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Appendix 2: Issues with the Exempt Laboratories Regulations

To date, the following issues with the Hazardous Substances (exempt Laboratories) Regulations 2001 have been cited.

  • Should the regulations be amended to account for the transition period? (The regulations make the distinction between approved and unapproved substances. Until substances are transferred from transitional provisions, there will be few approved substances and, strictly speaking, laboratories should comply with the much more restrictive provisions that apply to unapproved substances).
  • Should the disposal restrictions for unapproved hazardous substances be made less stringent? (Currently, unapproved hazardous substances have to be stored in containment until they are approved or have been treated so that they are no longer hazardous. Unapproved hazardous substances can also be disposed of via 'lawful export'.)
  • Are the requirements for laboratory managers and laboratory security reasonable given that many existing laboratories are contained within a single building but are used for different sorts of research by people from different departments or organisations? (The regulations can be read to apply to a single laboratory in a single building managed by a single organisation.)
  • Are the requirements for labelling too onerous given that laboratory access is restricted to personnel with specialist knowledge?
  • Are requirements to keep an up-to-date inventory of certain approved hazardous substances and all unapproved hazardous substances too onerous?
  • Do prescribed requirements for the transport of substances under section 33 have to be prescribed in the exempt laboratory regulations? (This is advocated in this discussion document.)


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