proposed academic laboratories hazardous waste
rule (Subpart K). AIRI described why they believe non-profit independent
research institutes (IRIs) should be included in the universe of
facilities covered by the final rule.  AIRI described the nature of IRIs
and the similarities to and affiliations with the academic institutions
covered by the proposed rule, providing examples such as:

Similar purposes: scientific discovery and training of scientists

Similar research environments to academic settings

Similar funding sources: federal and philanthropic funds

Coordination and affiliation with colleges and universities

Joint faculty appointments with colleges and universities

Similar quantities and types of hazardous waste generated from research
activities

The Office of Solid Waste representatives asked a number of clarifying
questions and asked for AIRI’s reaction to the proposed rule. 

