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Environmental Issues

Jan. 3, 2013

In 2010, Baylor undertook a self audit of environmental issues on campus in accordance with the U.S. Environmental Protection Agency (EPA) Incentives for Self-Policing: Discovery, Disclosure, Correction, and Prevention of Violations, which is referred to as the EPA's Audit Policy. The purpose of the Audit Policy is to encourage regulated entities, such as colleges and universities, to voluntarily discover and then promptly disclose and correct violations of federal environmental requirements with the incentive of reducing or eliminating penalties for violations. As a result of the self audit, Baylor found and disclosed instances of potential EPA violations, which have now been corrected, and the EPA waived all potential penalties. For all areas in the University, and particularly in those areas where correction was needed, Baylor must be diligent to discover and avoid further problems.

Several state and federal environmental statutes apply to Baylor, including the: Clean Air Act; Clean Water Act; Resource Conservation and Recovery Act; Safe Drinking Water Act; Toxic Substances Control Act; Emergency Planning and Community Right-to-Know Act; and Federal Insecticide, Fungicide and Rodenticide Act. Among the areas where environmental problems were found during the self audit were: pouring waste into laboratory sinks that drain into the city sewage system; pouring chemicals into other sinks that drain into the city sewage system; improper storage and abandonment of chemicals and paint; insufficient labeling of containers with hazardous materials; washing material and equipment outside of buildings so that the runoff went from driveways and parking lots into storm drains; pouring mop water into storm drains; incidental release of kitchen wastes into storm drains; disposal of aerosol spray cans and light bulbs in the general use trash cans; improper storage of used bulbs and batteries; and insufficient documentation of matters covered by the environmental statutes.

As mentioned above, these matters were promptly addressed after the self audit, but all departments need to work together to avoid future violations. A university that failed to make corrections after a self audit was hit with a fine and reprimand by the EPA, which stated: "EPA's self-audit policy is intended to help institutions recognize violations of federal environmental laws and take action to correct them," said EPA Regional Administrator Judith Enck. "We expect institutions that conduct their own audits to maintain compliance with the regulations. [College's] failure to do so is not consistent with this policy." The self audit policy allows colleges and universities to avoid fines once but certainly not the second time that violations are found.

Environmental awareness is not solely a matter of legal significance to avoid fines and penalties, but is also in accordance with Pro Futuris Aspirational Statement V. Judicious Stewardship. If any faculty member, staff member, or student observes actions that might cause an environmental issue, and does not get a satisfactory explanation upon inquiry, then contact should be made to the Office of Risk Management or this office. If the person observing the potentially problematic issue wishes to make an anonymous and confidential report, it can be done through the Ethics Point website or by calling Ethics Point toll free at 866-384-4277.