Environmental, Health, Safety and Risk Management
Subject:Environmental, Health, Safety and Risk Management
Policy: Environmental Health and Safety Policy
Effective Date: January 1, 2014
Review Date:January 2017
Responsible Party:Environmental Health and Safety Committee Chair
Introduction and Purpose:
MSU Statement of Commitment
Montana State University – Bozeman (MSU) is committed to maintaining a campus environment for students, faculty, staff, volunteers, and visitors that will not adversely affect their health, safety and surrounding environment, or subject them to risks of accidental injury or illness. We value the safety of our community in which no student or employee will be required to perform any task that is determined to be unsafe or unreasonably hazardous.
This policy endorses programs which:
- Provide safe and healthful conditions and reduce injuries and illnesses to the lowest possible level. No task is so important and no service so urgent that it cannot be performed safely.
- Assure compliance with applicable Federal, State, and local regulations providing for environmental health and occupational safety.
- Provide information, training, and safeguards to faculty, staff, and students regarding health and safety hazards, and to the surrounding community regarding environmental health hazards arising from operations and events at the University.
- Install and maintain facilities and equipment in accordance with recognized and accepted standards essential to reduce or prevent exposure to hazards by faculty, staff, students, and visitors.
- Provide appropriate personal protective equipment to all employees at University expense when engineering controls are not adequate to minimize exposure.
- Provide medical surveillance as required by law and as may be dictated by existing circumstances or programs.
MSU Statement of Accountability
To maintain a safe campus environment, all campus units will provide facilities, equipment and training that meet all Federal, State and Local Environmental Health and Safety (EHS) laws, rules, and regulations and will promulgate appropriate policies, standards and procedures to ensure compliance withthe University’s EHS Programs.
The ultimate responsibility for establishing and maintaining the EHS Programs at MSU rests with the President and Vice Presidents of the University. The guidelines found in the EHS Programs are reviewed and approved by the EHS Committee with recommendations from MSU Safety and Risk Management (SRM).
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 Policy and Programs. Failure to comply with established EHS rules, regulations, and procedures can lead to University disciplinary action.
Note: A list of abbreviations is included at the end of this policy document.
100.00 Administering Agency And Authority
The EHS Programs provide specific written programs, policies, procedures, hazard mitigation activities, training and documentation which are required by various laws and regulations including, but not limited to, the following:
- Administrative Rules of Montana (ARM): ARM 24.30.102(5) (extension incorporates Occupational Safety &Health Administration (OSHA) General Industry Citations from Title 29, 1910 or 1926)
- National Fire Code (NFC)
- National Fire Protection Association (NFPA) Standards and Regulations
- Nuclear Regulatory Commission (NRC) Requirements set forth in Title 40, CFR
- Resource Conservation and Recovery Act
- Montana Department of Environmental Quality (DEQ)
- Higher Education Opportunity Act, public law
- Montana Board of Regents (BOR) Policies
- Montana Safety Culture Act, 39-71-1501 to 1508, M.C.A.
- Environmental Protection Agency (EPA)
- Department of Homeland Security (DHS)
- Montana Code Annotated (MCA)
The EHS Policy is the institution’s overall EHS Policy statement and applies to all employees. EHS procedures, written programs, training requirements and guidelines apply to employees as described in the relevant policies and procedures. MSU departments, administrators, managers, faculty and staff are required to comply with the requirements and specifications established for this purpose in the EHS Programs that accompany this policy statement.
300.00 EHS Program Objectives
The EHS Programs are established to assist management in identifying hazards in the workplace, to provide tools and guidance to correct identified hazards, and to prevent hazards from occurring. In order to be effective the EHS Programs will adhere the following principles:
- Adequate training for specific workplace responsibilities.
- Thorough and regular self-inspections that are intended to prevent hazards from occurring.
- Hazardous condition reporting mechanisms which assure that employees can report potentially hazardous conditions without fear of reprisal, and assurance that such reports will receive prompt and serious attention.
- Systems and procedures which assure that workplace equipment and instrumentation are maintained in safe and good working conditions.
- Procedures to investigate any workplace accidents, near-miss incidents, and reported injuries and illnesses.
- Once identified, correction of all hazards should be completed as expeditiously as possible. If a hazard cannot be corrected for any reason, employees will be prohibited from working with continued exposure to the identified hazard.
400.10 University Administration
University President and Vice Presidents are ultimately responsible for establishing and maintaining effective EHS Policies and Programs for MSU.
400.20 Safety and Risk Management Department
SRM is responsible for:
- Providing leadership to develop and implement EHS Programs.
- Providing technical resources, staff support, advice, and consultation to University leadership, Safety Coordinators (SC), managers and supervisors concerning EHS issues.
- Formulating and drafting for review by the MSU EHS Committee, polices, procedures and guidelines necessary to implement the environmental health and safety programs under its jurisdiction.
- Monitoring the effectiveness of EHS Programs.
- Ensuring centralized EHS records, including training logs, inspection reports, compliance reports, and information requiring employee access are maintained.
- Investigating identified hazards and recommending actions to correct EHS deficiencies.
- Ensuring that EHS policies, written programs, and guidelines are communicated to working units, implemented and evaluated.
- Reviewing, formulating and disseminating all new and/or revised EHS codes, rules, and standards adopted, passed or enacted by applicable governmental or regulatory authorities.
- Acting as the University liaison with governmental and regulatory agencies regarding EHS.
- Stopping any University related activity which presents an unreasonable health or safety risk to University employees, students or visitors.
- Keeping a current roster of SCsand providing training and assistance.
400.30 Deans, Directors, and Department Heads
Deans, Directors, and Department Heads 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.
- Ensuring compliance with EHS Programs, policies, procedures and guidelines in their work units or areas as specified in the EHS Programs.
- Ensuring corrective action is taken to remedy any health and safety deficiencies identified in their areas of responsibility.
- Appointing sufficient SCs to perform the responsibilities provided in Section 400.50 below to cover all of their areas of responsibility.
- Stopping and/or complying with SRM requests to cease any University related activity which presents an unreasonable health or safety risk to University employees, students or visitors.
400.40 Managers, Supervisors, Faculty, and Principal Investigators
Managers, Supervisors, Faculty and Principal Investigators (PI) are responsible for:
- Ensuring effective implementation of and compliance with EHS Programs, Policies, procedures and guidelines as they relate to their operations.
- Ensuring that all of their employees and students receive the appropriate EHS training 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.
- Ensuring 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 the department. (SRM can provide assistance if requested.)
- Posting appropriate safety notices and/or procedures in conspicuous locations.
- Developing methods, as appropriate, to inform employees of 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 SRM when they become aware of a violation of any University, State or Federal environmental health or occupational safety rule or regulation.
- Seek assistance from SRM if a safety or environmental problem exists that cannot be handled with available resources.
- Stopping and/or complying with SRM requests to cease any University related activity which presents an unreasonable health or safety risk to University employees, students or visitors.
400.50 Safety Coordinators
SCs are appointed by Deans, Directors, or Department Heads and are critical to the effective implementation of the MSU EHS Program and ensuring MSU’s compliance.
SCs are responsible for:
- Coordinating with SRM.
- Assisting the Dean, Director or Department Head in the 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.
- Coordinating EHS activities, including coordinating EHS training for their areas.
- Assisting SRM in conducting periodic inventories and inspections.
- Preparing written reports, recordkeeping, and recommendations as needed to assist in compliance with EHS Programs.
- Providing assistance to correct identified deficiencies.
- Coordinating and scheduling periodic safety meetings with their constituents.
- Coordinating EHS policies and procedures with appropriate building supervisors.
400.60 Employees and Students
All MSU employees and students are responsible for:
- Using common sense and good judgment at all times to avoid potential hazards that may exist or be created in the work environment.
- Reading and complying with EHS policies, procedures and guidelines governing their activities.
- Promptly reporting unsafe conditions, environmental hazards as well as injuries and illnesses to the responsible supervisor or program director.
- Attending all required EHS education and training sessions.
- 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.
Disregarding or failing to comply with EHS laws, regulations, policies or procedures may result in disciplinary action.
500.00 Safety Committees
500.10 EHS Committee
The EHS Committee has responsibility to represent all of MSU-Bozeman regarding health and safety issues. The University is cognizant of its responsibility to provide an environment conducive to the health and safety of all employees, students, visitors and neighbors. In order to establish effective, uniform policies and programs in this area, the University EHS Committee has been established to advise MSU senior leadership.
The purpose of the University’s EHS Committee is to recognize, evaluate, and recommend controls of university environmental factors which might impair health, well-being, efficiency, or comfort. The EHS Committee guides and supports the work of SRM toward these goals and strives to develop a positive attitude toward safety in the faculty, staff, and students.
The University EHS Committee responsibilities include the following:
- Formulating, reviewing, and/or recommending the adoption of EHSPolicies related to the following:
- The use of hazardous chemicals, including: carcinogens, mutagens, teratogens and toxic, reactive and flammable chemicals.
- The use of physical hazards, including: lasers, cryogenic liquids, electrical hazards and compressed gases.
- Hazardous and infectious wastes.
- Other laboratory hazards affecting the environment, health and safety of the campus community.
- Occupational health and safety, including ergonomics.
- Fire safety.
- Vehicle safety.
- Establishing training programs per EHS requirements.
- Advising the University’s senior leadership, on the status of EHS Programs and their needs.
500.20 SafetyCommittees at the College, Department, Program, and/or
Work Unit Level
Deans, Directors, Department Heads, Managers and Supervisors may establish safety committees to function at the appropriate area of responsibility. Should a Dean, Director, Department Head, Manager or Supervisor elect to utilize a safety committee within their operational level of the MSU organization, the duties and responsibilities of the appointed safety committee should include responsibilities such as the following:
- Periodic review of accidents, injuries, damage and hazardous conditions reports within the corresponding operational level of organization.
- Implement appropriate occupational health and safety improvements.
500.30 Relationship of EHS Committee to Other Internal Review Boards
Other MSU safety review boards and committees (e.g. IBC, IRB, IACUC, RSC) exist to address specific content relating to their areas of research and study. These are distinct from the EHS Committee.
600.00 Compliance Guidelines
All employees shall adhere to safe and healthful work practices as defined by law and established University and Departmental environmental health and safety policies, programs, and guidelines. Failure to do so may result in disciplinary action.
700.00 Safety Communications
700.10 Departmental Safety Meetings
SCs will determine the need for and will schedule periodic safety meetings. These meetings should be scheduled at a time when most employees can attend, and SCs will keep minutes to document attendance and the topics discussed. Safety meeting minutes will be provided to SRM upon request.
700.20 Employee Safety Training
Departments will ensure that all employees receive specific training relating to their employee duties and responsibilities either on a periodic basis or prior to assignment on a new job or when work assignments change as provided in Section 1100 of this policy.
700.30 Student Safety Training
Faculty and staff are responsible for providing specific training programs (e.g., lab safety, art safety, shop safety, etc.) applicable to the student(s) prior to any academic or research activities. Students who are employees shall be considered employees for purposes of the specific job or work assignments relating to their employment. SCs are responsible to see that the records of trainings will be maintained and SRM has access to these records.
700.40 Environmental Health and Safety Training Resources
SRM provides several different types of resources regarding EHS training as provided in Section 1100 of this policy.
700.50 Safety Suggestions
Any environmental, health or safety concerns can be referred to SRM.
700.60 MSU President’s Policy Statement
The MSU President will annually issue an EHSPolicy statement which informs the University community that safety is a priority issue among MSU’s executive level administrators. The policy statement will urge all faculty and staff to actively participate in the MSU EHS Programs for the common good of the entire campus community.
800.00 Hazard Control And Inspections
Regular health and safety inspections are essential in order to create an atmosphere and working environment where the potential for exposure to unsafe conditions exists. A program of regular environmental health and safety inspections conducted at various levels throughout the MSU organization will help reduce the risk of injury and illness for faculty, staff, students and the public.
800.10 Hazard Control Procedures
Many hazards can be prevented from occurring through documented self-inspections. An effective hazard control system will identify potential hazards that exist or develop in the workplace, will determine how to correct hazards, and will take steps to prevent recurrence of hazards.
Upon completion of scheduled or unscheduled inspections, all findings will be prepared in writing and submitted to respective department heads and SRM. Corrective action or a suitable timetable for elimination of a hazard is the responsibility of the supervisor.
Once identified, hazards will be evaluated with regard to their severity potential. As the severity potential increases, the more urgent it is to correct the potential hazard, or to ensure that the hazard is removed from the workplace until such time as it can be corrected.
800.20 Hazard Classification
When evaluating potential hazards the following classification of hazards should be utilized to help determine the order of priority followed in correcting or removing hazards from the workplace:
Priority 1: Imminent danger exists. The hazard is capable of causing death or possible multiple deaths, widespread occupational illness or loss of facilities. Immediate measures shall be taken to isolate employees, students and visitors from the potential hazard. SRM shall be notified immediately upon discovery of a Priority 1 hazard. The hazard will continue to be isolated or removed from the MSU environment until completion of all corrections has been made. Serious consideration shall be given to permanently removing processes and/or equipment from the environment that ledto a Priority level 1 hazard.
Priority 2: The hazard has the potential to cause serious injury, serious occupational illnesses and equipment or property damage. Immediate measures shall be taken to protectemployees, students, and visitors from the potential hazard. The hazard will continue to be isolated until all corrections regarding the hazard have been made.
Priority 3: The hazard has the potential to result in minor injuries or occupational illnesses. Minor equipment damage may result. Immediate measures shall be taken to protect students and visitors from the potential hazard. Students and visitors will continue to be isolated from the potential hazard until such time as corrections have been made,eliminating the hazard.
Priority 4: The hazard only has the potential to result in temporary disruption to the workplace. Only injuries that would require minor first aide could occur. No significant loss of property or equipment is likely. If no injuries or losses have occurred due to the hazard, adequate warning signs or postings will be provided to warn employees, students and visitors that the hazard exists. If a loss or injury occurs due to the hazard, students and visitors should be isolated from the hazard until such time as corrections have been made to eliminate or isolate the hazard. Priority level 4 hazards should be corrected as soon as adequate time and resources allow.
800.30 Scheduled Workplace Inspections
- SCs shall arrange for or conduct regular and systematic workplace inspections which shall occur at least annually. Those departments engaged in hazardous operations are encouraged to conduct more frequent inspections. Self-inspection checklists are provided by SRM and can be downloaded from the SRM web site. Departments may develop their own inspection checklists and can contact SRM for assistance.
- Departments will maintain a record of all inspections. Copies of departmental inspections shall be provided periodically to SRM, or at their request.
- SRM will schedule and periodically conduct inspections of various work environments. The purpose of these inspections will be to assist departments in identifying their compliance deficiencies as identified in various EHS regulations, codes and rules. SRM will provide each department or work area inspected with a written review of identified compliance deficiencies. The departments are responsible for initiating actions to correct reported compliance deficiencies.
800.40 Unscheduled Workplace Inspections
- Departments will ensure a safety analysis is performed whenever they become aware of additional substantial safety hazards that are introduced into the work environment.
- SRM may conduct periodic unscheduled inspections of any workplace to help ensure the maintenance of a safe and healthy work environment. The purpose ofthese inspections will be to identify deficiencies, improve compliance, and aid in the creation of a safe and healthy work environment. SRM will provide eachdepartment and/or work area inspected with a written review of identified deficiencies, concerns and recommendations. MSU departments are responsible for initiating actions tocorrect reported compliance deficiencies.
800.50 Regulatory Agency Workplace Inspections
All work environments at MSU may be subject to periodic EHS and code compliance inspections conducted by various governmental and regulatory agency personnel. In many instances, departments will have advance notice of the intended inspection; however in some cases regulatory personnel may conduct unannounced inspections. Departments are instructed to take the following steps when approached by a regulatory representative desiring to conduct an unannounced inspection of an MSU workplace:
- Regulatory Representative must provide proper identification.
- Contact the following departments/individuals:
- Department Head
- Departmental Safety Coordinator
- Safety and Risk Management
- Discuss the intended scope of the inspection with the Regulatory Representative. Guidance for such discussions is located on the SRM website.
900.10 Employee’s Responsibilities
All employees are required to report to their immediate supervisor an on the job “injury” or what they believe to be an on the job injury as soon as reasonably possible after the injury occurs. All occupational ”diseases,” or what they believe to be an on the job disease, should be reported to the immediate supervisor as soon as the employee has reason to believe the “illness” is work related. Current definitions as defined by Montana Code Annotated can be found at MCA 39-71-119.
900.20 Supervisor’s Responsibilities
When an occupational injury or illness is reported to a supervisor, the supervisor and employee will submit a First Report of Injury form and ensure that other reporting requirements specified in SRM occupational injury reporting instructions are met.
1000.00 Written Program Requirements
In addition to this EHS Policy, some function-specific written programs are required by occupational health and safety rules, standards, and applicable policies to document responsible persons, legal requirements, and other useful information for departments, supervisors and employees.
1000.10 EHS Required Written Programs
Templates for the required written programs applicable to various MSU departments, programs and work groups are listed on the SRM website. The specific written program required is dependent upon the work environment, job tasks, duties and/or materials, tools and equipment utilized.
Administrators, supervisors and managers have the responsibility to conduct an assessment to identify the written programs required for work environments and activities under their supervision. Assistance is available throughSRM.
1000.20 EHS Recommended Written Programs
EHS Recommended Written Programs are those not required by code, statute, policy and/or regulation but may benefit an employee or group of employees by helping to clarify safety responsibilities and document safe work practices. Although not required, these recommended written programs may provide a better way to manage the root cause of documented occurrences of occupational injuries and illnesses or loss. MSU administrators, managers and supervisors are encouraged to identify the EHS Recommended Written Programs that will benefit the employees under their supervision. Program templates are available through SRM.
Effective dissemination of safety information is essential to employee safety and is required by occupational health and safety rules, standards, and applicable policies. It is necessary to provide training for employees concerning general work practices and emergency procedures as well as specific instruction with respect to hazards unique to each employee’s job assignment.
1100.10 EHS Required Training Programs
The required trainings applicable to various MSU employees are listed on the SRM website. The specific training is dependent upon the work environment, job tasks, duties and/or materials, tools and equipment utilized in the job or profession. When training is required by law or policy, training shall take place prior to initiating the work assignment.
Required training is a facet of an employees’ positions with MSU and shall be considered paid time within their normal working hours. Administrators, supervisors and managers have the responsibility to conduct an assessment to identify the training programs required for each employee under their supervision. SRM is available for assistance in identifying the required programs for employees.
1100.20 EHSRecommended Training Programs
EHS Recommended Training Programs are designed to help reduce the risk of occupational accident or illness and prevent unnecessary property damage and loss to a department or program. Although not legally required, these recommended trainings may provide an enhancement in managing the risks of occupational injuries and illnesses or loss. MSU administrators, managers and supervisors are encouraged to identify the EHS Recommended Training Programs that will benefit the employees under their supervision.
1100.30 New Employee Safety Training
All supervisors will ensure that newly hired employees attend all required trainings at the earliest practical opportunity as outlined on the SRM website. When training is required by law or policy, training shall take place prior to initiating the work assignment.
1100.40 Transferred Employee Training
All supervisors will ensure that existing MSU employees receive required general safety training at the earliest practical opportunity and required specific training prior to working new job assignments.
1100.50 Changes in Work Environment
Supervisors will ensure that employees receive required trainings whenever new substances, processes, procedures or equipment are introduced to the workplace which represent a new hazard, or whenever the supervisor receives notification of a new or previously unrecognized hazard.
1100.60 Training Documentation
Training records will include the topics, participants and dates of completion or attendance. SRM will maintain a record of all training provided by SRM and completed by each employee. MSU shall ensure that all records of employee safety training are created and maintained either by SRM, departments, or if established, a central training records repository.
1200.00 Environmental and Occupational Recordkeeping
Records for occupational injuries and illnesses, medical surveillance, exposure monitoring, inspections, as well as other activities and incidents relevant to EHS will be maintained per governing standards and regulations. Each department shall maintain records for its employees, forwarding a copy to SRM which serves as the central repository.
1200.10 Occupational Injuries and Illnesses
All occupational injuries and illnesses shall be reported as per Section 900 of the EHS Policy and Personnel Policy and Procedures Manual. SRM will record and report all occupational injuries and illnesses as required by State and Federal laws. Information will be kept on file and will be made available for review upon lawful request.
SRM will annually publish a summary of occupational injuries and illnesses as required by law. The summary will be provided during the month of February for occupational accidents and illnesses occurring in the previous calendar year. The annual summary will be posted in conspicuous places throughout campus traditionally used for posting employee and employment related information.
1200.20 Employee Exposure Records
Each employee exposure record will be preserved and maintained for the respective employee’s duration of employment plus (30) thirty years. Such records include, but are not limited to: workplace monitoring or measuring of a toxic substance or harmful physical agent; and where applicable biological monitoring results which directly assess the absorption of a toxic substance or harmful physical agent by body systems. It is the responsibility of departments using any regulated carcinogens to comply with any additional record keeping requirements under Montana Department of Labor and Industry (DLI) rules.
1200.30 Employee Occupational Medical Records
Occupational medical records for employees will be preserved and maintained for at least the duration of employment plus (30) thirty years. Such records include medical and employment questionnaires or histories; the results of medical exams and lab tests; medical opinions, diagnoses, progress notes, and recommendations; first aid records; descriptions of treatments and prescriptions; and employee occupational medical complaints. All such employee occupational medical records shall be kept strictly confidential.
1200.40 Documentation of Activities
Essential records, including those legally required for workers’ compensation insurance, insurance audits and regulatory inspection shall be maintained as required by law. The departments will keep records of steps taken to establish and maintain programs which must include the following:
- Records of scheduled and periodic inspections to identify unsafe conditions and work practices. The documentation includes the name of the person(s) conducting the inspection, the unsafe conditions and work practices identified, and the corrective action(s) taken with copies forwarded to SRM. These records will be maintained for a minimum of (7) seven years.
- Documentation of environmental health and safety training for each employee. Specifically, employee name or other identifier, training dates, type(s) of training and the name of the training provider will be included. Training records will be maintained for a minimum of (7) seven years.
1300.00 Access to Exposure and Medical Records
MSU recognizes that employees, their designated representatives, authorized representatives of the DLI – Safety Bureau, and other State or Federal officials as authorized by law have a right of access to relevant exposure and medical records. Such access is necessary to yield both direct and indirect improvements in the detection, treatment and prevention of occupational disease. Upon access request, the University shall assure that access is provided in a reasonable time, place and manner.
Department: Working units (i.e. institute, academic department, center, administrative departments, etc.)
- ARM: Administrative Rights of Montana
- BOR: Montana University System Board of Regents
- DEQ: Montana Department of Environmental Quality
- DHS: Department of Homeland Security
- DLI: Montana Department of Labor and Industry
- EHS: Environmental Health and Safety
- EPA: Environmental Protection Agency
- IACUC: MSU Institutional Animal Care and Use Committee
- IBC: MSU Institutional Biosafety Committee
- IRB: MSU Institutional Review Board
- MCA: Montana Code Annotated
- MSU: Montana State University– Bozeman
- NFC: National Fire Codes
- NFPA: National Fire Protection Association
- NRC: Nuclear Regulatory Commission
- OSHA: Occupational Safety and Health Administration
- PI: Principal Investigator
- RSC: MSU Radiation Safety Committee
- SC: Safety Coordinator
- SRM: MSU Safety and Risk Management Department