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New England Laboratories Project XL
Baseline Assessment
June 28, 2000
Boston College, University of Massachusetts Boston,
University of Vermont
Table Of Contents
I. Introduction
II. Purpose of the Baseline Assessment
III. Information Regarding the Institutions
IV. Description of Data Gathering Approaches
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A. Hazardous Chemicals of Concern
B. Generation of Laboratory Wastes
C. Environmental Awareness Survey
D. Laboratory Wastes Reuse and Redistribution
E. Costs of Laboratory Waste Management
V. Environmental Performance Indicator Results
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A. Hazardous Chemicals of Concern
B. Generation of Laboratory Wastes
C. Environmental Awareness Survey
D. Laboratory Wastes Reuse and Redistribution
E. Costs of Laboratory Waste Management
VI. Communication To Stakeholders
VII. For More Information
Appendices/Tabs
A. UVM Hazardous Chemicals of Concern
B. UMass Boston Hazardous Chemicals of Concern
C. Blank Environmental Awareness Survey
D. Example: HCOC Inventory at UMass Boston
E. Waste Generation Rates
F. Comparison of Environmental Awareness Survey Results
G. Institutional Environmental Awareness Survey Results
H. Costs of Compliance
I. Introduction
This initial baseline assessment of certain key environmental performance indicators relevant to the New England Universities Laboratory XL Project is required under the terms of the Final Project Agreement signed September 28, 1999. Under the terms of that agreement, this initial baseline report is due June 28, 2000.
The FPA, under Section III.G "Monitoring, Reporting and Evaluation Methods," requires that each university gather data relevant to the environmental performance of its laboratories and laboratory workers. The agreed upon Environmental Performance Indicators (EPIs) for the baseline assessment include:
1. A survey of "Hazardous Chemicals of Concern (HCOC)" and the quantity stored on the shelf in those laboratories covered by this XL Project (HCOC is defined in 40 CFR 260.102 as a chemical that the organization has defined as having the potential to be of significant risk to human health or the environment if not managed in accordance with procedures or practices defined by the organization.);
2. A measurement of laboratory wastes generated during a defined time period;
3. An environmental awareness survey of laboratory workers;
4. An evaluation of the amount of all laboratory wastes currently reused or redistributed;
5. A measure of the costs of compliance that includes available information on waste disposal costs.
II. Purpose Of The Baseline
The purpose of evaluating these selected EPIs is to generate a baseline against which future environmental performance can be compared. Over the next four years, the Universities will be collecting and making available annual environmental performance data with respect to these five EPIs, as well as monitoring, measuring and reporting on additional EPIs identified in the FPA. It is our belief that the merits of the XL regulatory model will be supported by evidence of the continual improvement of laboratory environmental performance at the three institutions.
III. Information Regarding the Institutions
Each institution has developed a draft Environmental Management Plan (EMP) that describes how to manage laboratory wastes at the institution. Each University intends to apply the EMP to all research and teaching laboratories that generate, or may generate, laboratory wastes. For the purpose of this report, it is important to appreciate the approximate number of laboratories at each institution.
| University of Vermont | 538 laboratory rooms |
| Boston College | 130 laboratory rooms |
| University of Massachusetts Boston | 144 laboratory rooms |
IV. Description of Data Gathering Approaches
A. Hazardous Chemicals of Concern (HCOC)
Each university developed a unique methodology for conducting HCOC risk assessment inventory. Each approach is described below.
1. University of Vermont
UVM's hazardous chemicals of concern (HCOC) inventory is based on the requirements of SARA Title III reporting. In 1990, a variety of regulatory chemical lists were reviewed to generate a list of approximately 400 hazardous chemicals considered to be of potential environmental or safety risk and likely to be found at UVM. This list is distributed to laboratories every January, and the laboratories report the quantity class of each chemical on the list that is stored there on a daily average basis (the original list of 400 was shortened after a couple of years of results had been gathered and certain chemicals were determined to be unlikely to be present or be present at an amount in the laboratory that triggered reporting). The cumulative totals for each building are reported to the Vermont Department of Emergency Management as the SARA Title III report for UVM. (For Title III report purposes, heating oil and other fuels and physical plant chemicals are included as well.). This process also serves as the HCOC survey required by the Project XL regulation. A copy of UVM's list of HCOCs is found at Tab A.
2. Boston College
Boston College has conducted a complete inventory of hazardous chemicals of the laboratories. There is no single "list" of HCOCs. A full inventory was completed by each laboratory and submitted to the Office of Environmental Health and Safety for review.
3. University of Massachusetts Boston
The University of Massachusetts Boston is required to annually conduct a full chemical inventory for the Boston Fire Department. The inventories for each laboratory are collected manually from laboratory Principal Investigators and entered into a database in the Environmental Health and Safety Office. Under Project XL, EH&S has designated the following materials to be HCOCs:
* EPA P-listed wastes
* OSHA Carcinogens
* OSHA Teratogens
* Explosive Chemicals
* Peroxide-forming chemicals
The list of HCOCs for UMass Boston is included at Tab B. EH&S is generating a separate list of HCOCs for each PI to review to insure that they inventory and effectively manage these chemicals.
B. Generation of Laboratory Wastes
Each university reported on waste generation rates for the previous calendar year. The waste was measured in pounds and was limited to hazardous wastes generated from laboratory activities. The University of Vermont has categorized its wastes according to specific types of labpacks and wastestreams, including compressed gases and aerosols and ethidium bromide wastes. The UVM data also covers previous years (1995-1999). The waste generation rates being reported as part of this baseline report are based on UVM's hazardous waste annual reports generated for the Vermont Department of Environmental Conservation. Because UVM's Environmental Safety Facility (ESF) is a Part B storage facility,
UVM is required to file two reports 1) one for the waste streams generated on campus and 2) another for those shipped out of the ESF. The numbers gathered for this report are the amounts shipped from the campus to the ESF. UVM chose to report these numbers because at this point in the waste handling process, laboratory waste streams are easily distinguished from other campus waste streams.
Boston College has categorized its wastes according to laboratory wastes, oil wastes and silica gels.
UMass Boston has categorized its wastes according to specific types of labpacks, as well as compressed gases and aerosols and non-hazardous/non-regulated wastes. In addition to data for 1999, data for the first six months of 2000 was calculated.
C. Environmental Awareness Survey
The Environmental Awareness Survey developed for the Project XL baseline was a cooperative effort among the three pilot schools, in consultation with a experienced survey professional from the University of Massachusetts Boston. A copy of a blank generic survey is included at Tab C.
Because of the size of UVM's laboratory population (about 1500 full time people) a random selection of 100 people was generated by taking every sixth name from the people who participated in the laboratory storage survey conducted over the last two years. In response to either the direct mail, a survey session or direct interview, each of these individuals subsequently completed the survey
Boston College distributed the survey to over 290 laboratory workers, including faculty, staff and students. Eighty-eight laboratory workers completed and returned the survey.
University of Massachusetts distributed the survey to an estimated 150 laboratory workers in departments covered by the Environmental Management Plan. The list of laboratory workers was generated from training records in the EHS Office. Because the list is updated only when EHS is notified of personnel changes, a number of surveys were returned because the individuals were no longer working at UMass Boston. As unopened surveys were returned to EHS, the surveys were resent to other individuals from the training database. For the first round, only approximately 30 laboratory workers completed the surveys. A second round was initiated by mailing the survey directly to laboratory students via student mailboxes. A final round consisted of giving several copies of the survey to faculty members to distribute and return. In all, 87 completed surveys were returned an analyzed.
D. Laboratory Wastes Reuse and Redistribution
Because the current regulatory framework does not easily support the reuse or redistribution of laboratory wastes, it was the assumption of each of the institutions that the institutional reuse/redistribution rate was less than one percent of wastes generated from laboratories. (According to a 1996 survey of approximately 100 academic institutions by the Campus Safety, Health and Environmental Management Association, nearly 95% of respondents reported that they redistributed or recycled less than 1% of the hazardous chemical waste otherwise destined for disposal).
Each university took steps to evaluate reuse/redistribution efforts at their respective institutions. Such steps included reviewing the centrally administered chemical distribution channel, departmental programs or any informal, collegial chemical exchanges. This evaluation was performed through selective interviews and email communications and discussions with technicians handling hazardous wastes in the laboratories.
E. Costs of Laboratory Waste Management
Each institution calculated its direct compliance costs for the proper management and disposal of chemical wastes from the laboratory. These costs were calculated for the previous fiscal year. Radioactive and biowaste were excluded from the analysis.
The costs of hazardous waste management could include:
* the amount billed to the institution by the disposal contractor;
* the labor associated with the collection of chemical wastes from the laboratories, including any transportation, repackaging, or paperwork preparation by institutional staff. Assumptions of the percentage of staff time dedicated to these activities were made by each XL Institution. For example, UVM estimated these costs as 50% of the ESF salary budget.
* The training costs for EHS staff and for laboratory workers managing chemical wastes.
* Equipment and supply costs.
* Federal, state or local fees or taxes associated with the management and disposal of hazardous waste.
V. ENVIRONMENTAL PERFORMANCE RESULTS
A. Hazardous Chemicals of Concern
All institutions found that the completion of the Hazardous Chemicals of Concern Surveys/Inventories provide researchers an opportunity to review the stock of unused chemicals in the laboratories and re-evaluate the value of retaining the chemicals in the laboratory. The survey also allows for container integrity checks as well as a review of expiration dates and appropriate storage.
The results of the 2000 inventory of HCOCs at UVM is sixty pages long and is not included in this written report. The list is accessible on-line at http://esf.uvm.edu/uvmemp/baseline/hcocinventory.pdf.
Based on its experience implementing the SARA Title III inventory, UVM has found that this risk management/inventory process regularly results in lab workers discovering materials being stored in the laboratory which can be discarded. The first several years the inventory form was used, chemical wastes generated by laboratories increased significantly in February and March. This effect has lessened in recent years, but there is still some evidence that the inventory stimulates improved housekeeping of chemicals in laboratory storage. UVM expects that the future implementation of the Environmental Management Plans, will further support this improved housekeeping and safe management of chemicals of concern.
Because Boston College and UMass Boston have generated a comprehensive inventory of HCOCs, a complete listing of these surveys is not included in this written report. The information is available from the EHS Office at each institution.
An example of a completed inventory from a laboratory at UMass Boston is included at Tab D. The EHS Office uses the full inventory to generate Operational Material Safety Data Sheets for each laboratory and to determine door signage as required under the National Fire Protection Association Standard 704. The HCOC inventory data will be used to raise laboratory worker awareness of these particularly hazardous chemicals and ensure that these chemicals do not remain on the shelf unnecessarily.
It is expected that the inventory process at Boston College and UMass Boston will have a comparable positive effect on laboratory waste disposal, general housekeeping and risk reduction, as observed at UVM. The complete list of inventories is available, upon request, from the EHS Office at Boston College and UMass Boston.
B. Generation of Laboratory Wastes
Results for the generation of laboratory wastes for the three institutions are included in Tab E (BC, UMB, UVM). A table is included for each institution. The total laboratory waste in 1999 for each institution is summarized below. Oil waste for Boston College was not included in the total for the following chart.
| Institution | Total Amount |
|---|---|
| Boston College | 25,269 pounds |
| UVM | 36,156 pounds |
| UMass Boston | 5,585 pounds |
As the chart above illustrates, there is wide variation in the quantity of laboratory wastes generated. This variation reflects the varying types of research conducted at the different institutions, the different types and sizes of laboratory rooms and the different approaches to waste management (e.g., UVM has a Part B permit to better support aggregation and lab packing).
The waste generation rates for UVM were calculated based on the actual amounts shipped from the campus to the university's Environmental Safety Facility, a Part B hazardous waste storage facility. The amount of hazardous waste shipped from UVM's laboratories (about 550) has been reasonably consistent from 1995-1999, with an average amount of just over 36,000 pounds during that period. It should be noted that the 1996 number does not include a large chemical clean out of the Chemistry Department that took place that year. This clean out produced more material than expected (about 11,000 pounds) and was not representative of a single year's waste production.
The annual variation from average of UVM's laboratory wastes (less than 10%) is much less than that observed for other campus wastes, whose totals are often driven by large construction and renovation projects which produce oil contaminated soils, lead paint debris, and other sporadic hazardous waste streams.
The waste generation rates at Boston College and UMass Boston are based on the quantity of waste collected from laboratories that is manifested and disposed of off-site. The BC table includes monthly data and averages, as well as annual total generation rate. The UMass Boston table also includes data from the first half of 2000.
C. Environmental Awareness Survey
A comparison table of the survey results for the three institutions is included at Tab F. It is important to note that the Environmental Management Plans have not yet been implemented at the institutions. Therefore, the "correct answer" to question #14 (the EMP) would not be expected. Correct answers were available, however, if a respondent identified appropriate waste management or chemical hygiene plan procedures currently in place. For example, many respondents at UMass Boston correctly identified applicable, existing waste management procedures.
Questions 3, 8, 11 and 13 asked respondents to provide a list of answers, rather than asking for a single correct answer. The number of answers provided reflects their complete familiarity with the issue at hand. We expect the number of correct responses to increase over time.
Laboratory workers at each of the institutions are generally unfamiliar with the regulatory concept of "acutely hazardous laboratory waste", which is specific to this Project XL Rulemaking, as well as the RCRA concept of acutely hazardous waste. This term will be specifically covered during the training that is delivered during the course of the XL Project. However, this is an interesting finding that illustrates the current challenge with the existing RCRA regulatory distinction and raises the question as to the value such a regulatory distinction has for laboratory workers handling and generating on a continuous basis small quantities of highly hazardous chemicals.
Laboratory workers at each of the institutions generally did not identify energy usage as the single biggest environmental impact associated with laboratory activities (Question 12). This question relies on a general judgment about the relative hazard of different environmental aspects. Therefore, it is likely that this question will continue to result in varied answers over the course of the project. It does reflect an important question about the environmental impact of laboratory work, however, particularly in light of the EPA Labs21 initiative.
It is noteworthy that most respondents recognized in question #4 that the disposal of laboratory chemicals is typically more than the purchase price. And more than 50% of lab workers at all three institutions believed incorrectly that fume hoods perform a filtration function prior to release to the air (question #10).
The demographic information illustrates that it will also be important to reach more faculty and Principal Investigators. At Boston College and UMass Boston, undergraduate students were the predominant respondent. At UVM, while few undergraduate students responded (7%), only 9% of the respondents represented faculty. This variation in response illustrates the variation in laboratory worker populations at the different institutions.
D. Laboratory Waste Reuse and Redistribution
UVM
UVM has implemented a chemical recycling program. UVM's chemical recycling program has two portions: the centrally administered ChemSource program and informal departmental programs that occur in a decentralized manner. They estimate that the amount of chemicals recycled as a result of the combination is less than 1% of the chemical waste generated by UVM (36,000 pounds/year).
1. ChemSource
ChemSource is the chemical distribution program managed by the Environmental Safety Facility staff. UVM purchases chemicals from commercial suppliers in case quantities and sells containers within the case to campus chemical users. This allows laboratories to buy small quantities of chemicals while realizing the price advantage of case purchases.
The amount of materials sold through this program has increased steadily over its 4 year history and is currently about 6600 pounds per year. ChemSource also takes advantage of opportunities to recycle chemicals that are reusable. Materials of good quality (i.e. no sign of physical degradation) that ESF staff collect as hazardous waste are stored separately from other chemical wastes and can be purchased through the ChemSource program for $2 per container.
Because of the uncertain quality of these materials, they are generally general lab use chemicals such as solvents and acids that are used for glass washing that are recycled this way. UVM estimates that about 60 pounds of chemicals are recycled annually through the ChemSource program.
2. UVM Departmental Programs
As might be expected, the departmental chemical recycling efforts varied in focus and effectiveness at UVM.
For example, the Pathology Department moves chemicals from lab to lab only when a laboratory is being decommissioned because a researcher is leaving. This happens about every year and a half and the only chemicals of interest to other researchers are general laboratory chemicals that are of general use. Specific chemical regents critical to experimental procedures are never moved from one laboratory to another because of concerns about quality and purity. About 100 pounds per year of chemicals is recycled in this way within the Pathology Department.
In the Animal Sciences Department, most chemical purchases are arranged through the departmental business manager, who is generally aware of what chemicals are already in the department. She takes advantage of opportunities to move chemicals from one laboratory to another to avoid the excessive purchase of new chemicals.
The Microbiology and Molecular Genetics Department has no centrally managed chemical management program so each laboratory acquires and stores chemicals on their own. According to the department lab coordinator, because of the small amounts of chemicals used and the high need for purity, there is very little interchange of chemicals (i.e. "not significantly different from zero") between laboratories.
BC and UMass Boston
A formal reuse and redistribution program does not exist at Boston College and UMass Boston. Based on interviews and data collection, each institution confirmed that its current reuse/redistribution rate of laboratory wastes is less than one percent of the laboratory wastes generated. Each institution received anecdotal information that suggests that unused chemicals are being discarded from the laboratories in the event the laboratory no longer has a need for the material.
E. Costs of Laboratory Waste Management
The costs of laboratory waste management at each of the institutions is included at Tab G (BC, UVM, UMB). A table is included for each institution. The total costs for the previous fiscal year (2000) are as follows:
| Institution | Total Cost | Normalized Per Lab Room |
|---|---|---|
| Boston College | $122,612.00 | $943.17 |
| UMass Boston | $27, 991.00 | $194.28 |
| UVM | $258,960.00 | $481.34 |
Because of the wide variation in types of laboratories and level of research, it is doubtful that the normalized costs per laboratory room are insightful in comparing across campuses. However, the normalized costs may show certain useful trend lines within each institution over the course of this project.
It is of interest, however, that the average cost per pound of laboratory waste was highest at UVM at $7.17 per pound, while UMass Boston ($5.10) and BC ($4.80) were slightly lower. This may be real costs associated with maintaining the Part B program or simply an artifact of UVM's larger program and more accurate cost accounting program. It is important to note that UMass Boston did not collect cost data prior to this XL Project, with the exception of hazardous waste contractor costs and outside training. Costs associated with the management of laboratory wastes will be effectively tracked going forward.
Finally, laboratory management costs in FY2001 may increase at all the institutions due to
1) training and labor costs associated with the implementation of the Environmental Management Plans and
2) increased laboratory cleanouts and disposal associated with the HCOC survey, periodic inspections and increased awareness of laboratory waste management.
VI. Communication To Stakeholders
This report will be available on the Lab XL Web Page at http://esf.uvm.edu/labxl.
Each University will also post its baseline report on its own web page.
The URLs are as follows:
University of Vermont - http://esf.uvm.edu/uvmemp/baseline.html
University of Massachusetts Boston - http://omega.cc.umb.edu/~ehs/index.htm
Boston College - http://www.bc.edu/ehs
Information regarding the availability of the report 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, identified as key stakeholders during the XL negotiation process, who expressed an interest in receiving ongoing information with respect to this project.
VII. For More Information
For more information about the New England Universities Laboratories Project XL, contact
Thomas Balf at the Campus Consortium for Environmental Excellence,
One Financial Center, Boston, MA 02111
(617) 951-1181 or at
Interested parties may also communicate with the XL University contacts directly at:
Ralph Stuart, UVM: 802-656-5403:
Suzanne Howard, BC: 617-552-0303:
Zehra Schneider-Graham, UMass Boston: 617-287-5444:
THE CAMPUS CONSORTIUM FOR
ENVIRONMENTAL EXCELLENCE
c/o NeXus Environmental Partners
One Financial Center, Suite 2900
Boston, MA 02111
617-951-1181
617-542-7437 (fax)
June 28, 2000
Ms. Gina Snyder
EPA New England
1 Congress Street
Suite 1100(SPE)
Boston, MA 02114-2023
RE: XL Baseline Report for the New England Universities Laboratory Project XL
Dear Gina,
In accordance with the New England Universities Project XL Final Project Agreement, I have enclosed three (3) copies of the initial Baseline Report. If you have any questions, please do not hesitate to contact me or any of the XL University contacts directly.
With best regards,
Thomas P. Balf
Copyright © 2002 The Campus Consortium for Environmental Excellence |