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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