EHS Management

EMS for Higher Ed—Common Compliance Deficiencies


EMS for Higher Ed—Common Compliance Deficiencies

The Resource Conservation and Recovery Act (RCRA) was passed in 1976 with the goal of regulating the handling and disposal of hazardous wastes. RCRA was strengthened and amended in 1984 and has become the backbone of the national strategy to safely manage hazardous and non-non-hazardous wastes, conserve resources, and clean up spills and releases. The EPA also added the Academic Lab Rule (Subpart K ) to RCRA regulations, which is an alternative that allows eligible academic entities the flexibility to make hazardous waste determinations in the laboratory, at an on-site central accumulation area, or at an on-site treatment, storage, or disposal facility (TSDF). Some of the  most common RCRA violations at colleges and universities include failure to:

  • Appropriately label and mark satellite accumulation containers,
  • Mark and date the accumulation period for each accumulation container,
  • Separate or protect containers of hazardous waste from containers storing incompatible materials or wastes,
  • Close containers that are accumulating hazardous waste (except when adding or removing waste),
  • Inspect hazardous waste containers, specifically on a weekly basis,
  • Maintain adequate aisle space to allow unobstructed movement of personnel or emergency equipment in the container storage areas,
  • Provide secondary containment around hazardous waste container storage areas with a functional floor drain,
  • Make hazardous waste determinations,
  • Provide and document initial hazardous waste training,
  • Obtain a permit when storing hazardous wastes for longer than 90 days,
  • Have an adequate Contingency Plan for new operations,
  • Maintain and operate the facility in a manner to minimize the possibility of any planned or unplanned release of hazardous constituents to air, soil, or surface water which could threaten human health or the environment.

Join us for our ISO 14001 webinar December 2 for cost-effective strategies for updating existing EMS or preparing an EMS that is certifiable to ISO 14001 in 2015. Learn more.


The Resource Conservation and Recovery Act (RCRA) was passed in 1976 with the goal of regulating the handling and disposal of hazardous wastes. RCRA was strengthened and amended in 1984 and has become the backbone of the national strategy to safely manage hazardous and non-non-hazardous wastes, conserve resources, and clean up spills and releases. The EPA also added the Academic Lab Rule (Subpart K ) to RCRA regulations, which is an alternative that allows eligible academic entities the flexibility to make hazardous waste determinations in the laboratory, at an on-site central accumulation area, or at an on-site treatment, storage, or disposal facility (TSDF). Some of the  most common RCRA violations at colleges and universities include failure to:

  • Appropriately label and mark satellite accumulation containers,
  • Mark and date the accumulation period for each accumulation container,
  • Separate or protect containers of hazardous waste from containers storing incompatible materials or wastes,
  • Close containers that are accumulating hazardous waste (except when adding or removing waste),
  • Inspect hazardous waste containers, specifically on a weekly basis,
  • Maintain adequate aisle space to allow unobstructed movement of personnel or emergency equipment in the container storage areas,
  • Provide secondary containment around hazardous waste container storage areas with a functional floor drain,
  • Make hazardous waste determinations,
  • Provide and document initial hazardous waste training,
  • Obtain a permit when storing hazardous wastes for longer than 90 days,
  • Have an adequate Contingency Plan for new operations,
  • Maintain and operate the facility in a manner to minimize the possibility of any planned or unplanned release of hazardous constituents to air, soil, or surface water which could threaten human health or the environment.

ISO 14001: Cost-Effective Strategies for Addressing Proposed Revisions for 2015

Join us December 2 to learn why the ISO 14001 standard is being revised and what is driving the revision. Register now.


The Clean Air Act (CAA) was passed in 1970 and major revisions were made in 1977 and 1990 and protects public health from a range of air pollutants from many different sources. Some common CAA violations include failure to:

  • Submit appropriate reports,
  • Monitor fuel for nitrogen and sulfur content,
  • Obtain minor permits,
  • Install or maintain opacity monitors in good working order,
  • Comply with annual or 12-month rolling cap for fuel or steam production,
  • Provide/document actual annual VOC emission calculations for solvent degreasers (including records of solvent additions and deletions from degreasers).
  • Keep monthly throughput records, install/testing vapor recovery system, and keep records of maintenance and malfunctions of vapor recovery systems at on-site gasoline pumps, and
  • Obtain permits and keep records of operating hours for emergency generators.

Underground storage tanks (USTs) are regulated by the Office of Underground Storage Tanks which was created in 1985 to work with states, territories and tribes to prevent and remediate releases from USTs. Common UST violations include:

  • Gasoline tank leak detection systems not working properly,
  • No leak detection systems on tanks,
  • Incomplete tank removal – proper backfilling of hole; contaminated soil on site.

The EPA also notes that a number of issues of noncompliance under more than one regulation include the failure to address potential for spills either because of a lack of planning, insufficient plans, or monitoring for spills.