Environmental Health and Safety Compliance (IV.A.4)

Volume IV: Facilities and Safety
Chapter A: Safety
Responsible Executive: Chief Financial Officer and Treasurer and Chancellors
Responsible Office: Environmental Health and Public Safety
Date Issued: May 1, 2011
Date Last Revised: May 1, 2021

Contacts
Statement of Policy
Reason for This Policy
Individuals and Entities Affected
Exclusions
Responsibilities
Definitions (defined terms are capitalized throughout the document)
Related Documents, Forms and Tools
Website Address for This Policy
History and Updates
Appendix

Contacts

Policy Clarification

Senior Director, Environmental Health and Public Safety
765-494-7504 | ehps@purdue.edu

Statement of Policy

Purdue University faculty, staff, students and contractors are required to comply with environmental, health, safety and preparedness laws and regulations issued by federal, state and local agencies, including but not limited to the federal and Indiana Occupational Safety and Health Administrations, U.S. Nuclear Regulatory Commission, U.S. Environmental Protection Agency, U.S. Department of Homeland Security, U.S. Department of Transportation, Indiana Department of Environmental Management and Indiana State Department of Health. Faculty, staff, students and contractors also must comply with related University policies, standards, procedures and instructions implemented in order to mitigate health and safety risks for individuals and the campus as a whole.

This policy requires the formation of safety committees under the structure of Purdue University’s Integrated Safety Plan (ISP). This structure provides a mechanism for indemnification from regulatory fines and provides updated University guidance for safety. If an issue of non-compliance results in a monetary fine from a Regulatory Agency, organizations that hold a current ISP certification will not bear responsibility for payment of the fine.

Department-related compliance expenses will be borne by individual departments. Certain departments on the West Lafayette campus and at University farms may request access to centrally funded compliance and risk reduction funds administered by the director of Radiological and Environmental Management (REM) for consideration of cost sharing.

Several laws and regulations require formal or informal guidance, training, and/or supervision as it relates to certain materials, substances, and samples. The University maintains systemwide safety committees in order to comply with these laws and regulations and to promote environmental and individual health and safety. These committees, tasked with systemwide oversight for particular areas of compliance, include the Chemical and Laboratory Safety Committee, Institutional Biosafety Committee, Laser Safety Committee, and Radiation Safety Committee.

Reason for this Policy

Compliance with federal, state, and local environmental health and safety laws and regulations, and with University policies, is essential to the ongoing success of the University. This policy identifies the mechanism to provide an infrastructure for emergency preparedness and environmental health and safety compliance with laws such as the federal OSH Act, the IOSH Act and those issued by other Regulatory Agencies and to provide health and safety guidance and information at the organizational level.

Individuals and Entities Affected

All units, organizations, students, faculty, staff and contractors of Purdue University.

Exclusions

There are no exclusions to this policy.

Responsiblities

Senior Director, Environmental Health and Public Safety

Administer this policy with the assistance of Radiological and Environmental Management (REM).
Provide administrative guidance for systemwide safety committees.

Associate Vice President for Research, Regulatory Affairs

Provide administrative guidance for systemwide safety committees.

Safety Committees

Under the direction of organizational leadership, achieve and maintain Integrated Safety Plan (ISP) certification, which includes safety self-audits, submission to REM audit/inspection, and abatement of any hazards found.
Meet regularly to discuss safety issues relevant to the organization represented, make recommendations for improvement, and disseminate new health and safety information.

Radiological and Environmental Management (REM)

Assist the Senior Director, Environmental Health and Public Safety in administering this policy.
Assist the appropriate Chancellor, vice president, vice provost or dean with implementation of required program responsibilities for environmental, health, safety and preparedness.
Conduct annual safety audits and organizational inspections in accordance with the ISP.
Provide qualifying organizations with ISP certification.

Chancellors

Serve on the Hazard and Risk Management Committee or assign a designee.
Direct campus-level oversight for safety committees in support of the ISP.
Oversee the assignment of required environmental health and safety program responsibilities on their campuses.

Vice Presidents, Vice Provosts, Vice Chancellors and Deans

Direct organizational oversight for safety committees in support of the ISP.
Oversee the assignment of required environmental health and safety program responsibilities within their units.

Hazard and Risk Management Committee

Convene semi-annually to review implementation of the ISP and to recommend improvements for enhanced regulatory compliance.

Faculty and Staff

Follow procedures and guidance issued by the Chemical and Laboratory Safety Committee, Institutional Biosafety Committee, Laser Safety Committee, and Radiation Safety Committee.
Complete requisite safety training as applicable for job responsibilities.

Definitions

All defined terms are capitalized throughout the document. Refer to the central Policy Glossary for additional defined terms.

Chemical and Laboratory Safety Committee
A committee formed in order to promote safe procurement, handling, use, storage and disposal of chemicals at each of the University’s campuses, research farms, agricultural centers, and related facilities and operations.

Hazard and Risk Management Committee
A standing committee co-chaired by the Associate Vice President for Research, Regulatory Affairs and the Senior Director, Environmental Health and Public Safety tasked with review of risk management and environmental health and safety programs and processes for University compliance with the applicable Regulatory Agencies. Its membership consists of the Chancellors or their designees, leaders of campus regulatory and compliance committees, and key individuals charged with implementation of the ISP and risk management.

Institutional Biosafety Committee
A committee formed in accordance with National Institutes of Health guidelines to oversee and review the biosafety of research conducted at or by Purdue University.

Integrated Safety Plan (ISP)
Purdue University’s structure for safety and emergency preparedness. Key elements of the ISP are active safety committees, annual safety self-audits, annual REM safety audits, abatement of deficiencies found during audits and administrative support for safety. The ISP is implemented to improve safety culture, assist with regulatory compliance and indemnify organizations from regulatory fines.

IOSH Act
The Indiana Occupational Safety and Health Act of 1971 (IC 22-8-1.1-1 et seq.), as amended from time to time, which applies the federal OSH Act and companion standards and regulations to agencies and instrumentalities of the state of Indiana, including Purdue University.

OSH Act
The federal Occupational Safety and Health Act of 1970 (29 U.S.C. Sections 651 et seq.), as amended from time to time, passed by Congress to ensure, so far as possible, safe and healthful working conditions for employees.

Laser Safety Committee
A committee formed in order to promote the safe use of lasers and laser systems at the University’s campuses, research farms and related facilities and operations, and at temporary job sites in accordance with the American National Standard for Safe Use of Lasers (ANSI Z136.1).

Radiation Safety Committee
A committee formed in accordance with U.S. Nuclear Regulatory Commission regulations to ensure the safety of the University and surrounding community in the utilization of all radioactive materials and radiation producing devices at the University and by its faculty, staff and students.

Radiological and Environmental Management (REM)
Purdue’s system-wide environmental health and safety compliance office, as administered on each campus, which is responsible for and authorized to develop and implement environmental, health, safety, and preparedness programs and to coordinate and monitor compliance with such programs and related laws and regulations.

Regulatory Agencies
Federal, state and local agencies with regulations applicable to Purdue University that are meant to ensure environmental health, safety and preparedness. These agencies include, but are not limited to, the U.S. Environmental Protection Agency, U.S. Nuclear Regulatory Commission, U.S. Department of Homeland Security, U.S. Department of Transportation, U.S. Department of Commerce, U.S. Food and Drug Administration, U.S. Department of Agriculture, U.S. Department of Health and Human Services, Indiana Department of Environmental Management, Indiana Department of Homeland Security, Indiana Department of Transportation and Indiana State Department of Health.

Website Address for this Policy

www.purdue.edu/vpec/policies/facilities-safety/iva4

History and Updates

May 1, 2021: This policy supersedes Executive Memorandum No. B-14 (Duties and Responsibilities of the University Radiological Control Committee) dated August 1, 2001, and Executive Memorandum No. D-2 (Composition, Duties, and Responsibilities of the Purdue University Laser Safety Committee) dated August 1, 2001. Included reference to systemwide safety committees.

December 1, 2020: Removed the policy’s interim status.

July 1, 2020: Added the concept of an Integrated Safety Plan for the overall structure of environmental health and safety compliance and removed the OSHA officers. Added the University Hazard and Risk Management Committee and removed the Safety Coordination Committee. Added responsibilities for safety committees, REM, and the Chancellors, vice presidents, vice provosts and deans.

November 18, 2011: Policy number changed to IV.A.4 (formerly I.2.4) and website address updated.

May 1, 2011: This policy supersedes the Revised Environmental Health and Safety Compliance Policy (Executive Memorandum No. C-36) dated May 20, 1999.

Appendix

There are no appendices to this policy.