Purpose

To determine if SUNY institutions have developed adequate controls to effectively safeguard campus communities against hazardous materials and waste. This audit covered the period from January 1, 2015 through May 4, 2018.

Background

The State University of New York (SUNY) is the largest comprehensive system of public education in the nation, comprising 64 autonomous campuses. In 2015-16, SUNY served nearly 1.3 million students, with approximately 91,000 faculty and staff. Campuses are located throughout the State, and SUNY maintains a central administrative office in Albany. For fiscal year 2015-16, SUNY had a budget of $13 billion, including State support totaling $4 billion, and over $1 billion in total research activity.

In order to promote a safer and more environmentally responsible SUNY community, SUNY’s System Administration established the Environmental Health & Safety Office (EHSO). The EHSO serves as a technical resource to provide tools, training, and communication for the campuses on best practices and compliance issues, including compliance with SUNY’s own requirements as well as local, State, and federal regulations for environmental management and occupational safety and health.

Hazardous materials are defined and regulated in the United States primarily by laws and regulations administered by the U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health Administration, and the U.S. Department of Transportation. Generally, a hazardous material is any item or agent (biological, chemical, radiological, and/or physical) that has the potential to cause harm to humans, animals, or the environment, either by itself or through interaction with other factors.

The EPA and the New York State Department of Environmental Conservation have detailed regulations defining hazardous waste. The EPA states that, simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment. Hazardous waste is generated from many sources, ranging from industrial manufacturing process wastes to batteries, and may come in many forms, including liquids, solids, gases, and sludge.

Key Findings

• Based on our visits to two University Centers (University at Buffalo [Buffalo] and Stony Brook University [Stony Brook]) and five campuses (Plattsburgh, New Paltz, Polytechnic Institute [Poly], Oneonta, and Cobleskill), we found there is significant variation in the adequacy of controls over hazardous materials.
• At most of the non-university center campuses, we found select areas in which controls over hazardous materials could be improved. However, these weaknesses were not pervasive throughout all areas of internal controls. In contrast, the University Centers had weaknesses throughout all the areas of internal controls we reviewed. For example, Buffalo’s system of internal controls over hazardous materials purchasing, access, and accounting is inadequate to provide reasonable assurance that students and campus communities are safeguarded from exposure. These weaknesses prevent proper monitoring and accounting for hazardous materials, compliance with legal requirements, and enforcement of restricted access to hazardous materials.
• SUNY officials have established controls over and complied with hazardous waste regulations that provide reasonable assurance that students and communities are safeguarded against exposure to hazardous waste. Officials have implemented controls to safeguard hazardous waste and comply with standards set forth by the various oversight agencies at the federal, State, and local levels.

Key Recommendations

To SUNY Administration:

• Provide guidance and support to campus officials in designing and implementing a system of internal controls that provide reasonable safeguards against intentional or accidental misuse of hazardous materials.
• Work with campuses to improve controls over access, procurement, or accounting for hazardous materials as necessary to further reduce risks relating to controls over hazardous materials.

To SUNY Institutions:

• Improve controls over access, procurement, or accounting for hazardous materials as necessary to further reduce risk relating to hazardous materials. This may include (but not be limited to):
  • Assessing risks to access, procurement, and accounting of hazardous materials and implementing controls to address them.
  • Monitoring and enforcing compliance with already established procedures in the Chemical Hygiene Plan, lease agreements, and other university policies.

Other Related Audit/Report of Interest

Department of Environmental Conservation: Selected Aspects of Inactive Hazardous Waste Site Remediation Cost Recovery (2014-S-14)