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Policy Contact: Environmental Health and Safety Office

1. Purpose

   This policy establishes the responsibility for the University’s health and safety compliance in the Environmental Health & Safety Office (EHS), details the scope of this responsibility, and provides required procedures to increase the efficacy and use of EHS’s services to better ensure the safety and compliance of University staff.

2. Policy
    
   1. All University activities shall be conducted using reasonable precautions to protect employees, students, the public, and the environment to minimize dangers to life, safety, and property. The University regards its responsibility for providing a healthful and safe working environment for its faculty, staff, and students to be a high priority.
       
   2. The Environmental Health & Safety Office (EHS) is responsible for ensuring that all University employees, students, and visitors are conducting its research and educational programs in compliance with all applicable federal, state, and local occupational, environmental, and safety regulations.
       
3. Procedures
    
   1. EHS will develop, maintain, and implement guidelines and procedures designed to assist University faculty, staff, and students in the safe conduct of activities on all of the University’s properties, in cooperation with other departments and units of the University. EHS will adopt and deploy guidance and best practices as applicable from South ��ֱ����’s Office of Risk Management and Department of Agriculture and Natural Resources, and from the United States’ Environmental Protection Agency, Occupational Safety and Health Administration, Nuclear Regulatory Commission, and other applicable safety standards from federal, state, and local authorities and entities. These guidelines and procedures shall include, but are not limited to, the following:
      1. Promulgating enforceable safety standards involving:
         1. General lab safety;
         2. Chemical hygiene and chemical laboratory safety;
         3. Radiation safety including radiation machines and radioactive materials;
         4. Biological materials and laboratory safety; and
         5. Ergonomics of offices and other work environments; EHS will ensure that safety guidance will be available in either paper or electronic formats under the general term “SDSU Laboratory and Occupational Safety Manual.”
      2. Conducting periodic audits and inspections to determine compliance with published guidance, including those contained in local, state, and federal laws and regulations regarding health and safety. The appropriate correction will be prescribed where necessary, and the response monitored to assure compliance.
      3. Reporting non-compliance with EHS guidelines, procedures, or prescriptions to appropriate supervisors.
      4. Monitoring of areas deemed necessary by EHS staff, including areas that may have hazards and risks associated with the materials and procedures that are used in the area.
      5. Coordinating of activities between EHS, Facilities and Services, UPD, University committees, and other departments and units in overseeing safety guidance and procedures at all levels of the University.

      6. Enforcing the appropriate correction where necessary, with enforcement actions depending on the severity of the violation or danger presented by the violation, and the correction monitored to assure compliance. These actions may include the following:

         1. EHS Guidance issued to the Principal Investigator (PI) responsible for the facility;
         2. Notification to the department head, dean, or school director and applicable VP;
         3. Increased audits of the facility to ensure that the violations have been addressed; and
         4. In extreme cases where there is imminent danger to the occupants of the laboratory, the building, or the environment, EHS is authorized to shut down the affected facility until the danger is no longer imminent.

         Unless impractical, EHS will obtain prior authorization for any enforcement action involving an imminent danger or serious violation from the Chair of the Emergency Management Team, who will inform the Emergency Management Team. EHS will also inform the Dean or equivalent University official and applicable Vice President overseeing the affected unit or department of any enforcement action after the action is taken. All actions taken by EHS pursuant to this policy shall comport with, and defer to, University Policies 10:3, 10:7, and 10:9; the University Emergency Management Plan; and associated protocols adopted by the Emergency Management Team.
          

   2. EHS, in coordination with other departments, will develop training—mandatory and voluntary—to ensure University staff are aware of the general and specific safety guidelines for work being performed in their respective facility.
      1. Training for unique and specific safety items must be performed and documented by the principal investigator. EHS has the authority to insist on changes or edits of such documents to ensure compliance with the University’s safety procedures.
          
   3. Once a semester, EHS will provide a report to the Chair of the Emergency Management Team, the Vice President for Technology and Security, the Vice President for Research and Economic Development, and to the Provost and Vice President for Academic Affairs, Vice President for Finance and Budget, or their respective successors, on the state of compliance with lab safety and training requirements by employees.

4. Responsible Administrator

   The Vice President and General Counsel and the Vice President for Technology and Security, or their designees, are responsible for annual and ad hoc review of this policy and its procedures. The University President is responsible for approval of this policy.

Approved by President on 05/13/2020. Revised, Approved by President on 09/15/2021.