Implementation of an ISO 14001based Environmental Management System at the University of Missouri Ro

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Implementation of an ISO 14001-based
Environmental Management System at the
University of Missouri -Rolla

• Mark Fitch
• Amy Gillman
• and a cast of fewer than you expect

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Bottom Line Up Front
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Overview

• UMR background
• Why implement an EMS?
• Initial plan, perceived challenges
• Accomplishments, real challenges
• Current status

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University of Missouri-Rolla

• 4500 students, 85 undergraduate
• 380 faculty, 630 full-time staff
• Small town campus
• 77 engineers
• Large engineering college
• Mining Engineering (Explosives)
• Metallurgical Engineering (Smelting)
• Nuclear Engineering

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Why Implement an EMS?

• UMR perceived as bad actor
• Inspectors alumni
• Governor's home town
• 10 year history of receiving violations
• Enforcement action (1996 NOV)
• One 55-gallon drum, exceeded 1-year disposal date
• 176,119 fine proposed

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Why Implement an EMS?

• UMR proposed EMS
• Supplemental Environmental Project
• 20,000 fine paid
• 867,000 anticipated SEP cost
• Consent decree
• Implementation in five phases
• Failure to meet goals fines

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Why Implement an EMS?

• UMR educates leaders in science and technology
• Proactive
• Expose students to industrial standards

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Consent Decree

• Environmental Policy Planning
• Completion by June 30, 1999
• Failure 55,000 fine
• Demonstrate 358,706 spent
• Implementation and Operation
• Completion by December 31, 2000
• Failure 65,000 fine
• Demonstrate 428,000 spent

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• Auditing and Corrective Action
• Completion by June 20, 2002
• Failure 10,000 fine
• Undetermined cost
• Management Review
• Completion by December 31, 2002
• Failure 10,000 fine
• Undetermined cost
• Certification Audit
• Completion by June 1, 2003
• Failure 16,000 fine
• Undetermined cost

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EMS Timeline

• Environmental Policy Planning, 3.5 mo.
• Implementation and Operation, 9 mo.
• Auditing and Corrective Action, 6 mo.
• Reality
• 2 years flailing, poor choice/use of consultant
  - NO PUBLICIZED HIGHER ED MODEL EXISTS
• Rolled up sleeves, now ahead of schedule

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EMS Implementation Plan

• (Plan policy)
• Policy from on high
• Aspects Impacts
• Legal Requirements
• Identify Significant Aspects
• Set Objectives
• Develop action plans

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Policy Planning

• Focused on challenges to implementation
• Faculty
• Administrative commitment (, power)
• Moving beyond compliance
• Constituent diversity (students, faculty, staff)

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Anticipated Faculty Challenge

• Lack of participation because
• Ignorance
• Added work, no reward perceived
• Threat to academic freedom
• Administrative response to "The hll with you!"?

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Considered Solutions

• Administrative orders
• Signage - "EMS Compliant Lab"
• rewards
• Compliance required to submit proposals

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Policy

• The University of Missouri-Rolla (UMR) has a
  major responsibility to educate tomorrows
  leaders in engineering and science. UMR believes
  that proactive environmental management is a
  fundamental component in educating our future
  leaders. UMR is committed to the protection of
  human health and the environment by integrating
  environmental stewardship into the education,
  research, administration, and business activities
  of the university. UMR is dedicated to an
  environmental management system that is focused
  on continually improving its impact on the
  environment, preventing pollution, and ensuring
  compliance with relevant environmental
  legislation and regulations, as well as with
  other requirements to which the university has
  subscribed.

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Aspects Impacts "A sense of where you are"

• Define activities (processes)
• Survey processes
• Owner
• Inputs
• Outputs
• Other (e.g. storage)
• Collect and compile data

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Aspects Impacts How?

• EHS surveyed Physical Facilities Chemistry
  laboratory
• Generated typical flow charts for surveys
• Defined typical processes, such as
• Chemical storage
• General office
• Chemical synthesis
• Process description yields impact identification

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Aspects Impacts Who does the work?

• Delegated to Deans/Vice Chancellors
• EHS personnel (Administrative Divisions)
• Hired EHS person for school/college (Mines
  Metallurgy)
• School/college coordinator, delegate
  responsibility to individual from each department
  (Engineering, Arts Sciences)

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Legal Requirements

• Criteria for defining significance of potential
  process impacts, such as
• RCRA (P-list, expired chemicals)
• UST
• Asbestos
• Title V (Air emissions)
• EPCRA (Community right to know)

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Identify Significant Aspects

• Based on criteria, categorize processes
• Identify most significant processes (result
  significant impact)
• Examples
• Construction Asbestos in older buildings
• Laboratories Hazardous waste generation

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Set Objectives

• For Significant Aspects
• Current status
• Legal requirements
• Campus goal
• e.g. No incidents of asbestos exposure
• Action to meet goal
• Develop methodology for .

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Develop Action Plans(Current)

• EHS drafts action plans
• Delegate action plan development to
  departments/units
• Specify actions
• Specify completion/monitoring dates
• Specify responsible person
• (Create ownership within units!)

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Realized Faculty Challenges

• Fear of paperwork and SOP's from ISO 9001
• Objectionable words "Training", "Standard
  Operating Procedures"
• "I don't know anything about chemicals"
• Added work for no pay
• Fear of secrecy violation (chemical inventories
  in Chemistry)

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What Works

• Demonstrable support from top
• EHS cannot develop system alone, must be owned by
  campus
• Steering committee - admin, faculty staff
• Subtle publicity, tailored presentations
• EMS document burden is within EHS units decides
  own
• EHS provides technical support
• Address motives do good, avoid trouble
• Constructive consultant use

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Tailored Presentations

• Staff happy for added protection, already
  accountable
• Most students are agreeable
• Faculty
• Nontechnical, little concern
• Emphasize EMS development input
• Option Perform outside of University Counsel

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What Works

• "Develop a reliable system for environmental
  good"
• ISO 14001 certification not goal

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Further info

• Copies w/ added documentation available at
• www.umr.edu/ehs
• or contact Amy Gillman
• gillman_at_umr.edu
• 573-341-4305 (EHS office)