Policies & Procedures

I. PURPOSE

This policy is intended to provide guidance to all Longwood University faculty, staff, students, where applicable, and those contract employees working within and under Longwood University's direction on all Longwood University properties. It provides a framework for the development and implementation of all University environmental, health and safety (EHS) procedures regarding compliance with federal, state, and local regulations regarding their compliance requirements.

II. SCOPE OF APPLICATION

The EHS Office provides environmental, occupational health and safety services to Longwood University including off-campus Longwood University facilities and properties to facilitate compliance with environmental, occupational health and safety, regulations, compliance directives and Executive Orders. These regulations include, but are not limited to, those promulgated by:

• Virginia Department of Environmental Quality (DEQ),
• Environmental Protection Agency (EPA),
• Virginia Occupational Health and Safety Administration (VOSH),
• Virginia Department of Workers Compensation (VWC),
• Virginia Department of Health (VDH),
• Department of Transportation (DOT), and the Virginia Department of Labor, (VDL), as well as;
• those directives and or Executive Orders from the Board of Education and the Governor's Office.

The mission of the EHS Office is to develop, coordinate and assist in the implementation of and required training related to appropriate EHS policies and procedures which promote an injury free career culture for all employees, students, contractors, and visitors studying, working or visiting our properties, as well as compliance to all environmental quality laws, rules, regulations, and standards. For these reasons, Longwood University has the responsibility to establish such procedures based upon this policy the appropriate compliance requirements and provide resources to ensure they are provided to all personnel affected.

Each employee guided by the Board of Visitors, Longwood Cabinet and directed by the President is responsible to carry out the intent of this policy and its procedures derived from its direction. The management of this document, it's control, research efforts and annual review of this policy and the procedures it directs is the responsibility of the Environmental, Health and Safety Office with assistance and recommendation from the designated EHS Committee.

III. ENVIRONMENTAL  

Although the environmental compliance component of the EHS Office shall be the lead organization for developing and managing the Longwood University's environmental compliance program, all individuals, and organizations, have responsibilities for its implementation.

The individual employee shall perform their job functions in accordance with work practices or procedures specific for their activities and in compliance with the Longwood University Environmental Management Plan.

Longwood University Environmental Goals shall meet or exceed the Virginia Department of Environmental Quality (DEQ) and where applicable EPA regulations, directives and Executive Orders established by the Governor's Office. These compliance standards shall be met through procedures, processes and plans with attached responsibilities to cover the below listed areas and those areas which may later be identified by a regulation:

• Environmental Management System (EMS)
• Spill Prevention, Control, and Countermeasure (SPCC)
• Air Permitting
• Lead-Based Paint
• PCB Management
• Asbestos Management
• Hazardous Waste Management
• Underground Storage Tanks
• Aboveground Storage Tanks
• Storm Water
• Pesticides and Related Materials
• Drinking Wate
• Hazardous Materials

IV. OCCUPATIONAL HEALTH AND SAFETY

Occupational Health and Safety measures must be a priority within any culture to reach goals intended to become an "injury free career culture". At Longwood University, safety is everyone's responsibility and all must strive to maintain a safe living, learning, and working environment. Faculty, staff, students, contractors, visitors, and other members of the Longwood University community must conduct University operations in accordance with applicable federal, state, and local regulations, and those approved policies and procedures under the University's EHS requirements.

This policy, when instituted is intended to assist in preventing accidents, illnesses, and injuries, increase safety awareness, meet requirements of occupational health and safety compliance standards, reduce institutional liability, identify hazards through risk assessments and establish safety responsibilities for personnel of the University community.

All members of the university community are expected to be thoroughly familiar with their safety responsibilities, strive to follow safety practices at all times, communicate hazards and incidents/accidents to supervisors, and be prepared for emergencies that may occur in the workplace. All members of the University's community must act proactively to ensure everyone is capable of having an "injury free career".

EHS will work closely with all departments, committees, employees, and students throughout the University to ensure compliance with the policy. This policy shall be the baseline for the following EHS procedures:

• Accident Investigation and Reporting
• Biosafety
• Chemical Hygiene
• Contractor/Sub Procedures
• Excavation, Trenching and Shoring
• Fall Protection
• Hazard Communication
• Hazardous Waste
• Hot Work Permit
• Lockout/Tagout
• Respiratory Protection
• Asbestos Operations and Maintenance
• Bloodborne Pathogen
• Confined Space Entry
• Electrical Safety
• Exposure Control Plan
• Fire and Life Safety
• Hazardous Materials
• Hearing Conservation
• Lead Hazard and Prevention
• Personal Protective Equipment
• Welding, Cutting, Brazing, & Soldering

The procedures above and those identified and put in place after the approval of this policy shall have policy strength and enforcement avenues to include disciplinary action as directed by the Longwood Human Resource requirements.

VI. RESPONSIBILITIES

The Office of EHS is responsible for the overall administration of the campus EHS policies and is accountable for Longwood University's compliance with all environmental, occupational health and safety regulatory agencies. The EHS is tasked to work within or chair where applicable the appropriate committees assigned to design, develop, and implement the EHS processes to ensure compliance of regulatory requirements, best industry practices and Longwood University EHS&EM policies and procedures. It carries out this mission by providing technical, regulatory, and related management services to the colleges, centers, departments, and the Institution that have a shared responsibility for operational accountability for regulatory compliance. EHS shall assist in the development and implementation of programs including; training, emergency response, and analysis of specific problems so that compliance is practical at the individual level.

What about routine and random inspections of worksites?

EHS shall coordinate all University responses to regulatory agencies' inquires, complaints, lawsuits, and other formal proceedings through the college, center or department heads where applicable and the Office of the President prior to approving methods for corrective action. The Director of EHS shall report to the office selected by the President.

1. University President
   
   Assumes overall responsibility for the development and implementation of Longwood University's EHS Policy at all facilities and property under Longwood University control.
2. Provost, Vice Presidents, and Deans
   
   Implement and enforce the EHS Policy and procedures in all facilities and operations under their control. Assist the EHS Office where applicable to meet the regulatory compliance requirements and establish processes and/or programs to ensure leadership guidance toward University EHS goals.
3. Directors/Department Heads
   Each Director and Department Head shall as necessary provide the following direction and EHS support by;
   • Implementing and enforcing the University EHS Policy and its procedures by communicating its requirements to faculty, students (where applicable) and staff.
   • Designate and empower a safety team(s) as necessary to address and coordinate safety efforts within scope of responsibility.
   • Direct individuals, including but not limited to faculty, managers, lab managers and supervisors, regular and temporary employees, visiting professors, and students, to complete required safety training and use appropriate personal protective equipment before working with hazardous chemicals, bio-hazardous materials, radiation, or physical/mechanical hazards in their working or learning environments.
   • Report all accidents, job-related illnesses, and work site injuries to the respective supervisor and/or department.
   • Conduct an investigation of all job-related illnesses, accidents, and work site injuries, complete the University's Accident Report and identify and report workplace hazards with corrective action methods.
   • Follow up on all hazard corrective actions and accident findings to ensure repeatable incidents do not occur.
   • Determine whether EHS requirements for departments are met, e.g., training, personal protective equipment, and corrective measures (including non-mandated items identified in safety audit).
   • Incorporate workplace safety requirements and responsibilities into each appropriate job description and ensure that workplace safety expectations are communicated to each employee.
   • Ensure that periodic safety self-audits of work areas and/or facilities are conducted, hazards are identified, reported to the EHS Office and corrective action taken.
   • Ensure that emergency action preparedness/evacuation plans and assembly points are identified and communicated to all personnel in order to ensure safe evacuations.
4. Lab Managers and Supervisors
   
   Shall ensure each employee responsible under their charge to include students, visitors, and contractors are advised of the appropriate EHS training required to conduct their task and shall:
   • Implement Longwood University's EHS Policy, procedures, and all other University safety programs in work areas under their supervision/control.
   • Require all staff members and students under their direction to attend and maintain current required safety training.
   • Maintain workplaces and equipment under their control in a safe, well-kept condition.
   • Ensure that hazards are proactively identified and corrected by implementing engineering or administrative controls, or by assuring use of necessary personal protective equipment.
   • Dispose of waste properly and in accordance with university, state and federal requirements.
   • Ensure contractors working in their areas are advised of the requirements of EHS specific area hazards within the contractor work area, e.g. hot work permit, fire alarms, steam systems, confined space, and or hazardous materials and hazardous waste.
5.  Faculty, Staff, and Students
   
   Employees and students must take personal ownership of their own conduct and immediate living, study, and work environments. This requires taking the initiative to report unsafe acts and unsafe conditions on campus. Employees and students are also responsible for wearing or using personal protective equipment, reporting accidents, injuries and illnesses and refrain from operating equipment without proper authorization and documented training. Each employee shall comply with the following:
   •  All regulatory compliance requirements in accordance with the work task they are provided and to the Longwood University EHS Policy and its Procedures.
   • Attend all required Longwood University EHS training.
   • Inform a supervisor or instructor of any safety or health hazards in the workplace on University property, or in areas tenanted or used by Longwood University.
   • Know their role in an emergency.
   • Report all incidents/accidents to your supervisor and assist in accident investigations as required.
6. Human Resources
   
   Include the EHS in its new employee orientation and support the EHS initiatives as follows:
   • Provide assistance where applicable in all EHS matters for resolution.
   • Provide worker compensation First Report of Injury data to the EHS on a quarterly basis.
   • Compile accident stats and injury data as required by EHS for annual report.
   • Compile all OSHA 300 Form reporting and provide reports to each department and EHS as required annually.
   • Send copies of all first reports of injuries to EHS within 10 days of receipt and manage all reports as required by OSHA.
7. Contractors/Sub-contractors
   
   Each general contractor, contractor, or sub-contractor shall perform its EHS responsibilities within the regulatory compliance requirements as outlined in the contract and Longwood University Safety Requirements for Contractors and Subcontractors procedures.
8. University EHS Committee
   
   The University EHS Committee is established through the EHS Office as a University Operational Committee with authority to review program and procedures to assist the EHS Office where applicable in implementing university EHS policy and regulatory compliance. The Committee is an informed multidisciplinary group charged with ensuring that the University maintains readiness to effectively address EHS issues. They are also charged to provide consultation and be an advisory source to EHS, to ensure compliance to policy.

VII. TRAINING

EHS training shall be conducted as required by the task being performed, the regulatory compliance requirements and the EHS procedure. All training records shall be required to list the subject matter title, instructor's name, date of the instruction, the class attendee's name and employee badge number, where applicable. All training records shall be kept for three years as required by Virginia Occupational Health and Safety Administration. All training must be completed within the time constraints provided by the EHS Office.

VIII. ENFORCEMENT CLAUSE

All faculty, staff, and students have the responsibility to abide by the EHS policies and procedures and report unsafe behavior/actions and operations which may cause any injury or harm to people, property, or the community. All faculty and staff have the responsibility to personally cease performing and request others to cease performing any action where it is determined that such action could result in the Immediate Danger to Life and Health (IDLH) under the OSHA guidelines. Each individual, who has responsibilities listed under the EHS Policy, shall ensure the EHS requirements within their operations are adhered to and provide the appropriate disciplinary action when required.

The EHS Director and its designated staff shall enforce all EHS policies and procedures equally and impartially. The EHS Office shall have the authority to issue a stop work order for any operation where anyone's health may be compromised or injury may occur until such time the situation is investigated to determine cause and corrective action is provided.

Revised and approved by the Board of Visitors, September 7, 2002.
Revised and approved by the Board of Visitors, September 11, 2009.