Environmental Compliance

The Clean Air Act is one of the most comprehensive and far-reaching pieces of environmental legislation ever written. Regulatory impacts and requirements stretch from the large boilers down to diesel powered generators. The Georgia Environmental Protection Division (EPD) manages the permit and air emission issues faced by KSU and interacts with state regulators on all air issues.

Kennesaw State University (KSU) proactively manages asbestos containing materials (ACM) in place by identifying ACM, maintaining those materials in good condition and removing ACM as needed during maintenance or renovation activities. The purpose of the program is to reduce or eliminate the risk of employee exposure to asbestos containing materials (ACM).

The Board of Regents (BOR) of the University System of Georgia requires that an Environmental Site Assessment (ESA) be complete, as part of environmental due diligent, to assess environmental risks pertaining to all University's and Foundation's real estate transactions. ESA is intended to identify any recognized environmental conditions which previously existed or currently exist at the subject property which may create liability for the institution or the BOR, significantly increase the costs of site development or use, and/or preclude development of the site.

Kennesaw State University (KSU) follows the BOR Criteria for Environmental Site Assessment which outlines the minimum requirements. At a minimum, the ESA must conform to the U.S. Environmental Protection Agency's Standards and Practices for All Appropriate Inquiries (AAI rule) and to the American Society for Testing and Materials (ASTM) International Standard E1527-13 "Standard Practice for Environmental Site Assessments: Phase I Environmental Site Assessment Process."

(Effective January 1, 2014 – All ESA Phase-1 reports conducted for USG Institutions, Foundations, or the Board of Regents shall follow the new standard.)

The Environmental Health and Safety Department (EHS) at Kennesaw State University (KSU) takes an active role in assessing operations involving high air temperatures, radiant heat sources, high humidity, direct physical contact with hot objects, or strenuous physical activities that have a high potential for inducing heat stress in a person engaged in such operations. Examples of such operations include but are not limited to: working in foundries, laundries, construction projects, commercial kitchens, boiler rooms, and out-door activities conducted in hot weather (such as grounds work).

The Indoor Air Quality program at Kennesaw State University (KSU) works with the faculty and staff of the university community to promote and ensure, as practical as is possible, a safe working environment for all employees through the recognition, evaluation, and control of workplace health and safety hazards, using knowledge and experience in industrial hygiene It is the goal of KSU to provide a work environment free of recognized hazards and to investigation staff concerns of poor indoor air quality (IAQ).

The Environmental Protection Agency (EPA) oversees The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  FIFRA is a law that is written to protect consumers, applicators and the environment. The EPA seeks to meet the goals of the act by controlling the production, sale, distribution and use of pesticides (40 CFR 152-180).

Under FIFRA, all pesticide-manufacturing plants, and all pesticides sold or distributed in commerce, must be registered with the EPA. Labels on pesticide containers include important safety information, instructions for applying the pesticide, and the intervals at which applicators can re-enter application areas. FIFRA regulations require that workers follow all label instructions. Workers must follow safety standards (the Worker Protection Standard) when they mix and apply pesticides, and state agencies must certify the workers who apply certain pesticides. FIFRA also mandates practices for managing waste pesticides and for handling container residues.

Certain aspects of FIFRA will apply to Kennesaw State University (KSU) if KSU personnel  apply pesticides. If a contractor applies pesticides, that contractor must adhere to the applicable portions of FIFRA. All workers using pesticides must receive training, and applicators must be state-certified if they work with restricted use pesticides.

The Worker Protection Standard does not apply to the research uses of unrestricted pesticides. It also does not apply to workers who do no more than handle empty containers.

The Georgia Environmental Protection Division (EPD) requires facilities to manage refrigerants properly to help protect the environment.

The purpose of the KSU Refrigerant Management Program is to:

• Maximize the recycling of ozone depleting substances (ODS) and to minimize the release of ODS to the ambient air from the servicing, repairing, maintaining, and disposing of refrigeration appliances on campus;
• Utilize certified technicians for the servicing, repairing, maintaining, and disposing of refrigeration appliances on the KSU campus;
• Maintain proper records of refrigerant consumption, technician training, and recycling and recovery equipment certifications;
• Ensure proper repairs are made for units with significant leak rates; and
• To ensure KSU  is in full compliance with Section 608 of the Clean Air Act Amendments and the requirements of 40 CFR Part 82, Subpart F.

To achieve the objectives stated above, KSU requires all employees and contractors whose job duties require the handling, ordering, repairing, servicing, maintaining, or disposing of refrigerant or refrigeration appliances to assist by ensuring the proper paperwork is being completed when work is being performed.

Kennesaw State University (KSU) is required to implement and comply with Spill Prevention Control and Countermeasure (SPCC) rules as regulated by the United States Environmental Protection Agency (US EPA) and requirement as regulated by the Georgia Environmental Protection Division (GA EPD). Both sets of rules were written to prevent the pollution of the waters of the United States from oils and other polluting materials. KSU maintains a SPCC plan to fulfill the requirements of these regulations. The plans are intended to provide guidelines to the University community for preventing the release of oil and other listed polluting materials into the environment, especially to surface waters. The Plan provides guidelines for inspections, preventive maintenance, commitment of resources, and emergency response procedures that will be implemented in the event of an oil or polluting material spill at the KSU.

The Stormwater Management Program (SWMP) is prepared as a requirement to comply with State and Federal regulations to minimize and/or eliminate stormwater discharges on University grounds in and around the KSU community. Our SWMP describes measures, procedures and practices that KSU will utilize to minimize the discharge of pollutants from campus into the stormwater drainage systems and adjacent receiving waters. In accordance with the Permit, the SWMP is required to include the following topics:

• Public education and outreach program(s) on stormwater impacts
• Public involvement and participation
• Illicit discharge elimination program for the campus
• Post-construction stormwater management program for new development and redevelopment projects
• Construction stormwater runoff control
• Pollution prevention and good housekeeping practices for University Operations
• Total Maximum Daily Loads

Congress enacted the Toxic Substances Control Act (TSCA) in 1976.  TSCA gives the Environmental Protection Agency (EPA) the ability to track the 75,000 industrial chemicals produced in the United States or imported into the United States.  EPA collects data on these chemicals and can require the manufacturer or importer to determine the risks that these chemicals pose to human health or the environment.  Under TSCA, the EPA can control the production, distribution, and importation of new and existing chemicals; establish specific disposal rules; and ban the use of high-risk chemicals, such as Polychlorinated biphenyls (PCBs).

TSCA also controls specific substances, such as asbestos, PCBs, lead, and biotechnology.  TSCA excludes tobacco, foods, food additives, drugs and cosmetics.  The TSCA program also excludes nuclear materials, munitions, and chemicals used solely as pesticides.  Other exemptions include naturally occurring materials, products of incidental reactions and end-use reactions, mixtures, byproducts, and substances made solely for export.

TSCA defines “research” as commercial research if a commercial entity directly provides partial or complete funding for the work.  It is not important who actually conducts the research.  If KSU personnel import or export chemicals for any purpose, the chemicals must be accompanied by import/export rule certifications.  In most cases, research activities are either exempt from TSCA rules pertaining to the significant new use rule and the pre-manufacture notice, or those activities are subject to fewer demands than those made on manufacturing.  As long as KSU meets the safety and recordkeeping requirements in 40 CFR 720.36 and 720.78, the chemicals created in small amounts for research are exempt from TSCA reporting.  However, if KSU were to produce chemicals commercially, more extensive TSCA requirements will apply.

The Georgia Environmental Protection Division (GA EPD) regulates discharges of wastewater to/onto the ground within the State of Georgia. Any projects at KSU involving cleaning activities outside, (including but not limited to the use of cleaners, soapy water, washwaters, etc.) or any waters mixed with waste matter must be communicated to KSU's Environmental Health & Safety prior to the management of such a project where wastewater is generated.