Although Bridgewater State University (BSU) is complying with state requirements for establishing recycling practices for disposal of its solid waste materials, improvements are needed in its administration of this activity. Lack of administrative procedures to ensure that BSU complies with state Executive Order 515 by integrating recycling practices at its facilities could result in improper waste-handling procedures that are detrimental to the environment.
Our audit testing disclosed the following:
- BSU’s management indicated that annual walkthroughs of recycling activities were performed as part of BSU’s control over the effectiveness of its recycling program; however, of the three annual walkthroughs performed by student managers in the recycling program during our 30-month audit period, only two were documented.
- The environmental health and safety officer could not produce 3 of the 33 signed hauler manifest forms2 for hazardous materials that were transported during our audit period. As a result, there was no documented chain of custody of these hazardous waste materials from the source of their generation to their ultimate recycling or disposal.
- Of the 10 hauler invoices for waste removal and related credits we reviewed (out of a total population of 30 invoices), 4 invoices lacked supporting documentation for the calculation of the credit deducted from the invoices.
- We examined 31 work orders (forms used to request unscheduled pickups of recyclables), out of 579 logged during the audit period, to determine whether the recycling process was documented completely. However, there were no written records documenting the initiation of work or the work performed, although the work was recorded in the logbooks. University officials indicated that work orders were initiated by phone calls, by emails, or in person, but they were not archived or documented in writing to support the logbooks.
- The recycling coordinator makes annual site visits to BSU’s primary recycling hauler to observe its practices and procedures. However, these visits were not documented in writing, and therefore any critique or evaluation of the strengths or weaknesses of the hauler’s handling of the university’s recycling requirements is not documented.
Section 12.01 of the Office of the State Comptroller’s Internal Control Guide states,
Managers and other staff in key roles should document internal control, all transactions and other significant events in a manner that allows the documentation to be readily available for examination. [Emphasis added.]
Section 7C of Executive Order 515 states,
Agencies shall ensure that they integrate increased recycling practices in the disposal of their own waste materials, including but not limited to paper, glass, cans, plastic bottles, containers and electronic equipment. This effort shall include the positioning of recycling bins in their offices and the contracting for recycling services to pick up and recycle these materials.
To ensure that the requirements of the executive order are fully implemented and adhered to, BSU needs to develop formal written policies and procedures that establish how this activity is to be administered and documented.
Reasons for Noncompliance
BSU has not established sufficient formal written policies and procedures that address all aspects of its recycling program.
BSU should establish sufficient formal written policies and procedures regarding its recycling program and establish monitoring controls to ensure that these policies and procedures are adhered to and that all activities related to this process are properly documented.
The results of the recycling bin location walkthroughs that were conducted by the University for the 30-month period under review were documented on a spreadsheet. During the audit period tested, Bridgewater State University implemented a policy change which was initiated during Fiscal Year 2016. This policy change included a ”commentary” section of the walkthrough. . . .
The University will review and implement an improved documentation system as it relates to hazardous materials that are transported. . . .
The methodology used to confirm the calculation of credits is performed through a third-party subscription which provides only two years of historical data. The University will consider the cost-benefit on expanding the subscription period with our vendor to view historical data or other methods of retaining historical data. . . .
Bridgewater State University will review and modify its policies and procedures, as necessary, to ensure that we are retaining recycling certificates as documentation of proper disposal of waste. . . .
The University will review and modify its policies and procedures to expand documentation that indicates the work ordered and the actual work performed for all work orders requested. . . .
The University has implemented practices beginning in 2017 that include documentation of the site visits and will continue this practice on a go-forward basis. . . .
BSU Policies and Procedures for Recycling Services and Refuse Removal Services . . . have been in place since 2010.
As noted above, although BSU had complied with state requirements for establishing recycling practices by having policies and procedures regarding its recycling activities in place since 2010, it needed to improve various aspects of its administration of this process, including its procedures and documentation.
We acknowledge that BSU gave the audit team some annual walkthrough and spreadsheet documentation for fiscal years 2016 and 2017; however, as previously noted, it was not able to provide the record of the annual walkthrough for fiscal year 2015. Further, although BSU asserts that it implemented a policy in fiscal year 2016 that included the completion of a commentary section for each walkthrough, the Waste Management (Solid Waste and Recycling) Unit of BSU’s Department of Facilities Management and Planning was not able to provide us with any commentary other than some emails related to the walkthroughs for fiscal years 2016 and 2017.
Based on its response, the university is taking measures to address our concerns.