like these that are left open and labeled inproperly are considered
hazardous waste, and the state or federal governments can
slap hefty fines on the University for such violations. Under
a new policy, U.Va.'s Office of Environmental Health and Safety
will be making unannounced inspections and recommends that
departments notify the office if they find unknown substances
in their areas.
New hazardous waste
policy leaves no bottle uncapped
has adopted a new policy for handling hazardous materials, having
narrowly missed being fined over $400,000 by the Environmental
Protection Agency last year for repeated infractions, such as
unlabelled or open containers of hazardous materials, dating back
the new policy, for the next five years U.Va.'s Office
of Environmental Health and Safety will conduct unannounced
biannual inspections of every site on Grounds where hazardous
chemicals are used. As with financial audits, the vice president
overseeing an area, as well as its dean and director or department
chair, will be notified about potential violations. There will
be an escalation of penalties for non-compliance that will be
assessed to the departments involved, said Ralph O. Allen, chemistry
professor and director of the OEHS.
new policy was prompted by an EPA visit last June, when the agency
found four violations in exactly the same places as the Virginia
Department of Environmental Quality had found them the previous
August. This could have resulted in enormous fines, Allen said.
web site for U.Va.'s Office of Environmental Health and Safety,
http://keats.admin.virginia.edu/, includes safety and waste
disposal policies and procedures, online chemical safety training,
the chemical waste pick-up request form, a laboratory survival
manual and information on what constitutes hazardous waste
and how to dispose of it properly.
responded in a very positive way to try to solve the problem,"
he said, adding that the University's readiness to create a new
approach to handling waste caused the EPA to be lenient, though
the agency fined Yale University $400,000 for four infractions
administration is serious about not letting this be a issue,"
he said. "They [put] a process in place and eliminated a
lot of the reasons we've had problems. They convinced the EPA
that we have a huge program with a lot of people involved, and
our compliance in generally excellent. ... I think we'll get fined
the new policy, the first time a lab is caught mishandling waste
by U.Va. inspectors, the person in charge must respond with a
letter describing how it happened and plans for preventing it
from happening again, Allen said, noting that the lab would then
be inspected quarterly for the next year.
the second violation, everyone in the lab must undergo training
with the Environmental Health and Safety Office, he said.
the third time, the department involved will be required to pay
a $25,000 fine and the name of the person who oversees the lab
will be reported to the DEQ.
vice presidents have said departments should not get caught a
third time, Allen said. Additionally, some deans have talked about
withholding research funding from departments after repeated violations.
violations themselves might seem trivial -- for instance, someone
in the art department puts some alcohol-soaked rags in a box,
forgetting to label it; a student working in a lab leaves a bottle
uncapped or unlabelled; a Parking and Transportation employee
shoves an empty, uncapped gasoline drum onto the loading dock,
where it fills with rainwater, which an inspector would assume
to be waste.
it's not labeled, it's regarded as waste," Allen said. "You
could have an EPA penalty of up to $27,500 per day per violation,"
measuring the time that's elapsed between when the DEQ cites a
violation and when the EPA finds it again.
Allen cited three sources of problems in science laboratories.
the teaching labs, it wasn't always clear who was responsible
for ensuring compliance; now that needs to be very clear,"he
said. "Every [person responsible for a lab] has to come up
with a plan and get it approved by the OEHS." There was also
a problem with people leaving U.Va. without disposing of their
lab materials. "A new person would come in and shove them
to the side. Department chairs are now responsible for notifying
the OEHS so it can arrange for disposal of any materials that
might be left behind," he said.
It can cost $30,000 to $40,000 to clean out a lab, including $250
to identify the contents of one container. Departments will now
have to pay that cost if they haven't notified the OEHS in a timely
manner, he said. During a recent amnesty period for unlabelled
materials, Allen's office disposed of over 4,500 bottles of chemicals,
following proper procedures.
U.Va. handled 500,000 pounds of hazardous waste in 1998, the most
recent year for which data are available, Allen said.
third problem stems from people not being aware of the new policy.
For instance, a graduate student who was away writing her thesis
when training sessions occurred came back to continue her experiments,
left a bottle open and was caught by OEHS inspectors.
"There's an incredible number of people who could do something
wrong," he said, pointing out that there are 1,300 locations
on Grounds where hazardous waste is generated, not including 2,000
figured out from our inspections what the problems are, and we're
solving them in a practical and significant way," Allen said.
"The EPA can see that."