"It hasn't been us, and we hope it will continue not to be us," says Vice President for Administration Sally H. Zeckhauser. "We've known increased standards were coming for many years, but we haven't been waiting for a disaster to happen."
In the existing system, the U.S. EPA sets the minimum standards, while individual states are free to raise these levels. Typically, Harvard deals with the Massachusetts Department of Environmental Protection rather than its national counterpart.
A Good Match?
Some academic institutions facing the stringent standards say many of the regulations designed for the industrial world do not apply well to universities, according to Vautin.
Officials at Stanford and Yale have questioned the appropriateness of certain regulations.
Currently, 19 universities, frustrated by the way the EPA counts hazardous waste sites, are working with the agency to change the site designation process.
"Many regulations were created around the industrial model of the 1970s and 80s," Vautin says. "In the last several years, there has been a greater level of interest in applying these regulations more broadly to places like research universities."
But applying these rules can be difficult, Vautin says, because of the many differences between manufacturing industries and research institutions, such as the volume of waste, production methods and logistical constraints involved.
Universities produce substantially smaller quantities of waste; and because of the laboratory system, the waste production is far more decentralized than in the industrial world, Vautin says.
"Being regulated like industry is too burdensome. The amount of chemicals we deal with in the lab is different than in industry," says James H. Rowe III '73, vice president for government, community and public affairs. "General understanding in the academic setting is significantly higher. This difference should be taken into account."
Vautin highlights one rule in particular as not applying to academia.
Industrial facilities are required to collect waste in large collection areas, which they do through centrally-located chemical facilities.
Academic institutions must create the equivalent kinds of collection facilities, even though laboratories are located all across university campuses. The resulting need for "satellite storage" facilities in each of the labs, Vautin says, reflects an industry standard which should not apply to a research institution.
"[Massachusetts' regulators] are becoming more results oriented, with a greater emphasis on enforcing regulations, and more people doing inspections," Griffin says. "They have done their job with industry and are now trying the extend their efforts."