This Environmental Management Plan (EMP) describes the specific measures the University of Vermont will take to protect human health and the environment from hazards associated with the management of laboratory wastes. Laboratory waste refers to the hazardous chemicals resulting from laboratory scale activities.

The EMP is written to meet the requirements of the Vermont and EPA site specific regulation for the New England Universities Laboratory Project XL for which UVM is one of three pilot sites. This XL Project was developed because the standard hazardous waste regulations established under the Resource Conservation and Recovery Act (RCRA) were preventing laboratories in higher education from fully developing their pollution prevention programs. The focus of this project is on the implementation of an institution-wide laboratory waste management program which effectively minimizes, reuses, collects and disposes of waste chemicals from campus teaching and research activities, and is detailed in the EMP.

The goal of the EMP is to continuously improve the University's Environmental Performance with regard to the management of chemical wastes from its laboratories. The plan discusses the roles and responsibilities of various groups in the campus community in meeting this goal. It describes specific procedures that laboratory workers and supervisors will follow in order to assure that laboratory waste is properly managed in accordance with the Minimum Performance Criteria of the site specific Project XL rule. Procedures for identifying and taking advantage of opportunities for hazardous waste minimization and pollution prevention are also included. Finally, it describes the training and information mechanisms that will be used to assure that laboratory workers are aware of and comply with the requirements of this plan.

The XL Project at UVM

The Lab XL Project, described in the Laboratory Environmental Management Standard (40 CFR 262 Subpart J) and the Final Project Agreement, consists of 5 components:

The Minimum Performance Criteria (MPC) are specific requirements, pertaining to laboratory activities and wastes that must be met by laboratory workers to assure that the XL regulation is achieving a level of protection exceeding that achieved by traditional RCRA regulations.

The Environmental Management Plan describes the management system that the University will implement to achieve compliance with the MPC. The EMP describes services provided by Environmental Safety Facility (ESF) staff, such as collection and management of laboratory chemical waste and tracking of regulatory requirements. The EMP also includes management tools such as pollution prevention objectives and targets to help upper management assess the success of the University's hazardous waste management program.

The Organizational Responsibilities described in the regulation are the administrative steps that must be taken by UVM to assure that the Environmental Management Plan is successfully implemented. These steps are included within the EMP.

The Training and Information Requirements stipulated in the regulation assure that laboratory workers and visitors throughout the University are aware of the University's hazardous waste management and pollution prevention program.

The Environmental Performance Indicators serve as measures to track the University's success at meeting its environmental goals with respect to laboratory waste disposal.

This XL project will produce superior environmental results with respect to the management of the University's laboratory chemical wastes. Success of this program will be determined by monitoring of Environmental Performance Indicators (EPI's), as described in the Project XL Final Project Agreement. Complete copies of the XL rule and Final Project Agreement, as well as reports of the current status of the EPI's can be found on the University's Lab XL web site at http://esf.uvm.edu/labxl.

Structure of the UVM EMP

The UVM EMP consists of a coordinated set of policy statements and implementation plans. These plans include assignment of roles and responsibilities, a specific procedure to be followed (described by a form and instructions for its use), and records that will be kept, when necessary. Many of the forms can be implemented either on paper or electronically, although some are required to be physically present with the laboratory waste.

These policies meet the requirements of the XL standard in specific ways. The forms are designed to implement the policies of the EMP and are organized in a straight forward manner for laboratory workers. An index connecting the regulatory requirements to the corresponding policy is provided on the UVM Environmental Safety Facility web site at http://esf.uvm.edu/uvmemp/miscdoc/empcriteria.html.

II. Oversight of Laboratory Operations

The University of Vermont's Policy for Management of Laboratory Waste has been signed by the University's president and describes the University's commitment to regulatory compliance, waste minimization, risk reduction and continual improvement of the environmental management system. The University of Vermont will continue to comply with all Federal, State and local environmental laws and regulations not specifically deferred by the Laboratory XL project. Accordingly, this project will not result in media transfer of chemicals (e.g., will not result in former RCRA wastes being inappropriately disposed to the air, land or water).

This policy meets the requirements of 40 CFR 262.105(b)(2).

Roles and Responsibilities (Environmental Health and Safety Policy)

The EMP operates as a partnership between UVM laboratory employees and Environmental Safety Facility staff. The roles and responsibilities of various segments of the campus community are described in the UVM Environmental Health and Safety Policy. The implementation of these responsibilities through the laboratory self-inspection and audit system are more specifically explained in Section III of the Administrative Section of this overview. In summary, these responsibilities are:

Campus Administrators: The University President, Vice Presidents, Provosts, Deans and Chairs will oversee the implementation of the Environmental Management Plan, primarily by reviewing the results of laboratory audits in their areas of responsibility and the Environmental Performance Indicators and the associated goals.

Laboratory Supervisors: Laboratory supervisors assure that workers in their laboratories understand and implement the procedures involved in day to day management of laboratory waste. They also assure that problems identified during the laboratory self-inspections and annual audits are resolved as soon as possible.

Chemical Hygiene Officers: Chemical Hygiene Officers, if appointed, oversee day to day laboratory activities to assure that safety procedures are appropriately implemented and provide technical assistance with regard to chemical safety concerns. If no Chemical Hygiene Officer is appointed, then the Laboratory Supervisor assumes this role.

Laboratory Workers and Students: Laboratory workers and students are responsible for following waste management procedures described in this Environmental Management Plan and following generally accepted safe work practices. If they have any questions about the interpretation of these procedures and practices, they are responsible for consulting the Chemical Hygiene Officer, Laboratory Supervisor or Environmental Safety Facility staff.

Environmental Safety Facility staff: ESF staff are responsible for managing the transport and storage of chemical waste outside of laboratories. In addition, they perform annual audits of campus laboratories in order to help assure that the laboratories comply with this Environmental Management Plan. ESF staff also manage the annual Hazardous Chemicals of Concern inventory, the annual Training Documentation inventory, the University's Pollution Prevention program and review legal and other documents for applicable requirements for laboratory operations.

Chemical & Biological Safety Committee: This committee consists of research faculty and staff and is responsible for reviewing and resolving incidents of non-compliance within the laboratory and concerns with implementation of the EMP.

This policy meets the requirement of 40 CFR 262.105(b)(3) for assigning organizational roles and responsibilities associated with this program.

Annual Program Review

The Environmental Management Plan is reviewed at least annually by senior management to ensure its continuing suitability, adequacy and effectiveness. The reviews may include, but not be limited to, a consideration of monitoring and measuring information, Environmental Performance Indicators, assessment and audit results and other relevant information.

This review meets the requirements of 40 CFR 262.105(c)(6)(iii)

Targets and Objectives

For the period of the Project XL Pilot Project (September, 1999 - September, 2003), the targets and objectives used to measure the success of the policy will be those described in the Project XL Final Project Agreement.

These objectives meet the requirement of 40 CFR 262.105(b)(2).

Laboratory Standard Operating Policies and Procedures

I. Planning for Chemical Hazards and Pollution Prevention

The University has a Chemical Hygiene Plan which sets forth criteria for the identification of physical and chemical hazards and the control measures to reduce the potential for releases of laboratory wastes to the environment. Laboratory supervisors are responsible for developing and implementing appropriate chemical hygiene policies and practices specific to the operations in their labs.

These policies and practices are described on the Hazardous Chemical Use Registration Form, (Procedure 1) which are maintained on file in each laboratory. These files are available for review during the annual laboratory audits conducted by ESF staff.

This program meets the requirements of the OSHA Lab Standard and 40 CFR 262.105(b)(5).

II. Preventing Releases To The Environment

UVM will assure that there will be no cross media transfer of chemical wastes. This means that laboratory wastes will be managed through the hazardous waste management program unless specific alternatives are permitted as described in the Standard Operating Procedures. University standards for sink disposal (Procedure 2) of chemicals, release of chemicals through fume hoods (Procedure 3) and mixing laboratory materials with other trash (Procedure 4) will be observed by all laboratory workers.

These provisions meet the requirements of 40 CFR 262.104(f)

III. Laboratory Waste Container Management

The management of laboratory waste containers are the first step in assuring proper disposal of hazardous waste. Proper labelling, storage and timely removal of these containers is critical to the safe and healthy conduct of laboratory work and compliance with government regulations. The criteria for these activities are the responsibility of the laboratory workers and are described in Procedure 5.

These provisions meet the requirements of 40 CFR 262.104(a-e)

IV. Emergency Preparedness and Response in Laboratories

In the event of a chemical spill or release, laboratory personnel will respond as outlined in the University's Hazardous Waste Contingency Plan. The size and contents of the spill will determine the appropriate response. Laboratory workers will take responsibility for responding to small emergencies. If the laboratory worker has concerns regarding their ability to respond safely, they will call Environmental Safety staff who will respond and assume responsibility for clean-up. In the event of a reportable emergency, the Environmental Safety Facility staff is responsible for investigating, documenting and taking actions to prevent future incidents as well as reporting the incident to appropriate authorities (Procedure 6).

These procedures meet the requirements of 40 CFR 262.105(b)11

V. Laboratory Self-Inspections

Laboratory supervisors are responsible for oversight of laboratory regulatory compliance. This responsibility is implemented through laboratory self-inspections (Procedure 7). It is the responsibility of the laboratory personnel to address any problems discovered during an inspection within the established time frame. ESF staff will assist in correcting non-compliances found during inspections as appropriate.

These provisions meet the requirements of 40 CFR 262.104(a-e)

Administrative Policies and Procedures

I. Documentation of Training and Laboratory Supervision

Training and Information

The environmental impact of UVM laboratory activities is directly dependent upon the practices of laboratory workers. It is critical that they understand the expectations of the University, standard operating procedures and potential repercussions of improper actions. This understanding is attained through information and training provided through a variety of media. The specific contents of the training are described below.

The laboratory supervisor or Chemical Hygiene Officer (CHO) will provide information about the Minimum Performance Criteria for management of chemical wastes to each laboratory worker when the worker is first assigned to a work area where laboratory wastes may be generated. This information will consist of a pamphlet, provided by the ESF, which summarizes portions of the EMP appropriate to their position. The laboratory supervisor or CHO will also provide information about the wastes generated in that laboratory. Laboratory supervisors will receive information about their role in administering the Environmental Management Plan from their Department Chair and/or the ESF staff.

The University will provide training for laboratory workers within 6 months of starting work. This training will include the information necessary to understand and implement the elements of the full EMP, including pollution prevention and environmental awareness training, that is relevant to their responsibilities. This training may involve a variety of media, including web based training, lecture-based training, individual discussions with laboratory workers during laboratory safety audits, and informal discussions with other laboratory workers. The success of this training will be demonstrated by quizzes appropriate to the role of the worker in the laboratory, based on the following table:

Role	Minimum Performance Criteria Information	Laboratory EMP Information	Environmental Awareness Training	Training Managed by
Unpaid students (taking classes or doing research)	x		x	Course instructor
Laboratory employees	x		x	Lab supervisor and/or CHO
Chemical Hygiene Officer	x	x	x	Lab supervisor
Laboratory Supervisor	x	x	x	Department Chair
Department Chair		x	x	Deans
Deans of Colleges and Schools		x	x	Provost
President and Provosts		x	x	ESF staff

Minimum Performance Criteria training programs will include, at a minimum, the following topics:

information about the Laboratory Environmental Management Standard and implementing and complying with the Environmental Management Plan
location and availability of the Environmental Management Plan
pollution prevention practices at the university, including employee involvement in identifying and implementing pollution prevention opportunities
emergency response measures
signs and indicators used to detect the presence of a hazardous substance or release
chemical and physical hazards associated with the lab wastes in their work area
personal protective equipment and relevant measures can take to protect human health and the environment
location and availability of reference materials

Laboratory EMP Training will include the following topics:

the UVM Environmental Health and Safety Policy
laboratory self-inspection procedures
laboratory safety audit procedures
oversight responsibility for individual laboratories
laboratories' role in the UVM pollution prevention program
the Laboratory XL pilot project
UVM's Environmental Performance Indicators

Environmental Awareness training will include the following topics:

regulatory requirements applicable to laboratory work
environmental aspects and impacts of laboratory work
the relative magnitude of various environmental impacts of laboratory work
pollution prevention strategies and opportunities in laboratory settings
emergency response preparedness and follow-up
sources of environmental information

The University will identify visitors that require information and training and inform them of the existence and relevant sections of the EMP. In addition, the University will make available its full EMP to laboratory workers, vendors, on-site contractors, and to governmental representatives via the ESF web site (http://esf.uvm.edu/uvmemp).

The delivery of training to laboratory workers will be documented by laboratory supervisors using the Training Documentation Procedure (Procedure 8).

This training plan meets the requirements of 40 CFR 262.105(b)(12)

Laboratory Identification and Supervision

All UVM laboratories are covered by this Environmental Management Plan. UVM laboratories are in the following buildings or facilities:

32 N. Prospect St.	Aiken Center	Angell Hall
Bio-Research Complex 655 Spear St.	Carrigan Hall	Colchester Research Facility
Cook Physical Sciences Building	Dewey Hall	Fletcher Allen Health Care, Clinical Research Center
Given Medical Center	Hills Building	Marsh Life Sciences Building
Miller Research Center (Dairy Farm)	Perkins Hall	Proctor Maple Research Center
Rowell Building	Rubenstein Ecosystem Science Lab	Stafford Hall
Terrill Hall	Torrey Hall	Votey Building
Williams Hall

The form described in Procedure 8 will be used by the laboratory department chairs to update the ESF's roster of campus laboratories. This form will be distributed to department chairs annually in January for review of laboratory supervisor assignments. These forms, along chemical inventories, lab audits, lab decommissioning forms and other information, will be used to update the ESF database of laboratories for compliance audit purposes.

This plan for maintaining a list of laboratories covered by the Environmental Management Plan meets the requirements of 40 CFR 262.105(c)(2)(ii)

II. Annual Surveys of Hazardous Chemicals of Concern

Each January, ESF staff oversee an inventory of hazardous chemicals of concern (Procedure 9). Laboratory personnel are responsible for completing and returning the chemical inventory form supplied by the ESF. At that time, laboratory personnel are responsible for reviewing chemicals stored in the laboratories with an eye to removing excess chemicals. "Excess chemicals" are hazardous materials that have no identified use within the next 12 months.

The results of this inventory are submitted to the Vermont Department of Emergency Management as part of the SARA Title III report and forms the basis of two of the Environmental Performance Indicators for the Lab XL project.

The Environmental Safety Facility staff has compiled a list of hazardous chemicals of concern based on 10 years of surveying the chemicals stored in UVM's labs. A chemical on the HCOC list meets one or more of the following criteria:

it has an expiration date based on safety considerations;
it is subject to regulation under the Vermont hazardous waste regulations;
it has a Poison Inhalation Hazard (PIH) designation by DOT;
other chemicals as determined by professional judgement.

This procedure meets the requirements of 40 CFR 262.105(b)(7),

III. Laboratory Compliance Audits and Oversight

ESF staff are responsible for institutional oversight of laboratory regulatory compliance. This responsibility is implemented through annual ESF staff laboratory audits (Procedure 10).

During this annual audit, ESF staff and laboratory personnel will address and correct any issues found which result in noncompliance and can be corrected at that time. If the noncompliance can not be corrected immediately, a compliance deadline (generally 30 days) will be determined and documented on the inspection form. Designated laboratory personnel will report back to the ESF staff in writing once the noncompliance has been corrected. A follow-up inspection of the lab will occur if more than a written response is necessary to assure compliance. The resolution of these problems will be documented by the laboratory supervisor using the Audit Response form of Procedure 10. The records of the resolution will be maintained by ESF staff in the Laboratory Audit database.

ESF staff will notify the laboratory supervisor of a lab determined to be out of compliance after the audit. If the lab does not comply by the determined deadline, the lab will be re-inspected and the Department Chair will be notified in writing. If the problem is not resolved in 90 days, the ESF staff will issue a report which will be sent to the Chemical and Biological Safety Committee (CBS) for further action. The CBS may work with the laboratory supervisor directly to resolve the issue or forward the concern to Vice Provost for Research for action.

In the case of an imminent danger to life, health or the environment, the Chemical and Biological Safety Committee is authorized to immediately order the cessation of the hazardous activity and close down laboratory activities until such activity has ceased and the responsible individuals have taken adequate measures to correct the situation and prevent recurrence of the noncompliance.

This procedure meets the requirements of 40 CFR 262.105(b)(15) and (16)

IV. Decommissioning Laboratories

A laboratory will be decommissioned as a result of laboratory renovation, relocation or a change in laboratory supervision. Laboratory personnel are responsible for notifying the University at least two weeks prior to the proposed laboratory moving date. The decommissioning procedure (Procedure 11) will be followed.

Prior to moving, laboratory personnel must segregate all chemicals that will not be used in new laboratory locations and tag each container with the UVM Laboratory Waste Tag. Unknown chemicals must be identified prior to moving. The Environmental Safety Facility is responsible for assisting laboratory personnel with laboratory decommissioning and unknown chemical identification.

This procedure satisfies the requirements of 40 CFR 262.105(b)(8)

V. Laboratory Waste Pickup and RCRA Hazardous Waste Determination

Within thirty days of the date on the waste tag, ESF staff will remove laboratory wastes and transfer them either to the designated waste storage area (the Given Bunker) or off-campus. At the Given Bunker, ESF staff will evaluate the laboratory wastes to determine whether they are reusable, recyclable or are RCRA hazardous wastes as described in the hazardous waste determination procedure (Procedure 12). This procedure meets the requirements of 40 CFR 262.104(i)(1) and (2). On rare occasions, ESF personnel may arrange for hazardous wastes to be transported from laboratory buildings directly to a TSDF.

Once the ESF staff determines that a laboratory waste is a hazardous waste, it will be managed in accordance with all applicable provisions of Vermont Hazardous Waste Regulations as well as the provisions of the Environmental Safety Facility's hazardous waste storage facility operating permit. ESF staff are responsible for assuring that the short term storage area (the Given Bunker) is managed in accordance with Federal and State RCRA regulations. They are familiar with emergency response procedures and are equipped with appropriate personal protection and spill control equipment. These University personnel are also trained, at a minimum, to 40 hour HAZWOPER standards. This procedure meets the requirements of 40 CFR 262.105(b)(14)

VI. Pollution Prevention

UVM is committed to promoting laboratory processes and practices that reduce or eliminate the use of hazardous materials and thus the generation of pollutants at the source. In instances where hazardous materials cannot be eliminated or reduced at the source, UVM will investigate methods for reuse and recycling. This commitment is implemented in a partnership (Procedure 13) between laboratory supervisors, workers and ESF staff.

UVM identifies objectives and targets for its hazardous waste minimization program on an annual basis. These are documented in the Pollution Prevention Plan and annual Performance Reports describing progress in meeting these objectives and targets. This plan and reports are submitted to the Vermont Department of Environmental Conservation's Pollution Prevention Division.

The EMP is reviewed at least annually by senior management to ensure its continuing suitability, adequacy and effectiveness. This review includes an evaluation of the policies and procedures which ensure ongoing identification, evaluation and implementation of pollution prevention opportunities.

This program meets the requirement of 40 CFR 262.105(b)(6), and 40 CFR 262.105(c)(6)(iii)

VII. Tracking Legal Requirements

The Environmental Safety Facility staff will identify and track legal requirements (Procedure 14) applicable to laboratory wastes and its management through review of resources below, and by participating in professional associations such as the American Chemical Society and the Campus Consortium for Environmental Excellence. Laboratory personnel will stay up-to-date with the contents and goals of the Environmental Management Plan and any new, pertinent information by means of the University web site, memorandums to faculty and staff, Environmental Council meetings, and scheduled training sessions.

Journals: Chemical Health and Safety from the American Chemical Society

Newsletters: Laboratory Safety & Environmental Management

Websites:

EPA Region 1 Colleges and Universities site,
Vermont Department of Environmental Conservation Waste Management Division,
Lab XL web page

This procedure meets the requirements of 40 CFR 262.105(b)(4).

VIII. Document Control

Record keeping requirements

The records associated with each of the procedures included in the Environmental Management Plan will be maintained according to the specifications included in the procedure.

This procedure meets the requirements of 40 CFR 262.105(b)(17)

Changes to the EMP

Revisions to the EMP can be proposed by any stakeholder and submitted to the Environmental Safety Facility staff. The ESF will bring proposed revisions with recommendations to the Chemical and Biological Safety Committee for review. The University can make changes to the EMP (Procedure 15) with the affirmation of the Chemical and Biological Safety Committee. The State of Vermont Agency of Natural Resources will be notified of all changes.

This procedure meets the requirements of 40 CFR 262.105(b)(13)

IX. Annual Review of Environmental Performance

This Environmental Management Plan and the environmental performance of the University laboratories with regard to chemical waste minimization will be reviewed annually. This review will take the form of a report prepared by Environmental Safety Facility staff to the Vice Provost for Research and the Chemical and Biological Safety Committee. The report will include updates on the Environmental Performance Indicators established by the Project XL Final Project Agreement and recommendations for improving the laboratory waste management program. Such recommendations will establish specific action plans with associated time lines and indicators of success. A template for this report is given in Procedure 16.

These provisions meet the requirements of 40 CFR 262.105(b)(6)

Document Control Information: http://esf.uvm.edu/uvmemp	For more information, contact esf@uvm.edu
Version 1.75	Last Updated: 9/24/08

University of Vermont