Environmental & Safety Management Policy
Introduction
Through its teaching and research, Harvard University is a prominent contributor to the development of practices and policies that enhance the global environment. It is appropriate that Harvard conduct its internal operations in the spirit of this leadership role, and in compliance with all applicable laws and regulations.
All operations should be a model of high-quality in environmental and safety practices. The following principles have been established to guide faculty, staff, and students in their activities at Harvard:
- Comply with all applicable environmental and safety laws and regulations;
- Minimize waste through efficient and appropriate use of resources;
- Encourage personal accountability for responsible environmental and safety behavior within the University community;
- Minimize hazards to students, faculty, staff, and visitors;
- Participate in the development of sound environmental and safety policies and regulations; and
- Require those who do business with Harvard to perform their work in a manner that protects the University from environmental and safety risks.
Management
Harvard University is a complex organization, consisting of ten schools and extensive support functions necessary to the operation of the institution. Consistent with its long-standing philosophy of decentralized management, the University places the primary responsibility for compliance with all applicable laws, regulations, and policies with its individual schools and central administration departments, each under the direction of a responsible "Corporate Officer" (e.g., Provost, Dean, or Vice President).
Yet, from a legal, regulatory, and public perspective, the University is one corporate entity (the legal name of the Corporation is "President and Fellows of Harvard College"), and it is held accountable as such by federal and state authorities: the actions of the University's individual constituents are those of the entire Corporation. For these reasons, the Corporation has the responsibility to establish policies and provide resources to ensure compliance with all environmental and safety laws.
Harvard performs this function through the following structure:
- University Environmental Health and Safety Policy Committee
The University Environmental Health and Safety Policy Committee serves as the primary source of leadership and policy guidance on all matters pertaining to environmental and safety compliance and related regulatory developments.
The Policy Committee is responsible for ensuring that sufficient University resources are available to maintain environmental and safety compliance, and that these resources are consistent with anticipated changes in the regulatory climate. In addition, the Committee develops University policy recommendations for approval by the President, and monitors developments to ensure that University policies are observed and remain current.
The Policy Committee also provides an annual report to the Corporation, summarizing the status of environmental and safety programs and risks affecting the University.
The Policy Committee is chaired by the Vice President for Administration, and includes broad representation by members of the faculty and administration.
- Environmental Health and Safety Operations Committee
The Environmental Health and Safety Operations Committee consists of administrators and operations managers from the schools and central departments who, with the Department of Environmental Health and Safety, work to ensure that activities and services are optimally provided to the University. The Operations Committee also evaluates environmental, health, and safety issues and proposes appropriate actions.
The Operations Committee is also responsible for monitoring the external regulatory environment and University practices to ensure that problems are appropriately identified, and responses developed.
The Operations Committee is chaired by a representative of the Vice President for Administration.
- Department of Environmental Health and Safety
The Department of Environmental Health and Safety ("EH&S") provides technical, regulatory, and related management services to the schools and departments. EH&S helps the schools develop and implement programs, including training, emergency response, and analysis of specific problems.
In matters of actual or potential regulatory enforcement action, investigations, or employee complaints, EH&S coordinates the University's response to external regulatory agencies concerned with workplace health, safety, and environmental compliance. EH&S works closely with the schools and departments and the Office of the General Counsel to ensure that a unified and consistent University position is provided in response to a governmental inquiry, complaint, or lawsuit.
- Schools and other University Departments
It is the responsibility of the Corporate Officer of each school and central administration department to conduct his or her operations in accordance with all applicable laws and regulations, and to implement the University's environmental and safety policies. With the guidance and assistance of the Department of Environmental Health and Safety, these responsibilities include, but are not limited to: training; informing employees, students, and visitors about workplace hazards and safety procedures; conducting inspections and audits; correcting violations; investigating incidents and complaints by employees and students; proper storage and disposal of hazardous materials; enforcing policies (including appropriately disciplining employees and students who violate environmental and safety requirements); and appropriately documenting activities and processes.
Each school or administrative department maintains financial and operational responsibility for day-to-day management and implementation of its environmental and safety programs, including any fines or penalties assessed by a governmental agency, remediation costs, and damages and expenses incurred as a result of judicial or administrative proceedings.
- Environmental and Safety Compliance Officers
Each Dean and Vice President shall designate an environmental and safety compliance officer ("Compliance Officer") to be responsible for implementation, management, and enforcement of environmental and safety compliance programs within the school or administrative department. The Compliance Officer shall act on behalf of the Dean or Vice President to manage environmental and safety activities in the school or department, and shall have authority to establish procedures, investigate complaints and incidents, and audit performance. The Compliance Officer shall also have the authority to commit financial and staff resources to ensure continued compliance with applicable environmental and safety regulations.
- University Faculty, Staff, and Students
It is the responsibility of each individual to conduct his or her activities at Harvard in compliance with all applicable government, University, and department policies and regulations. The success of the University's environmental and safety management activities requires the active involvement of individuals through participating in training; abiding by established safety and environmental procedures; reporting hazards and potential violations of regulations; and recommending improvements.
Reporting
It is the responsibility of the University to investigate and appropriately report environmental and safety incidents. It is the responsibility of all employees and students of the University to fully disclose any activity that may be, or may result in, a violation of any environmental and safety regulation, and to cooperatively participate in the investigation and remediation of any incidents.
Any incident, or questions or concerns regarding compliance, should normally be reported to the environmental and safety Compliance Officer at the school or administrative department. If the Compliance Officer is not available, incidents should be reported to the Director of EH&S, or the Director's designee.
Employees and students who report incidents in accordance with law and Harvard University procedures, or who raise questions or concerns about the University's environmental and safety procedures, will not be penalized by Harvard, and such action will not be recorded in the employee's or student's record.
Enforcement
Harvard University views compliance with all laws, regulations, and University policies as conditions of employment, and violation of such requirements shall be considered grounds for disciplinary action, including termination of employment.
Further, governmental agencies have established increasingly strict policies to ensure compliance with environmental and safety regulations, including harsh civil penalties and individual criminal prosecution leading to possible imprisonment and substantial fines. Accordingly, the University expects all faculty, staff, and students to be vigilant in complying with all environmental and safety requirements, and to acquire the information they need to properly conduct their activities at the University.
