The university is one of thousands of public and private higher-education institutions throughout the country facing possible inspection by the U.S. Environmental Protection Agency-an announcement that, in part, has catalyzed efforts to develop and institute a campuswide environmental safety policy.

The possible visit is "our most recent rationale to pursue all measures that will yield positive improvements," said Michael Dupre, associate vice president for university facilities, which houses the Department of Occupational and Environmental Safety. Charged with ensuring safe and environmentally sound practices throughout the campus, OES is at the forefront of facilitating dialogue about the proposed policy, said Dupre, who, along with OES Director Lou Henry, is soliciting participation from the campus community.

"We are trying to achieve a consensus-based, overarching campus safety policy," said Henry, emphasizing that the policy also will help define the roles of university community members in upholding safety standards.

The policy, as outlined by Dupre and Henry, should detail the responsibilities of supervisors, principal investigators and employees, and would include informing new employees of safety and health protocol; ensuring proper equipment and protective devices are provided, maintained and used; promptly reporting unsafe acts or conditions; providing proper training; coordinating and conducting internal inspections to determine compliance with current safety and environmental standards, and providing or acquiring necessary resources for health and safety equipment, materials and facilities.

While devoting the proper attention to safety takes time "away from our principal mission of teaching and research" and requires thoughtful spending of limited financial resources, Henry said, it can be done.

"My goal (is) to get everybody to do it as well as some do it," he said, citing as an example the Department of Chemistry, which has its own safety committee comprised of faculty and staff members that performs inspections. "They're just as resource-starved as everyone else...and they've found a way to do it right."

While UB follows state and federal regulations for safety, it currently has no university-specific policies in place. Dupre and Henry have been working to remedy that with "a lot of old-fashioned walking around"-literally knocking on classroom and laboratory doors in search of suggestions and concerns from principal investigators and researchers about workplace safety.

"Safety professionals have this challenge of trying to keep people mindful of things," said Dupre, citing complacency as the No. 1 offender. "There's room for improvement."

Henry agreed, noting that departmental disparity is not due to indifference.

"I've never met a principal investigator that didn't care about safety. It's a question of how rigorous you are and how well you are documenting what you do.and day-to-day aggressiveness," he said, emphasizing that PIs have a responsibility-in spite of constraints-to invest the necessary time and resources to meet safety challenges.

Still, both Dupre and Henry agree the possibility of an inspection gives credence to their crusade.

"It's as good a time as any to start building a quality program," Henry said, noting the two already have brought their proposal to both the Professional Staff and Faculty senates in hopes the bodies ultimately will endorse the policy. He said he and Dupre will revisit the Faculty Senate this month.

"Once the policy is endorsed, we will begin a dialogue with stakeholders," added Dupre, who is hoping to submit a policy draft to UB's top administrators for approval following that dialogue.

A major challenge in achieving compliance at UB, Henry said, is in developing better systems to track the acquisition, storage, use and disposal of hazardous materials. Toward that end, the university in December hired the environmental engineering firm URS Greiner Woodward Clyde to conduct a mock inspection of the campus and provide perspective "on our facilities and our programs, feedback on...areas we could improve," in addition to getting a feel for the inspection process, Henry said.

"We could wait for the EPA to get here, fix whatever they tell us to fix or we could start building a better program from the ground up," he said. "The policy isn't a magic pill to deal with the EPA inspection. We want to be safer and in better compliance-that's the goal."

Nina Habib Spencer, spokesperson for the EPA's Region 2-which covers New York, New Jersey, Puerto Rico and the Virgin Islands-said the initiative aimed at higher-education institutions was launched "largely because we were seeing some very distinct problems with environmental compliance."

Habib Spencer said the EPA is encouraging schools to conduct voluntary internal audits, the results of which could mean substantial reduction in civil financial penalties-between 75 and 100 percent-for disclosure and prompt correction of violations.

Negotiations are under way between SUNY counsel in Albany and the EPA in hopes of hashing out a SUNYwide, self-disclosure agreement.

And while an internal audit would not preclude the EPA from inspecting UB, Habib Spencer said the potential agreement-which could cover most, if not all, schools in the system-would put an institution "on a schedule for fixing violations that have been identified, and while those improvements are taking place, we wouldn't cite the school a second time for the violations." The EPA's standing policy of requiring supplemental environmental projects following self-disclosure, which entail updating or replacing equipment, often serve in lieu of paying a fine, she said.

The EPA already has visited several SUNY schools. While Habib Spencer could not disclose which institutions were visited, she did say that "any inspections we have done of SUNY schools gives us a better view of the state of environmental affairs in the SUNY system and an edge when it comes to verifying any problems the schools might identify themselves."