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In an unprecedented gesture, the EPA sent a letter to MIT President Charles M. Vest thanking him for MIT's swift and responsible action:
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
1 CONGRESS STREET, SUITE 1100
BOSTON, MASSACHUSETTS 02114-2023
Dr. Charles M. Vest
Massachusetts Institute of Technology
77 Massachusetts Ave.
Cambridge, MA 02139
Dear Dr. Vest:
As you know, the Massachusetts Institute of Technology (MIT) and the United States have just settled an enforcement action to resolve alleged violations of environmental law at MIT's campus. I want to take this opportunity to thank MIT for reacting so responsibly to the enforcement action.
At an April 1999 meeting between EPA and MIT staff, my staff pointed out that MIT's violations appeared to stem from lack of resources dedicated to environmental compliance, the decentralized nature of the organization, lack of accountability for compliance, and insufficient environmental training. While EPA inspectors did not find any release or actual damage to the environment at MIT, some of the violations (e.g., failure to keep containers of hazardous waste closed, storing incompatible wastes together, failure to keep an incinerator's opacity monitor in working order, and training violations) could have been dangerous.
Your staff listened closely at the meeting, and within a short period of time MIT has made great strides to overcome its institutional challenges to compliance. The challenges are many; MIT has thousands of laboratories that produce hazardous waste and thousands of researchers, staff, and students that require training. Also, the decentralized structure of the university has made efforts to maintain institutional control over environmental compliance more difficult, Your staff demonstrated to EPA that, in response to EPA's inspection, MIT took the following actions before settling this enforcement action:
- The reorganization in early 2000 of the central environmental, health and safety service offices at MIT with the goal of making them more responsive and accountable;
- The hiring in July 1999 of a Managing Director for Environmental Programs and Risk Management/Senior Counsel to establish senior management accountability for legal compliance as well as coordination of academic and operating activities to make MIT's campus more environmentally sustainable;
- The development and production in 2000 of a new web-based training module to further compliance with hazardous waste laws;
- The commencement in 2000 of a cross-training program to improve the knowledge base and performance of the staff of the central environmental, health and safety offices so that they can provide better service to the MIT community and support improved compliance performance in departments, laboratories, and research centers; and
- Addressing in 1998, 1999, and 2000, most of the alleged violations in the Complaint.
Your staff reports that EPA's enforcement case prompted MIT to look closely at its operations and make improvements. Rather than responding only by addressing compliance, MIT also took the actions listed below, all of which go beyond MIT's compliance obligations. MIT's decision to go beyond its compliance obligations by taking on far-reaching "green" initiatives is laudable.
- Your initiative in January 2000 to make MIT's campus more environmentally sustainable (the "Presidential Initiative");
- As part of the Presidential Initiative, the expansion of MIT's limited campus recycling program to include recycling of all types of paper, cardboard, magazines, newspapers, glass, aluminum, plastics, yard waste, food waste, computer equipment, metal and wood, increasing total recycling rates from 10.5% of total waste in January 2000 to 20.3% of total waste in December of 2000;
- As part of the Presidential Initiative, commencing a "green goods" purchasing program that in one year increased the use of recycled paper from less than 5% of total use on campus to 64% overall, 90-100% in the campus copy centers;
- As part of the Presidential Initiative, the commencement of a "green" building guidelines task force to develop and implement performance guidelines for the design and construction of more environmentally sustainable buildings on campus. The draft long-term objectives include energy conservation, greenhouse gas reduction, improved indoor air quality, increased recycling and conservation of materials, reduced total campus emissions, and supporting community-wide and regional sustainability efforts;
- The support of EPA's Clean Charles 2005 Initiative by, among other actions, purchasing and devoting a boat to the Initiative, providing the services of a graduate student for the Initiative, and being a sponsor and member of the Clean Charles 2005 Coalition.
Although my staff has not independently verified all of the results in the above actions, we did receive MIT's Environmental Programs Task Force 2000 Annual Report, which discusses the accomplishments of the initiatives, in detail.
One of the most exciting aspects of the settlement is MIT's commitment to make extensive environmental management system (EMS) improvements. Your staff has shared with us MIT's written concept for an EMS that will integrate compliance, education, regulatory training, research, and "green" environmental practices (such as the ones mentioned above, among others). This EMS concept uses automation technology to maintain the independence of research while creating better institutional oversight and accountability. Many aspects of MIT's EMS concept will go beyond the EMS requirements in the Consent Decree. EPA hopes that MIT's EMS will serve as a model for large academic research institutions, and is pleased to learn that EMS design and implementation will be overseen by people at high levels of MIT, namely a subcommittee co-chaired by the Vice President and Dean of Research and the Managing Director for Environmental Programs and comprised of senior faculty, researchers and administrators.
All of the above actions show that MIT responded to the enforcement action in a manner that put the health and safety of the community first. We are pleased that MIT recognizes and has funded programs to support the unique role that universities should play in the stewardship of the environment. We hope that MIT continues to fully fund and maintain these activities. Please let us know if we can support your efforts in any way. If you have any questions about this letter, please call me at (617) 918-1731.
Acting Director, Office of Environmental Stewardship
cc: Catherine S. Smith, EPA and Jamie Lewis Keith, MIT