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Pacific Southwest, Region 9

Serving: Arizona, California, Hawaii, Nevada, Pacific Islands, Tribal Nations

University of California and the Compliance Incentive Program

One would think that a college campus would be free from violations of environmental laws that businesses and municipalities face. They are, after all, the ivy walls and hallowed halls responsible for shepherding young adults out of childhood and into the real world. They must set examples by which to live.

But the facts are, in many cases, vastly different than the commonly held perceptions. With combined student and faculty populations, colleges can be larger than many small or even medium-sized towns and cities.

And like a municipality, colleges and universities use chemicals and hazardous materials on a day-to-day basis as part of instructing students in chemistry, medicine and other vocations. Sometimes they will use more exotic chemicals that result in more dangerous waste.

In response to the discovery that some universities and colleges are not in full compliance with environmental statutes and regulations, U.S. Environmental Protection Agency's Pacific Southwest Region 9 has developed a program to encourage universities and colleges to conduct self audits, evaluate compliance at their campuses and facilities - including medical schools - and disclose violations.

University of California at Irvine

This is a creative way of achieving greater environmental and human health protection than by using EPA's inspection and enforcement resources, alone. The "Compliance Incentive Program" uses EPA's self-audit policy to reduce or eliminate penalties under certain conditions for those entities that voluntarily disclose and correct environmental violations, fix any environmental harm, and agree to take steps to prevent recurrence.

The University of California - one of the United States' largest university systems - is a perfect example: In July 2001, EPA sent a letter to the Office of the President asking for the university's participation in the Compliance Incentive Program. Systemwide, UC agreed to participate.

Participating in a Compliance Incentive Project represented an extraordinary effort for UC. In performing and evaluating the audits, the university undertook an environmental regulatory self-evaluation effort that is unprecedented in scope and content for an academic institution.

In October and November 2001, the UC system audited its campuses and facilities and assessed compliance with hazardous waste management, risk management, emergency planning and preparedness requirements. UC completed audits of approximately 47 facilities. These facilities included all nine UC campuses, agricultural research stations, medical and veterinary schools, and other associated facilities.

Incentives for UC included reduced or waived penalties and fewer regulatory inspections during this period. Other advantages included early coordination with EPA on the scope, content, timing and reporting for the audit.

In March 2002, UC submitted its audit results to EPA and to state regulatory agencies. EPA evaluated UC's disclosures in accordance with EPA's Audit Policy. EPA found that most of the disclosed violations met all conditions of the Audit Policy and, therefore, were eligible for a 100 percent reduction of the penalties that would normally be assessed for the violations.

In September 2004, EPA concluded the UC project by issuing a consent agreement/final order to the Regents of the University of California under the federal Resource Conservation and Recovery Act to document the results of the project.

Industrial sectors, such as the University and College sector, that have had hazardous waste management problems that do not take advantage of participating in a Compliance Incentive Program will have an increased risk of EPA inspections and enforcement.

For more information, please refer to the Region 9 News Release, University of California steps up to audit its environmental management program.

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