Download SEP Summary

UPR Mayaguez Environmental Management System Summary
Introduction
In March and April 2005, EPA audited UPRM and found many violations related to RCRA (Resource
Conservation and Recovery Act). The initial fines proposed were over $900,000. After an administrative
process, fines were lowered to $450,000. Close to $400,000 of this fine was allowed to be paid thru the
development of a Supplemental Environmental Project related to the findings of an EPA Audit.
The proposed SEP is an Environmental Management System that will be focused on managing the
environmental impact of the use of materials required to fulfill the academic mission of UPRM. This is an
environmentally beneficial project which the UPRM agrees to undertake but that is not otherwise legally
required to perform under any federal, state or local law or regulation. For this purpose, an Office of
Environmental Management has been created at UPRM with Eng. María Isabel Fernández as director.
UPRM Environmental Management System
Issue Statement
UPR Mayaguez educational and research activities require the use of chemical substances and materials in
laboratories which that currently present an opportunity for Pollution Prevention opportunities and initiatives.
Project Objective Statement
The main objective is to develop and implement a system for managing all the aspects of the lifecycle of
chemical substances and materials used at UPR Mayaguez in an environmentally safe way, and promoting
source reduction and pollution prevention awareness. The system is a set of policies, plans, review
mechanisms, and procedures for purchasing, storing, using and disposing materials in way that improves
and guarantees the safety of the users, of the community and of the environment. The EMS program goals
and objectives are the following:
i. Develop a baseline of specific materials currently being used in the UPRM laboratories and
generating/handling waste areas.
ii. Develop a tracking system for such materials from purchasing to final disposal.
iii. Evaluate and quantify the efficiency of the system
iv. Evaluate use, reuse and recycling opportunities
v. Evaluate Pollution Prevention, Pollution Reduction and impact minimization opportunities
vi. Quantify waste disposal impacts
vii. Analyze and implement hazardous chemicals storage and disposal reduction opportunities
viii. Implement a self improvement management system for EMS revisions.
Project Description
The main goal of the UPR Mayaguez Environmental Management System is to reduce the impact of the
chemical substances and materials used at UPRM to fulfill its academic mission, and to promote source
reduction, pollution prevention and compliance promotion awareness, and activities. The main focus of the
UPRM EMS will be hazardous chemicals and wastes although universal wastes and electronic equipment will
also be managed. The UPRM EMS Project and its components have the following goals:
UPRM EMS Summary by Ivan Baiges
Page 1
8/13/2017
EMS
Component
description
goals
1.
Identify chemical substances and
materials used at the UPRM
campus.
Identify and implement alternate
use opportunities for hazardous
chemicals before they enter the
waste disposal scenario.
Identify where at UPRM are these
materials used and wastes
generated
Material /
Waste Life
Cycle
Management
System
The main objective of this
component is to quantify,
monitor and control usage of
hazardous chemicals on campus
in order to identify and
implement pollution prevention
and reduction activities as well
as source reduction
opportunities.
Material
Impact
Management
System
The main objective of this
component is to develop and
implement a system for
evaluating the impact of the
UPRM operations in the handling
of hazardous chemicals. This
information will assist the UPRM
in the formulation of pollution
prevention and source reduction
strategies and activities to
reduce the impact of material
usage at UPRM. Such activities
may include replacement of
hazardous chemicals with more
environmentally friendly
materials.
1. Quantify chemical substances and
materials used and its impact in the
UPRM waste disposal management
system; and wastes generated at
UPRM.
2. Evaluate and implement source
reduction and pollution prevention
strategies using the data base
developed in this project,
identifying the impacts of these
materials and wastes?
3. Quantify the impact of pollution
prevention and pollution reduction
strategies.
Laboratory
Material
Management
Program
This component is the
environmental compliance
promotion element of the EMS.
The main objective of this
component is to provide training
to the UPR Mayaguez
Community members that are
not required by law or regulation
to have such trainings, on the
proper handling of chemical
substances in classroom
laboratories and to clearly
identify wastes and raw
materials management
practices. Off campus entities
will be identified and invited to
1. Provide training on good
management practices to UPRM
community members directly
involved in the use and/or
management of hazardous
chemicals in laboratories. Identify
and invite Off Campus entities to
participate in the training program.
2. Promote pollution prevention and
source reduction awareness in the
UPRM community members Make
these training resources available to
the UPRM Community through the
UPRM Website. The UPRM Website
is an open site, which makes these
UPRM EMS Summary by Ivan Baiges
2.
3.
Page 2
8/13/2017
participate in the training
sessions.
training resources will available to
anyone. People such as students,
educators, members of the
regulated community, and other
educational institutions can access
and use this material for free.
UPRM EMS Benefits
The Material / Waste Life Cycle Management System will allow UPR Mayaguez to
a. Monitor and control hazardous material usage on campus
b. Reduce the environmental impacts by improper usage and disposal of hazardous materials.
c. Allow UPR Mayaguez to understand its waste stream and assess the impact of waste minimization
initiatives such as Green Chemistry and source reduction.
d. Create a purchasing system designed to favor environmentally friendly purchases
The Material Impact Management System will allow UPR Mayaguez to
a. Make a self assessment of the benefits or outcomes of all its operations.
b. Evaluate and rank materials according to their impact
c. Plan pollution prevention and pollution reduction strategies
d. Develop strategies for using materials in a way that have less impact on the environment when
compared to present practices, while still achieving the desired outcomes.
The Laboratory Material Management Program will provide UPRM with a systematic way of doing things, a
set of established best practices that all the laboratory users and supervisors will use in a standard way. All
laboratory users will know the way to operate the facilities in way that guarantees their safety, the safety of
the academic community and the environment. The establishment of standard operating procedures has
some benefits
a. Minimizes the possibility of inadequate management of materials and wastes.
b. Simplifies the training of personnel
c. Simplifies the work area supervision
UPRM EMS METRICS
Based on the fact that the EMS Team must create new processes and procedures which require considerable
development efforts, coordination efforts and a great cultural change – we propose a 36 month time frame for
the completion of the SEP. The proposed program goals are the following:
metrics
Year 1
Year 2
Year 3
1. Material Purchase Controlled - One of the goals of this EMS is to
control the purchase of materials at UPR Mayaguez. The metric is
the % of material purchases that is controlled by the system and it
will be measured as the total of purchases made at UPRM.
10%
15%
20%
2. Waste Tracking - One of the goals of this project is to monitor
waste generation. The use of waste tracking and material tracking
should allow us to compare what is bought and what is disposed.
20%
50%
75%
UPRM EMS Summary by Ivan Baiges
Page 3
8/13/2017
The metric is the % of waste that is accounted for based on user
and activity and it will be measured as the total of waste
generated at UPRM
3. Waste Reduction per capita – One of the goals of the EMS is to
reduce the waste generated on campus by keeping a better
inventory. The metric is the % of waste that is reduced on a per
capita basis. The % of reduction is based on year 0 baseline
5%
10%
15%
4. Surplus Material Usage - One of the goals of the EMS is to reduce
the unnecessary purchase and disposal of materials. The metric
for this goal is the % of available surplus material on the virtual
flea market that was purchased
10%
15%
20%
5. Material Consumption Reduction per capita – One of the goals of
the EMS is to reduce the unnecessary purchase and of materials.
This metric evaluates the material usage reduction on a per capita
basis. The % of reduction is based on year 0 baseline
5%
15%
20%
6. Material Impact System One of the goals of the EMS is to evaluate
the impact of the materials used at UPRM, which will be done by the
Material Impact System. The metric for this goal is based on the %
development of the impact system
15%
30%
45%
7. Material Impact Strategies Planning - One of the goals of the EMS is
to evaluate the impact if the materials used at UPRM. The metric will
evaluate the amount of impact management strategies, such as that
have been planned and are ready to be deployed.
2
2
3
8. UPR Mayaguez Laboratory Policy and Rules One of the goals of
the EMS is setup a system that assures that the UPRM Community
knows how to manage its materials and wastes. The metric is
having completed the creation and approval of the UPRM Work
Area / Laboratory Policy and Rules. The metric is the % of the work
areas covered by a policy and set of rules that have been approved
and adopted by the UPRM Community.
15%
50%
95%
9. UPR Mayaguez Laboratory Procedures - . One of the goals of the
EMS is setup a system that assures that the UPRM Community
knows how to manage its materials and wastes. The metric for
this goal is the % of the laboratories that have developed,
approved and implemented their Laboratory Procedures
15%
50%
95%
10. UPR Mayaguez Community Trained – One of the goals of the EMS
is setup a system that assures that the UPRM Community knows
how to manage its materials and wastes. One of the metrics is the
UPRM EMS Summary by Ivan Baiges
Page 4
8/13/2017
% of the UPRM Community that has been trained and certified.
a. % of Graduate Students Trained and Certified
20%
35%
50%
20%
30%
50%
25%
45%
65%
5%
15%
20%
b. % of Non Teaching Employees Trained and Certified
c. % of Undergraduate Students Trained and Certified.
11. UPR Mayaguez Laboratory Reduction of Incidents - One of the goals
of the EMS is setup a system that assures that the UPRM Community
knows how to manage its materials and wastes. The metric for this
goal is the % of the reduction of management incidents that happen
at UPRM in the work areas and laboratories. The baseline for this
metric are the number of incidents at year 0
Project Reporting
The proposed reporting frequency will be every three months (quarterly). The reports will include the completed
deliverables (see deliverable table) along with a expense report detailing the hours worked and the money spent by
worked and the money spent by UPRM.
YEAR 1







Develop detailed Workplan
Form and Train UPR Mayaguez EMS Team
Environmental Performance Data Collection and Gap Analysis
Establish Laboratory Procedure System Requirements and start Development
Establish Material Impact Evaluation System Requirements and start Development
Establish Material / Waste Life Cycle Management System Requirements
Software development
YEAR 2





Development of training manuals and procedures
Start creating Web based training manuals and procedures
Develop Virtual Flea Market
Test Material / Waste Life Cycle Management System
Develop Material Impact Management System and start system evaluation
YEAR 3







Deploy and test Web based training manuals and procedures
Test, refine and deploy Virtual Flea Market
Test, refine and deploy Material / Waste Life Cycle Management System
Test, refine and deploy Material Impact Management System
Conduct Internal EMS Audit
Implement Corrective Actions
Complete Management Review of UPRM EMS
AUDIT TEAM
UPRM EMS Summary by Ivan Baiges
Page 5
8/13/2017
The EMS will organize and establish an audit team composed from personnel from other UPR campuses that
have the necessary expertise to evaluate and provide recommendations on the EMS performance. Additional
personnel from the private sector or professional organizations may also be invited to form part of the audit
team. The audits will be performed on a yearly basis.
UPRM EMS FAQ’s
 Is the UPRM EMS Office part of the UPRM Environmental, Health and Safety Office? UPRM EHS Office
deals with regulatory practices, makes sure that the laws and regulations related to environment, health
and safety are followed. An EMS works to manage the environmental impacts of the organization, these
can be regulated issues such as hazardous materials and wastes, or it can work with unregulated aspects
such as solid waste and recycling. In the case of UPRM, the scope for the 1st three years will be hazardous
materials and wastes since that was what was agreed with EPA as part of the negotiation.
 Will the UPRM EMS Office do part of my work? Yes and no. The UPRM EMS will create and implement
programs that will make our lives easier in terms of managing our environmental issues. One example is
the implementation of the Material and Waste Management Software that will help us keep a record of
what we buy, what we discard and what we have as surplus. It is expected that each individual that
manages hazardous materials and wastes do so in a responsible and safe manner in order to assure
his/her personal safety, the safety of coworkers, members of the community and of the environment.
Material/waste management is considered one of the tasks related to research and teaching activities and
should be managed as an intergral part of experimental work. UPRM will not do this work for the
individuals.
UPRM EMS Summary by Ivan Baiges
Page 6
8/13/2017