Clarkson University Environmental Health & Safety Program Overview

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1 Clarkson University Environmental Health & Safety Program Overview Mission Clarkson University is committed to maintaining a safe living, learning, and working environment and to furnishing a workplace that is free from recognized hazards. It is the mission of the Risk Management and Environmental Health and Safety (EHS) Programs to provide a collaborative partnership with the campus community through managing risk, assessing and evaluating the environment, advocating safe work practices, and providing quality educational programs in order to facilitate and promote their work in a healthy and safe manner. Vision The vision of the EHS Program is to create a culture of health and safety on campus where all elements of EHS are fully integrated into all University programs and activities. It is the vision of Risk Management, EHS, and the University to incorporate a culture of a healthy and safe workplace and environmental stewardship and sustainability into the campus community. Faculty, staff, students and all other member of the Clarkson community have a responsibility in maintaining a safe and healthy work environment by attending training, knowing where to find information, and how to report an issue on campus. EHS Policy At Clarkson University, it is the responsibility of every employee and student to ensure a safe and healthy work environment. All members of the university community should be thoroughly familiar with their environmental, health, and safety (EHS) responsibilities, strive to follow EHS practices at all times, act proactively to prevent accidents and injuries, communicate hazards to supervisors, and be prepared for emergencies that may occur in the workplace or on campus. All operations should be a model of environmental health and safety practices. The following responsibilities have been established to guide faculty, staff, and students in their activities at Clarkson: minimize hazards to students, faculty, staff, and visitors; comply with all applicable environmental health and safety laws and regulations; complete required training; maintain personal accountability for responsible environmental and safety behavior within the University community; report hazards and potential violations of requirements; participate in the development of sound environmental health and safety policies and regulations; promote and encourage sustainability through efficient and appropriate use of resources; recommend improvements to support environmental and safety activities and participate in these efforts; and require those who do business with Clarkson to perform their work in a manner that protects the University from environmental health and safety risks. Roles & Responsibilities Clarkson University is an institute of higher education consisting of schools with academic and research missions, other affiliated centers and units, and the extensive support functions necessary to the operation of the institution. The University places the primary responsibility for compliance with all 1

2 applicable laws, regulations, and policies with its individual schools and departments, each under the direction of a responsible University Administrator (e.g., Provost, Dean, or Vice President). From a legal, regulatory and public perspective, the University is one corporate entity and is held accountable as such by federal and state authorities. The actions of the University's individual constituents are those of the entire Corporation. For these reasons, the University has the responsibility to establish policies and provide resources to ensure compliance with all environmental health and safety laws and regulations. University Administrators All University Administrators are responsible for ensuring that all employees reporting to them are aware of the Code of Business Conduct, are fully aware of the importance of compliance, and understand the procedures for reporting violations. Further, administrators are responsible for monitoring employee conduct through oversight of their department/unit business processes. The education, monitoring and reporting function are a critical responsibility of all University administrators and are an essential component of every administrator s managerial duties. Directors, Managers, Department Chairs It is the responsibility of the Directors, Managers, and Department Chairs to conduct operations in accordance with all applicable laws and regulations, and to implement the University's environmental health and safety policies. With the guidance and support of EHS, these responsibilities include, but are not limited to: ensuring appropriate training; informing employees, students, and visitors about workplace hazards and safety procedures; conducting inspections and audits; correcting violations; investigating incidents and complaints by employees and students; ensuring proper storage and disposal of hazardous materials; enforcing policies (including appropriately disciplining employees and students who violate environmental health and safety requirements); appropriately documenting activities and processes; and managing response to emergencies by obtaining, as needed, the assistance of appropriate internal or external resources Each school, administrative department and affiliated center maintains financial and operational responsibility for day-to-day management and implementation of its environmental health and safety programs. This includes support of specialized or ongoing operational services provided by its employees, EHS or others, responsibility for fines or penalties assessed by a governmental agency, remediation costs, and damages and expenses incurred as a result of judicial or administrative proceedings. Environmental Health & Safety Stewards Each Dean and Vice President shall appoint an Environmental Health & Safety Steward (EHS Steward) with responsibility for implementation, management, and enforcement of environmental health and safety programs within the school, administrative department or affiliated unit. The Dean or Vice President shall issue a letter of appointment outlining the authority and responsibility of the EHS Steward. The EHS Steward shall have the authority to: act on behalf of the Dean or Vice President to manage environmental health and safety activities in the school or department; establish procedures, investigate complaints and incidents, and audit performance; 2

3 require cessation of any activities that may pose an imminent hazard to persons, property or the environment; and commit financial and staff resources to ensure continued compliance with applicable environmental health and safety regulations. Employees and Students In order to promote and environmental health and safety culture, all employees and students need to actively participate in the EHS program. Employees and students are encouraged to report any unsafe acts or conditions, or any other hazards to their supervisor or appropriate office. Employees and students are responsible for assisting in making corrective actions from inspection and audit reports or by other request. Employees and students are responsible for attending all necessary trainings and follow University-wide programs and policies. Department of Risk Management and Environmental Health & Safety (RM & EHS) RM & EHS serves as the primary source of leadership in anticipating environmental health and safety requirements and risks, and developing mitigation strategies to minimize impacts to the University s people, academic and research enterprise, infrastructure and operations. In matters of regulatory compliance and safety, RM & EHS is authorized by the University to protect personnel and the environment. It is legally responsible for numerous permits, plans, regulatory filings and related matters, and works in collaboration with schools and departments to maintain effective standards and practices. RM & EHS will establish oversight, advisory, and compliance programs for monitoring campus operations and activities to ensure that adequate environmental health and safety measures are undertaken. Applicable health and safety standards promulgated by federal, state, and local agencies, as well as standing University policies, will be followed in establishing the criteria to assist units in compliance activities. In the absence of appropriate statutes and governmental regulations, the published standards of recognized professional health and safety organizations will serve as guides. RM & EHS implements this responsibility through close collaboration and consultation with University clients, and by providing technical, regulatory, and related management expertise. Core services provided to the University community include: identifying and assessing potentially hazardous operations and locations; evaluating existing or emerging environmental health and safety risks, regulatory requirements, standards, and best practices; developing institutional risk management strategies; providing training and awareness information to employees and students; monitoring hazards and risks, and auditing of control strategies; acting as the liaison to Environmental and Safety Compliance Officers, faculty, administrators, University committees and others involved in management of environmental health and safety risks at Clarkson University; serving as the University s primary liaison to environmental health and safety regulatory agencies; coordinating the University s response to regulatory agencies in matters of investigations, employee complaints, or potential or actual regulatory enforcement actions; and consulting with schools, departments, affiliated units and the Office of the General Counsel to ensure a unified and consistent University response to a governmental inquiry, complaint or lawsuit. 3

4 Committees Enterprise Risk Management Committee (formerly the Compliance Committee) The Enterprise Risk Management Committee (ERM), inception date January 2005, is guided by the Code of Business Conduct, and is intended to assure Clarkson s commitment to the highest standards of conduct and compliance by assuring that all employees are aware of their responsibilities in establishing an environment which is based on ethical behavior and full compliance with applicable laws, regulations, standards, and University policy. The ERM Committee serves as the primary source of leadership and policy guidance on all matters pertaining to regulatory compliance. The organizational structure of the ERM Committee is listed in Chart 1. CHART 1 Enterprise Risk Management Committee Co-Chairs: Anthony Collins & Nancy Kin Environmental Health & Safety Subcommittee The University Environmental Health and Safety (EHS) Committee serves as the primary source of leadership and policy guidance on all matters pertaining to environmental health and safety compliance and related regulatory requirements. The EHS Committee is responsible for monitoring environmental health and safety risks to the University and for confirming the availability of adequate resources to assure compliance with environmental health and safety regulations and standards. The Committee is apprised of regulatory developments and related risks by the University s Risk Management Department and Environmental Health & Safety Manager. The EHS Committee develops University policies and procedures, evaluates effectiveness of risk management strategies, and monitors the effectiveness of, and compliance with, University policies. The Policy Committee is co-chaired by the University Health & Safety Officer and the Director of Facilities and Services. Members include representation from Risk Management, Environmental Health & Safety, Campus Safety, Student Affairs, Facilities & Services and Faculty. Reporting Health or Safety Hazard 4

5 If you believe there is an immediate danger to the health or safety of yourself or others, call Campus Safety & Security at (or, from a campus telephone x6666). If there is no immediate danger to the health or safety of yourself or others, but you believe there is an ongoing or potential hazard that may need attention, contact your supervisor. If the problem cannot be remedied by a supervisor, or a supervisor is not available, contact the Risk Management Office ( ). Accident or Injury Follow the University s Accident Reporting Procedure, which can be found at Auditing Program The University has a responsibility to self-monitor the effectiveness of EHS programs as well as verify its compliance level to applicable laws and regulations. Audits can be focused on one subject matter such as Hazardous waste, they can be limited to one faculty or services or they can be tailored to meet special requirements such as those applicable to research grants. The purpose of the audits is to confirm what mechanisms are working properly, and identify activities that need improvement to meet University and/or legal requirements. Clarkson University s auditing program consists of a multiple tiered approached for inspection and evaluation of all the Environmental, Health and safety programs. Self-Auditing: Faculty, Department managers/chairs, and University Administration should conduct routine self-audits to ensure that safety and health programs are followed and to determine if corrective actions are needed. If deficiencies are noted during self-audits, work orders can be placed to have corrections addressed. RM&EHS are available to provide guidance, as needed. Internal Inspections: EHS conducts regular inspections of buildings, laboratories, renovation and construction projects, and other campus areas. The scope and frequency vary depending on the program. A written inspection report is provided to the manager or responsible party for that area. The report lists corrective actions for each finding as well as recommendations on how to make corrective actions. Program Audits: Periodically EHS audits EHS programs on campus. Audits can be more comprehensive than an inspection and a designed to evaluate one or more programs, rather than a specific location. Audits are presented to the EHS Committee for review and recommended best management practices. Program audits may also be conducted by an outside organization. Agency Inspections: EHS regulatory agencies conduct both planned and unannounced inspections of University facilities and operations. Regulatory agencies including, but are not limited to, U.S. Environmental Protection Agency, U.S. Occupational Safety and Health Administration, N.Y. Department of Environmental Conservation, N.Y. Department of Labor, and N.Y. Office of Fire Prevention and Control. When an inspection takes place, a representative from RM&EHS escorts the agency inspector during an inspection on campus. RM&EHS also coordinates any inspection exit meeting. Inquiries from Regulatory Agencies 5

6 If you receive an inquiry from any regulatory agency regarding health and safety, direct the individual to the Risk Management Office. Examples of these agencies include, but are not limited to: the Centers for Disease Control and Prevention (CDC); the National Institutes of Health (NIH); New York State Department of Environmental Conservation (NYSDEC); the United States Environmental Protection Agency (USEPA); the Occupational Safety and Health Administration (OSHA); the United States Department of Labor (USDOL); the United States Department of Transportation (USDOT); and the United States Nuclear Regulatory Commission (USNRC). Disciplinary Policy All safety rules, procedures, and plans in effect at this University shall be followed. If they are willfully violated, the violating employee will be penalized and disciplinary action will be taken. The severity of the penalty will be in direct correlation to the severity of the safety violation. The list of possible disciplinary actions includes: Verbal reprimand: An informal discussion of the incorrect behavior should take place as soon as possible after the supervisor has knowledge of the safety misconduct. Written reprimand: A written form documenting the safety misconduct, to be presented to the employee and placed in the employee's personnel file. Suspension: A period of time during which the employee is debarred from the function of attending work and during which the employee is not paid. Dismissal/termination of employment: The permanent separation of an employee from the University, initiated for disciplinary reasons, safety misconduct. All safety rules, procedures, and plans in effect at this University shall be followed. If they are willfully violated, the violating employee will be penalized. EHS Programs Occupational Safety Industrial Hygiene: Continuous attention must be paid to the identification, monitoring, and control of potentially harmful substances and physical agents in the campus environment. This program includes formal safety partnerships with University departments to provide continuous identification and correction of factors that contribute to the incidence of an incident, injury, or other detrimental effect. The program includes comprehensive services in industrial hygiene, personal protective equipment (including respiratory protection), exposure assessments, confined space entry, indoor air quality, hearing conservation, and more. The scope also includes injury/illness prevention programs, safety education programs, safety reviews, OSHA compliance, building inspections, shop safety, ergonomic assessments, and design plan review. Program priorities for the protection of university personnel will be work site evaluations, safety education, and engineering controls. Asbestos Program: This program includes establishment of campus procedures, identification, evaluation, and monitoring of the university asbestos program. RM&EHS will provide oversight and advice to departments and units regarding all campus asbestos matters, including identification of asbestos materials, OSHA and NYS DOL compliance, building surveys, project design, project monitoring, air monitoring, exposure assessment, and educational programs. Construction Safety Program: EHS works closely with the University Engineer, Construction Project Manager, and the Contractor on a comprehensive safety program on construction sites 6

7 on campus. This includes close coordination with construction project managers to ensure that construction site activities and projects are conducted in a safe manner. Safety programs include: site safety, contractor safety, excavation/trenching, design plan review, traffic/pedestrian safety, OSHA compliance and accident investigation. The design and construction of new campus buildings or alterations to existing university facilities must, at a minimum, comply with the regulations of federal OSHA, New York State and, if applicable, the city, town, or village in which they are located. Environmental Protection Technical evaluation of external environmental concerns in areas such as point source emissions, water quality, toxic emissions inventory and control, pesticide management, and aboveground storage tanks are included in the environmental programs of the University. RM&EHS must work with government regulatory agencies, obtain necessary permits, and coordinate university needs and interests. RM&EHS also work to prevent and resolve environmental problems, and maintain effective compliance monitoring programs. Laboratory Safety Laboratory Safety: This program includes comprehensive oversight in laboratory safety, facility design, training for safe laboratory practices and compliance with laboratory safety regulations. Specific programs address the following areas: Use, storage and disposal of hazardous materials Development of lab safety programs Waste minimization Fume hood evaluations Assistance with laboratory renovations Plan reviews Hazardous Materials Management and Emergency Response: EHS maintains chemical and radioactive waste material disposal programs servicing the Clarkson campuses to ensure the collection, transport, recycling, documentation and disposal of unwanted hazardous material in the most environmentally safe manner. EHS, as a part of the University Emergency Response team, also provides emergency response services for chemical, radioactive, and bio-hazardous material spills on campus property. Radiation Safety Program: This program includes provision of services and monitoring compliance with applicable regulations and appropriate standards associated with the use of radioactive materials and radiation-producing devices. All provisions of licenses and permits from the U.S. Nuclear Regulatory Commission and the New York State Departments of Health and Environmental Conservation must be observed and enforced. All external and internal exposures to radiation and all releases of radioactive materials to the environment must be kept below the applicable regulatory limits as well as low as reasonably achievable (ALARA). Non-Ionizing Radiation: Current industry-wide safe practices and procedures will be adhered to regarding laser safety for university personnel and the general public. Accepted safety practices will also be observed for other non-ionizing radiation such as microwaves and extremely low frequency electrical and magnetic fields. Biological Safety: EHS works with departments to coordinate a biological safety program for the campus. Applicable regulations and accepted standards governing the use, storage, and disposal of hazardous biological substances must be observed. Conscientious surveillance must 7

8 be maintained and appropriate resources and technology applied to the handling of biohazardous substances, consistent with regulatory controls and university policy. Alcohol Purchase Program: Clarkson University, as a not-for-profit institution, has a permit through the U.S. Bureau of Alcohol, Tobacco, Firearms and Explosives, to purchase alcohol for use in the laboratories as tax exempt. All purchases of Alcohol must be purchased through the university purchasing system. Controlled Substances: The University maintains a controlled substances license in order to purchase and use these materials for research. Strict adherence to the U.S. Drug Enforcement Agency s regulations must be completed by each researcher using controlled substances. Infection Control Continuous attention must be paid to maintaining a campus environment that observes accepted infection control practices in order to reduce the risk of spreading infections. RM&EHS coordinate with the University Student Health Center Director and members of the Pandemic Committee to meet and review Clarkson s infection control program. The program includes, but is not limited, to hand hygiene, cleaning/disinfection/sterilization, vaccination and recordkeeping, monitoring outbreaks, and trending illnesses. Fire Safety & Prevention Program activities must be sustained that serve to protect life and minimize the risk of injury and property damage from fire. Facilities and equipment must be inspected, maintained, occupied, and operated in compliance with applicable regulations and accepted standards for fire protection and life safety. Program activities include fire safety education, inspection and testing of fire extinguishers, fire detection and suppression equipment, fire evacuation drills, monitoring and enforcement of code compliance at special events and classroom activities, response to campus fire alarms, and emergency response services. Emergency Preparedness & Response Preparedness programs must be developed and maintained by all University Department to facilitate appropriate technical response to campus emergencies and disasters and to provide for the coordination of diverse response organizations and activities. 8

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