Taking Out the Trash

It happened to Stanford. It happened to Yale. And the University's environmental regulation administrators want to make sure it doesn't happen to Harvard.

In the aftermath of fines levied on Stanford and Yale last year for violations in the storage and disposal of hazardous waste, Harvard must deal with the warning signs that the U.S. Environmental Protection Agency is cracking down on college laboratories.

According to Thomas E. Vautin, associate vice president for Facilities and Environmental Services, the fines have put Harvard on notice that it, too, will have to tighten controls over chemicals and other toxins from research laboratories or face similar penalties.

And the fines, compared with campus precedents, are stiff. Stanford will pay close to $1 million for violations of California hazardous waste disposal laws. Yale, for similar violations, agreed to pay $348,000.

Vautin says that Harvard has used the situations in Palo Alto and New Haven to modify its techniques for properly storing and disposing of hazardous waste.

Learning from Stanford and Yale

According to California Environmental Protection Agency officials involved in the Stanford infractions, many of the violations included improper handling and storage of chemicals which could have led to serious incidents.

Stanford was accused of about 1,600 violations over a six-year period, from March 1988 to June 1994.

In one instance, investigators discovered hazardous waste containers left open. Many of them contained incompatible chemicals that were stored dangerously close to each other.

Yale faced a similar situation as U.S. EPA officials last fall charged Yale with keeping open or damaged containers of hazardous materials in areas where students worked, storing incompatible chemicals together despite risk of explosion and improperly labeling dozens of waste containers.

Yale was also cited for allowing students to work with highly explosive wastes without any formal risk training.

Although Vautin says Harvard's record of compliance with environmental regulations is significantly better than that of Stanford and Yale, the citations the other universities received led to renewed efforts to develop better waste management methods in Harvard's laboratories.

"Partly what we do is learn from the experiences of others," says Vautin. "It's not as though there are a lot of new regulations to carry out, but old ones are being applied and interpreted in new ways."

According to Joe Griffin, Harvard's manager of environmental affairs, these new interpretations signify a definite trend toward more rigorous standards.

The government has been taking a closer look at non-industrial sources of pollution," Griffin says. "The message being clearly sent is that there is going to be a stricter by-the-book approach to regulation."

New Challenges

The stricter governmental regulation of waste management is creating new challenges for the University, which is attempting to deal with the guidelines.

Because Harvard hires contractors specifically to dispose of waste, Griffin says the focus of the University's reforms has been on the labelling, storage and record-keeping of waste.

In each of these areas, according to Griffin, complications include the large number of chemicals used in very small quantities at a number of laboratories, as well as the need for uniform procedures at each of Harvard's campuses.

Other challenges resulting from regulations involve the more rigorous standards applied to waste than to raw chemical materials. While chemicals can sit on shelves for years, waste has to be removed in a matter of days.

The high turnover of personnel in college laboratories, a turnover not found in the industrial setting, makes implementing new techniques for waste management difficult.

Finally, the more rigorous regulations will have a great impact on Harvard's budget.

"The increase in environmental regulations have created increased demands on the administration, and on administrative budgets, in particular," says Provost Albert Carnesale.

Although Harvard can expect costs and budgets to be rise, Vautin says the specific budgetary impact of these new standards is still uncertain.

According to Vautin, because each school on Harvard's campus budgets its own waste disposal, aggregating the numbers is often a complicated matter.

In an attempt to lower the costs of complying with the stricter regulations, Harvard has improved cooperation between individual schools, heightened negotiations with waste removal contractors and implemented techniques such as "microscale" chemistry which produce less chemical waste.

Harvard's Record

According to Vautin, Harvard has not faced any significant infractions for at least five years.

The most recent unannounced inspection was of the waste processes and air quality of boiler plants at the Radcliffe campus. The inspection resulted in relatively minor recommendations which centered around improved record-keeping.

Vautin says Harvard's record is strong, especially considering that Massachusetts is generally recognized as having the some of the most stringent environmental regulations in the country.

"It hasn't been us, and we hope it will continue not to be us," says Vice President for Administration Sally H. Zeckhauser. "We've known increased standards were coming for many years, but we haven't been waiting for a disaster to happen."

In the existing system, the U.S. EPA sets the minimum standards, while individual states are free to raise these levels. Typically, Harvard deals with the Massachusetts Department of Environmental Protection rather than its national counterpart.

A Good Match?

Some academic institutions facing the stringent standards say many of the regulations designed for the industrial world do not apply well to universities, according to Vautin.

Officials at Stanford and Yale have questioned the appropriateness of certain regulations.

Currently, 19 universities, frustrated by the way the EPA counts hazardous waste sites, are working with the agency to change the site designation process.

"Many regulations were created around the industrial model of the 1970s and 80s," Vautin says. "In the last several years, there has been a greater level of interest in applying these regulations more broadly to places like research universities."

But applying these rules can be difficult, Vautin says, because of the many differences between manufacturing industries and research institutions, such as the volume of waste, production methods and logistical constraints involved.

Universities produce substantially smaller quantities of waste; and because of the laboratory system, the waste production is far more decentralized than in the industrial world, Vautin says.

"Being regulated like industry is too burdensome. The amount of chemicals we deal with in the lab is different than in industry," says James H. Rowe III '73, vice president for government, community and public affairs. "General understanding in the academic setting is significantly higher. This difference should be taken into account."

Vautin highlights one rule in particular as not applying to academia.

Industrial facilities are required to collect waste in large collection areas, which they do through centrally-located chemical facilities.

Academic institutions must create the equivalent kinds of collection facilities, even though laboratories are located all across university campuses. The resulting need for "satellite storage" facilities in each of the labs, Vautin says, reflects an industry standard which should not apply to a research institution.

"[Massachusetts' regulators] are becoming more results oriented, with a greater emphasis on enforcing regulations, and more people doing inspections," Griffin says. "They have done their job with industry and are now trying the extend their efforts."