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RESULTS
OF THE
EPA ENVIRONMENTAL COMPLIANCE AUDIT

August 9th - 12th, 2004

An EPA Environmental Compliance Audit was held during the week of August 9-12, 2004. The Audit team looked at environmental issues related to air emissions, asbestos, lead-based paint, pesticides, PCB's, hazardous waste, regulated medical waste, waste water, universal waste, bulk chemical storage, oil storage, storm water, used oil and more.

How Did We Do?

The auditors indicated that in general UB did very well on management of laboratory waste in Satellite Accumulation Areas (SAA). UB was NOT found to be in the category of “pervasive non-compliance”. The most important issue is: We want to sustain the level of compliance that was achieved during the audit. NO BACKSLIDING!

The results of the SUNY EPA Audit have been submitted to EH&S in a “draft report”. EH&S is in the process of reviewing this report for disclosure to the EPA in November. UB has 60 days to correct all of the “typical” findings in the report or 120 days for items requiring procurement. EH&S will forward all of the findings for each academic department to the Lab Safety Coordinators for that department. Each coordinator will bring the findings to the attention of the individual Principal Investigators and will track the corrections.

What Needs Work?

UB was not perfect and several laboratory waste violations were noted including:

• Failures to perform hazardous waste determinations on several materials including lead solder, stains, fixers and developers
• Improper labeling of hazardous waste
  o Most commonly, the UB Hazardous Waste Label was not used and therefore the words “Hazardous Waste” were mission from the label
  o Label not completely or properly filled out.
  o Stock chemical labels were degraded, illegible or missing
• Failure to keep Hazardous Waste containers closed (i.e., waste stored in open containers)
• SAA not located “at or near” the point of generation (i.e., movement of waste between rooms)
• In a few instances, failure to declare accumulated materials as waste (i.e., stockpiles of chemicals that are clearly not being used but have not been labeled as waste)
• Several lab samples were being stored in the same secondary containment bin as hazardous waste. Waste should be separated from all usable chemicals.
• Unlabeled or poorly labeled unknowns.
• Storage of wastes by compatibility
• Used oil labeled as “hazardous waste” rather than “used oil” (corrected on site)
  

Issues to be Resolved

Waste Violations: Most of the laboratory waste violations that were noted during the audit were corrected on site. Those violations which were not corrected on site will need to be corrected as soon as possible to avoid potential fines.

Waste Storage Areas: A few labs expressed a desire to move waste from one room to another because of volume. Regulations will require that these secondary rooms be established as a “90-day storage locations”. EH&S will meet with each of these labs individually to see if other options exist or make preparations to meet the regulatory burdens.

Chemical Stockpiles: Some stockpiles of chemicals were found that clearly require “laboratory clean-outs”. Any additional stockpiles should be brought to the attention of EH&S in the next few weeks.

Future Efforts Needed

Training: Principal Investigators and Lab Managers are responsible for making sure that incoming personnel are properly trained on the specific procedures related to handling hazardous waste in each lab. It is important to identify new people in the laboratory who need hazardous waste training and personnel who need a refresher class. EH&S will continue to hold regular training classes.

Waste Minimization: Methods to minimize waste are important in preventing future stockpiles. Visit the EH&S guidance on waste minimization here (pdf file).

Other Regulatory Requirements: There are other regulations besides the hazardous waste rules that we now need to work on. The fact that we have improved chemical storage and waste handling practices will make compliance in other areas easier to achieve.

Laboratory Inspections: In collaboration with the academic departments, EH&S will continue to perform in-house “inspections” of the campus laboratories to ensure that progress is being made in safety and environmental programs.

For a printer friendly version of the EPA Audit Results, click here (pdf file).

As before, one of the large contributions to the success of the audit was the hard work of University employees like you that are dedicated to a safe and healthy work place. Keep up the good work!