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.
• Eliminate and/or control potential hazards to students, faculty, staff, visitors and the community.
• 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.

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

The University is responsible for compliance with applicable laws and regulations relating to environmental health and safety. Brown University has policies and maintains procedures to support compliance.  It further promotes institutional accountability and personal responsibility for environmental and safety standards and workplace conditions for University Members and others within the University community by:

• Requiring safety training as a condition of employment or of participation in activities involving hazardous substances or other regulated materials;
• Linking continuing pay and/or employment or participation to required training and response to inspections or compliance reports;
• Imposing appropriate sanctions for failure to complete required training or to respond to inspections or compliance reports, which sanctions may include significant consequences for Continuing Noncompliance or Serious Noncompliance;
• Performing periodic inspections; and
• Monitoring and documenting issues, and overseeing/implementing enforcement processes that address adverse findings.

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

Continuing Noncompliance: A pattern of noncompliance by an individual/University Member that suggests a lack of understanding or disregard for the applicable laws, regulations or institutional requirements that protect the health and safety of University members or the environment, suggests a likelihood that noncompliance will continue without intervention. A 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 noncompliance by an individual/University Member that (i) significantly increases risks; (ii) adversely affects the health and safety of University Members; 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 University members or the environment.

University Member: All Brown faculty, employees (including administrative staff and paid student assistants), students, volunteers, research fellows and 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): EHS develops and enforces appropriate policies and procedures to comply with federal and state safety and environmental laws and regulations, as well as promotes the safety of University Members and the Brown University 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 and providing 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.

Office of the Provost: The Office of the Provost promotes and supports 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: The Office of the Executive Vice President for Finance & Administration promotes and supports 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: The University Safety Committees are 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 University Members and the Brown University community.

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.

In order 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 set forth in Faculty Rules and Regulations, the Handbook of Academic Administration, the University Code of Conduct and the Workplace Safety policy. Possible sanctions in these guidelines and policies include written reprimands, prohibition from entering certain workplace areas, inclusion of safety compliance performance in performance evaluations and salary determinations, transcript notations, probation, suspension, dismissal, expulsion and termination.

In addition to the sanctions set forth 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) include, but are not limited to, the following:

• Mandatory safety meetings;
• Mandatory re-training;
• Stop orders on purchases;
• Temporary shutdowns of facilities; and
• Freezing of submission of grants/contracts.

Brown University is a community in which employees 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.