Responsibility for Environment, Health and Safety

University of California, Berkeley



This document defines the responsibility and accountability for the environmental, health, and safety program at the University of California, Berkeley.

The Environmental, Health and Safety Policy Committee, as delegated by the Chancellor, sets environmental, health, and safety policy for the campus. In accordance with these policies, students, faculty, staff, administrators, visitors, and guests have responsibilities for complying, implementing, communicating and/or ensuring adherence to environmental, health and safety regulations, principles and practices. The Office of Environment, Health & Safety (EH&S) provides technical expertise, consulting assistance, and services to assure compliance with legal requirements.

Responsibilities of Individuals
Responsibilities of Management
Responsibilities of Department Administrators and Managers
Responsibilities of the Office of Environment, Health & Safety
Responsibilities of Faculty Oversight Committee

 

Responsibilities of Individuals


All Students, Faculty, Staff, Visitors and Guests
Every employee, student, or other person authorized to conduct activities at the University of California at Berkeley is responsible to:

  • Comply with applicable environmental, health and safety laws and regulations, University policy and accepted safe work practices.
  • Observe environmental, health and safety related signs, posters, warning signals and written directions.
  • Be familiar with the emergency plan, the emergency assembly area and emergency coordinators for their building, and participate in emergency drills.
  • Learn about potential hazards associated with their work and work area; know where information on these hazards is kept for their review; and use this information when needed.
  • Follow safe operating procedures and Material Safety Data Sheet (MSDS) guidance applicable to work performed, if the work involves hazardous materials.
  • Follow procedures and observe precautions for the use of special materials (such as carcinogens or biohazards), as detailed in the use authorization or other operating procedures.
  • Use personal protective equipment and engineering controls (e.g., fume hoods) appropriate to their work.
  • Curtail or stop their work if they reasonably believe continuation of the work poses an imminent danger to health or safety, and immediately notify a supervisor in the chain of authority over the work.
  • Report all unsafe conditions to their supervisor or safety committee as soon as is reasonably possible.
  • Warn co-workers about defective equipment and other hazards.
  • Participate in health and safety training applicable to their work situation.
  • Participate in required inspection and monitoring programs.

 

Responsibilities of Management


Senior Campus Administrators

THE CHANCELLOR is responsible to:

  • Ensure the implementation and overall effectiveness of the University's environmental, health and safety programs.
  • Determine, with the advice of the Environmental, Health and Safety Policy Committee or faculty committees related to particular environmental, health and safety matters, appropriate levels of responsibility on the campus for fulfilling the University's commitment to provide a safe environment and to conduct its operations in compliance with applicable laws and regulations and accepted practices for health, safety and environmental protection.


VICE CHANCELLORS are responsible to:

  • Communicate with their Deans and Directors about environmental, health and safety programs that need to be implemented through them.
  • Ensure that their Deans and Directors take appropriate steps to implement the programs.
  • Implement the University's environmental, health and safety programs in all departments/units within their respective jurisdictions.
  • Report to the Chancellor on the effectiveness of, and the budget and resources needs for, these programs.

 

Departmental Administrators and Managers


Deans and Directors (defined as academic and non-academic Deans, Directors, Assistant Vice Chancellors, Associate Vice Chancellors, and Associate Deans) are responsible to:

  • Ensure that environmental, health and safety obligations are carried out in the academic departments/administrative units under their control.
  • Communicate to employees, students, visitors and guests that health and safety and a concern for the environment are top priorities on the Berkeley campus, and that everyone shares in the obligation to perform work in a safe, healthful, environmentally protective manner.
  • Ensure that their academic departments/administrative units are implementing required programs in all subject areas including:

Ambient Air Quality Program
Biohazard Safety Program
Hazard Communication Plan
Hazardous Materials Management Plan
Chemical Inventory
Emergency Response & Training Plan
Injury & Illness Prevention Program
Laboratory Safety/Chemical Hygiene Plan
Risk Management & Prevention Program
Wastewater Discharge
Priority Pollutant Management Program

Delegation: Deans and Directors may delegate the details of program implementation to department chairs, safety chairs, department safety officers, management services officers or other appropriate persons within their jurisdiction. The ultimate responsibility, however, for ensuring implementation of these programs at the academic department/administrative unit level remains with the Deans and Directors.

MANAGERS (defined as academic and non-academic managers including Principal Investigators, other faculty and any other manager with direct oversight of operations) are responsible to:

  • Ensure that environmental, health and safety obligations are carried out by everyone working in their operations.
  • Communicate to their employees, students and visitors that health and safety and concern for the environment are top priorities on the Berkeley campus and that everyone shares in the obligation to perform work in a safe, healthful, environmentally protective manner.
  • Analyze work procedures to identify hazards; ensure measures are implemented to eliminate or control those hazards.
  • Ensure workplace hazards and environmental, health and safety-related policies and procedures are communicated to employees, students and visitors.
  • Ensure safe operating procedures are in place and are observed.
  • Ensure individuals working in their operations have the proper safety equipment and personal protective equipment to perform their work safely.
  • Inform employees/students of the availability of a medical surveillance program on campus to assist them in the case of potentially hazardous exposures or injuries.
  • Encourage prompt reporting of health and safety concerns without fear of reprisal.
  • Curtail or stop work being carried out under their authority if they reasonably believe that continuation of the work poses an imminent danger to health or safety. Upon directing that work be curtailed or stopped, if the situation cannot be corrected immediately, the Manager must notify 1) the Dean or Director under whose responsibility the work is being performed, and 2) EH&S.
  • Ensure that self-assessment inspections are performed regularly, that records are retained and that deficiencies identified in any inspection (self-assessment or EH&S) are addressed.


Managers have particular responsibilities in the following program areas (alphabetical listing):

  • Chemical Inventory Ensure that a chemical inventory report for every room or site (where hazardous materials are stored) is submitted to EH&S and that it is updated annually and whenever significant changes occur.
  • Emergency Response and Training Plan Contribute to the development of the departmental/unit plan, ensure that all employees, students and others know about the plan, and communicate the importance of participating in drills and otherwise following procedures set out in the plan. Departmental records must be maintained up to three years indicating all employees who participate in emergency response training.
  • Environmental Permits Equipment and operations involving underground storage tanks, regulated air emission sources, wastewater discharge or pre-treatment units, and hazardous waste treatment units must have operating permits, obtained via EH&S or Facilities Services (formerly PP-CS). The user has the responsibility for providing relevant information to obtain permits, meeting permit conditions, and any fiscal responsibility. EH&S or Facilities Services coordinate permit applications.
  • Fire Prevention Inspection Upon receipt of a Fire Prevention Inspection Report, ensure that all noted issues and concerns are corrected as appropriate.
  • Groundwater Protection Program Report any hazardous materials or other pollutants spilled to or discovered in soil or groundwater to EH&S for appropriate emergency or non-emergency clean up.
  • Hazard Communication Program Except in chemical laboratories, a written Hazard Communication Program is required if hazardous materials are used or stored.
  • Implementation of the IIPP will satisfy the requirements of the Hazard Communication Program.
  • Hazardous Material and Waste Management Inform employees and students that hazardous materials and hazardous waste, except as expressly authorized by regulations or campus licenses or permits, may not be disposed of via the sewer system, regular trash, fume hoods or other unsafe or environmentally damaging routes; and to stress the importance of proper hazardous material/waste management.
  • Hazardous Materials Management Plan Major components of this Plan, Chemical Inventory, Emergency Response, and Hazardous Material Spills are detailed elsewhere in this section.
  • Hazardous Material Spills and Releases Report immediately to EH&S or after business hours to the UC Police Department (UCPD), any hazardous material (except radioactive) spills or releases that could result in exposure of individuals or in a release outside the laboratory or other location where these materials are stored or used. Report to EH&S (or UCPD after business hours) any spills that cannot be cleaned up promptly and any spills that result in injury. The Manager must ensure that :
  1. Appropriate spill containment and cleanup materials are readily accessible to operations under her or his control.
  2. Employees/students in the workplace or laboratory know where the spill response materials are and know what to do in case of a spill or release.
  3. EH&S (or the UC Police Department) has been promptly notified about spills and releases occurring in operations under the manager's control.
  • Hazardous Material/Waste Management - Laboratory Unwanted hazardous material/waste from chemical manipulations carried out on a laboratory scale where multiple chemical procedures or chemicals are used must be pre-packaged by the producer. A completed material packing list fully describing the unwanted materials must be provided to EH&S to assist in classifying hazardous waste prior to pick-up.
  • Hazardous Material/Waste Management - Non-Laboratory Unwanted hazardous waste generated by Facilities Services (formerly PP-CS) and other facilities that are not laboratories and not under control of academic departments and that do not directly support a laboratory operation must be pre-packaged by the producer. A completed material packing list fully describing the unwanted materials must be provided to EH&S to assist in classifying hazardous waste prior to pick-up. In addition, these non-laboratories must establish satellite or waste accumulation areas and manage waste in compliance with Federal and state regulations/laws. EH&S is available for assistance in proper hazardous waste management.
  • Hazardous Waste Minimization Ensure that work being carried out in their operations is performed in a manner which prevents or reduces hazardous waste generation at the source and that when it cannot be prevented, it is managed in an environmentally safe manner. Methods of preventing or reducing hazardous waste generation include substituting non-hazardous or less hazardous materials for hazardous ones; making operational improvements, instituting changes in processes, methods or techniques; and reusing and recycling materials.
  • Injury and Illness Prevention Program (IIPP) The academic department/ administrative unit has the responsibility for local implementation and documentation of the IIPP. Guidelines are available from EH&S.
  • Laboratory Safety Program Ensure that a Chemical Hygiene Plan for laboratory safety, where hazardous chemicals are stored or used, is developed, implemented and coordinated with the departmental IIPP.
  • Risk Management & Prevention Program Ensure that purchases of acutely hazardous materials maintain building aggregate quantities to below threshold planning quantities. If those levels are exceeded, ensure that a RMPP is completed prior to use.
  • Special Materials (carcinogens or biohazards) Use Know which people under their supervision use any of the special materials noted above. Obtain required authorizations or submit the required registration information, as applicable, for special materials.
  • Biohazards Obtain a Biohazard Use Authorization (BUA) and ensure that anyone using non-exempt recombinant DNA, hazardous etiologic agents or oncogenic viruses has been listed on the BUA. Ensure that work is carried out in accordance with applicable laws, regulations and policies and the conditions contained in the BUA. EH&S can offer assistance in determining whether a BUA is required.
  • Carcinogens Ensure that "regulated carcinogens" have been registered with EH&S; that all individuals working with "select carcinogens" [more inclusive than "regulated carcinogens"] have been properly trained and are provided with appropriate protective equipment or engineering controls; and that procedures for the safe management of carcinogens are followed.
  • Training Ensure that everyone working in their operations is appropriately trained to identify and mitigate potential hazards.
  1. Determine and ensure appropriate training for those working under their supervision.
    Contact the appropriate departmental person (such as a safety officer) or EH&S as needed. Additional curriculum must be developed when new processes, procedures or equipment are introduced to the work site.
  2. Ensure that work requiring training is performed only by persons who have received the proper training.
  3. Document all training and know where records are retained.

Delegation: Academic and Non-Academic Managers may delegate specific activities to laboratory managers, research associates, graduate student instructors, management services officers or other persons capable of carrying out those activities. The responsibility for ensuring that required programs are implemented and that required duties are carried out in an appropriate manner remains with the Academic and Non-Academic Manager.

 

Responsibilities of the Office of Environment, Health & Safety


EH&S is responsible for tracking developments in environmental and health and safety laws and regulations and determining (with the assistance of University legal counsel, and oversight from EH&S Policy Committee faculty committees in particular areas) requirements that apply to the campus. Requirements are met through development of programs by EH&S and relevant faculty committees for implementation by campus departments as well as through direct services, consultation, and compliance assistance provided by EH&S.

EH&S is responsible for providing information to the campus community, through established communication channels, on programs, services, regulatory impact and compliance requirements.

Program Development

EH&S is responsible to develop and oversee programs to be implemented by the campus to meet legal requirements and environmental, health and safety policies adopted by the University, both by the Office of the President and the Berkeley campus administration. EH&S programs in development or in operation include (alphabetical listing):

  • Ambient Air Quality Program  EH&S assists with Bay Area Air Quality Management source permitting, developing programs to assist with compliance to regulations applicable to emissions of toxic air contaminants.
  • Biosafety Program  EH&S has developed a Biosafety program to assist the campus in complying with regulations and guidelines applicable to biohazardous material use.
  • Groundwater Protection and Underground Storage Tank Programs  EH&S assists campus departments with UST operating permits and conditions, developing programs to assist with compliance to regulations applicable to groundwater protection and assessing contaminated sites.
  • Hazard Communication The Injury and Illness Prevention Program contains provisions that satisfy hazard communication requirements. Training is available from EH&S upon request.
  • Hazardous Materials Management Plan
  • Acutely Hazardous Materials Management Plan (and RMPP)
    EH&S is implementing a program to prevent adverse consequences of releases of acutely hazardous materials. This program is directed toward academic and administrative departments using or storing hazardous chemicals.
  • Chemical Inventory Program  EH&S has developed a format for compiling the inventory of chemicals required by state and local laws. EH&S provides Mac and IBM computer software and instructions for Managers to use in completing or updating the inventory. EH&S maintains the inventory on a computer database and provides information to regulatory agencies as requested or required.
  • Emergency Response and Training EH&S is responsibilities for coordinating the development of local emergency response and training plans by academic and administrative units. Copies submitted by campus departments of emergency response and training plans are maintained in EH&S.
  • Hazardous Waste Management Facilities Program EH&S operates and maintains a hazardous waste generator facility for packaging wastes to be shipped off site; part of this effort has involved recommendations for upgrading the current facility for health and safety purposes, and overseeing the plans for a new replacement facility.
  • Hazardous Waste Minimization Program EH&S has developed a hazardous waste minimization program which includes educating faculty, students and staff on waste minimization, facilitating the exchange of surplus chemicals, and assisting campus hazardous materials users in finding ways of minimizing hazardous wastes.
  • Injury and Illness Prevention Program (IIPP) A campus IIPP has been implemented. EH&S is responsible to assist campus departments in developing and effectively implementing local IIPP plans.
  • Laboratory Safety Program EH&S is responsible for assisting all campus departments and laboratories to develop and implement a Chemical Hygiene Plan for each laboratory.
  • Strawberry Creek Environmental Quality Program EH&S manages environmental quality in Strawberry Creek, including coordination of the Strawberry Creek Committee, implementation of the Strawberry Creek Management Plan (campus Storm Water Pollution Prevention Plan) and water quality monitoring.
  • Toxic Gas EH&S is required to develop, and assist departments in implementing, a written program to ensure the safe use and handling of toxic gases on campus.
  • Wastewater Permits and Priority Pollutant Management Program EH&S assists with wastewater discharge permitting, developing programs and guidelines ("Think at the Sink" and Drain Disposal Guidelines) to assist with compliance to regulations applicable to wastewater discharge of chemicals. The Office of Radiation Safety assists RUA holders with guidance on drain disposal of radio nuclides and provides appropriate annual reporting to regulatory agencies.

Regulatory Liaison

EH&S has responsibility for communicating with regulatory agencies in the environmental, health and safety arena on behalf of the campus. Responsibilities may include informational and corrective action meetings, negotiations, campus input on pending legislation, and written communications. University legal counsel is consulted as appropriate.

Services EH&S is responsible to provide direct services to the campus, including:

Accident Investigation Perform investigations of accidents on the campus.

Asbestos Hazard Assessment Provide information about asbestos; perform asbestos inspections and evaluations, as requested; audit the work of asbestos abatement contractors.

Biosafety Services Assist the Committee for Laboratory and Environmental Biosafety to issue biohazard use authorizations (BUAs); monitor compliance with regulatory requirements applicable to biohazards and pathogens; respond to concerns and allegations about improper practices involving biohazardous materials; inspect BUA holders annually; review departmental manuals as requested for handling biohazardous materials.

Environmental Permits Assist in completion of environmental permits pertaining to air and water quality protection.

Fire Prevention Inspect campus buildings to identify and eliminate fire hazards, such as improper storage of flammable, electrical fire hazards and blocked hallways or exits.

Fume Hoods/Biohood Services Test fume hoods approximately twice a year and biohoods annually to assure that adequate airflow is being maintained. (Facilities Services (formerly PP-CS) is responsible for fume hood repairs.)

Hazardous Spill Response Upon request, provide assistance in hazardous material spill clean up; preparing written reports about reportable releases and notifying appropriate agencies about reportable spills.

Noise Monitoring and Hearing Conservation Conduct noise surveys to determine exposure; refer individuals, as warranted, to the Hearing Conservation Program (jointly operated by EH&S and the Occupational Health Program).

Hazardous Chemical, Radioactive and Medical Waste Management Provide prompt, safe, cost effective and legal waste management services to UCB chemical, radioactive, and medical waste generators. This includes:

Compliance Assistance
Waste Pick-Up
Hazardous Chemical Material Reuse
Transportation
Disposal
Tracking

Plan Review and Construction Inspection As delegated by the California State Fire Marshal, review and approve/deny plans for new construction and renovation and conduct construction inspections to assure compliance with applicable Fire Code requirement.

Respiratory Protection (the Respiratory Protection Clinic is jointly operated by EH&S and the Occupational Health Program) Perform fit tests to ensure proper protection for those individuals who need respirators; provide training in the use and care of respirators; perform workplace airborne hazard assessments; and perform air monitoring to verify respiratory protection.

Sanitation Inspect campus restaurants to assure sanitary provision of foods on campus; sample and analyze drinking water; monitor swimming pools for general safety hazards and adequate filtration and disinfection processes.

Training EH&S is responsible to offer training in the environmental, health and safety area.

Training areas include:

Asbestos Awareness
Biological Safety Cabinet Use
Chemical Inventory Software
Eye Safety
Fire and Life Safety
Food Sanitation
Forklift and Lift Truck Safety
Fume Hood Use
Hazard Communication
Hazardous Waste Disposal and Minimization
Injury and Illness Prevention
Laboratory Safety
Respiratory Protection