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i. SAFETY AT PRINCETON UNIVERSITY
Princeton University Environmental
Health and Safety Policy
Adopted October 17th 2001
Princeton University is committed to providing a safe and healthful
environment for its employees, students and visitors and managing the
University in an environmentally sensitive and responsible manner.
We further recognize an obligation to demonstrate safety and environmental
leadership by maintaining the highest standards and serving as an example
to our students as well as the community at large.
The University will strive to continuously improve our safety and environmental
performance by adhering to the following policy objectives:
- developing and improving programs and procedures to assure compliance
with all applicable laws and regulations
- ensuring that personnel are properly trained and provided with
appropriate safety and emergency equipment
- taking appropriate action to correct hazards or conditions that
endanger health, safety, or the environment
- considering safety and environmental factors in all operating decisions
including planning and acquisition
- engaging in sound reuse and recycling practices and exploring feasible
opportunities to minimize the amount and toxicity of waste generated
- using energy efficiently throughout our operations
- encouraging personal accountability and emphasizing compliance
with standards and conformance with University policies and best practices
during employee training and in performance reviews
- communicating our desire to continuously improve our performance
and fostering the expectation that every employee, student, and contractor
on University premises will follow this policy and report any environmental,
health, or safety concern to Princeton University management.
- monitoring our progress through periodic evaluations
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The EHS Mission
The mission of the Environmental Health and Safety Office is to provide
health and safety services to the University community through technical
support, information and training programs, consulting services, and
periodic auditing of health and safety practices and regulatory compliance.
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Responsibility for Safety
Department Chairs, Heads of Offices, Directors of Programs, Laboratory
Directors, Principal Investigators, managers, supervisors, foremen,
etc. are responsible for the health and safety of employees engaged
in activities under their direction or supervision. They must ensure
that their employees comply with all relevant regulations and
accepted standards and that work activities are performed in a safe
and considerate manner.
Each employee is responsible for complying with the applicable provisions
of health and safety standards and regulations promulgated by regulatory
agencies. They also must adhere to all University and departmental or
office safety policies and procedures and comply with safety directives
issued by their individual supervisors.
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Office of Environmental Health
and Safety
The Office of Environmental Health and Safety (EHS) serves the community
by providing technical support, information and training, consultation,
and periodic audits of health and safety practices and regulatory compliance.
The EHS staff comprises University employees working in a coordinated
effort to address health and safety issues in four broad areas: general
safety, chemical safety, radiation safety, and biosafety and sanitation.
An organizational chart listing primary responsibilities of the EHS
staff may be found on the following page.
General Safety addresses a number of issues affecting well-being in
the office, laboratory and shop. Chemical Safety involves our
Industrial Hygienists, who are concerned with the recognition, evaluation
and control of health hazards related to use of chemical and physical
agents. Radiation Safety provides services related to uses of
radioactive materials and radiation-producing equipment. Biosafety
and Sanitation includes services related to recognition, evaluation
and control of microbiological hazards and unsanitary conditions.
General Safety
(University Safety Engineer)
- Emergency Action Planning
- Personal Protective Equipment
- Material Handling and Storage
- Machinery and Machine Guarding
- Hand and Portable Power Tools
- Welding, Cutting and Brazing
- Electrical Safety, Lockout/Tagout
- Confined Spaces
- Ladders, Scaffolding, Fall Protection
- Compressed Gases, Cryogenics
- Construction, Excavation
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Chemical Safety
(Assistant Director for Laboratory Safety)
- Chemical Hazards
- Asbestos
- Chemical Fume Hoods and Laboratory Ventilation
- Chemical Waste Disposal
- Respiratory Protection
- NJ Right to Know
- OSHA Hazard Communication Standard
- OSHA Laboratory Standard
- Lasers
- Noise and Hearing Conservation
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Radiation Safety
(Health Physicists)
- Radioactive Materials (open and sealed sources)- All licensing,
registration, use and disposal
- Non-ionizing radiation, including Ultraviolet, Microwave
and RF Radiation
- Radiation Producing Machines and Devices, including x-ray
machines and electron microscopes
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Biosafety
(University Sanitarian)
- Food Protection and Sanitation
- Biological Hazards
- Insect and Rodent Control
- Animal Care Facility Sanitation
- Garbage, Refuse Storage and Removal
- Restroom and Recreational Sanitation including swimming pools
- Indoor Air Quality
- Lead Hazards
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Departmental Safety Managers
Many University departments have appointed a Departmental
Safety Manager to act as a liaison between the department and EHS.
In most academic departments, the department manager has taken on this
role. Individuals may contact the department manager or their
supervisor to determine who acts in this role in their department.
The Departmental Safety Manager has responsibility for oversight of
health and safety within the department and is a principal contact for
faculty, staff and students to address health and safety issues or concerns.
The Departmental Safety Manager works with faculty, management and supervisory
personnel in the department to identify potential hazards associated
with their operations and activities. The main objective is to
clearly identify and understand safety responsibilities, while providing
the means and authority necessary to carry out those responsibilities.
In some departments, the Departmental Safety Manager has assembled
a safety committee, consisting of representatives from a cross-section
of the department. The safety committee may assist the Departmental
Safety Manager in developing and implementing action plans to address
health and safety concerns.
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Departmental Health and Safety
Profiling
The myriad of requirements of health and safety regulations make compliance
a difficult proposition at best. To assist departments in determining
which regulatory requirements or other safety programs apply to their
specific circumstances, EHS has developed a health and safety profiling
system. The profiling process includes a joint, systematic review
of departmental operations and activities by EHS staff and department
representatives.
The product of this effort is a listing of safety programs that are
relevant to the particular needs of the department. As a result,
management is better able to focus on legitimate departmental safety
issues and, with assistance from EHS, begin the process of setting priorities
for developing and improving specific safety programs. The information
generated from the profiling process can be used in conjunction with
the relevant sections of the Health and Safety Guide to acquire a clearer
understanding of the roles and responsibilities of the Department, EHS,
Risk Management, Occupational Medicine, Facilities, and others in the
overall University safety effort.
The health and safety profiling procedure can be applied to an entire
department or to a functional area within a department. The profiling
process is applicable to both academic and non-academic departments.
In most cases, this process is initiated by the Department Manager or
other designated safety contact within the department.
Procedure
- Departmental Manager or other representatives meet with EHS staff
and respond to a series of questions based on the activities or operations
that occur within the department or departmental subdivision being
profiled.
- Department representatives review responses to verify the applicability
of specific safety programs to the operations in their department.
- Department conducts self-audits of existing programs to determine
strengths and weaknesses.
- Department compiles list of needed actions to initiate or improve
safety programs.
- Action items are prioritized and specific tasks are assigned (develop
an action plan).
- EHS conducts periodic review of the departmental safety program
(as discussed below).
Additional information about departmental safety profiling, including
the Departmental Health and Safety Profile
form, is available through EHS. A copy of the OSHA
Job Safety and Health Poster, required to be posted in each department
is available can be downloaded for posting.
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Departmental Health and
Safety Program Reviews
Periodically, EHS conducts a review of the departmental safety program
for most academic and administrative departments. The purpose
of the review is to evaluate the strengths and weaknesses of the departmental
safety program, to evaluate the effectiveness of EHS training and programs,
and to identify practices and programs that might serve as models for
other departments on campus. The review is not intended to be
an in-depth inspection of the department and facilities, nor a regulatory
compliance audit.
Procedure
First, EHS assembles a review team to include EHS staff with expertise
in each health and safety program included in the particular department’s
health and safety profile.
EHS coordinates a Pre-Review meeting with the EHS review team, the
departmental safety manager, and any other departmental staff with
specific health and safety responsibilities within the department.
This meeting is meant to accomplish the following:
- Review the profile to ensure continued accuracy
- Discuss notification of faculty, staff and students of the upcoming
review
- Select areas for the walkaround portion of the site visit
- Review applicable records and written programs
- Schedule site visit (2-7 hours)
A Site Visit is conducted in three parts, beginning with a meeting
with the individuals present at the Pre-Review meeting, members of
the departmental safety committee, faculty and any other individuals
identified during the Pre-Review meeting. At this meeting, the
review team poses a number of questions to help understand the structure
of the departmental safety program, including training issues, presence
and function of any safety committees, identification and communication
of health and safety issues, etc. The list of questions
is distributed during the Pre-Review Meeting, to help encourage a
more in-depth discussion of the issues.
Next, the EHS review team and interested departmental representatives
conduct a walkaround inspection of areas selected during the Pre-Review
meeting. These areas are selected to give a representative sampling
of the departmental activities, ensuring that each program identified
in the profile may be reviewed. This is not intended to be a
wall-to-wall inspection. For science and engineering departments,
10% or three laboratories (whichever is larger) are reviewed, along
with other areas, such as machine shops and stockrooms, to ensure
that all programs defined in the profile are reviewed.
During the walkaround, each applicable operation or facility is reviewed,
using the self-audit checklists included in this Health and Safety
Guide. Individuals working in these areas are interviewed to
determine the adequacy of the EHS and departmental training program.
Interview questions are furnished to the department during the
Pre-Review meeting.
The Site Visit concludes with a close-out meeting to discuss any
outstanding issues or concerns.
The review team prepares a draft report
for the departmental safety manager. Once the safety manager
and others in the department have reviewed and commented on the draft,
the review team prepares and submits a final report to the department
chair. The EHS review team leader follows up with the department periodically
thereafter.
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University Health and Safety Committees
Environmental Safety and Risk Management Committee
In the fall of 2000, the Committee on Occupational Safety and Health
(COSH) was reconstituted as the Environmental, Safety and Risk Management
Committee (ESRM) and the scope was broadened to include environmental
health and safety issues as well as visitor and contractor safety,
pollution prevention, building security systems, fleet safety, University-sponsored
off-campus programs, special events and athletic events.
The ESRM committee is responsible for developing policy and procedures
to improve oversight of these areas from a safety and risk management
perspective. It is also responsible for establishing written
institutional policies and guidelines,determining acceptable levels
of risk for the institution, approving and endorsing training and
audit procedures to ensure compliance with policies, and providing
guidance to the Office of Environmental Health and Safety, the Department
of Risk Management, the Department of Public Safety, and individual
academic and administrative departments. The committee
performs regular reviews of incident statistics including workers'
compensation losses, automobile accidents, visitor injuries, property
losses, fires/false alarms, and provides periodic reports of the status
of the University's safety and risk management efforts in these areas.
The following are ESRM subcommittees and groups:
The committee is chaired by Mark
Burstein , Executive Vice President. Members include:
The following individuals sit with the committee:
ESRM has established several University safety policies, some of which
are reprinted in the University Policy
section.
Radiation Safety Committee
The Radiation Safety Committee
(RSC) is a subcommittee of the Environmental Safety
and Risk Management Committee (ESRM). The RSC is responsible for
oversight of the University’s radiation safety program, grants authorization
to principal investigators and other senior staff members who plan
to work with radioactive materials, reviews incidents involving radioactive
materials, sets policies for the use of sources of radiation and gives
general supervision to the implementation of those policies.
The RSC is chaired by a senior faculty member and is comprised of
various faculty members, the Director of Environmental Health and
Safety, the University Radiation Safety Officer and other relevant
personnel.
Institutional Animal Care and Use Committee
The Institutional Animal Care and Use Committee is responsible for
ensuring appropriate care and use of animals involved in the University’s
research and educational activities. The Committee is also responsible
for University compliance with mandated federal policies and procedures
governing the care and welfare of animals.
The Institutional Animal Care and Use Committee is a subcommittee
of the University Research Board and consists of nine members appointed
by the President: five members of the faculty or professional research
staff from the natural sciences, a faculty member from a non-scientific
area, a veterinarian, an individual not affiliated with the University,
and an administrator from the Office
of Research and Project Administration. The University Sanitarian
and staff members responsible for maintaining animal facilities are
also invited to sit with the Committee.
Biosafety Committee
The Biosafety Committee is responsible for the review and oversight
of research activities in the life sciences. The purview of the Committee
includes all activities involving artificially recombinant DNA and
use of other potentially biohazardous materials.
The Biosafety Committee is a subcommittee of the University Research
Board and consists of ten members. The President appoints five members
of the faculty or professional research staff and two individuals
from the local community not affiliated with the University. Three
additional members are the Director of University Health Services,
the University Sanitarian,
and a University administrator appointed by the chair of the University
Research Board. The mayor and borough council appoint two individuals
(not affiliated with the University) as liaison representatives.
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Raising Safety Concerns
The responsibility for safety at Princeton University is discussed
at the beginning of this section, as well as in Section 9.1, Job Safety
of the Human Resources Policy
and Procedure Manual. Both supervisors and workers play an important
role in ensuring a safe and healthful workplace at Princeton University.
Individuals with specific safety questions or concerns are encouraged
to raise them with their immediate supervisor or their Department
Safety Manager. Dealing with safety issues through the supervisory
chain of command is the preferred method, however, when this approach
is unsuccessful in resolving a safety issue, concerns may be raised
by direct contact with an EHS staff member. EHS staff will, on request,
keep the name of a complainant confidential, however, in some instances,
this constraint may prevent thorough investigation and resolution of
a complaint.
Federal labor law prevents an employer from discriminating against
an employee for engaging in certain "protected activities", such as
filing of safety complaints with the federal Occupational Safety and
Health Administration (OSHA). Although employees have the legal right
to file an OSHA complaint, they are encouraged to first exhaust all
internal mechanisms for addressing safety issues, including supervisory
staff, Departmental Safety Managers and safety committees, EHS, or the
University Environmental, Safety and Risk Management Committee (ESRM).
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