Notes

Outline

New England Universities Project XL: A Regulatory Experiment in Managing Lab Chemicals Pro-Actively Presented by: Suzanne Howard Campus Consortium for Environmental Excellence June 5, 2002

Background What is EPA’s Project XL? What is the NE Universities Project? Who’s Involved? Three pilot schools The C2E2 Local and national stakeholders Federal and state regulators

Why go through this process? Provides a paradigm shift for EPA to view colleges/universities as different entities Manage EPA’s increase in penalties/fines Set up a performance based chemical management program – similar to OSHA’S Lab Standard Integrate an EMS Plan into campus culture

What is in the EMP? Each Schools Environmental Management Plan includes: Minimum Performance Criteria EMP specific requirements Organizational responsibilities Training & Information Environmental Performance Indicators The EPI’s would not apply if the Rule became final

Project Goals Increase faculty, staff and student involvement in EH&S programs Reduce costs in delivering support services Create a transferable, consistent and performance based regulation oriented to college and university labs nationwide Demonstrate to regulators that colleges and universities can go “beyond compliance”

Project Goals Transfer waste determination outside the laboratory or the famous question: “When is a waste a waste?” Project XL participants and colleagues throughout the country legitimately agree that the waste determination be by trained (EH&S) professionals outside the lab and in the main accumulation area.

RCRA & the College/University Timeline 1976 – RCRA 1983 – Prudent Practices 1989 – Report to Congress 1990 –Lab Standard 1994 – ACS Lab Waste Coalition 1995 – CA Lab Reg Reform Task Force 1997 – NE Lab Project 1999 – Lab XL in FR 2000 – ACE White Paper 2000 – NIH Regulatory Burden 2000 – HHMI Best Practices 2002 – CSHEMA APPA

Successes More effective waste management program than under the traditional RCRA model. Unprecedented support and increased awareness of laboratory investigators, researchers and workers A decrease in highly hazardous chemicals in the lab and in the generation of hazardous waste Ability to establish new programs when shortfalls in waste management are evident

Challenges Environmental Performance Indicators Pollution Prevention Fully representing the College/University Community nationwide Diversity of EPA Offices EMS vs. BMPs Tracking costs

Lessons We Have Learned Be pro-active with your regulators Communication and working effectively with all stakeholders - upper management, the laboratory population, critics, regulators The regulatory reinvention process requires time and money People inherently want to comply with regulations that protect human health and the environment…..especially when they fit into an organization’s overall culture and goals.

Current Status of the Project Implementation of EMPs First Year - 2001 Progress Report Second Year – 2002 Progress Report First EPA Audit at pilot schools completed Measuring Performance - EPIs EPIs are a significant challenge and clarification of them continues 2001 Comprehensive EPA XL Report includes a description of the EPA’s view of the project EPA Mid-Term Evaluation – May 31, 2002

Where are we going from here…. The Rule/FPA is effective until 9/30/03 Monitor, Report, & Evaluate will continue until then There is the potential for a one year extension if necessary Stakeholder Involvement will continue Internal – students, faculty, staff, administration External –EH&S colleagues, research community, regulators, concerned citizens

Resources EPA Project XL New England Web Site http://www.epa.gov/projectxl/nelabs/index.htm Campus Consortium for Environmental Excellence Web Site - http://esf.uvm.edu/c2e2/

Resources (cont.) Boston College Web Site http://www.bc.edu/bc_org/fvp/ehs/ U Mass Boston Web Site http://omega.cc.umb.edu/~ehs/index.htm University of Vermont Web Site - http://esf.uvm.edu/