Harvard Environmental Health and Safety Policy
Policy statement
Harvard University is committed to the sound health and safety of our students, faculty, and staff while minimizing our impact on the environment. We are also committed to finding innovative ways to better protect people and the planet and measure and improve our environmental, health, and safety performance.
We intend to adhere to sound environmental, health, and safety practices that are consistent with Harvard's teaching and research excellence.
Harvard is a complex organization, consisting of schools with academic and research missions, other affiliated centers and units, and the extensive support functions necessary to operate the institution.
Consistent with its long-standing philosophy of decentralized management, Harvard places the primary responsibility for compliance with all applicable laws, regulations, and policies with its individual schools and departments, each under the direction of a responsible corporate officer such as a provost, dean, or vice president.
The responsible unit is accountable for fines and penalties resulting from non-compliance, a model supported by the deans and Harvard administration.
Quality EHS performance is important to Harvard wherever we conduct our business. Our operations are a model for high-quality environmental, health, and safety practices.
Responsibilities and principles
These responsibilities and principles guide students, postdoctoral scholars, faculty, and staff in their activities at Harvard:
- Minimize hazards to students, faculty, staff, visitors, and our environment.
- Comply with all applicable environmental health and safety laws and regulations, wherever we operate.
- Evaluate and manage EHS risks related to our work.
- Measure and monitor EHS performance.
- Complete requisite training.
- Maintain personal accountability for responsible environmental and safety behavior within the Harvard community.
- Be engaged with, report, and question hazardous conditions or potential violations of environmental or safety obligations.
- Promote and encourage sustainability by efficiently and appropriately using resources.
- Recommend improvements to support environmental and safety activities and participate in these efforts.
- Assure that those who do business with Harvard perform their work in a manner that protects Harvard from environmental, health, and safety risks.
Governance and program guidance
These Harvard standing committees and other committees govern and guide the EHS program. This list does not include other committees with less common connections to EHS.
The Committee on Microbiological Safety (COMS) is a standing faculty committee. It reviews all research involving these materials and activities at Harvard and some Harvard-affiliated institutions:
- Bacterial and viral pathogens.
- Cells and cell lines.
- Creating transgenic animals, plants, and biohazards.
- Human and non-human primate tissues.
- Human gene transfer and xenotransplantation.
- Prions.
- Recombinant and synthetic DNA.
- Regulated biological toxins.
- Wild-type and genetically modified microorganisms.
The Facilities Safety Committee is composed of administrators involved in operating Harvard's physical plant and infrastructure. This includes representation from schools, departments, and others with building property and management or facilities responsibilities.
Committee activities include:
- Reviewing occupational and facilities safety risks and applicable standards, such as fire safety, Occupational Safety and Health Administration programs, and training.
- Developing implementation strategies for safety plans, procedures, and policies.
- Recommending, developing, and providing feedback on applicable EHS policies and practices.
Harvard's Institutional Review Boards (IRB) are governed by the Statement of Policies and Procedures Governing the Use of Human Subjects in Research at Harvard University.
Harvard IRB offices that oversee human research activities:
- Committee on the Use of Human Subjects in Research (Harvard University-area): Reviews projects from FAS, GSD, GSE, HBS, HDS, HKS, HLS, HRI, and SEAS.
- Office of Human Research Administration (Harvard Longwood Campus): Handles projects reviewed by the HMS and HSDM IRB, HSPH IRB, and the Committee on Human Studies.
Harvard IRB Institutional Animal Care and Use Committees (IACUC) that oversee animal use protocols:
The Lab Safety Committee is a university-wide governing body empowered to review and approve Harvard policies related to lab safety as well as safety training procedures and content.
The committee is composed of:
- Environmental Safety and Compliance Officers (ESCO) from lab-based schools.
- Faculty Principal Investigators (PI).
- Representatives from various other disciplines across Harvard.
Committee activities include:
- Advising the Office of the Vice Provost for Research and EHS on risk management issues related to lab safety.
- Evaluating potential hazards associated with research and teaching activities.
- Reviewing EHS lab inspection findings to ensure safety compliance and facilitate a culture of safety.
The Radiation Safety Committee is the governing body for all aspects of radiation protection within Harvard, including all affiliated research, instructional, and service units using ionizing and non-ionizing radiation sources or devices in facilities owned or controlled by Harvard.
The committee ensures:
- All possession, use, and disposition of radiation sources at Harvard complies with applicable regulations and the specific conditions of Harvard licenses.
- All associated radiation exposures are maintained as low as reasonably achievable (ALARA).
Roles and responsibilities
The EHS office within Campus Services administers Harvard's EHS programs.
EHS supports Harvard's mission of teaching and research by promoting a culture of safety, health, environmental protection, and emergency management.
EHS serves students, faculty, staff, and the broader community and environment around us.
EHS strives to fully understand its community and develop services specific to that community’s needs for buildings and facilities, labs, emergency services, and project support.
Harvard authorizes EHS to protect personnel and the environment in matters of regulatory compliance and safety.
EHS is legally responsible for many permits, plans, regulatory filings, and related matters. EHS collaborates with schools and departments to maintain effective standards and practices.
EHS implements this responsibility through close collaboration and consultation with Harvard and by providing technical, regulatory, and related management expertise.
EHS provides core services to the Harvard community, including:
- Identifying and assessing potentially hazardous operations and locations.
- Evaluating existing or emerging environmental, health, and safety risks, regulatory requirements, standards, and best practices.
- Developing institutional EHS and emergency management risk mitigation strategies.
- Providing training and awareness information to employees and students.
- Monitoring hazards and risks and auditing control strategies.
- Operating Harvard systems that facilitate training, inspections, monitoring, records, data, reporting, and Harvard EHS metrics.
- Being the liaison to ESCOs, faculty, administrators, Harvard committees, and others involved in managing environmental health and safety risks at Harvard.
- Serving as Harvard's primary liaison to environmental, health, and safety regulatory agencies.
- Coordinating Harvard's response to regulatory agencies for investigations, employee or community member complaints, and potential or actual regulatory enforcement actions by consulting schools, departments, affiliated units, and the Office of the General Counsel to ensure a unified and consistent Harvard response.
EHS also provides specialized or dedicated operational services to schools and departments through expense recovery arrangements.
Each senior corporate officer must appoint an ESCO responsible for implementing, managing, and reinforcing environmental, health, and safety programs within the school, administrative department, or affiliated unit.
ESCOs are the primary point of contact with EHS and work closely with EHS staff to identify local priorities and coordinate EHS service delivery.
Contact EHS to learn more about your local ESCO.
The dean or vice president must issue a letter of appointment outlining the ESCO’s authority and responsibilities.
The managing director of EHS chairs the ESCO committee. The committee members are senior administrators from major schools and departments, EHS, and a network of ESCOs.
Each ESCO is authorized to:
- Act on behalf of the senior corporate officer to manage environmental, health, and safety activities in the school or department.
- Establish procedures, investigate complaints and incidents, and audit performance.
- Require stopping any activities that may pose an imminent hazard to people, property, or the environment.
- Commit financial and staff resources to ensure continued compliance with applicable environmental, health, and safety regulations.
A primary responsibility of the ESCO is establishing internal management, accountability, and communication structures to implement and track environmental and safety requirements, status, and related risks. ESCOs rely on EHS support and guidance to implement these responsibilities.
ESCO duties:
- Ask for technical help and guidance from EHS to understand risks, risk mitigation strategies, and environmental and safety requirements for their school, department, or affiliated unit.
- Establish mechanisms to implement and monitor compliance requirements. Examples of mechanisms include local safety committees, Lab Safety Officers (LSO), or facility manager networks.
- Ensure that personnel attend required training.
- Take appropriate action to stop any conditions that may result in imminent hazard to people, property, or the environment.
- Notify the senior corporate officer of unresolved compliance issues and situations involving potential safety hazards, exposures, accidents, injuries, illnesses, spills, releases, or other regulatory or environmental issues.
- Notify the director of EHS of any unresolved compliance issues and situations. Ask for EHS guidance to implement corrective actions as needed.
- Facilitate and promote exchanging information within the school or department and with EHS for collaborative problem solving and program improvement.
- Represent the school or department on either or both the Facilities Safety Committee or Lab Safety Committee.
- Participate in developing strategies, policies, and procedures for environmental and safety compliance management at Harvard.
- Provide an annual briefing to the senior corporate officer and the director of EHS on their school or department's environmental and safety program status, trends, and risks.
The senior corporate officer (vice president or dean) of each school, administrative department, and affiliated unit is responsible for:
- Ensuring their operations are conducted following all applicable laws and regulations.
- Locally implementing Harvard's environmental, health, and safety programs in support of this policy.
With guidance and support from EHS, these responsibilities include:
- Ensuring appropriate training.
- Informing students, staff, and visitors about workplace hazards and safety procedures.
- Ensuring appropriate training.
- Conducting inspections and audits.
- Correcting and resolving problems or violations.
- Investigating incidents and complaints.
- Ensuring proper management of hazardous materials.
- Implementing policies, including appropriately escalating student or staff non-conformance issues with environmental health and safety requirements.
- Appropriately documenting activities and processes, and data collection.
- Managing responses to emergencies by obtaining, as needed, help from appropriate internal or external resources.
Each school, administrative department, and affiliated unit maintains financial and operational responsibility for routine management and implementing its environmental, health, and safety programs. This includes:
- Supporting specialized or ongoing operational services provided by its staff, EHS, or others.
- Responsibility for fines or penalties assessed by government agencies, remediation costs, and damages and expenses from judicial or administrative proceedings.
PIs and unit managers must implement, manage, and enforce a safe and compliant environment within their area of responsibility.
Primary responsibilities include:
- Conducting periodic self-inspections.
- Developing appropriate environmental, health, and safety procedures.
- Reporting incidents.
- Training staff.
Major EHS management programs
EHS, schools, and administrative units collaboratively assess hazards and determine if various regulations apply to their operations.
EHS accomplishes most hazard and program assessments using internal expertise and coordinates hiring special experts if necessary.
After EHS, schools, and administrative units identify protective and compliance programs, they develop and assign a management plan and organization support.
EHS may use data from schools and administrative units to prepare required regulatory reports. EHS shares this data with schools and administrative units.
EHS must track and communicate regulatory changes and projected impacts across Harvard. EHS accomplishes this through ESCOs and its network of staff embedded throughout Harvard.
Harvard must investigate and appropriately report environmental, health, and safety incidents or program non-conformance.
Students, staff, and Harvard-affiliates must disclose any activity that may be or could cause a violation of any environmental health and safety regulation.
Staff must:
- Immediately notify appropriate emergency responders of any situation that could cause an imminent hazard to people, property, or the environment. Emergency responders include the Harvard University Police Department (HUPD), local public safety, local fire department, or Operations Center.
- Communicate additional notifications to the ESCO or unit manager. If the ESCO is not available, report incidents to the director of EHS.
Schools and departments have authority and responsibility for emergency management planning and response, consistent with the Harvard emergency management plan.
In emergencies, schools and departments use their Local Emergency Management Teams for incident notification, response, and recovery. They may engage resources from internal services providers like the HUPD, EHS, Operations Center, or Harvard University Health Services and external service providers as appropriate.
EHS activities:
- Provide regulatory liaison, technical help, and operational guidance as requested or required.
- Work with the school and emergency responders to establish safety and other criteria to resume normal operations.
- If EHS cannot resolve an issue with local lab or administrative staff, escalate safety, health, or environmental compliance issues to management staff (including the ESCO).
All students, staff, and Harvard-affiliates must fully cooperate and appropriately participate in incident investigations and remediation.
Harvard does not penalize students or staff who report incidents following legal and Harvard procedures or communicate questions or concerns about Harvard's environmental health and safety procedures. Harvard does not record these actions in student or staff records.
Harvard views compliance with all laws, regulations, and Harvard policies as conditions of employment and academic eligibility.
Violating these requirements is grounds for Harvard action, including either or both termination of employment or enrollment status. The corporate officer is responsible and authorized to implement such actions.
Government agencies establish strict policies to ensure compliance with environmental, health, and safety regulations, including civil penalties and individual criminal penalties leading to possible prosecution, imprisonment, and substantial fines.
Harvard expects all students, postdoctoral scholars, faculty, staff, and Harvard affiliates to vigilantly follow all environmental, health, and safety requirements and acquire the information they need to properly conduct their activities at Harvard.
EHS uses a layered training approach:
- The Harvard Training Portal (HTP) is the baseline for training on compliance programs and more simplified EHS awareness.
- EHS facilitates or provides classroom-style training on issues that must be more interactive for effective learning. Labs and facilities provide apprenticeship training, which is hands-on, mentor-to-mentee level training on local practices.
- EHS or schools or administrative units may hire very specialized training expertise for some specialized programs or equipment.
The HTP provides robust reporting capability and can help schools and departments track student and staff training completion.