Environmental Programs


The Environmental Program (EP) provides support and services to Emory with a focus on protecting human health and environmental resources. This program evaluates and manages the environmental outcomes of Emory operations with the goal of minimizing environmental impact and promoting overall environmental stewardship. This goal is accomplished through implementation of Federal and State regulatory requirements that are designed to protect our environment.

Responsibilities of this program include evaluation of regulatory requirements, implementation of programs based on these requirements, and assessments of programs to assure compliance with applicable environmental regulations.

Services

EP interacts with essentially every operational facet of Emory. Our primary charge is regulatory evaluation, implementation, and compliance assurance. Collaboration with other divisions at Emory is essential to protecting resources and improving operational effectiveness. Organizational interactions that further the goal of environmental stewardship include support with Office of Sustainability Initiatives, Project Management and Construction, the Center for Emergency Preparedness and Response and other critical stakeholders.

Program Management

The Clean Air Act (CAA) governs air pollution in the United States. This act establishes the federal standards on air pollutants, emission control methods from sources, and establishes air quality regulations. Emory operations such as steam generation for heating and cooling, emergency generator operations, and refrigerants management are regulated under the CAA. Emory currently maintains a Title V permit.

The Clean Water Act (CWA) governs the protection of Waters of the United States. The CWA establishes water quality standards for protection of surface waters from pollutant discharges. EHSO oversees a number of programs that protect waters around Emory through programs, inspections, management practices, such as National Pollution Discharge Elimination System (NPDES) Storm Water Management; Fats, Oil, and Grease (FOG) management, and the Spill Prevention, Control, and Countermeasure (SPCC) plan.

NPDES/Storm Water Management

Emory is proactive in managing potential pollutants that may be discharged into nearby water bodies as the result of rain events. This is accomplished by program evaluation and inspections to ensure regulatory compliance with applicable regulations.

Fats, Oils & Grease

Fats, Oils, and Grease (FOG) are part of the Clean Water Act (CWA) Pretreatment Regulations and targets the discharge of oils discharged by food service. FOG must be captured and managed by a Grease Removal System (GRS). GRS’s include oil-water separators, grease traps, or grease interceptor devices that capture the FOG. GRSs must be maintained by having the FOG periodically removed from the system. Controlling FOG discharges will help publicly-owned treatment works (POTWs) prevent blockages that cause public health and water quality problems. GRSs are typically permitted by the local POTW. These permits must be renewed annually at Emory.

Spill Prevention, Control, & Countermeasure (SPCC)

Oils are stored and used by Emory, which include petroleum oil, fuel oil, mineral oil, and vegetable oils. In order to meet the requirements of the Spill Prevention Control and Countermeasure (SPCC) regulations Emory must implement a SPCC plan. This plan prevents oils from reaching waterways by establishing procedures, engineering controls, inspections, and counter measures.

Guidance

CERCLA, often referred to as Superfund, has the purpose of imposing responsibility on entities to remediate large chemically contamination.  The part of CERCLA which impacts Emory is the Emergency Planning and Community Right to Know Act (EPCRA) which requires that information regarding hazardous materials stored or used be provided to emergency response planning groups through a report titled Tier II. This report informs Emergency Planning Agencies of the types and quantities of certain chemicals on our campuses and is provided to the State Emergency Response Commission, Local Emergency Planning Committees, County-specific HAZMAT teams, and local fire departments.

The Department of Transportation (DOT) regulates hazardous materials transportation. A hazardous material is a substance that is capable of posing an unreasonable risk to health, safety and property when being transported. Hazardous materials that are intended for transportation on or off campus MUST be shipped by individuals that are trained in DOT regulations. Please refer to the Safety Data Sheet (SDS) of the material you want to ship to verify what hazards, if any, your material may possess. Materials that are not considered to be hazardous by the DOT do not have to follow the DOT regulations. Packages must not be transported using any means of public or personal transportation. There are size limits for individual packages based on the hazard class and packing group of the material. Please contact EHSO for information on the quantity limits of your hazardous material.

Please contact EHSO with shipping questions.

Materials of Trade (MOTs) are hazardous materials that are transported by Emory employees to directly support business purposes. EHSO oversees the transportation of hazardous materials and provides training on MOTs. EHSO will also advise personnel on the quantity limits and packaging, marking, and labeling requirements.

The Emory community takes pride in maintaining a beautiful 630-acre campus. This requires the occasional use of pesticides which must be carefully applied and managed. Emory uses Integrated Pest Management (IPM) techniques to minimize pesticide use. All Emory staff that are responsible for pesticide application receive training to ensure proper and safe use of pesticides. All applicators have a pesticide application license with the state of Georgia or are under the supervision of an individual with a license. EHSO frequently audits applicators and sites of application to ensure compliance at all levels. Emory is a neonicotinoid free campus to protect bees and other pollinators.

Guidance

The Environmental Program (EP) coordinates the ordering and receipt of radioactive materials for Emory and its affiliates to ensure compliance with local, state and federal regulations. Transportation of radionuclides for research and clinical uses including sealed sources are managed by EP relieving Emory faculty and staff of the associated regulatory responsibility. Radioactive Material orders submitted through Emory Express, are monitored regularly to ensure orders are reviewed and approved without delay. 

The silver recovery inspection program ensures that no silver is discharged down the drain. Recovering silver from wastewater solutions such as those produced by film processing units and medical x-ray films requires compliance with the EPA regulations, holding environmental accountability for those producing silver discharge. The EPA has standards for the disposal of silver in concentrations exceeding 5 ppm (parts per million). It is Emory University’s policy that zero silver is discharged down the drain to ensure this limit is not met or exceeded.

Spaces containing film processing units are inspected annually, at a minimum, to ensure the standards are met. Please email chemwaste@emory.edu for further information about installing and decommissioning dark rooms.

Guidance

At Emory University, we pride ourselves in developing and implementing sustainable practices to reduce our carbon footprint, promote healthy living, and ensure reuse and recycling practices as often as possible. EHSO promotes and collaborates with the Office of Sustainability Initiatives, the Green Labs program and other organizations throughout campus to make Emory’s facilities as environmentally sound as possible without compromising any safety aspects. EHSO and Sustainability strive to promote Environmental Stewardship.

EHSO promotes sustainability by:

  • Recommending recycling of all materials and reduction of landfill waste during our audits,
  • Working with Green Labs to encourage green practices (microscale experiments, turning off lights, recycling appropriate materials, etc.) within Emory’s laboratories,
  • Picking up all waste that could be hazardous and choosing appropriate means of disposal that promote recycling materials when possible (this includes our battery recycling program), and
  • Ensuring all safety controls are in place to prevent any release into the environment.

The Toxic Substances Control Act (TSCA) was established in 1976 by the Environmental Protection Agency (EPA). This act manages and restricts the use of toxic chemical substances and their mixtures. Managing includes production, importation, use, and disposal of specific chemicals. This act is primarily known for its affiliation with polychlorinated biphenyls (PCBs), asbestos, radon, and lead-based paint. However, the list is not limited to these materials.

TSCA also requires importers and exporters of chemical substance, mixtures or articles to either certify that the chemical substances comply with TSCA or are not subject to TSCA. Certain chemicals are excluded and certain chemicals require no certification. Anyone at Emory having questions about this requirement should contact EHSO.

Any toxic materials covered under TSCA cannot go into the regular (landfill) trash and must be disposed of through EHSO or an Emory-approved vendor.

Underground Storage Tanks (UST) systems at Emory are used to fuel emergency power generators at Emory's research buildings, hospitals, and other critical locations. USTs are managed by the Facilities Management staff of their respective organizations. The purpose of the Underground Storage Tank (UST) Management Program is to outline a method to comply with applicable Federal and State regulations regarding UST management at Emory. USTs are defined as tanks that contain a regulated substance (such as petroleum products) that are located 10% or more beneath the surface of the ground. Emory’s USTs are regulated by the U.S. Environmental Protection Agency (EPA) and the Georgia Environmental Protection Division (GA EPD). The UST Management Program applies to all USTs at Emory University, Emory Healthcare, and The Emory Clinic locations. EHSO’s Environmental Compliance Program at Emory, in partnership with Facilities Management, ensures UST compliance with State and Federal Regulations.

UST Class C Operator Training 

UST Class C Operators are those staff who have primary responsibility for initial response to emergencies (alarms, spills, releases, etc.) at the UST site. Class C Operators must be trained upon initial job assignment EHSO's Underground Storage Tank Compliance Training for Class C Operators. Class C Operators will be expected to attend this training annually.

Guidance

Training

Any staff member who has responsibility for managing USTs or provides oversight is required to have appropriate training. Staff are required to take either A, B, or C Operator training depending on their role and responsibilities regarding USTs. Contact EHSO’s UST lead for further information.