What is the problem?
UMass Boston has more than 150 teaching and research laboratories, using a wide variety of hazardous chemicals.
These include flammable, toxic, corrosive and explosive materials. Because these chemicals are used in small quantities on a limited basis, they present little danger. After they have been used, their disposal is carefully managed by the staff of UMass Boston's Environmental Health and Safety Office. However, we are concerned that the EPA may find regulatory problems with the handling of hazardous waste on campus.
How does the EPA regulate universities?
EPA regulations affect various aspects of university operations. One of its largest impacts is on the handling of hazardous waste generated by laboratory work. The largest portion of the work done by health and safety departments at campuses across the country is responding to these regulations. At UMass Boston, about two-thirds of the health and safety budget is specifically related to hazardous waste disposal.
EPA inspectors and enforcement personnel have become more strict in interpretating the hazardous waste regulations in laboratory settings during the 1990's. Enforcement actions taken at Stanford, Yale, the University of Connecticut, and Boston University have resulted in fines of over $300,000 at each institution.
What is Project XL?
Project XL is one of the EPA's efforts at regulatory reform, part of the Clinton-Gore initiative to "reinvent government". The concept behind Project XL is that organizations that can identify specific regulations which prevent them from achieving improved environmental performance can propose revised regulations and test those regulations for a period of time. If the improved performance is achieved, the regulation may be used to cover other organizations as well.
What is the XL proposal UMass Boston is involved in?
We believe that the fines mentioned above represent problems with the regulations as much with the institutional systems for managing hazardous wastes. Because of this concern, a group of New England academic institutions (the Laboratory Consortium for Environmental Excellence or LCEE) has drafted a new standard for the handling of hazardous waste in laboratories.
We believe use of this standard in place of the current regulations will allow us to put into place a more effective health and safety program which covers all of the potential safety and environmental impacts of laboratory work more effectively. Three "pilot schools", UMass Boston, Boston College, and the University of Vermont, will implement the Project XL for laboratories on a trial basis.
Why is UMass Boston involved?
UMass Boston is involved to improve our environmental program. The simple fact is that waste handling within laboratories themselves might not pass detailed regulatory scrutiny. We feel that the environmental management standard developed by the LCEE will enable us to meet the spirit of the regulations without increasing the stress on lab resources, and create significant improvements to our environmental program.
What will UMass Boston have to do?
As a Project XL participant, UMass Boston will develop an Environmental Management Plan, which will identify the environmental responsibilities of lab personnel. This plan will require upper level support and lab worker commitment in order to implement successfully. UMass Boston will also have to identify and measure various Environmental Performance Indicators to determine whether its environmental performance has been improved by the XL. In return, UMass Boston and the other pilot schools will not have RCRA regulations enforced within laboratories on campus.
What will it cost?
Participation in the Project XL in unlikely to cost UMass Boston additional money. Currently, all project costs have been handled within the EH&S operating budget. The LCEE is aggressively seeking funds to support the XL work of the pilot schools and we are optimistic that funding will be available. The EPA itself has already given a grant of $60,000 for development of the proposed standard.
What are the benefits?
Participation in the XL will have a variety of benefits for UMass Boston. In addition to the change in regulatory structure that XL represents, participation in the project has significantly improved UMass Boston's relationship with the federal and state hazardous waste regulators. It has established UMB as a national leader in environmental health and safety thinking. (The January, 1998 report "Straight Talk About College Costs and Prices", written by the National Commission on the Cost of Higher Education, appointed by Congress cited environmental regulations as an example where regulatory reform is necessary for academic institutions.) And it has opened new opportunities for faculty and student involvement in the health and safety program.
Where can I get more information about XL and UMass Boston?
Contact Zehra Schneider Graham at 287-5445 with questions or comments.