Performing Self-Audit of the Nation's Largest Urban University

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The United States Environmental Protection Agency (USEPA) sent a strong message to institutions of higher education when it released its College and University Initiative five years ago: adhere to the same environmental compliance standards as private industry, or face hefty fines and penalties. Rather than wait for a surprise USEPA audit, the City University of New York (CUNY) opted for a proactive approach, negotiating an agreement with USEPA that essentially is a five-year contract to self-audit, disclose, and correct so CUNY’s compliance could be documented and maintained.
Passing the Test Undertaking the self-audit program would be no easy task. CUNY is the nation’s largest urban university, with 19 campuses and more than 400,000 students spread throughout New York City’s five boroughs. Its 11 senior colleges, six community colleges, graduate school, and law school are unique– some have traditional campuses with quads, athletic fields, and landscaped grounds; others are high-rise buildings with no grounds. Some have buildings that are blocks, even miles, apart. Some have extensive laboratories; two schools have no labs at all. To provide the broad experience and consistency needed for its program, CUNY retained O’Brien & Gere. Campus by campus, building by building, O’Brien & Gere staff is reviewing emission sources throughout, checking files and records, and meeting with facilities and maintenance staff, planning staff, professors, and department chairs. Audits include inspections of hazardous waste storage areas, facility maintenance buildings, research laboratories, art studios, and graphic arts and print shops. O’Brien & Gere project team members visit greenhouses and athletic training facilities, and check above ground and underground storage tanks, dry wells, and wastewater discharges. They assist with emissions inventories, facility air permits, new source review, opacity tests, and permit applications and modifications. O’Brien & Gere also assists the colleges with appropriate corrective actions and other environmental compliance services, where needed. During key points in the program, as many as 30 O’Brien & Gere staff have had assignments, helping CUNY to meet its compliance requirements and obligations under its agreement with the USEPA. Lessons Learned Now, almost halfway through its volunteer audit program (8 of 19 campuses), CUNY is developing a comprehensive Environmental Management System (EMS), and is a model to other colleges and universities for meeting the challenge of environmental leadership.
For a copy of O'Brien & Gere's Portfolio Magazine, please contact Tom Kogut

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