I. Policy
The California State University recognizes Environmental Health and Safety (EH&S) as an integral function and is committed to providing a safe and healthy environment for our students and employees.
The EH&S function incorporates the policies, procedures, support services, oversight, and stewardship necessary for the University to not only provide a safe and healthy environment for students and employees by complying with applicable EH&S laws and regulations, but to foster a culture of safety.
II. Purpose
The purpose of this policy is to establish practices that enhance the safety of the faculty, students, staff and volunteers in the CSU. Furthermore, this policy shall provide a framework for EH&S processes, assessment, accountability and reporting.
III. Responsibility
All employees who assign and/or oversee work are responsible for ensuring that compliant work controls and procedures consistent with Federal, State and local regulations and University policies are implemented and maintained to provide for the protection of individuals and to safeguard the environment. Each individual is expected to comply with applicable EH&S regulations and University policies, programs and procedures. Additionally each individual is expected to: perform work in a safe and reasonable manner, report and address hazards they become aware of (personal observation or via a reporting process) and act to ensure the health and safety of themselves, coworkers, students, and all others at the University without fear of reprisal. Compliance with health and safety regulations is paramount and enforcement and remediation are campuswide responsibilities.
The chancellor has designated that the Office of Systemwide Risk Management (SRM) has administrative oversight and responsibility for supporting campuses in the development of EH&S programs and resource documents. SRM shall provide guidance on EH&S laws, regulations, policies, and procedures as well as other appropriate support to ensure campus programs are effective.
Each campus president shall designate a campus EH&S program administrator with the authority to establish and maintain the campus environmental health and safety program. Additionally, the campus president is responsible for promoting a culture of safety by ensuring safety and environmental protection exist at all organizational levels within the Campus.
Camus senior leadership (e.g. Vice President, Provost) is responsible for ensuring environmental health and safety programs are established, implemented and maintained for operations within their divisions and departments (including self-support and auxiliary organizations).
Campus EH&S program administrators are responsible for establishing, communicating and maintaining campus environmental health and safety programs that meet the requirements of the applicable Federal, State and local regulations. They are further responsible for assisting the campus in identifying health and safety hazards and for providing organizational leadership with information about hazards and appropriate controls.
To ensure employees are aware of and adhere to applicable EH&S requirements, deans, and directors are responsible for establishing, promoting, and maintaining a culture of safety within their respective colleges and departments/units, classrooms, laboratories and for maintaining and monitoring compliance with those EH&S requirements. Areas of responsibility include, but are not limited to, hazard assessment, training, maintenance and use of safety equipment, inspections, and hazardous materials management. They must attend/complete all required EH&S training and follow the procedures described in the training. If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation.
To ensure employees are aware of and adhere to applicable EH&S requirements, Department Chairs are responsible for establishing, promoting, and maintaining a culture of safety within their respective departments/units, classrooms, laboratories and for maintaining and monitoring compliance with those EH&S requirements. Areas of responsibility include, but are not limited to, hazard assessment, training, maintenance and use of safety equipment, inspections, and hazardous materials management. They must attend/complete all required EH&S training and follow the procedures described in the training. If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation.
CSU managers and supervisors are responsible for identifying hazards associated with their duties/job functions, including any applicable reporting of identified hazards, learning and implementing EH&S requirements that are applicable to employees, areas and operations under their control. They must attend/complete all required EH&S training and follow the procedures described in the training. If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation.
Faculty shall identify and report hazards associated with their teaching and research activities. Faculty shall ensure students, employees, and official volunteers who are associated with their teaching and research activities, receive appropriate information, training, and safety equipment. Faculty shall comply with applicable laws, regulations, policies, and programs of which they are reasonably informed. Faculty should work with their department safety coordinator and/or EH&S department to implement applicable EH&S programs and document compliance with applicable EH&S requirements. They must attend/complete all required EH&S training and endeavor to follow the procedures described in the training. If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation.
Staff, are responsible for reporting all identified hazards to their appropriate administrator. They must attend/complete all required EH&S training and follow the procedures described in the training. Training must be timely and in advance of the assignment of duties. Training information must be presented in a manner that employees receiving it are capable of understanding. Employee safety and environmental compliance are based on individual responsibility for safety and environmental stewardship. Staff support EH&S compliance by engaging in safe practices while performing activities at the University. Each individual is directly responsible for ensuring his or her own safety and for promoting a safe, healthy, and environmentally-sound workplace. An employee shall be responsible for other persons within a reasonable expectation of safety. Proper authority, training, appropriate equipment and span of control is necessary for staff to maintain a safe and healthy environment. If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation.
Student Workers and Official Volunteers are responsible for reporting all identified hazards to their appropriate administrator. They must attend/complete all required EH&S training and follow the procedures described in the training. Training must be timely and in advance of the assignment of duties. Training information must be presented in a manner that Student Workers and Official Volunteers receiving it are capable of understanding. Student Worker and Official volunteer safety and environmental compliance are based on individual responsibility for safety and environmental stewardship and they support EH&S compliance by engaging in safe practices while performing activities at the University. Each individual is directly responsible for ensuring his or her own safety and for promoting a safe, healthy, and environmentally-sound workplace. An employee shall be responsible for other persons within a reasonable expectation of safety. Proper authority, training, appropriate equipment and span of control is necessary to maintain a safe and healthy environment. If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation.
Students shall follow all established EH&S requirements for their campus. They must attend/complete all required EH&S training and follow the procedures described in the training. Students are responsible for ensuring their own safety and reporting identified hazards to their faculty, residential assistant, or campus EH&S departments.
IV. Requirements
Management shall demonstrate leadership and commitment with respect to environmental health and safety, and address safety concerns brought to their attention.
Campuses shall establish, implement and maintain written environmental health and safety programs as required by applicable laws, regulations, policies, and recognized needs that should include, but are not limited to, the following elements:
- Person(s) with the authority and responsibility for implementing and maintaining the EH&S program.
- Programs shall address the applicable laws, regulations, policies, and recognized needs for EH&S programs, and provide guidance to establish compliance, eliminate or minimize hazards, and mitigate risk.
- Programs should include processes for hazard identification. Hazard assessment should consider conditions and activities to take place and methods/measures to eliminate or minimize hazardous conditions and mitigate risk.
- Changes in processes/conditions require a reassessment of hazards.
- Written programs should be reviewed and/or updated as required by regulation, when circumstances change, or a minimum of every three years.
- The EH&S program administrator shall communicate recognized program requirements to the campus community.
- Communication may consist of new or revised written EH&S programs, training, webpage content, and safety committee meetings and minutes.
- The EH&S program administrator shall collaborate with the appropriate faculty and staff to implement applicable programs. This includes but is not limited to conducting regular meetings with campus safety committees. All meetings held between EH&S program administrators and campus safety committees shall be recorded and the minutes distributed.
- EH&S training requirements shall be identified and assigned by the EH&S program administrator or the faculty/staff in charge of the activity process as proscribed in the Responsibilities section of this document. Training will be assigned to affected faculty, staff, student workers and official volunteers.
- The written program will define the training content, training timeliness and frequency of refresher training.
- Laboratory safety training shall include initial laboratory safety training, as well as refresher training a minimum of every three years or more frequently should laboratory hazards change.
- Completion of employee training should be documented and training records shall be maintained in accordance with Executive Order 1031: Systemwide Records/Information Retention and Disposition Schedules Implementation.
Faculty/Staff will ensure a hazard assessment is conducted for student activities in their classes, labs, shops, field experience, and like learning environments. Hazards to be considered include potential for exposure to biological, chemical and/or physical hazards (e.g. in chemistry, biology, physics, engineering, or art labs). The program will include:
- Developing and implementing student training programs that inform students of the potential hazards and the safe educational practices/procedures that must be utilized to avoid injury or illness.
- Completion of student training should be documented and training records should be maintained in accordance with EO 1031. Systemwide Records/Information Retention and Disposition Schedules Implementation.
- Upon request, EH&S staff shall collaborate with academic departments on hazard identification and assessment to help determine and develop student training needs.
- Inspections and Program Reviews
- Departments with identified hazards (e.g. laboratories) shall conduct self-inspections for applicable EH&S programs to ensure compliance with the requirements. The results of these self-inspections shall be sent to the department chair or administrator in charge.
- In addition to departmental self-inspections, the campus EH&S program administrator or designee shall conduct inspections and program reviews of each department with identified hazards. EH&S shall provide the department chair or administrator in charge with written report on the status of their compliance, including observations and recommendations.
- Based on the results of inspections and program reviews, the EH&S program administer or designee will evaluate the effectiveness of the campus EH&S program(s), make appropriate changes and communicate them to affected department chairs, administrators, safety coordinators and others as applicable.
- Monitoring, Measurement and Reporting
- Upon request and/or when identified, EH&S shall provide assistance to departments to ensure they have the necessary information and support to comply with the requirements.
- Deans, directors and department administrators and/or chairs shall ensure appropriate actions are taken within their departments to correct any identified EH&S program deficiencies.
- The CSU endeavors to maximize the safety of its employees, students and volunteers. Nevertheless, when accidents occur, the CSU will endeavor to correct deficiencies that led to that occurrence. Campus responses to accidents should generally be remedial as opposed to punitive.
V. Annual Report
The Campus EH&S Program Administrator shall provide an annual Environmental Health and Safety report to the Campus president with a copy to the Systemwide Office of Risk Management. The purpose of these reports is to evaluate environmental health and safety for effectiveness and regulatory compliance and to communicate and document the results of that evaluation.
The annual report may be of a design established by each campus; however, certain Key Performance Indicators (KPI) must be included in all annual reports. These KPIs and a template for an annual report can be found in Attachment A. This template may be reevaluated and updated as necessary.
Annual reports are due on November 1st for the preceding academic year.
VI. Authority
This policy is issued pursuant to Section II of the Standing Orders of the Board of Trustees of the California State University, and as further delegated by the Standing Delegations of Administrative Authority.