6.02 Adoption and On-going Review of EHS System, Roles and Responsibilities

Policy and Procedures for Adoption and On-going Review of the University of Georgia’s Comprehensive Environmental Health and Safety Management System and Roles and Responsibilities

1. Purpose. The purpose of this policy is to describe the policy and procedures for adoption of UGA’s Comprehensive Environmental Health and Safety Management System (“Comprehensive EHSMS”) and to define roles and responsibilities as required by EHS Policy No. 6.01, titled “University of Georgia’s (UGA’s) Environmental Health and Safety Policy.”

2. Scope. EHS Policy No. 6.01 and this policy will be the dominant governing policies at UGA defining how UGA approaches and manages all aspects of environmental health and safety. EHS Policy No. 6.01 and this policy will cover all campuses and units of the University of Georgia, with no exceptions.

3. Required Review. This policy will be reviewed annually, and all changes to this policy must be approved by the EHSMS Executive Committee. All other associated policies, tied to and stemming from this policy, will be revised accordingly.

4. Procedures for Adoption and Review of UGA’s Comprehensive EHSMS.

a. Adoption. The Executive Committee will have oversight over the adoption and annual review of the Comprehensive EHSMS. The Executive Committee will coordinate, work with and direct various university committees, academic and operating units, the Office of the Vice President for Research, and the Environmental Safety Division as needed, on all matters relating to environmental health and safety at UGA. The Comprehensive EHSMS will govern how UGA manages all aspects of environmental health and safety. It will be an integrated set of processes and procedures for managing the day-to-day EHS compliance operations to enhance the level of compliance and to increase efficiency of operations in a comprehensive manner. The Comprehensive EHSMS will use a process-driven approach to track information, identify safety risks, set safety goals, take action to ensure safety, assess results of those actions, and adjust processes as necessary to produce the intended results.

b. Annual Review. The Executive Committee, working together with various faculty and administrative staff, will review annually the Comprehensive EHSMS and all subsequent associated policies to ensure adherence with UGA’s Environmental Health and Safety Policy (EHS Policy No. 6.01). Any revisions to the Comprehensive EHSMS will be approved by the Executive Committee and communicated to all UGA employees through coordinated communications from the Office of the Vice President for Research and the Environmental Safety Division.

c. Accountability and Compliance. UGA will define the responsibilities of all stakeholders, and hold each stakeholder accountable to those responsibilities and overall compliance with UGA’s Environmental Health and Safety Policy (EHS Policy No. 6.01), this policy, and the Comprehensive EHSMS. Any stakeholder determined not in compliance will be required to complete additional training and to remedy the non-compliance matter. Any stakeholder found to be in repeated non-compliance will be subject to appropriate disciplinary action including possible removal from the laboratory or work environment, suspension or dismissal from UGA.

d. Training. All stakeholders must complete defined training offered by the University prior to carrying out their assigned responsibilities and work and must complete on-going training no less than annually. All training must be documented.

5. Roles and Responsibilities.

a. Academic and Research Units.

i. Laboratory Personnel. Laboratory Personnel are any persons who work, teach or observe within a designated research or instructional laboratory or field environment. Laboratory personnel include, but are not limited to, students, non-students, teaching assistants, instructors, and any visiting personnel. The responsibility of each Laboratory Personnel is to conduct activities in compliance with all laboratory-specific procedures, applicable EHS federal, state, and local regulations and UGA policies and procedures and to assist the lead investigator or their designee with all EHS matters.

ii. Laboratory Supervisor/Laboratory Coordinator. The responsibility of each Supervisor or Coordinator is to provide day-to-day supervision of research and activities in the laboratory and to ensure that those activities comply with all applicable EHS federal, state, and local regulations and UGA policies and procedures and to keep informed and assist the Principal Investigator, Instructor, or Lead Investigator or their designee with all EHS matters.

iii. Principal Investigator/Instructor/Lead Investigator (“PI”). The responsibility of each PI is to ensure that all laboratory activities under his/her direction are conducted in compliance with laboratory-specific procedures defined by the PI, applicable EHS federal, state, and local regulations, as well as UGA policies and procedures. With assistance from the Office of Research Safety and the Environmental Safety Division, each PI is responsible for developing, implementing, and updating a laboratory-specific chemical hygiene plan for the safe use, storage, and disposal of chemicals and other hazardous materials in his/her laboratories. PIs must ensure that all personnel working in their laboratories have adequate training to carry out their assigned tasks and receive on-going training. PIs have the responsibility to remedy all non-compliance matters. PIs vacating any laboratory spaces have the responsibility to leave the space ready for future occupancy.

iv. Department Head and Center/Institute Director. The responsibility of each Head or Director is to ensure that all research and activities in the Department or Center/Institute are conducted in compliance with all applicable EHS federal, state, and local regulations and UGA policies and procedures. Heads and Directors must ensure that all laboratory spaces under their direction or oversight are properly maintained while in use and safely cleaned after the spaces are vacated. Heads and Directors have the responsibility to remedy all non-compliance matters and have overall financial responsibility on such matters.

v. Deans. The responsibility of each Dean is to ensure that all research and activities in the college or school are conducted in compliance with all applicable EHS federal, state, and local regulations and UGA policies and procedures. Deans must ensure that all laboratory and non-laboratory spaces under their direction or oversight are properly maintained while in use and safely cleaned after the spaces are vacated. Deans have the responsibility to remedy all non-compliance matters. Colleges or Schools will have overall financial and compliance responsibility for all laboratory spaces to which they have been assigned.

b. Administrative and Operating Units.

i. Administrative and Operations Staff. The responsibility of each Administrative and Operations staff person is to conduct activities in compliance with all applicable EHS federal, state, and local regulations and UGA policies and procedures, to help ensure that the administrative or operating unit is in compliance with EHS regulations and UGA policies and procedures and to assist the Supervisor, Unit Head, or Director.

ii. Administrative and Operations Supervisor. The responsibility of each Supervisor is to provide day-to-day supervision of activities in his/her designated area to ensure that they are in compliance with all applicable EHS federal, state, and local regulations and UGA policies and procedures, and to assist the Administrative or Operations Unit Head or Director with all EHS matters.

iii. Administrative and Operations Unit Head/Director. The responsibility of each Unit Head or Director is to ensure that all activities in the administrative units are conducted in compliance with all applicable EHS federal, state, and local regulations and UGA policies and procedures. Unit Heads and Directors must ensure that all personnel working in their units have adequate training to carry out their assigned tasks and receive on-going training. Unit Heads and Directors have the responsibility to remedy all non-compliance matters.

c. Environmental Safety Division (ESD) and the Office of the Vice President for Research (OVPR).

i. ESD and OVPR staff. The responsibility of each ESD and OVPR staff person is to provide assistance and maintain a level of expertise in designated EHS regulatory and program areas. The responsibility of each ESD and OVPR staff person is to maintain his/her certifications or training needed to perform his/her responsibility, communicating with various academic and administrative units across the campus, developing and reviewing policies, procedures and guidelines, providing EHS training, responding to requests for assistance, addressing incidents, and maintaining EHS training and compliance records.

ii. Associate Vice President ESD. The responsibility of the Associate Vice President ESD is to oversee and supervise the ESD, and to be the primary contact for EHS matters, both within non-research areas at UGA and with the external community. The responsibility of the Associate Vice President ESD is to ensure that ESD is providing assistance and support to UGA regarding EHS matters, to handle administrative and personnel matters, and to communicate to the UGA Administration as needed regarding EHS matters. The Associate Vice President ESD is a member of the EHSMS Academic/Research Steering Committee and the EHSMS Administrative/Operations Steering Committee.

iii. Associate Vice President for Research. The responsibility of the Associate Vice President for Research is to oversee and supervise the EHS staff in the OVPR and to be the primary contact for EHS matters within research areas at UGA. The responsibility of the Associate Vice President for Research is to ensure that OVPR is providing assistance and support to UGA regarding EHS matters, to handle administrative and personnel matters, and to communicate to EHSMS Executive Committee as needed regarding EHS matters. The Associate Vice President for Research is a member of the EHSMS Academic/Research Steering Committee and the EHSMS Administrative/ Operations Steering Committee.

d. UGA Committees.

i. EHSMS Academic/Research Steering Committee. The EHSMS Academic/Research Steering Committee will meet periodically, but not less than quarterly, to guide the development and implementation of those aspects of the UGA EHSMS that will enhance environmental, health, and safety programs and compliance of academic/research activities at UGA. At the discretion of the EHSMS Executive Committee, this steering committee may be discharged following implementation of the EHSMS. Reactivation and recharge of the committee by the EHSMS Executive Committee will be based on institutional need.

ii. EHSMS Administrative/Operations Steering Committee. The EHSMS Administrative/Operations Steering Committee will meet periodically, but not less than quarterly, to guide the development and implementation of those aspects of the UGA EHSMS that will enhance environmental health and safety programs and compliance of administrative/operations activities at UGA. At the discretion of the EHSMS Executive Committee, this steering committee may be discharged following implementation of the EHSMS. Reactivation and recharge of the committee by the EHSMS Executive Committee will be based on institutional need.

iii. EHSMS Executive Committee. During the implementation of the EHSMS, the EHSMS Executive Committee will meet periodically, but not less than quarterly, to review and provide guidance on the design, development and implementation of the EHSMS. After implementation of the EHSMS, the Executive Committee will meet periodically, but not less than twice a year, to review and provide oversight on the Comprehensive EHSMS.

iv. Standing and Ad hoc Committees. The EHSMS Executive Committee, directly or through the Comprehensive EHSMS, will form and charge standing and ad hoc UGA committees as needed. Standing committees include the Research Safety Committee, the Radiation Safety Committee, Institutional Review Board, and the Institutional Biosafety Committee.

e. Senior Administration.

Senior Administration are all UGA cabinet members including the Director of Athletics, Associate Provosts, Vice Presidents, Vice Provost, Provost, and President. The responsibility of Senior Administration to environmental health and safety is consistent with their organizational and reporting responsibility.