Background
In 2000, when the EPA Region II's University Enforcement Initiative launched, Cornell decided to "self audit" and self-disclose. The EPA, in making a final determination on the self-disclosure expressed the following:
"In making the final determinations above, EPA believes Cornell is capable of achieving a higher standard of self-policing and greater compliance with laws and regulations that protect human health and the environment. Consistent with the purposes of the Self-Disclosure Policy, EPA expects Cornell to institute, on a continuing and company-wide basis, the internal policies and procedures necessary to prevent recurrence of violations of environmental requirements."
The Cornell Administration and the teams contributing to the CMS development acknowledge the need to institute internal policies and procedures to prevent recurrence of violations and to enable increasing improvement of our compliance status. In addition, there are numerous voluntary undertakings and good management practices that become most effective by being institutionalized. The experiences of many organizations demonstrate that the way to accomplish these goals-improved compliance and effective voluntary environmental stewardship undertakings-is by the use of a formal management system.
Why the management-system approach?
Regulations can be difficult to interpret, confusing and even, occasionally, contradictory. At the same time, Cornell is a complex, decentralized organization where areas of authority and responsibility are often not obvious. The law does not require a management system; however, given these conditions, to operate in compliance and implement effective "beyond compliance" programs, requires a systems approach to the behavior of the organization. In addition there is pressure in this direction from both within and outside the university.Commitments by University Administration
In reaction to the EPA's university enforcement initiative, both President Rawlings and Vice President Hal Craft committed, in two separate letters to the EPA, to develop an EMS. In his letter President Rawlings stated:The letter of September 28, 2000 from Hal Craft reiterated this:"We have also embarked on the initial review and development of an environmental management system (EMS), one tailored to the unique needs and challenges of a research university."
"Finally, as noted in the President's July 21, 2000 letter, Cornell is currently evaluating how to design and implement an overarching environmental management system (EMS) for the university which would complement and further integrate the existing compliance management systems for Cornell."
CMS Endorsement
The CMS has received commitment from upper-level management, confirming it as the best approach to managing Cornell's safety, health and environmental performance in support of University Policies2.9-Environmental Compliance and Voluntary Initiatives and 2.4-Health and Safety. In December of 2004, Stephen Campbell, Associate Vice President of Business Services endorsed the approach of the CMS after reviewing the Development Plan (pdf).On July 29, 2005 an appointment of the CMS Steering Team (pdf) was signed by the University Provost, the Provost for Medical Affairs at Weill Medical College, the Executive Vice President of Administration and Chief Financial Officer, the Vice President of Human Resources, and the Senior Vice Provost for Research. The appointment promotes and supports the work of the Steering Team and recognizes their broad campus representation as essential to the success of the CMS.
