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Campus earns an ‘A’ in EPA review
Voluntary self-audit ‘an offer we couldn’t refuse,’ says EH&S

| 17 November 2004

The Berkeley campus recently received high marks — and no penalty fines — in a major audit of environmental-management practices at University of California campuses. The audit was conducted under a special program of the Environmental Protection Agency (EPA). An EPA report, issued last month, closes out a voluntary self-audit of 47,000 facilities at nine UC campuses and agricultural research stations — 1,400 of them at Berkeley — evaluating compliance with federal regulations on hazardous-waste management, risk management, and emergency planning and preparedness.

The review was conducted in 2001-02, after the EPA invited UC to participate in a voluntary program that allows campuses to conduct self-audits, disclose any violations found, correct the violations, and establish procedures to prevent recurrence. While some compliance deficiencies were observed throughout the UC system, Berkeley had the fewest violations per laboratory or shop of any UC campus.

“This is quite an accomplishment, considering that many other universities have received heavy penalties,” says Patrick Goff, associate director of the Hazardous Materials and Radiation Safety unit at Environment, Health, & Safety (EH&S). At a campus as large as Berkeley, he notes, you’ll often find a number of serious violations, triggering EPA fines “as high as $27,500 a day.” In 1998 and 1999, for instance, the University of Hawaii was levied a $1.8-million fine for environmental violations, and many other campuses nationwide have received lesser, but significant, penalties.

The EPA in recent years has aggressively monitored college campuses — which it says are “similar to small cities” — that have medical and research facilities, power plants, wastewater-treatment facilities, incinerators, and hazardous-waste treatment and disposal centers. Under a new voluntary audit program, the agency gives campuses the option to audit themselves, report their findings, and take steps to prevent future violations — in exchange for decreased risk of violations or fines. “It was an offer we couldn’t refuse,” says Goff.

Systemwide, UC was levied $9,750 in penalties as a result of the audit. At Berkeley, EH&S staff spent 3,000 hours to audit every space where hazardous materials are used or stored — from custodial closets to large labs. The majority of violations it found were open containers or containers without labels, which were corrected on the spot. He attributes the campus having passed the audit with no fines in part to the fact that it has worked closely with the EPA in the last decade to simplify its process for hazardous materials — taking some of the responsibility out of the hands of lab workers and giving it to EH&S professionals intimately familiar with applicable regulations. “Keeping it simple is making it safer,” he says.

The self-audit has been “a great experience all around,” says Goff. “Besides meeting the EPA objective of better compliance for the campus, it also brought EH&S issues home to people in the labs” and helped jump-start several new EH&S programs, “which will improve compliance and environmental safety for the campus in the long run.” These include an ongoing program to train incoming graduate students and new employees on proper procedures for handling hazardous laboratory materials; a new system for labeling and requesting speedy pick-up of hazardous materials by EH&S staff; and a poster on “How to Dispose of Unwanted Material at UC Berkeley.” EH&S has also instituted a yearly campuswide audit, modeled on the EPA review but focused each year on a specific issue. This year’s focus was eyewash-safety showers and hazard-communication and chemical-hygiene plans.