Multimedia Environmental Compliance Services For Colleges and Universities

College and University facility administrators and environmental managers are continuously looking for ways to lower their risk of noncompliance and be protected from governmental regulatory compliance inspections that can result in monetary penalties. As part of this compliance effort, facilities often establish environmental policies and programs that seek to improve environmental compliance and reduce risk. To ensure that these policies are kept up to date with current regulations and are being properly implemented by staff, facilities often adopt a more formal environmental audit program conducted by a third party, such as D&B Engineers and Architects (D&B).

For more than 20 years, D&B has been offering comprehensive multimedia environmental compliance and permitting services to small, mid-size, and large colleges and universities. D&B has developed a rigorous technical approach to support multimedia compliance audits for the aerospace industry, industrial plants, the major transportation sector, general manufacturing, and hospital/healthcare networks. With that expertise and extensive experience, the firm has developed best practices which are implemented within comprehensive multimedia compliance services to colleges and universities.

Due to the broad and complex nature of multimedia environmental compliance, our team draws upon the expertise of several engineering and environmental disciplines. Each member of the team has extensive public health and compliance experience, in combination with engineering, scientific and project management qualifications in specific environmental media. In addition, certain managers and senior staff members within D&B have prior regulatory agency experience in areas such as hazardous waste, solid waste, wastewater, and water supply, as well as expertise and hands-on experience in conducting compliance inspections and in understanding permit and other regulatory requirements.

Typically, D&B’s multimedia experts, together with college and university facility staff, complete a systematic review of standard operating practices and policies, permit conditions, applicable regulations, and operating records for individual facilities as well as entire campus systems. D&B conducts a thorough facility inspection and reviews all waste generation and handling processes and operations, petroleum tanks, chemical storage areas, air handling and treatment systems, boiler and mechanical rooms, and clinical and research laboratories. The audit team then completes a systematic determination of the status of compliance of the facility with federal, state and local regulatory requirements, as appropriate. D&B’s audits consistently meet or exceed the detailed inspections conducted by governmental enforcement inspectors. When needed, recommendations for corrective action, ranging from procedural or programmatic changes to the design and implementation of fully compliant waste storage areas or above/underground storage tank systems may be presented, along with engineering cost estimates. In addition, a check of facility environmental safety factors, including indoor air quality, may be conducted to complete a comprehensive review of the facility.

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Key Regulatory Updates Impacting Colleges and Universities

A large percentage of the hazardous waste generated by colleges and universities is a result of academic and research laboratories. In response, the EPA provides a flexible framework under the Resource Conservation and Recovery Act (RCRA), including the optional Subpart K standards specifically for academic laboratories. However, recent and upcoming regulatory changes are introducing new, mandatory obligations that affect hazardous waste management across all higher education institutions.

• e-Manifest Third Final Rule: Effective January 22, 2025, this rule mandates that all Large Quantity Generators (LQGs) and Small Quantity Generators (SQGs) register and maintain an account in the RCRAInfo database to use the electronic hazardous waste manifest system.
  • Impact: Colleges classified as LQGs or SQGs must transition from paper-based manifests to the e-Manifest system for tracking hazardous waste shipments.
  • Implication for institutions: This update requires facility-wide registration and updated procedures to retrieve final signed manifest copies electronically.
• Regulations for PFAS: By July 11, 2025, new regulations under the Toxic Substances Control Act (TSCA) will require reporting on the use, production volumes, and disposal of Per- and Polyfluoroalkyl Substances (PFAS) since 2011.
  • Impact: Universities with research programs or departments that have used PFAS compounds may be subject to extensive reporting requirements.
• Methylene Chloride (DCM) Management: The EPA’s 2024 final rule on methylene chloride under TSCA sets strict new workplace safety requirements, including the creation of a Workplace Chemical Protection Program (WCPP).
  • Impact on academic labs: Laboratories using DCM must meet a series of deadlines in 2025 for initial exposure monitoring, implementing safety measures, and developing a WCPP.

Conflict with existing standards: These new EPA standards for DCM create potential for confusion or conflict with existing Occupational Safety and Health Administration (OSHA) regulations. 6 NYCRR 371.1(c)(4)(iii)

• Exemption of disposal of Hand Sanitizer in large quantities.
  https://dec.ny.gov/sites/default/files/2024-10/handsanitizerhwfs.pdf
  College and Universities should be aware of the exemption available in 6 NYCRR 371.1(c)(4)(iii) for the disposal of hand sanitizers in large quantities by returning the hand sanitizer to the manufacturer or a recycler that can reclaim the material legitimately. Generators must submit a C7 Notification form to the DEC before sending off sanitizer for recycling. By doing this, generators can avoid reporting hand sanitizer as additional hazardous waste.
• 6 NYCRR Parts 596-599 (now 597-598) and Part 613 regulate the storage of hazardous substances (CBS) and petroleum (PBS) in New York, These regulations were revised in 2015 and again in 2023 to align with federal laws, with the CBS regulations significantly restructured into new Parts 597 and 598 and the PBS regulations remaining under a revised Part 613. The regulations cover facility registration, hazardous substance identification, release reporting and prohibition, and standards for new and existing tank systems.
• Adding aerosol cans to the Universal Waste Regulations EPA (.gov)
  • In Dec 2024 — With this rule, EPA adds hazardous waste aerosol cans to those “universal wastes” regulated under title 40 of the Code of Federal Regulations (CFR), part 273.

Implications for Institutional Hazardous Waste Programs

The cumulative effect of these changes is a more complex compliance landscape for universities.

• Enhanced digitalization: The mandatory shift to e-Manifests requires colleges to invest in digital record-keeping and training for waste management personnel.
• Expansion of regulated waste streams: New rules for PFAS and DCM expand the types of chemicals under specific federal reporting and management obligations, requiring updates to internal chemical inventories and disposal protocols.
• Risk of increased penalties: Institutions face increased maximum civil penalties for RCRA violations as of January 8, 2025, making compliance with the new rules more critical.

D&B has completed both initial and follow-up audits for these facilities to ensure that the corrective actions identified have been completed in accordance with the applicable laws and regulations, as well as annual audits to ensure continued compliance going forward.

D&B understands that training facility personnel can be a time consuming and challenging goal. Therefore, D&B offers comprehensive environmental compliance training that complies with the extensive and often overwhelming reality of environmental regulation that apply to many industry sectors. In order to make our programs as “user-friendly” as possible, we develop a customized training program using facility-specific information, photographs, company policies, protocols, and standard operating procedures (SOPs).

D&B focuses on providing training that is tailored to meet the client’s specific needs. Our courses are presented by environmental professionals with years of industry and regulatory agency experience. To ease the learning curve, our training programs translate EPA’s 40 CFR regulations (and their state specific analogues) into understandable, plain English. We customize each program, showing its applicability, significance, and impact on the client’s operations.

Many training programs are designed to train those recently hired who need a general, overall waste management introduction; those recently assigned to positions involving hazardous waste management responsibilities; and anyone looking for a review of the basics, such as on-site hazardous waste managers, environmental managers and engineers, senior operations executives, and safety personnel, educational staff, laboratory staff, maintenance/engineering employees, and strategic business planners. Other training programs are focused on specific topics to meet a particular need at the facility, and often are a unique “one-of-a-kind” training program. For larger organizations that already have established compliance and training programs, D&B has developed “Train the Trainer” programs that provide in- house environmental health and safety professionals with the tools needed to continually develop and present up-to-date compliance training programs to new staff and departments as well as provide periodic refresher training to existing staff.

To support for day-to-day facility operations, D&B has conducted Phase I/Phase II Environmental Site Assessments (ESAs) on behalf of Colleges and Universities who are looking to lease or acquire facilities to expand their operations. Phase I ESAs are conducted in accordance with ASTM E1527-13 and EPA “All Appropriate Inquiry” requirements. If on-site Recognized Environmental Conditions (RECs) are identified as part of a Phase I ESA, a Phase II ESA may be required that could potentially include soil and groundwater sampling, indoor air sampling, and/or hazardous materials (i.e. asbestos, lead-based paint or PCB) assessments.

This is particularly important to facilities that are expanding their operations with the construction of new facilities or applying for environmental permits that require in-depth environmental review, coordination with federal and/or state regulators and public notice. D&B also provides technical expertise to the insurance industry for the management of environmental risk. D&B’s environmental services involve product release investigation, regulatory negotiation, impact delineation, and remedial evaluation. D&B’s technical expertise can bring about the resolution of an environmental claim resulting in dollar savings and claims reductions.

Whether your facility has requirements for annual, 5-year or 10-year mandatory inspections and/or testing programs, or requires a more rigorous program, D&B can meet your needs.

The front-line elements of an effective petroleum and chemical bulk storage tank compliance program includes quality design, routine inspection services, and a consistent maintenance program. These are the backbone of D&B’s bulk storage compliance services. D&B’s environmental, structural, civil, mechanical, electrical, and chemical engineers are experienced in providing comprehensive design and inspection services in compliance with federal, state, and local regulatory requirements.