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ENVIRONMENTAL HEALTH & SAFETY MANAGEMENT POLICY

Introduction

Through its teaching, research and service as Arizona’s largest university, Arizona State University (ASU) is a prominent contributor to the policies and practices that enhance the global environment. It is therefore highly appropriate that ASU conduct its internal operations in the spirit of this leadership role, and in compliance with all applicable laws, regulations and appropriate recommendations.

All operations should be a model of quality in Environmental Health & Safety (EH&S) practices. The following principles have been established to guide staff, students and volunteers in these practices at ASU:

  1. Support ASU policies which place the institution at the forefront of quality initiatives which promote awareness and compliance at all levels of the institution;
  2. Practice personal accountability for responsible behavior within the ASU community;
  3. Comply with applicable laws and regulations and with appropriate institutional guidelines and recommendations;
  4. Participate in the development of sound institutional policies and regulations;
  5. Support ASU policies that place ASU at the forefront of environmental quality initiatives that reduce hazardous waste generation and conserve ASU resources; and,
  6. Encourage those who do business with ASU to apply with the principles.

Scope

This policy provides guidance to ASU staff, students and volunteers for the development and implementation of ASU 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 loss prevention. This policy is not intended to apply to ASU policies and procedures regarding public or personal security or crime prevention.

Management

ASU is a complex organization that consists of four campuses and remote sites that provides extensive support functions necessary to the operations of the institution. From the legal, regulatory and public perspectives, ASU is one corporate entity and is held accountable as such by federal and state authorities.

For these reasons, ASU has the responsibility to establish policies and provide resources that ensures compliance with all environmental, health and safety laws. For purposes of this responsibility the following structure is utilized:

A. Department of Environmental Health & Safety

The Department of Environmental Health & Safety (EH&S) is responsible for the administration of the campus policies and is accountable for ASU’s compliance with all environmental health and safety regulations. It carries out a mission that provides 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 ASU legal counsel, and as required representation by the Office of the Attorney General, EH&S coordinates all ASU responses to regulatory agencies' inquires, complaints, lawsuit 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 Vice President for University Administration and Legal Affairs.

B. Colleges/Schools and Other ASU 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, departments conduct training; inform employees about workplace hazards and safety procedures; conduct inspections and corrects violations; investigates incidents and employee complaints; enforces policies; and appropriately documents activities and processes.

Each Dean and major operating unit director designates an Environmental Health & Safety Compliance Officer to be responsible for the coordination of operations within the colleges/schools or major operating unit departments. The Environmental Health & Safety 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 Environmental Health & Safety Compliance Officer has the responsibility to report activities and unresolved compliance issues to the delegating authority as well as the Director of 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 ensures that ASU responds appropriately to assure compliance with current and potential environmental health and safety regulations. The Committee examines the gradations of response possible for a given environmental health and safety regulation and determining the most appropriate course of action for the institution and its employees. In this context, the Committee recommends ASU policy for approval by the President, and monitors developments to ensure that ASU policies are observed and remain current.

The ASU EH&S Policy Committee is chaired by the Deputy Vice President for University Administration, and includes broad representation by members of the faculty and administration.

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 to ensure that activities and services are efficiently provided to ASU. The Operations committee also evaluates ASU-wide environmental health and safety loss prevention issues and proposes recommended policy actions to the Policy Committee. The EH&S Operations Committee also monitors the external regulatory environment and ASU practices to ensure that problems are appropriately identified and response strategies developed.

The EH&S Operations Committee is chaired by the Director of EH&S. The EH&S Operations Committee reports through the Director of EH&S to the Deputy Vice President for University Administration.

E. Special Committees

Faculty-chaired committees oversees aspects of the ASU Environmental Health & Safety Program that impacts research activities (Institutional Biosafety Committee and Radiation Safety Committee) shall maintain their role of faculty governance and shall report to and be appointed by the Vice President for Research and Economic Affairs. Additionally, the Institutional Biosafety Committee and the Radiation Safety Committee review research proposals relative to their field of expertise. The Committees and other non-faculty chaired Environmental Health & Safety Committees recommends policies related to their area of program oversight to the ASU EH&S Policy Committee.

F. ASU Employees 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 the 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 employees and students shall follow established ASU EH&S policy and abide by federal, state and local laws and regulations.

Information and Assistance

EH&S provides annual training for the departmental EH&S Compliance Officers, and provides a manual of fact sheets for their reference. In addition, EH&S maintains a campus Internet resource that includes 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, maintains regular communication with the EH&S Compliance Officers and responds in a timely manner to all requests for advice or assistance.

Reporting

ASU investigates and appropriately reports all environmental health and safety incidents. It is the responsibility of all ASU employees to completely disclose 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. Employees and students who report incidents in accordance with applicable laws and ASU procedures, or who to raise questions or concerns about ASU's environmental health and safety procedures, will not be penalized by ASU and such action will not reflect adversely on the employee's or student's record.

Enforcement

ASU views compliance with all applicable laws and regulations as a condition of employment, and violation of requirements is considered grounds for disciplinary action, including termination of employment.

Furthermore, governmental agencies increasingly establishes strict policies that ensures compliance with environmental health and safety regulations; including, harsh civil penalties and individual criminal prosecution leading to possible imprisonment and substantial fines. Accordingly, ASU expects all staff and students to be vigilant in complying with all applicable environmental health and safety laws.

 

Updated 9/25/07

 


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Contact Email: EHS@asu.edu

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