Brown University Environmental, Health and Safety Management Policy
1. Goals
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:
a. Comply with all applicable federal and state environmental and safety laws and regulations. Comply with specific University policies that address these laws and regulations as applicable.
b. Eliminate and/or control hazards to students, faculty, staff, visitors and the community.
c. 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, regulations and University policies to protect themselves and the University.
d. In accordance with Brown University’s sustainability goals, Brown University will minimize its energy use, reduce negative environmental impacts and promote environmental stewardship. Brown will use the opportunities created by these actions to further its educational, research and service missions.
2. Management
The University is responsible for compliance of applicable laws, regulations and policies relating to environmental, health and safety. These are the responsibility of individual faculty, staff, students and the various departments and administrative units or their administrative officers, including responsible Senior Officers (Deans or Vice Presidents).
The University’s Safety Committees are responsible for working with the Office of Environmental Health and Safety (EHS) to develop and enforce appropriate procedures to maintain compliance with federal and state safety and environmental regulations as well as ensuring the safety of the Brown University community. EHS is the conduit for communicating compliance requirements and for the implementation of the procedures outlined below.
3. Implementation
Brown University maintains procedures to support compliance with applicable environmental and safety regulations and supports these principles by:
Reinforcing institutional accountability and promoting personal responsibility for environmental and safety standards and workplace conditions within the University community by:
a. Requiring responsible individuals (PIs, Lab Managers, Faculty, Staff, etc.) to affirm their understanding of, and compliance with EHS policies at the time of application and renewal of grants/contracts involving potentially hazardous substances or other regulated materials;
b. Making completion of training a condition of employment or participation for those working with hazardous substances or other regulated materials;
c. Linking continuing pay and/or employment or participation to required training and response to inspections or compliance reports;
d. Making training and response to inspections or compliance 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;
e. Establishing appropriate sanctions for failure to complete required training or be responsive to laboratory inspections or compliance reports (see Enforcement and Sanctions section below);
f. Performing periodic inspections and monitoring to document issues and formalize the internal enforcement process to address findings with increasing mandatory sanctions and/or penalties up to and including termination of employment.
4. Enforcement and Sanctions
The University acknowledges and accepts responsibility for compliance with all applicable federal and state laws and regulations for workplace safety and environmental protection. The University relies on faculty, staff and students to understand established University procedures to make safety, environmental protection and sustainability a part of the Brown culture. EHS is responsible for working with the Brown community in establishing and refining those procedures, monitoring compliance and ensuring appropriate supervisors and senior officers are aware of environmental, health and safety issues. Sanctions and penalties by supervisors and senior officers will be in accordance with the following:
a. Faculty, Staff and Students: 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. Sanctions for non-compliance with these and other university policies are set forth in Faculty Rules and Regulations, the Handbook of Academic Administration, the Brown University Student Handbook and Human Resources Policies. These documents and guidelines 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.
b. Specific Operations: Enforcement and sanction procedures that can be applied to a particular operations (e.g., laboratory, academic unit) in which compliance with environmental or safety regulations have been found deficient include:
- Mandatory safety meetings;
- Mandatory re-training;
- Stop orders on purchases;
- Temporary shutdowns of facilities; and
- Freezing of submission of grants/contracts.