Improving  EPA's  Performance
                    with  Program Evaluation
                    Project in Excellence and Leadership: New England Universities'Laboratories
                    Mid-Term Evaluation: Piloting Superior Environmental Performance in Labs
                                                                                 Series No. 8
By continuously evaluating its programs,  EPA is able to capitalize on lessons learned and incorporate that
experience into other programs. This enables the Agency to streamline and modernize its operations while promoting
continuous improvement and supporting innovation. This series of short sheets on program evaluation is intended
to share both the results and benefits of evaluations conducted across the Agency, and share lessons learned
about evaluation methodologies in this evolving discipline. For more information contact EPA's Evaluation Support
Division at www.epa.gov/evaluate.
           At a Glance
Evaluation Purpose
To garner lessons learned and highlight
opportunities to improve the overall
environmental performance of the universities
for the rest of the project.
Evaluation Type
Mid-term Outcome Evaluation
Publication Date
September  2002
Partners
EPA Office of Policy, Economics and
Innovation, EPA Region 1, Boston College,
University of Massachusetts Boston, University
of Vermont, Vermont Department of
Environmental Conservation, Massachusetts
Department of Environmental Protection, and
Nexus Environmental Partners
Contact
Suganthi Simon, OPEI (202) 566-7416
Background: Why was an evaluation
performed?

Over the last fifteen years, the regulated community has recognized
the difficulties in tailoring regulations to the unique environmental
and structural aspects of academic and research laboratories. The
Occupational Safety and  Health Administration's  (OSHA)
laboratory standard is written specifically for laboratories, while
the Resource Conservation and Recovery Act (RCRA) Subtitle C
makes no distinction among its many different regulated entities.
This dual and dissimilar regulatory scheme currently governing
labs has proven to be unwieldy.
In 1999, a consortium of university laboratories in New England
joined the U.S. Environmental Protection Agency's Project XL
(excellence and Leadership) to test an innovative program to reduce
regulatory inefficiencies  and achieve better environmental
performance than what is required under the current regulatory
structure.   Three universities—Boston College, University of
Massachusetts Boston (UMB), and University of Vermont
(UVM)—are testing the integration of RCRA hazardous waste
regulations with OSHA's performance-based Chemical Hygiene
                                                            NCEI

                                                            NATIONAL CENTER FOR
                                                            ENVIRONMENTAL INNOVATION

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Plan.  This harmonization system requires the use of
performance-based criteria to effectively manage
laboratory wastes with an Environmental Management
Plan (EMP).  The EMP  is specifically tailored to the
research needs and processes of each university.
The new system focused on the following priority areas:
(1)  increasing faculty, laboratory staff, and student
training  to improve individual behavior in  the
laboratory and overall environmental  awareness of
staff and  students; (2) generating pollution prevention
ideas; (3)  reducing laboratory hazardous waste generation;
and (4) increasing chemical redistribution and reuse.
By December 2000, all three schools had implemented
their EMPs and had  actively  begun to  track their
commitments and progress in meeting the  stated goals
and objectives of the pilot project. In June 2001, the
three  schools issued the  first annual progress report
for the project, which yielded mixed results.  The project
partners agreed to conduct a mid-term evaluation to
obtain a clear picture of why the schools  were seeing
certain EMP elements take hold and why others seemed
to be having minimal results. The mid-term evaluation
discusses  the results of the universities' efforts to
actively encourage chemical  reuse and recycling,
enhance conformance with internal policies, increase
efficiency, and promote  environmental stewardship
within laboratories.

Basic Evaluation Approach:  How
did they do  it?
The evaluation was conducted  by a team  comprising
staff from EPA's Office of Policy,  Economics  and
Innovation  (OPEI), the universities, (Nexus
Environmental Partners), the Vermont Department of
Environmental Conservation (DEC), and  the
Massachusetts  Department of  Environmental
Protection. The evaluation involved the  seven steps
outlined below.
Step I:   Develop an evaluation plan and evaluation
          outline.
Step II:   Use a logic model to lay out a framework
          for understanding the project. The logic
          model   graphically  represents   the
          relationship among program  inputs,
          outputs, and intended outcomes.
Step III:  Develop a standard set  of discussion
          questions for use in conducting group
          discussions with the schools.
Step IV:  Collect qualitative data by conducting
          group  discussions  with  university
          administrators, students,  and faculty at
          each of the three  universities.
Step V:  Collect and analyze compliance data from
          project universities soon after EMP
          implementation and gather compliance data
          on  non-project universities as baseline
          comparison data to compare the first-year
          audit results at the participating universities.
          Conduct regular team conference calls on
          the EMP development and implementation
          phase with key environmental, health, and
          safety staff from the three universities,
          (Nexus Environmental Partners), and with
          Vermont DEC.
Step VI:Analyze group  discussion  data  and
          information and prepare report findings and
          recommendations.
Step VII: Share report findings and recommendations
          with the evaluation team and  chart  a
          communications plan for the  evaluation
          findings with senior  managers and other
          interested parties.
     Approach for this  Evaluation
Step I
Develop Evaluation Plan
Step II
Develop Logic Model
Step III
Develop Interview/Discussion Questions
Step IV
Conduct Interviews
StepV
Collect and Analyze Data
Step VI
Develop Findings and Recommendations
Step VII
Share Findings and Recommendations

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Evaluation Results:  What was
learned?
The mid-term assessment of this project indicated that
the project showed great success in some important
areas:  developing EMPs, training staff, increasing
awareness, shifting attitudes and behaviors, improving
the range of activities that determine compliance and
emergency preparedness, and demonstrating that the
environmental management system approach  to
managing laboratory waste is slowly gaining hold and
making progress. At the same time, as fully described
in the report, the project has not shown the expected
successes in other areas—such as chemical reuse and
redistribution or pollution prevention—for a  variety
of academic and cultural reasons. The lessons learned
highlight areas of great progress and areas that require
further thought, discussion, brainstorming, and action.
In the era of heightened awareness of domestic security
issues, colleges and universities can benefit from a more
holistic management scheme, such as the New England
Universities' Labs project, that stresses chemical
awareness, proper chemical handling and disposal, and
better laboratory housekeeping in general.

Evaluation Outcomes:  What
happened as a result?

The final project agreement (FPA) for the New England
Universities' Laboratories Project XL originally expired
in 2003. EPA staff extended the FPA and will adjust
aspects of the pilot project based on the findings and
recommendations included in  the evaluation.  The
evaluation will be used to identify the strengths and
weaknesses of the New England Universities'  Labs
program, offering suggestions for  continuous
improvement and creating a  system of learning within
EPA, the states, and the  universities on laboratory
innovation. The evaluation will also be used to inform
a national dialogue on the  potential for regulatory
reform for  academic laboratories.  Specifically EPA's
Office of  Solid Waste and  Emergency Response is
considering the pilot's  experience as it considers the
development of a national rule that may regulate
hazardous wastes in college and university laboratories.
United States
Environmental Protection
Agency
Office of Policy,
Economics and Innovation
(1807T)
      June 2003
EPA-100-F-03-012

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