ENVIRONMENT AND SAFETY PLAN

A. Overview

This Environment and Safety Plan identifies the roles, responsibilities, communications networks, training programs, and other mechanisms by which the Faculty of Arts and Sciences (FAS) seeks to ensure the safety of its personnel and the environment in all of the Faculty’s diverse activities. These include, but are not limited to, laboratory and non-laboratory research, academic instruction, administrative activities, the operations and management of facilities by University personnel and contractors, and the disposal of wastes. The Plan aims to ensure that the Faculty’s programs are integrated across students, staff, and faculty, and across units of the Faculty.

Within the Faculty, as in other parts of the University, primary responsibility for safety and environmental compliance lies in the hands of Environmental and Safety Compliance Officers ("ESCOs") who report to the Administrative Dean of FAS. The ESCOs work with a Committee on the Environment and Safety (CES). They, and other members of the Faculty, can call upon the Environmental Health and Safety Department (EH&S) for technical and operational support.

B. Responsibilities of the Office of the Dean

The Dean of FAS provides the leadership to ensure that an effective safety program is in place. The Dean appoints the Committee on Environment and Safety and the ESCOs.

1. Committee on Environment and Safety (CES)

Purpose: The mandate of the CES is to advise the ESCOs, the Faculty, and the Administration and to assist them in:

• Identifying and reducing risks to personnel, property, and the environment; and
• Assuring compliance with the requirements of regulatory and grant-funding organizations

Membership: Ordinarily, the Committee will be chaired by the Administrative Dean or his or her designee and include the ESCOs, representatives of the Faculty administration, the Director and Associate Director of EH&S, and others the Dean may invite.

Responsibilities:

• Advising the ESCOs and the FAS administration on environmental and safety policies and risks to members of the Harvard community
• Advising and assisting the ESCOs and the FAS administration on mechanisms for communicating this information through written and electronic notices and documents, meetings, periodic training sessions, and other appropriate mechanisms
• Recommending improvements in the safety and environmental programs, including education and training programs

2. Environmental and Safety Compliance Officers (ESCOs)

Under the authority delegated by the Dean of the Faculty of Arts and Sciences through the Administrative Dean of the Faculty, the ESCOs bear primary responsibility for promoting and maintaining a safe, healthful, and environmentally sound workplace. Their specific duties include:

• Implementing the recommendations of the CES
• Identifying personnel or property at risk of exposure to particular safety or environmental threats
• Informing students, faculty, and administrators of safety and environmental program requirements and assuring that they are followed
• In consultation with the Administrative Dean, ensuring that technical and financial resources are sufficient to conduct safety and environmental programs that meet regulatory requirements and Harvard's standards
• Periodically updating the Dean, through the Chair of the CES, of the status of environmental and safety programs throughout the Faculty
• Reviewing procedures for responding to emergencies and assessing hazards

C. Responsibilities of Department Chairs

Chairs are responsible for environment and safety programs in their departments. The Chair of a large department may delegate to a Laboratory Director, a Department Administrator, or some other suitable official the day-to-day responsibility for facilitating safety and environmental programs in the department. The Chairs of departments in which chemicals are used must appoint Chemical Hygiene Officers ("CHOs") to help them coordinate laboratory safety policies and procedures. Chairs’ responsibilities include:

• Maintaining up-to-date lists of personnel working in their departments for use in tracking and documenting that environment and safety training requirements are satisfied
• Maintaining a list of Group Safety Coordinators (see below) and providing a forum where they can exchange information on safety and environmental issues
• Ensuring that required training records of departmental personnel are maintained either by the department or by EH&S
• Communicating compliance issues to those in charge of laboratories or to their Group Safety Coordinators
• Coordinating departmental responses to compliance matters such as new regulations, inspections, regulatory violations, etc.
• Conveying information about safety and environmental issues appropriately (to departmental personnel, ESCOs, and the CES)
• Coordinating the implementation of office ergonomics, Hazard Communication, and other safety and environmental programs for students, staff, and faculty

D. Responsibilities of Faculty and Other Supervisors

1. All Research Supervisors

Faculty members and others with supervisory responsibilities are expected to promote safe and environmentally responsible practices by:

• Ensuring that their students and staff members receive the training and equipment that they need to protect their safety and their environments and to comply with environment and safety requirements. Safety and environmental issues are not limited to laboratories (for which extra precautions are noted below). Obstacles, lighting, and precautions against repetitive stress injuries are of concern to everyone.
• Exchanging safety and environmental information at appropriate meetings
• On request, providing ESCOs and the CES with relevant information on their activities and effective means for implementing safety and environmental requirements

2. Special Responsibilities of Research Supervisors in Charge of Laboratories

Individuals with overall responsibility for teaching and research laboratories must take additional special steps to implement safety and environmental programs in their laboratories. These responsibilities include ensuring that:

• Laboratory staff receive required safety and environmental training
• Personal protective equipment assessments are performed and documented
• Periodic self-assessments of the laboratory are performed
• Safety equipment is used properly and maintained appropriately
• Plans for eliminating safety hazards and instances of environmental non-compliance are implemented
• Laboratory personnel are accountable for their performance on matters of the environment and safety
• In laboratories in which chemicals are used, a copy of the Chemical Hygiene Plan is readily available

A qualified laboratory employee, designated as a "Group Safety Coordinator," may help a research supervisor carry out his or her responsibilities. Assigning duties to such an assistant does not reduce the supervisor’s responsibility for laboratory conditions. Often, through department Safety Committees, Group Safety Coordinators convey information from CHOs and Laboratory Directors to laboratory workers. Their responsibilities may include:

• Serving as points of contact for safety and environmental communications and concerns within the laboratory, and coordinating follow-up actions
• Implementing and monitoring self-assessment programs
• Ensuring that laboratory personnel are informed of required training or other activities
• Ensuring that all required safety equipment and documentation are available and properly maintained
• Requesting technical expertise from EH&S to assist with corrective action plan implementation
• Routinely advising research supervisors of areas of actual or potential non-compliance in the laboratory, and tracking remedial efforts
• Informing CHO or department Safety Committee of potentially hazardous situations

E. Responsibilities of Staff and Students

Every individual is responsible for conducting his or her activities at Harvard in accord with all applicable government, University, and departmental policies and regulations. Failure to abide by established environment and safety procedures, to participate in training, and to report hazards and violations are serious matters. Everyone can contribute to a safe and sound environment by complying with regulations and recommending improvements.

F. Responsibilities of the Department of Environmental Health and Safety

A central responsibility of EH&S is to give laboratory personnel guidance and technical support in implementing safety and environmental programs. EH&S fulfills a quality assurance role by giving PIs, ESCOs, and the CES timely and accurate information on the status of implementation programs and program trends. Under the guidance of the CES, EH&S develops plans to correct significant program deficiencies. These corrective action plans are reviewed, modified, and forwarded by the CES to the Dean of FAS for review, approval, and dissemination. The responsibilities of EH&S include:

• Advising the ESCOs and departments on, and assisting with the development of, appropriate safety and environmental programs that conform with established policies, regulations, and standards
• Providing training, technical assistance, and other services
• Developing self-assessment tools for use by laboratory personnel, and guiding them in the use of these tools
• Periodically informing the FAS community of significant safety or environmental issues
• At the request of ESCOs, periodically reviewing and following up on self-assessments provided by PIs or Group Safety Coordinators
• At the request of Department Chairs or PIs, sending EH&S representatives to provide on-site technical assistance
• Periodically giving the CES a summary of observations and recommendations based on the self-assessment results
• Maintaining appropriate documentation of environmental and safety policies and programs, including records of training, inspections, and hazardous waste disposal