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Leveraging Limited Resources To Obtain Better Compliance

Region 2's College & University Compliance Initiative: Environmental Results From An Integrated Strategy. Leveraging Limited Resources To Obtain Better Compliance. Six Year Status Report. Academic Labs Rule. Proposed Rule published in Federal Register May 23, 2006

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Leveraging Limited Resources To Obtain Better Compliance

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  1. Region 2's College & University Compliance Initiative: Environmental Results From An Integrated Strategy Leveraging Limited Resources To Obtain Better Compliance Six Year Status Report Region 2 College & University Compliance Initiative

  2. Academic Labs Rule Proposed Rule published in Federal Register May 23, 2006 90 day public comment period Originally ended August 21, 2006 CSHEMA, C2E2, NACUBO and ACE asked for an extension of public comment period Public comment period extended Ended September 20, 2006

  3. 111 Public Comments on Proposal 66 individual colleges & universities 17 states/state groups 13 trade groups 8 academic - AAMC, ACS, CSHEMA, C2E2, COGR, HHMI, NACUBO/ACE, VESCO (13 VT schools) 5 non-academic 6 federal government 9 other or no affiliation given

  4. Main Points from C/U Comments Applicability of Rule Expand to include CESQGs, teaching hospitals, photo labs, field labs, stockrooms Expand to include all HW on campus – dual regulation is too confusing Performance-based Standards Proposal is too prescriptive to be truly performance-based Clean-out Incentives Supportive of incentives for voluntary clean-outs Allow CESQGs to do clean-outs without fully opting in Laboratory Management Plan LMP should NOT be enforceable Other areas Supportive of opt-in approach Add consolidation area/super satellite area Add working container Eliminate LQG status based on 1 kg/month of acute HW Allow one EPA ID# per campus Allow treatment in the lab Lab waste is MUCH more than 9% of C/U’s total HW

  5. Main Points from State Comments Applicability of Rule 5 states said to limit to C/Us only 5 states said to expand to others with labs Performance-based Standards 5 states said they are not enforceable; will lead to inconsistent enforcement 3 states said to add more prescriptive labeling requirements Clean-out Incentives 7 states said HW from clean-outs should be counted LMP Enforceability 2 states said LMP should NOT be enforceable 4 states said LMP should be enforceable

  6. Main Points from Other Comments Applicability of Rule Expand to include other facilities with labs R&D labs (Government, commercial, non-profit), hospitals 2 said to expand to include all HW – dual regulation in “untenable” Performance-based Standards Proposal is too prescriptive to be truly performance-based Clean-out Incentives 4 supportive of incentives for voluntary clean-outs 2 said clean-outs should be mandatory 1 said HW from clean-outs should be counted Laboratory Management Plan 4 said LMP should NOT be enforceable 3 said LMP should be enforceable Other areas Add consolidation area/super satellite area Add working container 2 said to allow treatment in the lab

  7. If EPA Finalized as Proposed 2 states said they would adopt the rule 1 school said it would opt in 12 schools said they would NOT opt in 2 C/U trade groups said many schools are unlikely to opt in

  8. EPA’s Next Steps Re-convene Agency workgroup for final rule phase Work toward Early Guidance with AAs AA tasks workgroup with issues for workgroup to focus on in final rule Workgroup develops options and recommendations for management Management makes decisions regarding final rule

  9. Finalizing & Implementingthe Labs Rule EPA prepares Final Rule Final Rule is reviewed by OMB Final rule is signed & published in the Federal Register (Summer 2008) C/Us in AK, IA can implement the Labs Rule (not authorized) Other states get authorized for Labs Rule C/Us in authorized states can implement the Labs Rule

  10. Contact Info for OSW Labs Team Kristin Fitzgerald Fitzgerald.Kristin@epa.gov 703-308-8286 Trisha Mercer Mercer.Patricia@epa.gov 703-308-8408 Meg McCarthy McCarthy.Meg@epa.gov 703-308-8653 Jessica Biegelson Biegelson.Jessica@epa.gov 703-308-0026

  11. Goals For Compliance Initiative • Improve environmental compliance and safety at main and off-site facilities. • Change the culture to one in which environmental compliance is a priority. • Ensure compliance of entire sector; not just those reached through inspections. • Ensure continued compliance by implementing permanent changes. Region 2 College & University Compliance Initiative

  12. Approach • Region 2 combined the following strategies to address compliance issues in this sector: • Compliance assistance • Compliance incentives (voluntary audit/disclosure) • Compliance monitoring • Enforcement • Pollution prevention • Environmental management systems (EMS) Region 2 College & University Compliance Initiative

  13. Results: Compliance Monitoring & Incentives Programs Region 2 College & University Compliance Initiative

  14. PERCENT / YEAR Region 2 College & University Compliance Initiative 14

  15. University and College SEPs • 11 settlements include SEPs • Range from $26,000 to $270,000 • Total value of SEPs = $1,810,297 Region 2 College & University Compliance Initiative

  16. Types of SEPs • Chemical Tracking & Control Systems • Mini/Micro-Scale Chemistry • Solvent Recovery Systems • Other Equipment/Technology Modifications • Environmental Compliance Promotions • Environmental Management Systems Region 2 College & University Compliance Initiative

  17. Results:Environmental Benefits Region 2 College & University Compliance Initiative

  18. Root Causes Of Noncompliance Systemic violations appear to stem from: • Inadequate resources for people, equipment and training to carry out environmental activities; • Limited or no environmental compliance accountability for individual departments, laboratories, and staff; • Limited authority vested in environmental compliance officials; Region 2 College & University Compliance Initiative

  19. Root Causes Of Noncompliance • No clear environmental compliance chain-of-command; • Scattered, incomplete, and missing environmental compliance documentation; • Incomplete institutional knowledge regarding environmental regulatory requirements; and • Broad use of hazardous materials when effective substitutes exist Region 2 College & University Compliance Initiative

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  24. College & University Violations2007 Region 2 College & University Compliance Initiative

  25. College & University RCRA Violations - 2007 Region 2 College & University Compliance Initiative

  26. College & University CAA Violations 2007 Region 2 College & University Compliance Initiative

  27. Survey Overview • 61 colleges completed and returned the audit survey • 18,345 faculty are reported to be working at these facilities • 25,922 staff are reported to be working at these facilities • 399,498 students are reported to attend these facilities • 2191 facilities are reported to compose these 61 colleges Region 2 College & University Compliance Initiative

  28. Region 2 College & University Compliance Initiative

  29. Understanding Of Waste Management Regulations Before And After Compliance Initiative (42% - 97%) Region 2 College & University Compliance Initiative

  30. Understanding Of Above Ground Storage Tank Regulations Before And After Compliance Initiative (46 - 91%) Region 2 College & University Compliance Initiative

  31. Understanding Of Under Ground Storage Tank Regulations Before And After Compliance Initiative (51% - 90%) Region 2 College & University Compliance Initiative

  32. Understanding Of Clean Air Act Regulations Before And AfterCompliance Initiative (34% - 83%) Region 2 College & University Compliance Initiative

  33. Understanding Of Wastewater Discharge Regulations Before And After Compliance Initiative (44% - 74%) Region 2 College & University Compliance Initiative

  34. Understanding Of Spill Prevention Control Countermeasure Plans Before And AfterCompliance Initiative (33% - 87%) Region 2 College & University Compliance Initiative

  35. Understanding Of Toxic Substances Control Act Before And AfterCompliance Initiative (43% - 75) Region 2 College & University Compliance Initiative

  36. Understanding Of Pesticide Regulations Before And AfterCompliance Initiative (49% - 79%) Region 2 College & University Compliance Initiative

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  39. Top $$ Saving Activities Region 2 College & University Compliance Initiative

  40. Top $$ Saving Activities Region 2 College & University Compliance Initiative

  41. Top Five Pollutant Reductions Region 2 College & University Compliance Initiative

  42. Five Simple Waste Reduction Activities • Install automatic light sensors • Install water saver plumbing fixtures • Send kitchen grease to a reclamation facility • Switch from disposable to reusable plates, eating utensils, and cups for cafeteria services • Reduce the use of disposable cleaning materials Region 2 College & University Compliance Initiative

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  49. Reported College & University Audit Costs • Average cost of audit is $44,012 • Average cost of audit without 5 most expensive (>$100,000) is $13,331 • Average cost of compliance is $124,788 • Average cost of compliance without 7 most expensive (>$100,000) is $23,047 Region 2 College & University Compliance Initiative

  50. Region 2 College & University Compliance Initiative

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