The EPA & U
"EPA Cites Central Connecticut State University for Water and Waste Violations" (EPA New England, 2002)
"EPA Proposes $358,000 Penalty Against Fitchburg State College for Waste Violations" (EPA New England, 2003)
"University of Washington to Spend $135,769 for CFCs Violations" US EPA Region 10: The Pacific Northwest (2003)
These headlines are about a college and two universities, but make no mistake, they could be about your camp! Generally, the US Environmental Protection Agency's (EPA) mission is to "protect human health and to safeguard the natural environment -- air, water and land -- upon which life depends" (US EPA1, 2003).
The EPA is the federal agency most concerned with organizational compliance regarding violations of environmental laws and regulations, like the improper handling and storage of hazardous waste that was generated at the university (Central Connecticut State University); the storage of hazardous waste adjacent to active classrooms (Fitchburg State College); and the release of Chlorofluorocarbons (CFCs) from a leak in a refrigeration system (University of Washington).
Though each of these seem more likely to occur in a larger organization, without proper information about and attention to EPA laws and regulations, any organization might be found in serious violation.
The EPA is a federal agency that is invested in environmental science, research, education and assessment efforts. The EPA develops and enforces environmental laws and regulations, offers financial assistance through state environmental programs, performs environmental research, sponsors voluntary partnerships and programs and furthers environmental education.
EPA-regulated entities include industry, academia, government agencies and other organizations. In recent years the EPA has started to take a hard look at academia (as demonstrated in the headlines above).
It is not unrealistic that the EPA will continue to meet its mission through education and regulatory compliance, continuing their efforts with larger and smaller organizations, whether profit or not-for-profit.
So, more to your point as a camp owner or director, how do EPA regulations affect camps? Camps must meet federal regulations regarding the environment designed to make a cleaner environment a reality, and any organization can be held accountable for not meeting EPA regulations.
As the EPA looks toward 2008 its 2003-2008 Draft Strategic Plan makes clear the five goals of the agency:
Goal 1: Clean Air -- Protect and improve the air so it is healthy to breathe and free of levels of pollutants that harm human health or the environment.
Goal 2: Clean and Safe Water -- Ensure drinking water is safe. Restore and maintain oceans, watersheds and their aquatic ecosystems to protect human health, support economic and recreational activities and provide healthy habitat for fish, plants and wildlife.
Goal 3: Preserve and restore the land by reducing and controlling risks posed by releases of harmful substances; promoting waste diversion, recycling and innovative waste management practices; and cleaning up contaminated properties to levels appropriate for their beneficial reuse.
Goal 4: Healthy Communities and Ecosystems -- Protect, sustain or restore the health of people, communities and ecosystems using integrated and comprehensive approaches and partnerships.
Goal 5: Compliance and Environmental Stewardship -- Improve environmental performance through compliance with environmental requirements, preventing pollution and promoting environmental stewardship. Protect human health and the environment by encouraging innovation and providing incentives for governments, businesses and the public that promote environmental stewardship.
Camp owners/managers should have no problem recognizing aspects of the EPA Goals 1-5 that will affect the operational management of their environments.
The management of anything hazardous that might be released into the air, water or on land (fuels, chemicals, wastewater and so on); the handling and maintenance of hazardous waste producing equipment and materials (refrigeration units, maintenance shops, etc.); waste production and the recycling of non-hazardous materials (paper, cardboard, food); and other potential hazards as defined by the EPA.
Further, camp owners/managers will need to pay attention to new laws and regulations that will evolve concurrent with the approval of the EPA's 2003-2008 Draft Strategic Plan. Following is a list of concepts regarding EPA compliance and practical steps camps can take to better manage camp practices.
Concept One: Environmental Policy (organizationally created by the EMS team). With the full commitment of the organization's leadership and in accordance with the organization's mission, the Environmental Policy identifies and defines the purpose of the Environmental Management System (EMS).
Specifically, the Environmental Policy should seek to foster active promotion of environmental values and actions that will sustain a healthy community.
Concept Two: Environmental Management System (EMS). Environmental Management Systems (EMSs) are used to identify and manage the impacts that organizational operations have on their environment.
The systems serve both to mitigate selected impacts that are currently regulated (assuring compliance with environmental laws and regulations), and may also provide the organization an opportunity to reduce impacts that are currently unregulated.
EMSs are a great idea for camps, because a lot of what camping is all about relies on the environment. Camps need to be interested in environmental protection, so an effective EMS will serve the camp in two ways… The camp will benefit directly from the EMS (internal benefit), and the EMS can also serve as a clear demonstration to the public of the camp's commitment to the environment. Further, the EMS can help the camp by identifying the causes of environmental problems and assist with managing and/or eliminating the problems. Another way to look at an EMS is that your camp can save money and reduce negative impacts on the environment.
Steps to Compliance
1. Create an Environmental Management System Team.
Members of your EMS team could/should include the camp owner/manager, camp maintenance manager, food service manager, program manager (you may wish to choose a couple of additional representatives under programming, like the arts and crafts director, environmental or nature director), office manager and waterfront director.
2. Consider the initial EMS planning steps.
• Define the camp's goals and define the project scope or fenceline.
• Secure management commitment. Management should also oversee that the goals for the EMS are consistent with the camp mission.
• Select an EMS champion -- the person in your organization who will drive the process.
• Build an EMS Implementation Team (see comments above regarding the nature and makeup of the EMS Implementation Team).
• Hold a kick-off meeting where the team discusses the organization's objectives and initial steps.
• Conduct a preliminary review of the camp's compliance with EPA laws and regulations and environmental initiatives.
• Develop a project plan and schedule reviewed and approved by the camp owner/manager.
• Secure resources and assistance. There may be support from several outside sources available, such as your local EPA officials.
• Initiate employee involvement. The more employees involved in the process, the more the employees take ownership for the EMS.
• Monitor and communicate progress against the project plan.
3. Follow the "Key Elements of an EMS: A Snapshot".
• Environmental policy -- Develop a statement of your organization's commitment to the environment. Use this policy as a framework for planning and action
• Environmental aspects -- Identify environmental attributes of your products, activities and services. Determine those that could have significant impacts on the environment.
• Legal and other requirements -- Identify and ensure access to relevant laws and regulations, as well as other requirements to which your organization adheres (see EPA Laws and Regulations, available on-line at www.epa.gov/epahome/lawregs.htm).
• Objectives and targets –- Establish environmental goals for your organization in line with your policy, environmental impacts (see the list below), the views of interested parties and other factors.
• Environmental management program –- Plan actions necessary to achieve your objectives and targets.
• Structure and responsibility –- Establish roles and responsibilities for environmental management and provide appropriate resources.
• Training, awareness and competence -– Ensure that your employees are trained and capable of carrying out their environmental responsibilities.
• Communication –- Establish processes for internal and external communications on environmental management issues.
• EMS documentation -– Maintain information on your EMS and related documents.
• Document control -– Ensure effective management of procedures and other system documents.
• Operational control -– Identify, plan and manage your operations and activities in line with your policy, objectives and targets.
• Emergency preparedness and response -– Identify potential emergencies and develop procedures for preventing and responding to them.
• Monitoring and measurement -– Monitor key activities and track performance. Conduct periodic assessments of compliance with legal requirements.
• Nonconformance and corrective and preventive action -– Identify and correct problems and prevent their recurrence.
• Records -– Maintain and manage records of EMS performance.
• EMS audit –- Periodically verify that your EMS is operating as intended.
• Management review -– Periodically review your EMS with an eye to continual improvement.
4. Complete an Environmental Assessment: Sample Aspects and Impacts.
• Which activities and services interface with the environment in a way that could result (or has resulted) in environmental impacts?
• What materials, energy sources and other resources are used in regular operations?
• What are the primary sources of emissions to the air, water or land?
• What are the primary types of waste produced?
• What are the primary sources associated with each waste?
• Does the treatment or disposal of these wastes have potential environmental impacts?
• How does our land or infrastructure (such as buildings and campus grounds) interact with the environment?
• Which activities (for example, chemical or fuel storage) might lead to accidental releases?
• Are the impacts actual or potential?
• Are the impacts beneficial or damaging to the environment?
• What is the magnitude or degree of these impacts?
• What is the frequency or likelihood of these impacts?
• What is the duration and geographic area of these impacts?
• Which parts of the environment might be affected (air, water, land, flora or fauna)?
• Is the impact regulated in some manner?
• Has anyone inside or outside the camp expressed concerns about these impacts?
Finally, it's important to work with local EPA officials to maintain a superior and ongoing relationship. The EPA is in the business of assisting organizations that are willing to meet EPA laws and regulations.
Dr. Richard J. LaRue is Chair of Exercise and Sport Performance, University of New England.
CEC (2000). Improving Environmental Performance and Compliance Ten Elements of Effective Environmental Management Systems. Montreal, Canada: Commission for Environmental Cooperation. Available on-line at www.epa.gov/compliance/resources/policies/incentives/ems/cecguidedoc.pdf
EPA New England (2002). EPA Cites Central Connecticut State University for Water and Waste Violations. Available on-line at www.epa.gov/ne/pr/2002/oct/021012.html
EPA New England (2003). EPA Proposes $358,000 Penalty Against Fitchburg State College for Waste Violations. Available on-line at www.epa.gov/ne/pr/2003/feb/030213.html
P. J. Stapleton and M. A. Glover (2001). Environmental management systems: An implementation guide for small and medium-sized organizations [second edition]. Ann Arbor, MI: NSF International. Available on-line at www.epa.gov/owm/iso14001/ems2001final.pdf
UNE (2002). University of New England College of Arts and Sciences Environmental Policy. Biddeford, ME: UNE.
US EPA1 (2003). Our mission, Who we are, What we do, How we are organized, Our budget and performance, Contracting opportunities, and Our history. Available on-line at www.epa.gov/epahome/aboutepa.htm#mission
US EPA2 (2003). Draft Strategic Plan 2003-2008. Available on-line at www.epa.gov/ocfopage/plan/2003sp.pdf
US EPA Region 10: The Pacific Northwest (2003). University of Washington to Spend $135,769 for CFCs Violations. Available online at http://yosemite.epa.gov/r10/homepage.nsf/bcd405ea472282c08825674a0067c667/57db0f65bae4db0788256cd400817867?OpenDocument
US EPA Laws and Regulations. Available on-line at www.epa.gov/epahome/lawregs.htm