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Policies and Procedures: Environmental Policies

Brown University General Environmental Health and Safety Management Policy Statement

Brown University is fully committed to protecting the environment and maintaining a safe and healthy campus and workplace. The following principles have been established to clarify the University’s commitment towards these goals:

1. Comply with all applicable environmental and safety laws and regulations and with specific University policies that address these laws and regulations

2. Minimize hazards to students, faculty, staff, visitors, and the general community.

3. Require those who do business with Brown and/or visitors who avail themselves of Brown University facilities to perform their work in a manner that adheres to all applicable laws and regulations, and protects the University.

4. Minimize waste through efficient use of resources and substitution.

Management

The University is responsible for compliance with all applicable laws, regulations, and policies relating to environmental health and safety. The University places the primary responsibility for compliance with these applicable laws, regulations, and policies with individual faculty, students and staff and its various departments and administrative units or their administrative officers, including responsible Senior Officers (Deans or Vice Presidents).

The University’s various Safety Committees are responsible for developing appropriate procedures for the University to be in compliance with federal and state regulations. The Office of Environmental Health & Safety is the conduit for communicating safety related compliance requirements, and for the implementation of the procedures outlined below.

Implementation

In furtherance of the principles defined above, Brown University has restated its Policies and Procedures on Safety in order to comply with all applicable environmental and safety laws and regulations by:

A. Reinforcing institutional accountability and promoting personal responsibility for environmental and safety standards and workplace conditions within the University community by:

• requiring PIs to affirm their understanding of and compliance with the University’s safety policies and procedures at the time of application and renewal of grants/contracts involving potentially hazardous substances or other regulated materials;

• making training a condition of employment or participation for those working with hazardous substances or other regulated materials and

• linking continuing pay and/or employment or participation to required training and response to inspections or assessment reports;

• making training and response to inspections or assessment reports a condition of obtaining course credit or degree completion when working with hazardous substances or regulated materials is a part of course or degree requirements;

• establishing appropriate sanctions for failure to secure required training or be responsive to laboratory inspections or assessment reports (see Enforcement and Sanctions section below);

B. Instituting periodic monitoring using a documented review process and strengthening the internal enforcement process to address the seriousness of findings with increasing mandatory employment sanctions and/or penalties up to and including termination of employment.

Enforcement and Sanctions

While the University acknowledges and accepts responsibility for compliance with all applicable laws, regulations, and policies regarding workplace safety, the University relies on the awareness of such rules and regulations by faculty, staff and students and their assurance that as members of the Brown community they will abide by them. The Office of Environmental Health & Safety is responsible for monitoring compliance and for making the appropriate supervisors and senior officer aware of violations. Imposition of sanctions and penalties by supervisors and senior officers will be in accordance with the following:

1. Students, Faculty and Staff: In order to both communicate this compliance expectation and to incorporate workplace safety into policies governing faculty, students and staff, the University has included compliance with workplace safety regulations into academic and administrative guidelines as well as employee manuals. Safety regulations are now (or will soon be) incorporated into the Faculty Rules and Regulations, the Handbook of Academic Administration, the Brown University Student Handbook and the Human Resources Policies and Practices manual. Sanctions for non-compliance with these and other university policies are set forth in these documents and guidelines, and include written reprimands, prohibition from entering certain workplace areas, inclusion of safety compliance performance in performance evaluations and salary determinations, transcript notations, probation, suspension, dismissal, expulsion, and termination.

2. Laboratories and Academic Units. Specific enforcement and sanction procedures that can be applied to a particular laboratory or academic unit in which safety regulations have been found to have been violated include:

  • Mandatory safety meetings
  • Re-training
  • Stop orders on purchases
  • Temporary shutdowns of laboratory facilities
  • Freezing of submission of grants/contracts.