HRP Associates, Inc - College Peer Audit Program

HRP Associates, Inc. College Peer Audit Program

Approximately five years ago, EPA began an enforcement initiative against colleges and universities beginning in New England (EPA Region 1). Fines for multimedia inspections were in the middle six figures ($500,000-$600,000). The initiative moved south to New York and New Jersey (EPA Region 2), which caused the Association of Independent Colleges and Universities of Pennsylvania (AICUP) to seek a way to avoid fines for its colleges. The solution was a “peer environmental audit” program, approved by EPA, that allowed each college to self-audit using personnel from peer audit institutions trained on environmental regulations and armed with auditing software. This program succeeded in Pennsylvania (EPA Region 3) and New Jersey (AICUNJ) and is now being implemented in the southeast (EPA Region 4) at 109 colleges and universities in the states of Alabama, Florida, Georgia, North Carolina, and Tennessee. Having spoken to EPA officials in Region 5 (Midwest) and Region 7 (Plains), it is reasonable to assume that EPA college and university initiatives are soon to start in those regions. Consequently, 34 colleges and universities in Indiana and Michigan have also entered into similar self audit agreements with EPA.

Utilizing the EPA Compliance Incentive Initiative, HRP Associates, Inc., with legal partner Halloran & Sage LLP, negotiates an Audit Agreement with private colleges and universities, as well as public universities via the Associations and Federations of the Independent College and Universities within a respective state. The Audit Agreement is an effective mechanism for resolving a broad range and number of institution-wide violations discovered during environmental audits pursued under EPA’s Audit Policy.

Specifically our team provides:

An “Amnesty Agreement” with EPA
A three-day Peer Auditor Environmental Training Program
Project management
Supervision of audit, disclosure of violations, and completion of a final compliance report for EPA
Receipt of EPA Notice of Decision (NOD) waiving all gravity-based penalties

Accomplishments of the program to date:

Average penalties waived per college $537,000
As a result for every $1 spent, $7-$10 dollars saved in fines and penalties
Increased number of environmentally trained and aware faculty, administration and facilities personnel
New culture of environmental compliance on-campus created
Setting foundation for continuous improvement through Environmental Management Systems (EMS)
Favorable publicity arising from EPA signing ceremony with Regional Director, State officials and participating colleges

The peer-audit and the Audit Agreement approach blends the best elements of a self-audit and a third-party independent audit by enabling trained peers from participating schools to audit each other’s campus under the direction of an experienced professional auditor. Each peer auditor brings inherent knowledge and experience of the campus environment, yet, with the compliance training that the program provides, the auditors also provide third-party objectivity. Of equal importance, each peer auditor learns from their experience conducting audits on other campuses and brings that knowledge and expertise back to their own campus. Furthermore, the relationships built during this audit

program have opened up dialogue between the participating schools regarding environmental initiatives and compliance strategies. The peer-audit program fosters an atmosphere of change and cultural sustainability previously unseen on college campuses in such large scale.

Environmental Initiatives Developed on Campus

As a result of participating in the peer audit program, the colleges and universities have developed and implemented several improvements to their campuses, which have exceeded the context of environmental compliance including:

Modifications of labs and lectures to include environmental compliance discussions;
Implementation of solid waste recycling programs at educational facilities and residential halls, and even through community programs;
The use of water conservation through installation of waterless urinals;
The use of campus “zip cars” to eliminate automobiles on campus;
The benefit of paid public transportation for students, faculty and staff to eliminate the number of automobiles on campus;
Integrating the campus Facilities Department with the Physics faculty to create an Energy Conservation study on campus with students;
The investigation of using solar power to provide hot water to residential life;
Organization of campus sustainability committees;
Placement of dedicated staff to serve as campus Environmental Health & Safety Coordinators;
Development and implementation of campus-wide Chemical Hygiene Plans;
Development and implementation of campus-wide Waste Management Plans;
Development and implementation of Environmental Management Systems;
Preparation of environmental videos for new student orientation;
OSHA awareness for regulatory compliance;
Investigation of alternative fuel usage (bio-diesel);
Middle school and high school outreach for environmental compliance assistance;
Elimination of the use of cafeteria trays to reduce the amount of food waste and amount of wastewater generated during cleaning;
Chemical "swap shops" on campus (between departments) to try to eliminate obsolete/legacy chemicals and to prevent excess chemical ordering;
Network/informational pages set up on school intranets for tracking EH&S information, thus providing a network for everyone involved on campus;
Elimination of aerosol can use on campus;
Elimination of mercury (thermometers/barometers/thermostats) campus-wide.


Daily lectures	Typical violation in Art Department: disposal of oil based paint & solvent cleaners to sink	Software exercise: field instruction with tablet

References

Participating States & Colleges/Universities

Testimonials