This policy establishes the requirements for workplace safety and reporting.

This policy applies to the Brown Community, those who do business with Brown, and visitors who use Brown University facilities regardless of the source of funds.

Brown University is committed to protecting the environment and maintaining a safe and healthy campus and workplace. Brown adheres to the following principles:

• Comply with applicable federal and state environmental and safety laws and regulations.
• Identify, eliminate and/or control potential hazards to the Brown Community and the environment.
• Require those who do business with Brown and those approved to use University facilities to perform activities in a manner that adheres to applicable environmental and safety laws, regulations, and University policies.
• Enforce safe work practices.

For the purpose of this policy, the terms below have the following definitions:

Continuing Noncompliance: A pattern of noncompliance by an individual/Brown Community member that suggests a lack of understanding or disregard for the applicable laws, regulations, or institutional requirements that protect the health and safety of the Brown Community or the environment, suggests a likelihood that noncompliance will continue without intervention. Continuing Noncompliance may involve frequent instances of minor noncompliance or a failure to respond to a University request to resolve a noncompliance or pattern of minor noncompliance.

Serious Noncompliance: A pattern of noncompliance by an individual/Brown Community member that (i) significantly increases risks; (ii) adversely affects the health and safety of the Brown Community; or (iii) is the result of a willful violation of any applicable federal, state, or local laws or regulations that protect health and safety of a Brown Community member or the environment.

Brown Community: All Brown employees, faculty, staff (including administrative staff and paid student assistants), students, volunteers, research fellows, trainees, visiting faculty and researchers, and individuals who are involved with activities implicating environmental, health, and safety laws and regulations.

All individuals to whom this policy applies are responsible for becoming familiar with and following this policy. University supervisors and employees with student oversight duties are responsible for promoting the understanding of this policy and for taking appropriate steps to help ensure and enforce compliance with it.

Environmental Health and Safety (EHS): Develop and enforce policies and procedures to comply with federal and state safety and environmental laws and regulations, as well as promotes the safety of the Brown Community. EHS communicates compliance requirements. Additionally, EHS is responsible for:

• Developing, reviewing and updating the University’s environmental, health and safety programs;
• Providing assistance and support for complying with environmental, health and safety requirements;
• Developing, providing, and/or coordinating training as appropriate on University environmental, health and safety programs; and
• Conducting inspections for compliance with federal and state laws and regulations, as well as University policies.
• Conducting a review of the laboratory/working environment upon notification that a minor will be working there, and advising the hiring manager on any restrictions relevant to the minor’s assigned tasks.

Office of the Provost: Promote and support the University’s compliance with applicable federal and state environmental health and safety laws and regulations, as well as University policies and programs, for the Brown academic community. When needed, the Office of the Provost assists with implementing consequences resulting from noncompliance with this policy.

Office of the Executive Vice President for Finance & Administration: Promote and support the University’s compliance with applicable federal and state environmental health and safety laws and regulations, as well as University policies and programs for the Brown non-academic community. When needed, the Office of the Executive Vice President for Finance & Administration assists with implementing consequences resulting from noncompliance with this policy.

University Safety Committees: Responsible for working with EHS to develop and enforce appropriate policies and procedures to comply with federal and state safety and environmental laws and regulations, as well as to promote the safety of the Brown Community.

University Human Resources: Provide guidance to the hiring manager when hiring a minor for employment. Ensure the hiring manager understands laws and regulations regarding the employment of minors, as well as any limitations on terms of employment in the University setting (e.g., Policy on Minors in Laboratories).

Failure to comply with this and related policies and procedures is subject to disciplinary action, up to and including suspension without pay, or termination of employment or association with the University, in accordance with applicable (e.g., staff, faculty, student) disciplinary procedures or for non-employees may result in the suspension or revocation of the users (e.g., vendor, supplier or other third party) relationship with Brown University.

To both communicate this compliance expectation and to incorporate workplace safety into policies governing faculty, students, and staff, compliance with workplace safety regulations is incorporated in University academic and administrative guidelines (e.g., handbooks), as well as employment policies. Sanctions for non-compliance with these and other university policies are outlined in Faculty Rules and Regulations, the Handbook of Academic Administration, and the University Code of Conduct. Possible sanctions in these guidelines and policies include written reprimands, prohibition from entering certain workplace areas, the inclusion of safety compliance performance in performance evaluations and salary determinations, transcript notations, probation, suspension, dismissal, expulsion, and termination.

In addition to the sanctions outlined in the guidelines and policies referenced above, enforcement and sanction actions that may be applied to particular operations (e.g., laboratory, academic unit or administrative operation, machine shop) include, but are not limited to, the following:

• Mandatory safety meetings;
• Mandatory re-training;
• Stop orders on purchases;
• Prohibition from working in laboratories or areas where hazards exist;
• Temporary shutdowns of facilities; and
• Freezing of submission of grants/contracts.

Brown University is a community in which individuals are encouraged to share workplace concerns with University leadership. Additionally, Brown’s Anonymous Reporting Hotline allows anonymous and confidential reporting on matters of concern online or by phone (877-318-9184).

The following information complements and supplements this document. The information is intended to help explain this policy and is not an all-inclusive list of policies, procedures, laws and requirements.