Environmental Health & Safety Manual (EHS)

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Effective: 3/1/2007

Revised: 11/26/2012

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EHS 005: Management Policy

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Purpose

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To provide guidance to ASU faculty, staff, students, and volunteers with a framework for the development and implementation of university policies and procedures regarding compliance with federal, state, and local regulations for environmental protection (air, water, soil), occupational safety, public health, biological safety, fire safety, hazardous materials management, and ASU risk management requirements

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Source

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University policy

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Applicability

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This policy and management structure applies to all ASU campuses and all ASU activities. This policy is not intended to apply to ASU policies and procedures regarding public or personal security or crime prevention.

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Background

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The following principles have been established to guide faculty, staff, students, and volunteers in Environmental Health & Safety (EH&S) practices at ASU:

  1. comply with applicable laws and regulations and, where appropriate, other institutional guidelines and recommendations
  2. support ASU policies that place the institution at the forefront of quality initiatives promoting awareness and compliance at all levels of the institution
  3. practice personal accountability for responsible behavior within the ASU community
  4. participate in the development of sound institutional policies and regulations
  5. support university policies that place ASU at the forefront of environmental quality initiatives to reduce hazardous waste generation and conserve resources and move ASU toward an environmentally sustainable future

    and

  6. encourage those who do business with the university to apply these principles.

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Policy

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Through its teaching, research, and service, Arizona State University (ASU) will conduct its internal operations responsibly with respect to environmental health and safety and in compliance with all applicable laws and regulations.

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Procedures

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EH&S shall provide annual training for the departmental EH&S compliance officers and shall provide a manual of fact sheets for their reference. In addition, EH&S shall maintain a campus internet resource that shall include current ASU EH&S bulletins, safety and health information, and links to other appropriate regulatory agencies, material safety data, etc.

The director of EH&S, or a designee, shall maintain regular communications with the EH&S compliance officers and shall respond in a timely manner to all requests for advice or assistance.


Reporting

ASU is committed to investigating and appropriately reporting all environmental health and safety incidents. It is the responsibility of all employees of ASU to disclose fully any activity that may be or may result in a violation of any environmental health and safety regulation, and to participate cooperatively in the investigation and remediation of any incidents.

Any incident or questions regarding compliance should normally be reported to the environmental health and safety compliance officer at the college, school, or administrative department. In the event that the compliance officer is not available, incidents should be reported to the director of EH&S or the director’s authorized designee.


Enforcement

ASU views compliance with all applicable laws and regulations as a condition of employment, and violation of such requirements shall be considered grounds for disciplinary action, including termination of employment or suspension or expulsion for students.

Further, governmental agencies have established increasingly strict environmental health and safety regulations, which may include harsh civil penalties and individual criminal prosecution leading to possible imprisonment and substantial fines. Accordingly, ASU expects all faculty, staff, students, and those who use ASU property or resources to be vigilant in complying with all applicable environmental health and safety laws.


Responsibilities

A. Department of Environmental Health & Safety

Environmental Health & Safety (EH&S) is responsible for the administration of ASU EH&S policies and ensuring ASU’s compliance with all environmental health and safety regulations.

EH&S carries out its mission by providing technical, regulatory, and related management services to the colleges, schools, and departments who have a shared responsibility for operational accountability for regulatory compliance. EH&S assists the colleges, schools, and departments in the development and implementation of programs, including training, emergency response, and analysis of specific problems so that compliance is practical at the unit level.

EH&S is the unit responsible for all official ASU contact with external governmental regulatory agencies concerned with workplace environmental health and safety compliance. In consultation with the ASU Office of General Counsel, EH&S shall coordinate all ASU responses to regulatory agencies’ inquiries, complaints, lawsuits, and other formal proceedings.

By working with a Policy Committee, EH&S is instrumental in the design and implementation of an effective environmental health and safety program. EH&S reports to the executive vice president, treasurer and chief financial officer (CFO).

B. Colleges, Schools, and Other University Departments

It is the responsibility of each college, school, and administrative department to conduct its operations in accordance with all applicable laws and regulations, and to implement ASU’s environmental health and safety policies.

With the professional guidance and assistance of EH&S, these responsibilities include, but are not limited to:

  1. training
  2. informing employees about workplace hazards and safety procedures
  3. conducting inspections and correcting violations
  4. investigating incidents and employee complaints
  5. enforcing policies

    and

  6. appropriately documenting activities and processes.

Each dean and major operating unit director shall designate an EH&S compliance officer to be responsible for the coordination of operations within the colleges, schools, or major operating unit departments.

The EH&S compliance officer shall have delegated authority from the dean, chair, or director for managing environmental health and safety activities in the college, school, or department, including authority to establish procedures, investigate complaints and incidents, and audit performance.

The EH&S compliance officer will have the responsibility to report activities to the delegating authority as well as the director, EH&S. The departmental EH&S compliance officers serve as associates and adjuncts to EH&S professional staff within the scope of this policy.

C. ASU Environmental Health & Safety Policy Committee

The ASU EH&S Policy Committee serves as the primary source of policy guidance on all matters pertaining to environmental health and safety compliance and related regulatory developments. The ASU EH&S Policy Committee is responsible for recommending policies that will ensure compliance with current environmental health and safety regulations to the executive vice president, treasurer and chief financial officer (CFO).

The committee is charged with examining the gradations of response possible for a given environmental health and safety regulation and recommending what it believes to be the most appropriate course of action for the institution and its employees. In this context, the committee recommends ASU policy for approval by the executive vice president, treasurer and chief financial officer (CFO) and monitors regulatory developments and compliance.

The ASU EH&S Policy Committee is advisory to the executive vice president, treasurer and chief financial officer (CFO) and includes broad representation by members of the faculty and administration. The provost of the university, the senior vice president for Knowledge Enterprise Development, and the chief Human Resources officer or their designees serve on the committee to facilitate research and graduate faculty input on all committee issues.

D. Environmental Health & Safety Operations Committee

The EH&S Operations Committee is an institutional group of operations managers from the colleges, schools, and departments who work with the director of EH&S. The Operations Committee also evaluates ASU-wide environmental, health, safety, and loss prevention issues and proposes recommended policy actions to the Policy Committee.

The EH&S Operations Committee is also responsible for monitoring the external regulatory environment and ASU practices to identify problems and response strategies.

The EH&S Operations Committee is chaired by the director of EH&S.

Special Committees

Faculty-chaired committees overseeing aspects of the ASU EH&S program impacting research activities (Institutional Biosafety Committee, Radiation Safety Committee) shall maintain their role of faculty governance and shall report to and be appointed by the senior vice president for Knowledge Enterprise Development or designee. Additionally, the Institutional Biosafety Committee and the Radiation Safety Committee review research proposals relative to their field of expertise.

These committees and other non-faculty chaired EH&S committees will be responsible for recommending policies related to their area of program oversight to the Policy Committee.

E. ASU Faculty, Staff, and Students

It is the responsibility of individuals to conduct their activities at ASU in compliance with all applicable government, ASU, and department policies and regulations.

The success of ASU’s environmental health and safety management activities directly depends upon the active involvement of individuals through participation in training; abiding by established safety and environmental procedures; reporting hazards and potential violations of regulations; and recommending improvements.

ASU faculty, staff, students, and anyone using ASU resources or property shall follow established ASU EH&S policy and abide by federal, state, and local laws and regulations.

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