Harvard University Environmental Health & Safety Policy

Introduction

Through its teaching and research, Harvard University is a prominent contributor to the development of practices and policies that enhance the global environment. It is the intent of Harvard to conduct its internal operations in the spirit of this leadership role, and in compliance with all applicable laws and regulations.

All operations should be a model of high-quality in environmental health and safety practices. The following responsibilities have been established to guide school and department faculty, staff, postdoctoral scholars, and students in their activities at Harvard:

  • 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 Harvard to perform their work in a manner that protects the University from environmental health and safety risks.

Management

Harvard University is a complex organization, 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. Consistent with its long-standing philosophy of decentralized management, the University places the primary responsibility for compliance with all applicable laws, regulations, and policies with its individual schools and departments, each under the direction of a responsible “Corporate Officer” (e.g., Provost, Dean, or Vice President).

From a legal, regulatory and public perspective, the University is one corporate entity (the legal name of the Corporation is “President and Fellows of Harvard College”). The University 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 Corporation has the responsibility to establish policies and provide resources to ensure compliance with all environmental health and safety laws and regulations. Harvard performs this function through the following structure:

University Environmental Health and Safety Policy Committee

The University Environmental Health and Safety Policy Committee (“Policy Committee”) serves as the primary source of leadership and policy guidance on all matters pertaining to environmental health and safety compliance and related regulatory developments.

The Policy 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 Department of Environmental Health and Safety (“EH&S”). The Policy Committee develops University policy recommendations for approval by the President, evaluates effectiveness of risk management strategies, and monitors the effectiveness of, and compliance with, University policies.

The Policy Committee provides an annual report to the President and Fellows of Harvard College, summarizing the status of environmental health and safety programs and risks affecting the University.

The Policy Committee is chaired by the Executive Vice President and includes broad representation by members of the faculty and administration. Members are appointed by the senior executive of their school or department for a renewable 3 year term; term appointments may be staggered to ensure continuity of membership.

Environmental Health and Safety Operations Committee

The Environmental Health and Safety Operations Committee (“Operations Committee”) serves as the primary stakeholder body to review and endorse the scope of services provided by EH&S to the University community. The Operations Committee seeks consensus among its membership to ensure consistency in approach and implementation of compliance programs and services throughout the University.

The Operations Committee reviews environmental health and safety risks and applicable regulatory requirements, standards and best practices. The Operations Committee consults with other University stakeholders, as appropriate, and advises EH&S in the development of plans, procedures and implementation strategies to ensure compliance and mitigate adverse impacts to the University.

The Operations Committee is chaired by the Vice President for Campus Services and includes Environmental and Safety Compliance Officers from the schools and administrative departments, the Director of Environmental Health and Safety, and EH&S staff support.

The Operations Committee may convene subcommittees to address stakeholder-specific functions or issues (e.g., laboratory safety, facility safety, new regulations, auditing processes). In addition to Operations Committee membership, subcommittees may include representation from the schools, departments or others with specific subject matter expertise. EH&S will facilitate and assist the subcommittees in their work.

Department of Environmental Health and Safety

The Department of Environmental Health and Safety 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, EH&S 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.

EH&S 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 Harvard;
  • 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

EH&S may also provide specialized, or dedicated operational services to schools and departments through expense recovery arrangements.

Schools, University Departments and Affiliated Units

It is the responsibility of the Senior Corporate Officer (e.g., Vice President, Dean) of each school, administrative department and affiliated unit 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 EH&S, 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 unit 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, EH&S 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 and Safety Compliance Officers

Each Dean and Vice President shall appoint an Environmental and Safety Compliance Officer (“Compliance Officer”) 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 Compliance Officer.

The Compliance Officer 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;
  • 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

Principal Investigators and Unit Managers

Principal Investigators and Unit Managers have the responsibility for the implementation, management and enforcement of a safe and compliant environment within their area of responsibility. Primary responsibilities include development of appropriate environmental health and safety procedures, periodic self-inspections, staff training and incident reporting.

Incident Reporting and Investigations

The University has the responsibility to investigate and appropriately report environmental health and safety incidents.

Employees, students, and others affiliated with the University have the responsibility to disclose any activity that may be, or may result in, a violation of any environmental health and safety regulation.

All personnel should immediately notify appropriate emergency responders (e.g. HUPD, local public safety, fire department, University Operations Center, or others) of any situation that may result in an imminent hazard to persons, property or the environment. Additional notification must be made to the Compliance Officer or unit manager. If the Compliance Officer is not available, incidents should be reported to the Director of EH&S.

Schools and departments retain the authority and responsibility for emergency management planning and response, consistent with the University Emergency Management Plan. In emergencies, schools and departments will utilize their Local Emergency Management Teams for incident notification, response and recovery. They may engage the resources of internal services providers (e.g. HUPD, EH&S, University Operations Center, UHS, etc) and external service providers as appropriate.

EH&S provides regulatory liaison, technical assistance and operational guidance as requested or required, and works with the school and emergency responders to establish safety and other criteria for resumption of normal operations.

All employees, students and others affiliated with the University are expected to fully cooperate, and participate as appropriate, in the investigation and remediation of any incidents.

Employees and students who report incidents in accordance with law and Harvard University procedures, or who raise questions or concerns about the University’s environmental health and safety procedures, will not be penalized by Harvard, and such action will not be recorded in the employee’s or student’s record.

Enforcement

Harvard University views compliance with all laws, regulations, and University policies as conditions of employment, and of academic eligibility. Violation of such requirements shall be considered grounds for disciplinary action, including termination of employment and/or enrollment status. The Corporate Officer has the responsibility and authority to implement such actions.

Governmental agencies have established strict policies to ensure compliance with environmental health and safety regulations, including civil penalties and individual criminal penalties leading to possible prosecution, imprisonment and substantial fines. Accordingly, the University expects all faculty, staff, postdoctoral scholars, and students and University affiliates to be vigilant in complying with all environmental health and safety requirements, and to acquire the information they need to properly conduct their activities at the University.

APPENDIX A

Role of the Environmental and Safety Compliance Officer

Each Dean or Vice President will appoint an Environmental and Safety Compliance Officer (“Compliance Officer”) who will have authority and responsibility for implementation, management, and enforcement of environmental health and safety compliance programs within the school, administrative department or affiliated unit.

A primary responsibility of the Compliance Officer is to establish the internal management, accountability and communication structures to implement and track environmental and safety requirements, status and related risks. The Compliance Officer will rely upon the support and guidance of EH&S in implementing these responsibilities.

A primary responsibility of the Compliance Officer is to establish the internal management, accountability and communication structures to implement and track environmental and safety requirements, status and related risks. The Compliance Officer will rely upon the support and guidance of EH&S in implementing these responsibilities.

Compliance Officer Duties:

  • seek the technical assistance and guidance of EH&S in understanding risks,
  • risk mitigation strategies, and environmental and safety requirements for the school, department or affiliated unit;
  • establish mechanisms (e.g. local safety committees, lab safety officers, facility manager networks) to implement and monitor compliance requirements;
  • ensure that personnel attend required training;
  • take appropriate action to halt any conditions that may result in imminent hazard to persons, property, or the environment;
  • notify the Dean or Vice President of unresolved compliance issues and situations involving potential safety hazards, exposures, accidents, injuries, illnesses, spills, releases or other regulatory or environmental issues;
  • notify the EH&S Director of any unresolved compliance issues and situations, and seek EH&S guidance in implementing corrective actions as needed; facilitate and promote the exchange of information within the school or department and with EH&S in the interest of collaborative problem solving and program improvement;
  • represent the school or department on the EH&S Operations Committee and participate in the development of strategies, policies and procedures for environmental and safety compliance management at Harvard; and
  • provide an annual briefing to the Dean or Vice President and the Director of Environmental Health and Safety on the school or department’s environmental and safety program status, trends and risks.