Second Year (Midway) Progress Report
New England University Laboratories Project XL
|Message from the Coordinator
Specific Campus Reports and Appendicies:
|II. Activity Since Last Report
|University of Massachusetts Boston
|III. Format of This Report
|University of Vermont
|IV. Data Summary
|Lab XL Inspection Scorecard
|V. Communication to Stakeholders
|Environmental Awareness Survey
|VI. For More Information
We have good news to report. In the laboratory, we have witnessed unprecedented support by laboratory investigators, researchers and laboratory workers for the implementation of a waste management plan developed with, and for, our research community. Based on the environmental awareness surveys, we have seen an increase in the environmental awareness level of laboratory workers. The use of surveys of highly hazardous chemicals, together with the laboratory cleanout efforts, self-inspections and management tools, have resulted in a decrease in the number of highly hazardous chemicals in the laboratory. Finally, the level of conformance with each institution's management plan standards has improved. We believe the waste management program at the Lab XL institutions is clearly more effective than it was under the traditional RCRA model.
Our efforts have also begun to bear fruit in terms of developing lessons learned associated with the development and implementation of the laboratory Environmental Management Plan, and the collection and analysis of performance data. We are confident that at the end of the Project the strengths and weaknesses of the concepts behind this XL Project and the EPIs designated to measure performance can be fully assessed.
Perhaps our greatest sense of achievement is tied to the integration of a chemical safety and environmental management culture in the laboratory and the "buy-in" of faculty, staff and students. The systematic implementation of the program and the systemic nature of the Environmental Management Plan regulatory model have fostered the organizational capability for institutional change. While this foundation has required time to establish, it is this trusting partnership between the Environmental, Health and Safety staff and the diverse group of independent researchers at each institution that is critical to the success of this pilot project.
There are also challenges that we are only now beginning to face. The performance goals associated with minimizing the environmental impact of chemical activities in the laboratory are not yet fully realized. In year 2000, only the University of Massachusetts Boston saw a decrease in laboratory waste generation rates. Last year, the waste generation rates fell at Boston College and the University of Vermont. We hope that next year will bring further declines in waste generation rates, yet, the number of researchers and the type of chemical research is a stronger determinant of waste generation rates than an effective chemical management program.
We are concerned that the EPI built around the reuse of laboratory waste is problematic. The Lab XL institutions have built the organizational capacity to enhance conformance and foster pollution prevention, but they can not overcome the legitimate quality assurance and cultural barriers to the reuse of laboratory waste in research and teacher settings of higher education. We have also learned, however, that a viable, informal system for the sharing and exchange of surplus chemicals appears to exist at all three institutions. For example, 82% of survey respondents at UMass Boston reported that they used surplus or unneeded chemicals from other laboratories. The pilot institutions will be distributing pollution prevention (P2) surveys to researchers to gauge the frequency of these lab to lab interactions and assess whether there is any value in a formal, centralized program for the reuse of surplus chemicals.
Further understanding of these pollution prevention challenges will take rigorous institution-specific approaches. For example, halogenated solvents account for roughly 80% of the laboratory wastes at Boston College. Pollution prevention efforts at BC will therefore focus on minimizing solvent waste streams. UMass Boston will focus on servicing those laboratories that identify very specific opportunities and verifying P2 activities in the labs. The University of Vermont, the largest institution in this project, will distribute a P2 questionnaire and will use the responses to identify those opportunities that are most applicable to the broadest number of laboratories.
In order to more fully explore these issues, we are consulting with our professional peers on other campuses. We are co-sponsoring a symposium at the August meeting of the American Chemical Society in Boston on the regulatory issues associated with laboratory waste. We are also moving forward with plans to host a workshop in the fall that will focus on pollution prevention and green chemistry in the laboratory. This workshop will discuss specific techniques and case studies for minimizing laboratory wastes through product substitution, microscale and treatment. We will also discuss how to implement and manage these techniques in a manner that encourages researchers to embrace the opportunities. Finally, we will discuss how to measure pollution success in a multi-laboratory institution where multiple small improvements may be hidden by the volume of larger wastestreams.
Meeting these challenges will take more hard work, more data gathering, and more rigorous analysis. It will also require all the stakeholders to reassess the Environmental Performance Indicators vis a vis the merits of regulatory reform.
We recognize that the pollution prevention opportunities are currently aligned with the granting of regulatory flexibility. We share those aspirational P2 goals. The achievement of the P2 goals alone should not, however, determine the success of this project or affect the imperative for regulatory reform in higher education laboratories. The primary regulatory relief of this Project - clarification, really - is the postponing of the RCRA waste determination from the laboratory to the institution. This regulatory relief -- combined with the development and implementation of an internally developed waste management plan -- is the keystone that locks the chemical and waste management pieces together.
It will take at least the full four years of the Project to fully realize all the performance goals and understand the ramifications and the opportunities associated with this performance-based approach. We look forward to the ongoing discussions and learning that will continue over the life of this XL Project.
Performance reports have been completed by each of the New England Universities Lab Project XL Participants: Boston College, University of Massachusetts Boston and the University of Vermont. These are included at Tabs A, B, and C respectively.
As described in the FPA, the Lab XL participants use nine EPIs to track and evaluate their institution's "environmental performance." The EPIs are classified by type - pollution prevention (5 indicators), compliance (2 indicators) and environmental literacy and awareness among laboratory workers (2 indicators). Nine indicators were selected because of the complexity and the interactivity of the waste management activities, the multiple outcomes sought and uncertainty with respect to the selection of the perfect indicator for this project. The emphasis on pollution prevention reflects the collective desire to minimize the chemical impacts associated with laboratory research, to the extent practicable, as measured by laboratory waste generation and reuse of waste chemicals.
Major activities and interactions with the Environmental Protection Agency (EPA), the Vermont Department of Environmental Conservation (VT DEC) or the Massachusetts Department of Environmental Protection (MA DEP) are identified below:
* The University of Massachusetts Boston was audited by EPA and MA DEP personnel on May 14 and May 18 (closeout meeting), 2001. The audit team visited over 90 laboratories.
* The University of Vermont was audited by EPA personnel and VT DEC on October 15, 2001. More than two hundred laboratories were evaluated.
* EH&S representatives from the XL Institutions and a senior administration representative from UVM met on September 27th, 2001 with staff from EPA Region I, EPA Headquarters, VT DEC and MA DEP to discuss performance to date. This all-day meeting involved a comprehensive and honest discussion of the hurdles and delays found in implementing the EMP and the associated measurement systems for the EPIs. Discussion of the origins of, and the assumptions associated with the EPIs, allowed the group to begin to explore whether the EPIs were measuring the correct performance outcomes and whether the measures accurately portrayed the value of this alternative approach. Based on this discussion, the Washington DC EPA representative, Suganthi Simon, together with EPA subcontractor Industrial Economics, commenced further evaluation and interpretation of the data in order to most effectively understand and tell the Lab XL story.
* The institutions participated (e.g., conference calls, meetings, information sharing) with Industrial Economics and the U.S. EPA in an assessment of the environmental awareness testing program and the results to date. A draft copy of their report was completed in March 2002.
* A sub-committee representing the XL Institutions, VT DEC, MADEP and EPA worked collaboratively to develop a revised "matrix" or scorecard for assessing and "grading" the inspections of laboratories with regard to container management, housekeeping, pollution prevention, self-inspection and training. A copy of this scorecard is included at Tab D.
* We participated in EPA's mid-term evaluation of the New England Universities' Laboratories Project XL. The goal of this mid-term evaluation is to garner lessons learned from the Project and to highlight opportunities to improve the overall environmental performance for the universities for the remainder of the project. Industrial Economics and the EPA conducted on-site interviews at each institution in March 2002. These visits found significant benefits to the EMP approach, as opposed to the RCRA approach, as voiced by principle investigators, researchers and students. EPA's report may be issued this summer 2002.
At the smaller institutions, Boston College and the University of Massachusetts Boston, HCOC inventories were conducted in all laboratories and HCOCs that posed a safety risk were identified. Efforts to remove these chemicals or confirm the removal of the HCOCs from the laboratories are still underway. At UVM, the analysis of HCOC survey results found that HCOCs on the shelf have declined over the past few years. The table below illustrates that the chemical count per laboratory decreased from 26 HCOCs per laboratory during the period 1995-1999 (pre-XL) to 18 per laboratory, a 34% decrease, during the first two years of the XL program. The total pounds of HCOCs per laboratory also decreased 34%, from 216 to 143 pounds during this period.
The institutions have learned that the best approach for preventing the accumulation of HCOCs on the shelf includes a combination of management tools: (1) The surveys; (2) Training - recent trainees are likely to return to their labs and assess the shelf for pyrophors, reactives; (3) self-inspections (e.g., good housekeeping is perhaps the best predictor of the absence of an expired HCOC on the shelf); (4) review of chemical storage issues during laboratory waste pickup; and (5) effective purchasing controls and information management.
We have learned that this management indicator (percentage response rate to a survey) may be less important than many other indicators, such as good housekeeping scores on the inspection scorecard, frequency of spills/accidents, or actual quantity of HCOCs in the laboratory.
Conducting pollution prevention assessments and implementing pollution prevention initiatives appears to be straightforward. There are two reasons for the delay in conducting such assessments at the three XL Institutions. First, it has taken time for the EH&S Departments to develop the organizational capability (e.g., relationships, trust, service, clear expectations) to implement P2. Management consultants suggest that it takes 2-3 years to initiate institutional change. Second, a strategy for implementing P2 for hundreds of laboratory workers and laboratories with small, unique waste streams must be carefully considered. The Lab XL Institutions believe that they are now at a crossroads that allows them to effectively pursue pollution prevention.
Each institution has developed a P2 survey and has or will soon distribute the survey to researchers. As the relationship between EH&S and researchers continues to expand under the EMP model, each institution has become increasingly aware that P2 is occurring in the laboratories. For example, the UMass Boston P2 survey results suggest that 33% of researchers have already taken chemical substitution steps and 59% have "downsized" experiments to reduce the quantity or toxicity of hazardous chemicals. These P2 initiatives are implemented informally, without institutional or centralized EH&S support.
Meeting institutional pollution prevention challenges will take rigorous institution-specific approaches. For example, halogenated solvents account for roughly 80% of the laboratory wastes at Boston College. Pollution prevention efforts at BC will therefore focus on solvent waste streams. At UMass Boston, the EH&S staff will emphasize servicing those laboratories that identified P2 opportunities, verifying P2 activities in those laboratories that completed the survey and checking in on laboratories that did not respond to the P2 survey. The University of Vermont, the largest institution in this project, will distribute a P2 questionnaire and will identify those opportunities that are most applicable to the broadest number of laboratories. UVM is also working on the replacement of formaldehyde-based preservatives for tissue samples and the further development of green chemistry laboratory exercises.
The C2E2 has also initiated steps to host and/or co-sponsor a workshop in the fall that will focus on pollution prevention and green chemistry in the laboratory. This workshop will discuss specific techniques and case studies for minimizing laboratory wastes through product substitution, microscale and treatment. We will also discuss how to implement and manage these techniques in a manner that encourages researchers to embrace the opportunities. Finally, we will discuss how to measure pollution success in a multi-laboratory institution where multiple small improvements may be hidden by the volume of larger waste streams.
We anticipate that next year's progress report will be focused on our efforts to assess P2 opportunities and implement P2 programs relevant to laboratories.
Reuse/redistribution programs are in place at the three schools, but the existence of these programs can not overcome the legitimate quality assurance and cultural barriers to the reuse of laboratory waste in research. The results from this project are similar to the lessons learned at many other colleges and universities that have implemented surplus chemical and waste exchange programs. You can lead a researcher to laboratory waste, but you can't make him use it. Efforts to reuse such waste materials in teaching laboratories is possible; however, efforts to utilize green chemistry laboratory exercises at each of the institutions may minimize the potential for reuse that we foresaw three years ago.
We also have good news to report, although the performance is not captured by the EPI. Our outreach and data collection efforts have confirmed that researchers may use unopened or surplus virgin chemicals. In fact, we have learned that an informal, viable system for the sharing and exchange of surplus chemicals appears to exist at all three institutions. For example, at UMass Boston, 82% of the respondents to the P2 survey said that they used excess chemicals from another laboratory instead of buying new chemicals. Boston College and UVM will also be distributing P2 surveys to researchers to further gauge the frequency of these interactions and assess whether there is any value in a formal, centralized program for the reuse of surplus chemicals. We wish to determine, among other things, if there is a role for EH&S to enhance the grass roots, informal, network of professional trust or if a formal, structured EH&S program could impede success.
Laboratory Waste Generation Data (un-normalized)
Percent Change from 2000
Percent Change from Baseline
34, 335 lbs.
36, 764 lbs.
23, 211 lbs.
University of Massachusetts Boston
3, 710.66 lbs.
5, 584.76 lbs.
University of Vermont
33, 387 lbs.
38, 269 lbs.
38, 646 lbs.
Efforts to normalize the waste generation rates have been generally unsuccessful. Neither the number of rooms, number of researchers, research dollars or square footage of laboratories can accurately normalize the data, although these approaches may be used qualitatively by EH&S professionals to assess institutional trends. We may therefore have to rely on un-normalized data to achieve the Project's 10% laboratory waste reduction goal. The institutions believe that waste generation will continue to decline as a result of fewer laboratory cleanouts, enhanced information and training, and pollution prevention activities scheduled for 2002/2003. However, we believe that factors outside EH&S control, such as research activity, are a stronger determinant of waste generation rates than an effective chemical management program.
The data in last year's report showed that EMP training enhanced environmental awareness at all three institutions, although issues of variable data collection and analysis have been identified. The data in 2001 shows that the environmental awareness of laboratory workers has stabilized after showing significant progress last year. The chart below illustrates that the improvement in the average percent of correct answers. The trend is remarkably consistent between institutions.
The surveys reached a more diverse audience in 2001. For example, 50% of respondents at UVM had worked in a laboratory for less than two years. At UMB, 46% of respondents were undergraduates who were generally unfamiliar with the EMP. The surge in scores the previous year may therefore have been attributed to response bias caused by the high percentage of long-term faculty and staff who responded to the survey or the small sample size in 2000 that responded to the surveys at UMB and BC.
Based on these results, the XL Institutions are faced with a number of issues and challenges that must be addressed to further raise the survey scores. Challenges include how best to track and train undergraduate students and transient laboratory workers. Should the training be designed to be more closely aligned to the survey? Should the physical impacts of laboratory activities be emphasized or can this information be distributed through alternative communication channels? What's the relationship between the survey scores and the inspection grades?
The data suggests that the EH&S staff at each of the universities continued to reach more laboratory workers. At UVM, more than 600 people completed training last year, compared to 284 in 2000 and 140 in 1998. At Boston College, more than 300 people have received EMP training, which is estimated as more than 90% of the laboratory worker population. At UMass Boston, 89% of all laboratory workers have been trained.
As every college or university knows, tracking laboratory workers and getting them to training is no easy task. The three institutions are continuing to build effective processes, and associated databases, to more effectively track the entry and exit of laboratory workers. Looking ahead to the next year(s) of the Project, the number of laboratory workers trained each year may begin to stabilize or decline, depending on whether refresher training is required by the institution or specific departments. Under these circumstances, other indicators, such as inspection "grades" and environmental awareness survey results may be more informative indicators than the actual number of workers trained.
This EPI has been problematic, although simply understood. The nine EPIs of the Lab XL Project act as de facto objectives and the targets with respect to each institution's management of laboratory waste program. Therefore, the setting of additional objectives and targets appears unnecessary.
Yet, each institution did set "interim" program objectives for program improvement. For example, Boston College set an objective to develop its final list of HCOCs and achieved its objective. Each institution set an objective to regrade prior year laboratory inspections using the new scorecard. UMass Boston completed its implementation of the bar coding system in the laboratories. Program objectives are being appropriately established and met by the Lab XL participants.
Boston College and UMass Boston were able to regrade their inspections from 2001 and 2000 to the new scorecard, but only for the areas of container management and housekeeping. Scores at BC, for example, showed substantial improvement within departments (e.g., Chemistry Department score improved by 18%) and by category (e.g., average housekeeping score across all departments improved by 16%).
UVM was able to apply the grading system only to the 2001 audit results (the first under the EMP), but was able to provide scores in all categories based on their extensive inspection checklist. Trends in the level of EMP compliance for the 532 laboratories audited will be available for next year.
We believe that the grading scheme will provide a great deal of data next year with which we can evaluate laboratory performance improvements over time, within and across departments and by categories such as compliance, basic management (e.g., housekeeping) and beyond compliance components.http://www.c2e2.org. The Project XL section of the C2E2 web site continues to receive approximately twelve hits per day from people seeking information regarding this project. Each University will also post their status update on its own web page. The EH&S web sites are as follows:
Information regarding the availability of the update will be posted to the XL and Safety listserves, managed by Ralph Stuart at UVM, announced in each campus newsletter and communicated to individuals or organizations. Additionally, individuals identified as key stakeholders during the XL negotiation process, or other interested parties identified since September 28, 1999, will receive a communication that this status report is available.
In addition, the UVM Environmental Council received an EPA grant to develop greater stakeholder involvement from the Burlington, Vermont community by communicating information regarding the XL project performance in the context of the environmental impacts associated with the University's operations and activities. This most recent information regarding the XL Project will be integrated into that larger report. For additional information regarding that project, contact Gioia Thompson at [email protected] or by telephone at 802- 656-3803.
Interested parties may also communicate with the XL University contacts directly at:
Copyright © 2002 The Campus Consortium for Environmental Excellence |