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FY2004 Compliance Assistance Activities Highlights
FY2004 Annual Results Topics
The Fiscal Year 2004 Compliance Assistance Activities Highlights report contains the following categories:
Greening the Government
Environmental Lessons for Schools, Colleges and Universities
Taking Care of Health-Care Institutions
Explaining National Pollution Discharge Elimination System Storm Water Program
Greening the Government
As part of its Green Procurement Initiative, Region 3 has taken the lead to urge federal agencies to purchase recycled-content products. This year, thirty-four assessments were completed, including two on-site inspections to provide compliance assistance to federal agencies with more 500 employees in the region. The Solid Waste Program has provided follow-up assistance to over 80 percent of the assessed facilities to increase the number of products with recycled content they purchase. This initiative is a program element of the Resource Conservation Challenge.
Environmental Lessons for Schools, Colleges and Universities
A number of EPA regions have used compliance assistance and a mix of other compliance and enforcement tools to improve environmental management practices at schools, colleges and universities.
EPA Region 1 used several compliance tools to foster behavioral changes and environmental improvement at colleges and universities and called it the C/U Integrated Strategy. Through its Audit Policy Initiative, colleges and universities were invited to voluntarily discover and disclose violations and correct and prevent them. Out of 331 college or university facilities, 171 participated. Region 1 developed a catalog of Best Management Practices and a guide to help colleges and universities design and implement cost-effective environmental management systems (EMS) to ensure environmental compliance and minimize environmental impacts. The region is working with the University of Massachusetts, Lowell, EMS Service Program to train and assist colleges and universities in implementing and sustaining such systems.
Harvard’s Kennedy School of Government and Industrial Economics Inc. independently evaluated the effectiveness of the strategy and the value of the specific tools offered. Findings included:
- 75 percent of those participating in the audit initiative took short-term corrective actions
- 96 percent of those participating made long-term environmental management changes
- 81 percent intend to conduct future audits
- Audit disclosures identified clear problem areas, which gave EHS staff more leverage within their universities
- EPA outreach efforts (workshops, Web site, list of violations) were considered highly effective.
EPA Region 2 discovered, mainly through inspections, that many academic institutions were not aware of their responsibilities under environmental laws. A multi-year integrated compliance strategy has achieved outstanding results. Initially, the region sent out letters to all 375 colleges and universities in New York, New Jersey, Puerto Rico and the Virgin Islands to inform them of its intent to inspect them during the Fall of 2000 and urge them to audit themselves and disclose violations under EPA’s Audit Policy. To help colleges and universities understand the regulations, conduct audits and develop environmental management systems (EMS), the region developed a Web site and mailed information on available resources. It also partnered with state agencies and university associations on a series of seminars. Region 2 has concluded 15 “campus-wide” audit agreements, including one with the State University of New York. An additional 92 self-disclosures were received from colleges and universities, some of whom were not part of any formal audit agreement. Due to the disclosures, 1,090 violations have been corrected. Under FY04 audit agreements alone, more than 60,000 students are now better protected from environmental hazards; more than 120,000 pounds per year of hazardous waste and 1,535,000 gallons of oil are now being managed properly. The University of Puerto Rico had been improperly using Class V injection wells for underground sewage and disposal of chemicals from laboratories, pesticides, etc. More than 80 wells island-wide are now better managed.
Not all campuses took advantage of the Audit Policy. Region 2 has inspected 51 colleges and universities and taken 16 enforcement actions, totaling $2.7 million in penalties. Settlement agreements included supplemental environmental projects (SEPs), which involve improvements at the facilities that go beyond what the law requires. Three facilities agreed to implement mini-scale chemistry in all chemistry teaching laboratories. Columbia University developed an environmental management system as well as a chemical tracking system to identify and reduce excess procurement, track storage and ensure proper disposal. Several universities joined together in an environmental compliance promotion project to help K-12 schools meet their environmental requirements through guidance documents and seminars.
Region 3 also conducted an integrated strategy for schools to address environmental and public health issues. The region’s 60 on-site reviews and surveys of schools found many schools were unaware of environmental regulations; laboratories were improperly handling and storing chemicals and disposing of wastes; fluorescent ballasts were leaking PCBs; drinking water contained unsafe levels of lead; pesticides were improperly applied; and permitting requirements for boilers were unmet. The region worked with the District of Columbia Department of Health and the Maryland Department of the Environment to address these issues. The region has trained 100 D.C. and Maryland schools on lab management practices, hazardous waste management and indoor air quality issues. Most participants said they learned more about environmental management practices and intended to share the information with colleagues and managers.
Taking Care of Health-Care Institutions
Hospitals are a major environmental and public health concern in its 480 hospitals. Hospitals introduce toxic chemicals into the environment, such as mercury and dioxin, generate a wide variety of hazardous wastes, produce 2 million tons of solid waste and exacerbate air pollution problems. Random inspections at hospitals across the country have found significant violations, especially in the management and disposal of hazardous waste.
EPA Region 2 embarked on a compliance and enforcement initiative in New York, New Jersey, Puerto Rico and the Virgin Islands to:
- increase the compliance rate among medical facilities;
- encourage the development and implementation of environmental management systems;
- eliminate the mercury-containing waste from the health-care waste stream by 2005; and
- cut the volume of all hospital waste generated in half by 2010.
The Region 2 multi-year strategy has three-prongs. First, environmental assistance is provided to help health-care facilities understand their environmental obligations, identify pollution prevention opportunities and develop environmental management systems. Regional staff participated in numerous health-care meetings and conferences, partnered with the Veterans Administration (VA) to develop a national environmental training program for VA hospitals and developed a variety of compliance assistance checklists and tools. The region also held 11 environmental compliance workshops, which reached more than 735 entities, and five hazardous waste identification and management courses for health-care facilities. Of those attending the hazardous waste identification training, 65 percent reported that improved understanding of hazardous waste management. The region urges hospitals to join the Hospitals for a Healthy Environment Program to educate their professionals about pollution prevention opportunities.
Next, the region encouraged health-care facilities to perform voluntary compliance audits and enter into corporate-wide agreements under EPA’s Audit Policy. The Agency received 58 disclosures. Thirty-six hospitals or hospital systems have entered into audit agreements with EPA covering all major federal environmental programs, including air, water, pesticides, solid and hazardous wastes, emergency planning, Community Right-to-Know and toxic substances control These agreements included the largest hospital in New York City and the third largest teaching hospital in the United States. Voluntary disclosures resulted in the correction of 868 violations that represented a potential $2,307,620 in penalties had EPA discovered them through inspections. More than 120,000 staff and approximately 1 million patients and more than 15 million outpatients benefit annually from this program.
Finally, the region takes enforcement actions as appropriate. The region has conducted 42 inspections and issued nine complaints totaling $939,062 in penalties. The majority of these complaints are for improper disposal and management of hazardous waste. Region 2 has prepared more information on its activities related to healthcare.
Building on the Region 2 initiative, Region 1 conducted three workshops to address environmental issues for hospitals.
Veterans Health Administration Medical Centers
In 2004, EPA and the Veterans' Health Administration (VHA) expanded a very successful two-year-old collaboration. The VHA has developed a new infrastructure for managing their environmental program. It launched its Green Environmental Management System (GEMS) at 140 VA Medical Centers, with the goal that each will have a functioning environmental management system by December 2005. GEMS includes a new environmental compliance auditing program in cooperation with the U.S. Army Corps of Engineers. The VHA presents training courses for their staff and management; several have included EPA faculty.
The EPA-VHA collaboration resulted in VHA hiring about 166 full-time employees who will spend half their time on environmental work. Over four years, VHA will spend about $32 million for environmental program improvements. In addition to funding the new employees, $4.5 million will be spent on baseline third-party environmental audits, $4.5 million will be spent every three years for follow-up third-party audits, $180,000 will be spent annually for audit tracking, and $40,000 was spent to develop and publish the GEMS Guidebook EPA completed environmental management reviews at 17 VHA medical centers to assist them in designing and implementing environmental management systems. EPA and VHA shared in funding these reviews.
The EPA and VA collaboration began in 2002 when EPA inspections of VA medical centers revealed repeat violations of environmental regulations, particularly those involving federal hazardous waste management regulations.
Explaining National Pollution Discharge Elimination System Storm Water Program
EPA Region I undertook an initiative to offer compliance assistance with Phase II of the NPDES storm water program to newly regulated entities, primarily small communities, small municipalities and small businesses. The goal was to ensure that the regulated entities filed for environmental permits and adopted appropriate facility management practices to minimize storm water run off. EPA Region I built partnerships with trade and local government associations, identified and advocated Best Management Practices, offered dozens of workshops and presentations, crafted written and web-based tools, wrote articles for newsletters and magazines, and provided individualized assistance. As a result, almost 100 percent of MS4s (municipal storm sewer systems/small communities) applied for permit coverage by the deadline, as did about 90 percent of Publicly Owned Treatment Works (wastewater treatment plants).
Annual Results by Fiscal Year
FY2006 | FY2005 | FY2004 | FY2003 | FY2002 | FY2001 | FY2000 | FY1999