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Environmental Compliance and Beyond: What Gets Measured Gets Done

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Campuses expected to be in full compliance with agency requirements. ... program began with some initial awkwardness but has developed a certain procedural rhythm. ... – PowerPoint PPT presentation

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Title: Environmental Compliance and Beyond: What Gets Measured Gets Done


1
Environmental Compliance and Beyond What Gets
Measured Gets Done

Howard N. Apsan, Ph.D. University Director
Environmental Health and Safety The City
University of New York Presented at the CSHEMA
Conference 2007 Seaport Hotel Boston MA July
23, 2007
2
EPAs College and University Initiative
  • The EPA felt that colleges and universities,
    because of their status, should set a standard of
    environmental leadership.
  • National college and university initiative.
  • Campuses expected to be in full compliance with
    agency requirements.
  • EPA to measure compliance in one of two ways
  • Direct EPA enforcement inspections.
  • Voluntary audit and disclosure agreements.

  • 1


3
CUNY Moves Early on Voluntary Disclosure
  • CUNY was one of the first public universities to
    opt for voluntary disclosure.
  • Audits conducted within a 5-year period.
  • Final audit reports to be disclosed to EPA
    semi-annually.
  • Avoid gravity-based and economic-benefit fines.
  • Minimize inter-agency referrals.

  • 2

4
Visiting a campus in the weeks before an audit
is like visiting a study hall during final exams
week.
  • Lab chemicals storage and labeling.
  • Hazardous wastes.
  • Air emissions (e.g. permits, Community
    Right-to-Know).
  • Petroleum bulk storage (e.g. registrations,
    system upgrades).
  • Asbestos and lead.
  • Radioactive sources.
  • Universal wastes and electronic wastes.
  • Select agents (e.g., anthrax, botulism, plague).
  • Training and documentation.


  • 3

















5
CUNY Audit Statistics
  • The audit program began with some initial
    awkwardness but has developed a certain
    procedural rhythm.
  • Eighteen campuses audited to date, including
  • 10 senior colleges.
  • 6 community colleges.
  • 2 graduate school.

  • 4

6
CUNY Audit Statistics
  • The success of an audit is measured not only by
    the number of findings it generates, but by how
    well it prepares the campus for the future.
  • First 14 audits resulted in greater than 4.2
    million in fines.
  • 100 of fines were waived.
  • Far fewer findings in recent audits.
  • Ultimate goal of zero findings.


  • 5

7
Corrective Action
  • Once the audit is over (and sometimes even while
    it is still under way) the corrective action
    phase begins
  • Internal assessments of audit findings.
  • Environmental sampling and analysis.
  • Labeling, record-keeping, training.
  • CUNY environmental management system (EMS).
  • Current regulatory status.
  • Improvement targets set.

    6

8
Continuous Improvement
  • At a time when colleges and universities must
    compete for students and resources, it is
    remarkable that there is so much cooperation in
    the EHS arena.
  • CUNY Environmental Health and Safety Council.
  • New York Campus Environmental Resource.
  • SUNY Environmental Health and Safety Association.
  • Environmental Protection Agency.
  • Several public meetings in collaboration with
    Region II.
  • Additional resources and information.

  • 7




9
Measuring the Success of the Audit Program
  • CUNY is still developing effective measurement
    tools.
  • Why measurement is challenging
  • Success measured not in profitability, but in
    cost avoidance.
  • CUNYs measurement tools
  • Comparison of audit findings against potential
    fines.
  • University-wide and Campus specific criteria.

  • 8

10
Achievements and Next Steps
  • We need indicators that will foster a commitment
    to compliance, as well as a fundamental change in
    the environmental culture of the university.
  • Gaining insights from the CUNY-wide productivity
    program.
  • Including EHS criteria in presidential
    performance evaluations.
  • Integrating EHS indicators into general
    management systems (e.g., Enterprise Resource
    Planning.)

  • 9





11
Beyond Compliance
  • Risk Management.
  • Natural progression.
  • Emergency preparedness EHS.
  • CUNY Sustainability Initiative.
  • 30 in 10 Challenge.
  • Environmental stewardship.
  • 10

12
Environmental Compliance and Beyond What Gets
Measured Gets Done
  • What gets measured gets done.
  • Continuous improvement.
  • Trust, but verify.
  • 12

13
References
  • What Gets Measured Gets Done Two Years into the
    CUNY-EPA Audit Agreement.
  • Howard N. Apsan
  • Environmental Quality Management, Autumn 2005
  • For more information contact
  • howard.apsan_at_mail.cuny.edu
  • 13
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