A Program for Reducing Institutional Risk When Releasing Potentially Hazardous Assets
Costello, Richard G., Emery, Robert J., Journal of Environmental Health
Modern academic and research activities necessitate the use of a wide variety of hazardous substances and agents. The environmental health protection programs which exist within these institutions usually include monitoring for occupational exposures and environmental discharges to assist in maintaining a safe and healthy setting for students, faculty, staff, and the surrounding community. Discharges of potentially hazardous materials to the environment may include airborne releases through local exhaust ventilation, water discharges via laboratory or clinic sinks, vacuum and drain lines, and waste discharges in the form of designated radioactive, biological, or hazardous chemical waste materials. Another significant source of environmental discharge is represented by the release of potentially hazardous institutional assets through auctions, donations, or transfers [ILLUSTRATION FOR FIGURE 1 OMITTED]. Within this context, institutional assets are defined as any used or surplus equipment or supplies exhibiting a residual value, and include items such as laboratory apparatus and maintenance equipment. Institutional assets may possess overtly hazardous characteristics, such as sources of laser or x-ray radiation, or have hazardous characteristics enhanced or added by the institution, such as the removal of a safety switch or contamination with infectious agents. Such assets represent a source of personal harm and institutional liability when released as surplus through auction or donation (1). Examples of common potentially hazardous institutional assets are listed in Table 1.
Since institutional assets can be released in a variety of forms and configurations, environmental health protection programs may not have systems in place to effectively monitor and control this route of environmental discharge. To control the release of potentially hazardous assets, a program was developed and implemented at the University of Texas Houston Health Science Center which incorporates the comprehensive waste tracking principles established by the Resource Conservation Recovery Act (RCRA) for hazardous waste, and the due diligence investigation, mitigation, and disclosure principles applied in the environmental site assessment process for real estate transactions (2,3).
Facility and Program Description
The University of Texas Houston Health Science Center (UTHHSC) is a major research and academic institution located within the Texas Medical Center complex. Established in 1972, the UTHHSC consists of the Dental Branch, Graduate School of Biomedical Sciences, School of Public Health, Medical School, School of Nursing, and the School of Allied Health Sciences. To maintain a safe and healthy setting for all students, employees, faculty, staff and the surrounding community, the UTHHSC operates the Environmental Health and Safety Department, comprised of divisions for radiation safety, occupational hygiene & safety, and environmental protection. The primary function of the Environmental Protection Division is to ensure that all materials leaving the institution are in compliance with existing and anticipated environmental rules and regulations, and that such releases are performed in the most cost effective means possible. The scope of this charge includes the management and oversight of all designated hazardous waste materials, sanitary sewer releases, air effluents and, most recently, the release of potentially hazardous institutional assets. The Environmental Protection Division is responsible for the creation, implementation, and maintenance of the Comprehensive Asset Tracking, Evaluation, and Release program, subsequently assigned the acronym "CATER."
Prior to the creation of the CATER program, no systematic mechanism existed within the institution to address the release of potentially hazardous assets. Equipment overtly identifiable as potentially hazardous, such as biosafety cabinets and centrifuges, was previously subjected to review on an ad hoc basis. …