Comment submitted by Mike Burba, Assistant Radiation Safety Officer, University of Cincinnati

"Burba, Michael (burbamj)" <BURBAMJ@UCMAIL.UC.EDU> 08/29/2006 12:18 PM To: Group Rcra-Docket@EPA cc: "Morris, Vicki (morrisvr)" <MORRISVR@UCMAIL.UC.EDU> Subject: EPA-2050 AG 18 RCRA-2003-0012 I agree with the basic concept of this rule; however, I suggest the rule be expanded to include “research” laboratories at affiliated hospitals or private research foundations. It is not uncommon for individuals who are faculty members at a college or university to be assigned space to perform their research at an affiliated hospital or research foundation. The types and quantities of waste generated in a “research” laboratory at a hospital or private research foundation is the same as at any college or university laboratory and causes the same risk to the public or the environment. As long as the laboratory is conducting “research” and not clinical analyses or other activity not related to basic research, such as, determining the contents of samples using a proven process, the rule should apply to them. Thank you for considering my comments. Mike Burba Assistant Radiation Safety Officer University of Cincinnati PO Box 670591 170 Panzeca Way Cincinnati, Ohio 45267-0591 513-558-4110 513-558-9905 (Fax)