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Leveraging Limited Resources To Obtain Better Compliance

Region 2's College & University Compliance Initiative: Environmental Results From An Integrated Strategy. Leveraging Limited Resources To Obtain Better Compliance. Five Year Status Report. Goals For Compliance Initiative.

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Leveraging Limited Resources To Obtain Better Compliance

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  1. Region 2's College & University Compliance Initiative: Environmental Results From An Integrated Strategy Leveraging Limited Resources To Obtain Better Compliance Five Year Status Report Region 2 College & University Compliance Initiative

  2. Goals For Compliance Initiative • Improve environmental compliance and safety at main and off-site facilities. • Change the culture to one in which environmental compliance is a priority. • Ensure compliance of entire sector; not just those reached through inspections. • Ensure continued compliance by implementing permanent changes. Region 2 College & University Compliance Initiative

  3. Approach • Region 2 combined the following strategies to address compliance issues in this sector: • Compliance assistance • Compliance incentives (voluntary audit/disclosure) • Compliance monitoring • Enforcement • Pollution prevention • Environmental management systems (EMS) Region 2 College & University Compliance Initiative

  4. Region 2 College & University Compliance Initiative

  5. Region 2 College & University Compliance Initiative

  6. Results: Compliance Monitoring & Incentives Programs Region 2 College & University Compliance Initiative

  7. ACTIONS/YEAR Region 2 College & University Compliance Initiative

  8. PERCENT / YEAR Region 2 College & University Compliance Initiative

  9. University and College SEPs • 10 settlements include SEPs • Range from $26,000 to $270,000 • Total value of SEPs = $1,711,297 Region 2 College & University Compliance Initiative

  10. Types of SEPs • Chemical Tracking & Control Systems • Mini/Micro-Scale Chemistry • Solvent Recovery Systems • Other Equipment/Technology Modifications • Environmental Compliance Promotions • Environmental Management Systems Region 2 College & University Compliance Initiative

  11. Results:Environmental Benefits Region 2 College & University Compliance Initiative

  12. Root Causes Of Noncompliance Systemic violations appear to stem from: • Inadequate resources for people, equipment and training to carry out environmental activities; • Limited or no environmental compliance accountability for individual departments, laboratories, and staff; • Limited authority vested in environmental compliance officials; Region 2 College & University Compliance Initiative

  13. Root Causes Of Noncompliance • No clear environmental compliance chain-of-command; • Scattered, incomplete, and missing environmental compliance documentation; • Incomplete institutional knowledge regarding environmental regulatory requirements; and • Broad use of hazardous materials when effective substitutes exist Region 2 College & University Compliance Initiative

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  26. Region 2 College & University Compliance Initiative

  27. Bulb Crushers Region 2 College & University Compliance Initiative

  28. Bulb Crushers Region 2 College & University Compliance Initiative

  29. College & University Violations2005 Region 2 College & University Compliance Initiative

  30. College & University RCRA Violations - 2005 Region 2 College & University Compliance Initiative

  31. College & University CAA Violations 2005 Region 2 College & University Compliance Initiative

  32. College & University CWA Violations 2005 Region 2 College & University Compliance Initiative

  33. College & University TSCA Violations - 2005 Region 2 College & University Compliance Initiative

  34. College & University EPCRA Violations - 2005 Region 2 College & University Compliance Initiative

  35. Top 10 RCRA Violations From Inspections – 936 Violations Region 2 College & University Compliance Initiative

  36. Top 10 RCRA Violations From Inspections – 936 Violations Region 2 College & University Compliance Initiative

  37. Top 10 RCRA Violations From Disclosures – 245 Violations Region 2 College & University Compliance Initiative

  38. Top 10 RCRA Violations From Disclosures – 245 Violations Region 2 College & University Compliance Initiative

  39. Survey Overview • 61 colleges completed and returned the audit survey • 33,899 faculty are reported to be working at these facilities • 69,205 staff are reported to be working at these facilities • 399,498 students are reported to attend these facilities • 2191 facilities are reported to compose these 61 colleges Region 2 College & University Compliance Initiative

  40. Region 2 College & University Compliance Initiative

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  46. Understanding Of Waste Management Regulations Before And After Compliance Initiative (40% - 98%) Region 2 College & University Compliance Initiative

  47. Changes in Understanding – Very High Responses Region 2 College & University Compliance Initiative

  48. Changes Made as a Result of the Initiative Region 2 College & University Compliance Initiative

  49. Changes Planned as a Result of the Initiative Region 2 College & University Compliance Initiative

  50. Region 2 College & University Compliance Initiative

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