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A state college and a community college were recently cited for violating the enforcement efforts that EPA has directed to colleges and universities. In January, Raritan Community College was charged with violating hazardous waste rules and assessed a penalty of $40,000. Last month, Fitchburg State College was cited for the improper handling, labeling, and storage of hazardous wastes, receiving a proposed penalty of over $350,000.

The wastes involved were generated in laboratories, art classes, and print shops. In addition to chemicals, solvents, and waste paint, the EPA complaint included improper handling of used computer monitors and spent fluorescent light bulbs. In one case, EPA noted that memos proved administrators had been made aware of the conditions by employees prior to the EPA inspection.

Among the other problems cited by the EPA were

  • failure to determine whether solid waste generated by the institution was hazardous;
  • failure to provide required training for employees;
  • allowing conditions that might lead to a fire, explosion, or release of hazardous waste;
  • storage of incompatible corrosive and organic wastes next to each other;
  • storage of unlabeled or unknown wastes; and
  • degraded storage containers for hazardous waste.

EPA regional offices in the northeast have been actively pursuing enforcement actions against colleges and universities for several years. EPA Regions I, II, and III have been pushing institutions to enter into self-audit agreements to disclose and correct violations before EPA makes an inspection. Institutions that have not entered into agreements are more likely to be targeted for enforcement actions.

The NACUBO contact on environmental health and safety issues is Michele Madia, policy analyst, (202) 861-2554,

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