Environmental Health and Safety Policy

Purpose

The purpose of the Environmental Health & Safety policy is to formalize the University of Dayton’s commitment to provide a safe and healthy environment for all students, faculty, staff and visitors of our campus community and to define a strategy for achieving and maintaining university-wide compliance with all environmental, health, and safety laws and regulations.

Scope

The University of Dayton (University) is committed to providing a safe and healthy environment for all members of the campus community. All University activities are to be conducted in a manner that ensures the protection of students, faculty, staff, visitors, property, and the environment.

Policy History

Effective Date:  January 25, 2016

Approval:  February 9, 2023

Policy History: 

• Approved in Original Form: January 25, 2016
• Approved as amended:  February 9, 2023

Maintenance of Policy: Assistant Vice President for Compliance, Environmental Health & Safety, Division of Audit Risk and Compliance.

Policy

It is University policy to comply with all applicable health, safety and environmental protection laws, regulations and requirements. To meet this standard of excellence, the University implements management initiatives and best practices to systematically integrate health, safety, and environmental considerations and sustainable use of natural resources into all activities. This policy provides a framework of compliance with applicable federal, state and local regulations and University policies, programs and procedures.

I.  ROLES AND RESPONSIBILITY

1. President, Provost, Vice Presidents are responsible for:

• The University President has the ultimate responsibility for environmental, health and safety programs for the University.
• Under the authority delegated by the President, the Executive Administration (Provost and Vice Presidents) provides appropriate financial and organizational support to assure operations are conducted safely and in compliance with applicable environmental, health and safety laws and regulations.
• Executive Administration (Provost and Vice Presidents) approves and authorizes the implementation of policies and programs for safety and compliance including the establishment of consequences for non-compliance as well as unsafe acts or creating unsafe working conditions.

2. Associate and Assistant Provosts, Deans, Chairs, Department Heads, Directors, Division Heads and Group Leaders are responsible for:

• Providing a safe and healthful environment in those areas and for those employees, students and others for whom they have supervisory or administrative responsibility, incorporating safety and health as an integral part of their activities.
• Promoting compliance with EHS programs, policies, procedures and guidelines in their work units or areas.
• Supporting the need for any corrective action to remedy health and safety deficiencies identified in their areas of responsibility.
• Appointing sufficient safety coordinators to perform the responsibilities to cover all of their areas of responsibility.
• Complying with EHS requests to cease any University-related activity which presents an unreasonable health or safety risk to University employees, students or visitors.

3. Environmental Health & Safety (EHS) are responsible for:

• Providing leadership to develop and implement EHS policies, programs and procedures; see Appendix A.
• Providing technical resources, staff support, advice, and consultation to University leadership, safety coordinators, managers and supervisors concerning EHS issues.
• Formulating and drafting for review, policies, procedures and guidelines necessary to implement the environmental health and safety programs under its jurisdiction.
• Monitoring University compliance and the effectiveness of EHS programs.
• Maintaining and centralizing EHS records, including training logs, inspection reports, compliance reports, and other health and safety record information.
• Investigating identified hazards and recommending actions to correct deficiencies.
• Implementing and communicating EHS policies, written programs and guidelines to all working units.
• Acting as the University liaison with governmental and regulatory agencies regarding environmental health and safety matters.
• Ceasing any University-related activity which presents an unreasonable health or safety risk to University employees, students or visitors.

4. Safety Coordinators and Safety Committees

Safety Coordinators and Committees are appointed by Deans, Directors, or Department Heads and are critical to the effective implementation of the EHS/RM program and ensuring University compliance.

They are responsible for:

• Coordinating with EHS.
• Assisting the Dean, Director or Department Head in the communication, development and implementation of required EHS Programs.
• Assisting the Dean, Director or Department Head in the identification and implementation of required training programs for employees.
• Reviewing environmental health and safety activities.
• Coordinating appropriate training for staff, faculty, students, visitors and volunteers in their areas.
• Assisting EHS in conducting periodic inventories and inspections.
• Preparing written reports, recordkeeping and recommendations as needed to assist in compliance with EHS programs.
• Assisting with incident or near-miss incident follow-up investigations.
• Providing assistance to correct identified deficiencies.

5. Managers, Supervisors, Faculty, Group Leaders and Principal Investigators are responsible for:

• Implementing compliance with EHS policies, programs, procedures and guidelines as they relate to their operations.
• Providing all of their employees and students with the appropriate training requirements as well as instruction regarding general safe work practices and instructions specific to their job duties. Such education and training shall take place prior to assignment to potentially hazardous activities. See the University of Dayton Safety Training Policy.
• Completing documentation of all EHS training of employees and students in their areas of responsibility is maintained.
• Developing and maintaining an inventory of hazardous materials present in all work areas within their areas.
• Posting appropriate safety notices and/or procedures in noticeable locations.
• Developing methods, as appropriate, to inform outside contractors and/or University maintenance personnel working in areas under their supervision of the hazards to which those employees may be exposed.
• Reviewing accident and injury reports for their area(s).
• Promptly notifying EHS when they become aware of a violation of any University, State or Federal environmental health or occupational safety rule or regulation.
• Seek assistance from EHS for safety or environmental issues identified in their areas.
• Complying with EHS requests to cease, any University-related activity which presents an unreasonable health or safety risk to University employees, students or visitors.

 6. Employees are responsible for:

• Reading, understanding and complying with EHS policies, procedures and guidelines governing their activities.
• Prompt reporting of unsafe conditions, environmental hazards as well as injuries and illnesses to the responsible supervisor or program director.
• Completing all required EHS training.
• Asking questions of their supervisors when there is a concern about an unknown or potentially hazardous situation.
• Conducting themselves in a manner which promotes safety and avoids unsafe or unhealthful conditions.
• Using common sense and good judgment at all times to avoid potential hazards that may exist or be created in the work environment.

7. Students and visitors are responsible for:

• Following all safety instructions in the use of facilities, equipment and hazardous materials.  
• Reporting injuries, safety incidents, hazardous work conditions and near misses to their supervisor or appropriate faculty member/University representative.

II.  ENFORCEMENT AND RESPONSE TO NON-COMPLIANCE

The primary responsibility for the environmental health and safety of the workplace belongs to each University employee. However, employees functioning in a supervisory role have a heightened responsibility to ensure that safe conditions, practices and training are provided and followed within their areas of control. Members of the campus community shall cooperate fully with all aspects of the EHS policies and programs. Failure to comply with established EHS policies, programs and procedures can lead to University disciplinary action under the general rules of conduct of all University employees, applicable collective bargaining agreements and the University student Conduct Code. 

Applicable Regulations and Regulatory Agencies

1. Occupational Health and Safety (OSHA)
2. Environmental Protection Agency (EPA)
3. National Fire Protection Agency (NFPA)
4. Nuclear Regulatory Commission (NRC)
5. Ohio Department of Health (ODH)
6. Regional Air Pollution Control Agency (RAPCA)
7. Dayton Fire Department (DFD)
8. Ohio Building Code (OBC)
9. Department of Homeland Security (DHS)
10. Department of Transportation (DOT)
11. Comprehensive Environmental Response
12. Compensation and Liability Act (CERCLA)
13. Superfund Amendments and Reauthorization Act (SARA)
14. Higher Education Opportunity Act (HEOA)
15. Spill Prevention
16. Control and Countermeasure (SPCC)
17. Department of Labor (DOL)

Reference Documents

1. Appendix A: Health and Safety Programs
2. Asbestos Management Policy
3. Hazardous Materials Management Policy
4. Fire Safety and Evacuation Policy
5. Laboratory and Technical Area Safety Policy
6. Safety Training Policy
7. Open Flame Policy
8. Emergency Eyewash and Shower Installation and Maintenance Policy
9. Integrated Health & Safety Manual