Procedure 13:
Laboratory Pollution Prevention Program

Policy

As part of its commitment to environmental responsibility, UVM is committed to using, whenever possible, processes and practices that:

• reduce or eliminate the amounts of hazardous materials used,
• substitute less hazardous materials, or
• use materials that can more easily be reused or recycled.

An important reason for this is to prevent the generation of pollutants and wastes at the source.

In instances where hazardous materials cannot be eliminated or reduced at the source, UVM will investigate methods for their reuse and recycling. In order to be able to assess the success of these efforts, UVM will identify environmental objectives and targets on an annual basis as described in the Project XL Final Project Agreement and the Environmental Management Plan. By adopting the policies, plans and procedures outlined in UVM's EMP, the University of Vermont will continually improve its environmental performance with regard to hazardous waste from laboratories. The University is responsible for making available the resources necessary to implement the pollution prevention measures described in the EMP.

The University provides training for laboratory workers which includes information about the elements of UVM's EMP that are relevant to their responsibilities. This training covers pollution prevention programs and practices at the University, and promotes employee involvement in identifying and implementing pollution prevention opportunities.

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. In addition, the University submits an Annual Pollution Prevention Performance Report describing progress in meeting current objectives and targets to the Vermont Agency of Natural Resources.

This plan, which contains more details of specific pollution prevention projects is available at http://esf.uvm.edu/uvmemp/adminfiles/statep2.html.

Plan

Who:

Pollution prevention is a shared responsibility between laboratory workers and ESF staff. Laboratory workers will identify the most prominent pollution sources in their work and consider alternatives suggested by ESF staff. ESF staff will provide technical support in assessing the feasibility and impact of particular strategies.

ESF staff educate lab personnel about UVM's commitment to pollution prevention and specific pollution prevention efforts during trainings and laboratory audits. During these interactions, laboratory workers inform ESF staff about pollution prevention, waste minimization and source reduction efforts underway within their lab. ESF staff document pollution prevention efforts on the UVM Pollution Prevention Project Plan form.

When

Pollution prevention projects will be developed as the opportunity arises. At least one campus-wide project will be identified annually by ESF staff. ESF staff will complete the UVM Pollution Prevention Project Plan whenever notified of or initiating a pollution prevention/waste minimization effort on campus. ESF staff will identify these initiatives by reviewing current waste streams, tags database and information gained in training sessions.

Where

Hazardous waste minimization efforts for labs are done on a case by case basis. Some efforts are applicable to many UVM labs; other efforts are limited to a few labs. Some efforts are focused on physical processes, other efforts on administrative or cultural changes.

Procedure

Records

Pollution prevention ideas are recorded and tracked on the UVM Pollution Prevention Program Project form for planning and implementation and are accumulated into a database which is reviewed annually to assess the value of each project. Projects which have proven their value are integrated into appropriate laboratory standard operating procedures.