SUBJECT:  Environmental Protection Agency Compliance Initiative

The federal Environmental Protection Agency has embarked upon a compliance initiative to ensure that the nation's colleges and universities are handling hazardous chemical waste according to state and federal environmental laws. The initiative requests that institutions self-audit their facilities, correct problems promptly, and prevent recurrence of problems. The UC system, including UCSD, participated in such a self-audit, and submitted a comprehensive report to the EPA on March 22, 2002.

As outlined in UCSD's EH&S policy, this campus is committed to conducting its activities in a healthy, safe, and environmentally sound manner. UCSD's goal as a responsible steward of the environment is to have no environmental compliance violations.

The audit found that 34% of the waste containers audited in clinics, laboratories, and shops had some type of compliance problem that did not conform with UCSD's Hazardous Waste Guidelines (http://www-ehs.ucsd.edu/hazwaste/hazwaste.htm).
Our goal is to expeditiously correct this situation.

The most common problems, and corrective actions, are these:

-- Missing or improperly completed hazardous waste tags. The Hazardous Waste Tag must be filled out completely and attached when the first amount of waste is placed in the container.
(http://www-ehs.ucsd.edu/hazwaste/hazbk/waste_storage.htm#tag)

-- Hazardous waste stored longer than allowable accumulation times. Laboratories should request that EH&S staff remove hazardous waste within 90 days of the accumulation start date, or sooner if the quantity threshold (one quart of extremely hazardous waste or 55 gallons of all other hazardous waste) is reached.
(http://www-ehs.ucsd.edu/hazwaste/hazbk/waste_storage.htm#quantity)

-- Hazardous waste stored in open containers and/or containers in poor condition. This can be corrected by using secondary containment and keeping all waste containers closed except when adding or removing material.
(http://www-ehs.ucsd.edu/hazwaste/hazbk/waste_storage.htm#cont)

-- Improper hazardous waste determination. Determine whether a waste material is a "hazardous waste" or an "extremely hazardous waste." If unsure, contact EH&S for assistance with waste determination.
(http://www-ehs.ucsd.edu/hazwaste/hazbk/chemwast.htm)

-- Improper disposal of waste to sewer, municipal trash, or atmosphere. Do not dispose of hazardous chemical waste into sinks, floor drains, sewers, storm drains, municipal trash, or by evaporation.

To prevent re-occurrence of these problems, the UCSD Chemical Safety and Surveillance Committee has directed EH&S to implement the following measures by July 1, 2002:

-- All new laboratory workers will be required to attend an introductory laboratory safety and hazardous waste class that will satisfy initial training requirements. Current refresher training requirements will still apply.

-- The UCSD policy and procedure manual will be amended to require each lab, shop or other area using hazardous materials to appoint an "Area Safety Coordinator" to identify problems and act as a liaison with EH&S.

-- EH&S will prepare summaries of safety performance, based on semi-annual laboratory audits. These will be distributed to each Principal Investigator, Department Chair, Dean and Vice Chancellor, showing overall safety performance in his or her area of responsibility.

We greatly appreciate the cooperation of everyone at UCSD for assistance in conducting the audit, and in these follow-up initiatives. Please contact EH&S if you have questions or would like further information about the audit.

                                                Steve Benedict
                                                Director
                                                Environment, Health, and Safety