CUMC Embarks on Environmental Self-Audit
The inspections fulfill an agreement CUMC signed with the U.S. Environmental Protection Agency in March that requires CUMC to audit its own environmental programs, including the handling of hazardous waste in all its laboratories, and report any violations to the EPA.
Robert Lewy, M.D., Ph.D., senior associate dean and chairman of the Institutional Health and Safety Council, welcomes the agreement. "We are delighted to partner with the Environmental Protection Agency to continue to improve our environmental programs," he says. "We have long embraced and supported a commitment to excellence in environmental stewardship."
Kathleen Crowley, director of environmental health and safety, says the self-audit is a good opportunity to evaluate the effectiveness of CUMC's environmental programs without the stigma and heavy financial penalties typical of an EPA-led audit.
"The audit is not an option," she says. "We can either wait to be audited by the EPA where fines are assessed when violations are found or we can partner with the EPA and self-audit. With our EPA self-audit agreement, we are permitted to correct any violations we find and disclose without penalties being imposed. If the same violation is found on a subsequent EPA audit, however, punitive penalties can and would be assessed."
In 1999, EPA Region 2 began focusing attention on colleges and universities because the EPA found that many institutions were not aware of their responsibilities under various environmental laws. Under the EPA Voluntary Self-Audit Policy, institutions are encouraged to partner with the EPA and self-audit and report violations instead of waiting for a surprise visit from the EPA's auditors.
Surprise audits, like the ones performed on Columbia's Morningside Heights campus and the Lamont-Doherty Earth Observatory in March 2001, can be costly. The EPA initially imposed fines of nearly $800,000 on Columbia. Most of the penalty resulted from violations regarding the use of hazardous chemicals and the disposal of hazardous waste.
Phase 1 of the CUMC audit, which will begin Oct. 4, will focus on the handling of hazardous chemicals and waste. Common violations include improperly labeled waste containers, open chemical containers, or failure to collect all hazardous wastes.
Inspections, which will be conducted by an outside environmental consulting firm, will last about 20 minutes. The PI and/or the lab safety manager should be available for questions during the audit.
Upon completion, the auditors will prepare a report for the EPA listing any violations found and describing how CUMC intends to prevent recurrence. This latter part is critical; if the EPA discovers the same violation in a subsequent audit, the fines can be double the original amount that would have been assessed.
Phases 2 and 3 of the audit will begin next year and will involve further inspections of CUMC's physical plant, residential buildings, and all of CUMC's air and water programs.