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In an unprecedented gesture, the Environmental Protection Agency (EPA) thanked MIT President Charles M. Vest in writing for having MIT acting swiftly and decisively following a campus inspection in 1998.
"I want to take this opportunity to thank MIT for reacting so responsibly to the enforcement action," the acting director of the EPA Office of Environmental Stewardship, Sam Silverman, said in the letter to President Vest. He went on to say, "MIT's decision to go beyond its compliance obligations by taking on far-reaching green initiatives is laudable."
The letter said:
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 who 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:
- ï¿½ï¿½ï¿½ï¿½ï¿½ï¿½The 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's decision to go beyond its compliance obligations by taking on far-reaching 'green' initiatives is laudable.
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.
A version of this article appeared in MIT Tech Talk on April 25, 2001.