Managing Hazardous Wastes and Toxic Substances in a University Setting

Major universities conduct so many different activities that it is difficult to fully comply with complex environmental regulations. Recent enforcement actions and large penalties against Yale and Stanford have emphasized the importance of developing programs to help assure environmental compliance.

Several universities have implemented formal environmental compliance audit (ECA) programs. Typically, an ECA is conducted using a combination of in-house experts and qualified third-party specialists, who examine university operations and procedures, determine what regulations apply, and evaluate the efficacy of existing policy and practice.

An ECA program systematically identifies potential trouble spots, and allows regulatory or management discrepancies to be addressed in a logical fashion.

An ECA also is useful for determining the compliance “health” of a campus, and to program future environmental improvements to maintain compliance with evolving regulatory requirements.

An ECA might consider of one or more of the following programs:

  • air
  • wastewater
  • water supply
  • hazardous waste
  • solid waste
  • storage tanks
  • spill preparedness and response
  • toxic substances
  • historical contamination sites
  • pesticides, and
  • natural resources

The ECA scope is customized to the needs of a particular institution. ECAs range from those focusing on one or two specific areas (e.g., hazardous waste management or Use and underground storage tanks) to facility-wide audits addressing all aspects of environmental management.

Significant audit findings should be reviewed orally, to permit rapid implementation of major findings, and to quickly correct any misunderstandings the audit team may have developed. To enhance the confidentiality of ECA findings, many universities have the ECA performed at the request of legal counsel.

Some ECA reports include development of an environmental information system, to assist the environmental compliance staff in maintaining compliance and progressing toward milestones for improvements.

SCS Engineers is an environmental engineering and consulting firm with offices nationwide. Some of the nation’s leading experts in environmental compliance auditing are members of our staff. The firm has assisted hundreds of universities, hospitals, public utilities, government agencies, transportation companies, and private manufacturers with a wide range of environmental compliance services.

For additional information, including copies of recent publications on the subject of ECAs, please contact your nearest SCS Engineers regional office:

SCS ENGINEERS
Jeffrey D. Marshall, P.E., Vice President
11260 Roger Bacon Drive
Reston, Virginia 22090
(703) 471-6150

E-mail: [email protected]
Internet: http://www.scsengineers.com

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