University Safety Policy

Policy Statement 19

Environmental Health & Safety

I. Purpose

This Policy Statement outlines the major roles and authority of the Office of Environmental Health
and Safety (EHS) at Louisiana State University (LSU). The document also provides a framework that
facilitates the protection of life, property, and the environment. Lastly, this Policy Statement sets forth
safety and environmental responsibilities, provides support for safety rules and procedures, and
establishes activities/programs which are necessary for the successful implementation of the
University's Environmental Health and Safety Program.

II. Definitions

For the purposes of this Policy Statement, the following definitions shall apply:

“Institutional Biological and Recombinant DNA Safety Committee (IBRDSC)” shall be defined
as the committee which is charged by the University and AgCenter with overseeing the safety and
security of biological research on campus. The IBRDSC operates under joint oversight of the Vice
President for Research and Economic Development and the LSU AgCenter and Director Louisiana
Agricultural Experiment Stations. Specific activities/responsibilities of the IBRDSC are outlined in the
IBRDSC Policies and Procedures Manual and are to be considered as an extension of this policy.
“Radiation Safety Committee” shall be defined as the committee whose charge is to oversee
safety and security in the use of radioactive materials and other sources of radiation on campus.

III. General Policy

The University has a strong commitment to the health and safety of all employees, students, and
visitors at the institution. Recognizing that a healthy environment is critical to the quality of life of all
living organisms, LSU is committed to protecting the environment from harm due to campus
operations and activities. This includes protecting the air, both indoors and out, lakes, and streams
and grounds. In keeping with these commitments, the Office of Environmental Health and Safety
(EHS) shall have the authority to enforce compliance with the requirements referenced in this policy,
and other applicable environmental and safety regulations. Enforcement action will be taken only
after consultation with senior administration, unless there is an immediate danger to the health and
safety of personnel or an immediate danger to University property. In the event of immediate danger
or major noncompliance, the Director for EHS will be responsible for taking any actions, including
facility closure, required for protection of the health and safety of personnel or protection of
University property. The Executive Director for Risk Management will notify central administration of
any facility closures. Remedial actions will be required before a closed facility will be reopened.

In addition, the following shall be followed:

• In the interest of providing a safe environment for employees, students and visitors, all
  University activities, including, but not limited to, the design, construction, operation and
  maintenance of University facilities, shall be conducted in accordance with all applicable
  safety codes such as the National Fire Protection Association (NFPA), American National
  Standards Institute, (ANSI), American Society of Mechanical Engineers (ASME), American
  Society for Testing and Materials (ASTM), and with all governmental safety and
  environmental standards, including, but not limited to, those issued by the Louisiana State
  Fire Marshal, the Occupational Safety and Health Administration (OSHA), Environmental
  Protection Agency (EPA), Louisiana Department of Environmental Quality (LDEQ),
  Department of Transportation (DOT), Nuclear Regulatory Commission (NRC), and other
  similar state, federal or local agencies. Guidelines of the State Office of Risk Management
  (ORM) will form the foundation for the University safety program.
• Safety and environmental rules and procedures in the University Safety Manual are essential
  to the safety program and shall be vigorously enforced by supervision, using disciplinary
  action where appropriate. In addition to enforcement activities, supervisors are responsible
  for planning and assigning work that is within the training, capability, and skills of workers.
• Critical program elements such as periodic safety inspections, safety training, accident
  investigations, and safety meetings shall be implemented for all work groups, including
  those elements outlined in the University Safety Manual.
• Recognizing that proper training is critical to employee safety, the University will provide
  safety and skills training to achieve a skilled and safe work force.

IV. Environmental Control

It is the University's intent to provide a safe environment that is conducive to studying, learning, and
working, and to minimize any recognized hazards. Any situation or deportment which disrupts the
studying, learning, or working process, or introduces a hazard, is prohibited. Eating and drinking is
prohibited in classrooms except for University approved events. The use of classrooms for activities
other than scheduled classes must first be approved by the responsible party. Smoking is prohibited
in all University learning and working environments. All animals, except those specifically required
for research or teaching purposes, or those that are medically approved, are prohibited in all
University facilities, including all learning and working environments. The Veterinary School Clinic,
which regularly services clients, is the only area of the School of Veterinary Medicine with the
authority to maintain client animals on the LSU campus. Deans, Directors, and Department Heads
are responsible for enforcement of this policy within their units and faculty members are responsible
for the enforcement of this policy in their classrooms.
Any person using outdoor areas of the LSU campus has the responsibility of maintaining control of
their animals at all times.

NOTE: Learning and working environments include classrooms, studios, laboratories, offices,
conference facilities, seminar rooms, practice rooms, libraries, designated study areas, and
carrels.

V. Responsibilities

1. Each and every employee shall be responsible for their own safety, for promoting the
   safety of co-workers, and for protecting the local environment. Employees must report
   and/or correct all safety and environmental concerns, including, but not limited to, those
   3
   relating to facilities or procedures. Failure to follow appropriate safety standards may
   result in disciplinary action, up to and including termination of employment.
2. Vice Presidents, Deans, Directors, and Department Heads shall implement the safety and
   environmental program in their areas of administrative responsibility and shall be accountable
   through their respective administrative channels for the control of accidents and hazardous
   exposures in the work environment. They shall also set the example for environmental control
   by emphasizing and adopting good environmental practices in processes and procedures,
   including, but not limited to, prudent purchasing, use and disposal of chemicals and materials.
   LSU is subject to environmental regulations promulgated and enforced by local, state, and
   federal environmental agencies. Any individual or group found to be in violation of these
   regulations will be potentially responsible for fines levied by the enforcement authorities and
   will be subject to other appropriate corrective action.
3. The Office of the Director of Environmental Health and Safety (EHS) is the principal
   provider/coordinator of all University safety and environmental requirements, including, but
   not limited to:
   1. Providing resources for the identification, evaluation, and control of hazardous situations,
   2. Providing safety, security criteria, and assessments for research and teaching labs
      working with potentially hazardous chemicals, biological or physical agents or processes,
   3. Developing and issuing rules and procedures,
   4. Consulting with employees and management, and
   5. Providing safety training, hazardous waste disposal, and occupational safety and
      health exposure evaluations.

EHS, jointly with environmental permit holders, will monitor laws and regulatory rules and
procedures relating to the environment, act as contact point for interface with
environmental regulatory agencies such as the Louisiana Department of Environmental
Quality (LADEQ), US Environmental Protection Agency (EPA) and the City of Baton
Rouge on regulatory issues, and interface with legal representatives for the University in
citations/disputes on environmental issues.

NOTE: Radiation safety is the responsibility of the Radiation Safety Committee on campus.

D. The University Safety Committee is an advisory committee reporting to the Director of
Environmental Health and Safety. The University Safety Committee shall provide
recommendations to the administration that will enhance the University Environmental Health
and Safety Program. 

VI. Administrative Positions Holding Environmental Permits

(Discharge permits to the Air or Water, Hazardous Waste Disposal. etc.

Administrative department heads shall assure that environmental permits are obtained where
required under law. The permit holder shall:

1. Assure that permitted activities are conducted in strict compliance with the environmental permit through proper operation and maintenance of equipment, adequate procedures,
   recordkeeping, reporting and periodic inspections;
2. Jointly with EHS, monitor developments in regulations and laws affecting the permit;
3. Maintain permit in up-to-date status, with appropriate renewals, data submittals, reporting
   and other requirements;
4. Cooperate with and assist EHS personnel in its role in monitoring permitted activities and investigating incidents; and
5. Jointly with EHS, obtain proper permits or permit modifications from permitting agencies for new or re-furbished processes or equipment.

NOTE: Where appropriate, refer to the Environmental Programs section of the University Safety Manual for guidance in administering this program.

VII. Chemical Use and Research - Safety and Security

The US Department of Homeland Security enforces the Chemical Facility Anti-Terrorism Standard
(CFATS) which applies to possession, use and transfer of certain high hazard chemicals. EHS,
through the Chemical Safety Manager, assures that adequate compliance controls and procedures
are in place, through consultation, training, inventory procedures, inspections and other compliance
requirements under CFATS.

Principal investigators and unit heads assure safety and environmental compliance through activities
such as inventory control and reporting as required by EHS; supervising and training laboratory and
support workers to assure safety and security; cooperating with inspections and investigations; and
correcting deficiencies identified in these activities.

VIII. Biological Research - Safety and Security

To assure that activities involving biological research, diagnostics, instruction, and other activities
involving biological materials and toxins are conducted in a safe and secure manner, the Institutional
Biological and Recombinant DNA Safety Committee (IBRDSC) has been delegated the authority for
registration, approval and oversight of recombinant DNA (rDNA) and biological research activities.

1. All research activities involving the use of rDNA, pathogenic microorganisms
   infecting humans, animals or plants, and biological toxins must be registered
   with, and approved by, the IBRDSC. Principal investigators’ and unit heads’
   responsibilities include, but are not limited to:
   1. Registering research with the IBRDSC;
   2. Supervising and directing laboratory and support personnel;
   3. Ensuring that lab personnel have proper training; and
   4. Providing access to labs for inspections and assuring that prompt corrective action is
      employed upon notice of a safety/security violation or concern.
2. The Biological Safety Manager in EHS supports the activities of the IBRDSC, and provides:
   1.