It's a situation no institution wants to find itself in: getting singled out, not for earth-friendly efforts, but for an Environmental Protection Agency investigation. Yet messing with hazardous waste laws can result in just that.
As the target of an investigation that began earlier this year, for example, Yale may have to fork over nearly $30,000 for failing to meet financial assurance requirements of federal and state hazardous waste laws.
The investigation is part of a crackdown on the proper management of hazardous and nonhazardous solid waste, as outlined in the Resource Conservation and Recovery Act, first passed in 1976.
In Yale's case, the problem is in the area of financial assurance, one of the EPA's 2006 priorities. Officials overseeing facilities that treat, store, or dispose of hazardous waste must prove-through an audit and then subsequent annual reports-that their organization has the funds available to properly clean up the facilities when their operating life ends, explains Andrea Simpson in the Office of Environmental Stewardship of the EPA's New England Regional Office, which is conducting the investigation. In 2002, Yale submitted documents demonstrating its financial assurance obligations were met. Yet officials there did not provide annual updates for 2003 or 2004.
Simpson says that colleges and universities are more likely to get fined for not complying as generators of hazardous wastes than for issues related to the storage of these wastes. But the take-away is the same: Stay on top of all EPA requirements. The EPA's Compliance and Enforcement website, www.epa.gov/compliance/index-e.html, can help. -Melissa Ezarik