EHS-MS Manual

Welcome to MIT's Environment, Health and Safety (EHS) Management System Manual. This Manual is designed to serve as a comprehensive guide to the EHS Management System and all of its related components. It provides a detailed overview of the Management System's design and approach, and a summary discussion on all of the organizational components of the Management System. The Manual is an excellent source for obtaining a high-level and comprehensive perspective and understanding of the Institute's EHS requirements and the tools available to meet those requirements. All students, faculty, and staff should read the Manual to better assist in contributing to sound EHS practices.


 


The Manual is organized around the seven central components of the Management System:


  • MIT's EHS Policy and Objectives 
  • The Roles and Responsibilities for Implementing the Management System
  • How MIT Plans for Continual EHS Improvement
  • The EHS Training Requirements and Delivery Systems 
  • EHS Services and Data Management 
  • Inspections and Audits, and
  • EHS Communications 

The Manual can be used in two ways. Reading the Manual in its entirety will provide the most integrated and comprehensive perspective on the purpose, approach, and tools MIT has deployed to help the MIT community meet and surpass its EHS obligations. Also, the Manual can be used as a central reference source to access information on specific components of the Management System as needed.


The Manual provides links to essential procedures and tools that support the day-to-day demands of implementing the Management System and carrying out your EHS activities.


Can't find what you are looking for? Please contact the EHS Office at 617-45(617) 452-3477 or send us an e-mail at environment@mit.edu.


 


1.0 EHS Policy and Objectives


 


1.1 Introduction


MIT has a comprehensive and integrated Environment, Health, and Safety Management System (EHS-MS) that is sustainable for the long term within our academic research setting. A highly collaborative effort that draws on the leadership and expertise of faculty, researchers, students, administrators, and staff, the EHS Management System helps to shape how all members of the MIT community view their environment, health, and safety responsibilities, carry out MIT's comprehensive and integrated environmental commitment in their day-to-day activities, and assess MIT's performance against our goals.


 


A Systems Approach


Through the well-defined and structured EHS Management System that is embedded in the daily activities of the Institute, MIT has an infrastructure that ensures long-term success and sustainability in meeting and surpassing its environment, health and safety obligations. Each component of the EHS Management System is designed to work interdependently in an integrated fashion that continually reinforces the common objective of improving EHS performance.


 


To ensure the organizational sustainability of the EHS Management System, all components of the Management System, such as Policy and Objectives, Planning, Training, and Inspections are designed and established as formal systems, integrated into on-going academic and facilities operations, and evaluated on a regular basis to identify areas for continual improvement. It is these core systematic components that act both independently and cooperatively to form the backbone of the EHS Management System.


 


One of the central principles of this system and of our EHS Policy is the commitment to reflect our long held values of excellence not only in our research and teaching, but also in our operations. This management system provides improved institutional capacity and accountability for achieving and maintaining compliance with MIT's high standards for EHS performance, and federal, state, and local EHS regulations in MIT's departments, laboratories, and centers (DLCs), while simultaneously retaining the independence of research and teaching. The EHS-MS also creates a more sustainable campus by encouraging the incorporation of positive initiatives into activities, such as reducing wastes and toxic materials, preventing pollution, and conserving and reusing resources. One of the defining features of MIT's EHS-MS is to integrate regulatory compliance with positive initiatives and educational programs in a decentralized academic research setting.


 


The EHS-MS operates in tandem with MIT's existing policies and procedures. This management system includes and implements MIT's EHS Policy which has the full authorization, approval and support of the MIT Academic Council, our highest policy-making council convened by the President and comprising the Institute's senior officers. MIT senior management has established and is committed to maintaining the EHS-MS.


 


This Manual describes the elements of MIT's EHS-MS; the established policies and procedures that MIT follows to meet applicable environment, health and safety performance and legal requirements; and policies and procedures to comply with other requirements to which MIT voluntarily subscribes.


 


1.2 EHS Policy and Guiding Principles


MIT has adopted a comprehensive Environment, Health and Safety (EHS) Policy that describes and communicates the Institute's commitment to excellence in environment, health and safety stewardship. In particular, MIT's EHS policy commits the Institute to:


  • Minimizing adverse EHS impacts,
  • Achieving and maintaining compliance with EHS regulations,
  • Achieving a high standard for accountability for EHS stewardship,
  • Providing educational opportunities, and
  • Continually improving EHS performance

The Working Group and  the Institute Council on Environment, Health and Safety, (co-chaired by the Vice President for Research and Associate Provost and the Managing Director, EHS Programs, and comprising senior faculty and administrators), developed and endorsed the policy. The policy was then presented to the Academic Council, which is chaired by the Institute President and serves as the President's cabinet for Institute-wide policy-making. Following approval by the Academic Council, the policy was adopted by MIT on December 11, 2001 and reaffirmed on November 2, 2007.


 


The EHS Policy is communicated to the MIT community through a variety of means as described more fully in the EHS Communications Plan and outlined in Section 8, Communications. The EHS Policy is provided to students, faculty, researchers, and staff during many orientation and training opportunities.


 


The EHS Policy is reviewed and modifications to the policy are considered periodically as part of the overall EHS-MS management review process as described in Section 6.1, Inspections.


 


1.3 Targets, Objectives, and Action Plans


MIT is committed to being at the forefront of large academic research institutes in measuring and continuously improving environment, health and safety performance. One way that MIT improves its EHS performance is through the implementation of action plans to meet specified objectives and targets. The objectives and targets are developed through a variety of processes as described in Section 3.9, Establishing and Updating Targets, Objectives, and Action Plans and progress is monitored on an ongoing basis.


 


2.0 Roles and Responsibilities


 


MIT's Environment, Health and Safety Management System is responsive to the overall structure and culture that exist in the MIT community.


The EHS-MS Organizational Structure, shown in the chart, provides a framework that fosters communication and effective working relations among Departments, Laboratories, and Centers (DLCs), the Environment, Health and Safety (EHS) Office and MIT's senior officers (including the President, Provost, Chancellor, Executive Vice President, Vice Presidents, and Deans).


 


2.1. Institute Leadership


 


2.1.1   Senior Officers


MIT's Senior Officers include the President, Provost, Chancellor, Executive Vice President, Vice Presidents, and Deans. This executive staff provides resources, including human resources, specialized skills, technology, and financial resources, essential to the implementation and control of the EHS-MS. (See Chart)


 


2.1.2 Councils and Committees


The organizational structure of the EHS-MS is designed to incorporate multi-disciplinary relationships to assure that EHS issues are addressed in a comprehensive and integrated fashion. These relationships are established through various committees whose functions are summarized below:


  • Institute Council on Environment, Health and Safety and the Committees on:
  • Animal Care
  • Assessment of Biohazards and Embryonic Stem Cell Research Oversight
  • Radiation Exposure to Human Subjects
  • Radiation Protection
  • Reactor Safeguard
  • Toxic Chemicals
  • Use of Humans as Experimental Subjects

Institute Council on Environment, Health and Safety


The Institute Council on Environment, Health and Safety (ICEHS) reports to the President and is responsible for coordinating policy development, the assessment of procedures of the Institute Committees concerned with specific areas of environment, health and safety, and overseeing the implementation and effectiveness of the EHS-MS. The Council serves as a forum in which shared concerns of these Committees are coordinated and where issues of individual Committees are resolved. The Council is also responsible for identifying new environment, health and safety issues that emerge as new activities are undertaken and new technologies evolve. In instances where such new activities do not fall within the purview of an existing committee, the Council may expand the area of concern of an existing committee or recommend the creation of a new committee.


The Council's membership includes:


  • Vice President for Research and Associate Provost, Chair
  • Managing Director, Environmental, Health and Safety Programs
  • Director, Environment, Health and Safety Office
  • Chair, Committee on Animal Care
  • Chair, Committee on Assessment of Biohazards and Human Embryonic Stem Cell Research Oversight
  • Chair, Committee on the use of Humans as Experimental Subjects
  • Chair, Committee on Radiation Protection
  • Chair, Committee on Reactor Safeguard
  • Chair, Committee on Toxic Chemicals
  • Institute Auditor
  • Dean's Office
  • Service Administrators from Department of Facilities, Lincoln Laboratory, and MIT Medical
  • Working Committee Representatives

Committee on Animal Care


MIT's Committee on Animal Care (CAC) reviews and approves all experiments involving animals to ensure that MIT researchers working with animals comply with federal, state, local and institutional regulations on animal care. To that end, the CAC inspects animals, animal facilities and laboratories, and reviews all research and teaching exercises that involve animals before approving experiments to be performed.


Committee on Assessment of Biohazards and Human Embryonic Stem Cell Research Oversight


The Committee on Assessment of Biohazards and Human Embryonic Stem Cell Research Oversight (CAB/ESCRO) reviews and approves research involving potential health and safety problems associated with biological research and Dual Use Research of Concern (DURC)


Committee on Radiation Protection


The Committee on Radiation Protection is responsible for developing and monitoring the Institute's radiation protection program. The Committee is also responsible for assuring the Institute's compliance with radiation protection regulations promulgated by state, federal, and local agencies.


Committee on Reactor Safeguard


The Committee on Reactor Safeguard is responsible for matters of nuclear safety related to the MIT Research Reactor, including the safety of personnel on and off site. The Committee reviews and approves all new operating plans and policies, including significant modifications, and all new experiments involving significant changes in procedure prior to implementation. The Committee verifies that nuclear reactor operation is consistent with MIT policy, rules, approved operating procedures, and license provisions.


Committee on Toxic Chemicals


The Committee on Toxic Chemicals is responsible for reviewing current practices with regard to the effects of toxic chemicals, including carcinogens. The Committee is also responsible for developing policies necessary to control the risks and exposure to personnel working with such agents, and for ensuring compliance with rules and regulations.


Committee on the Use of Humans as Experimental Subjects


The Committee on the Use of Humans as Experimental Subjects (COUHES) reviews and approves all research involving human subjects that is performed under the auspices of MIT in accordance with Federal regulations and MIT policy. Types of research that must be reviewed by the Committee include investigation of new drugs and medical, radiological, engineering, physiological, behavioral, sociological, and nutritional studies.


 


2.2 Departments, Laboratories and Centers (DLC)


The Departments, Laboratories and Centers (DLC) are the primary organizations that implement and maintain sound EHS practices and that assure EHS compliance. (See Chart)


The following sections explain roles and responsibilities for EHS activities within DLCs. A person in a specific role is responsible for certain EHS activities whether by performing those activities or overseeing other in performing those activities. This is intended to provide flexibility to each DLC and the central EHS office to operate in the most efficient and effective manner while defining certain functions that must be performed.


 


2.2.1 Department Heads/Directors, Principal Investigators and Supervisors


DLC Head/Director - has the primary responsibility and authority of directing and managing the DLC and therefore has final responsibility for assuring sound EHS practices and compliance within the DLC. The DLC Head/Director is ultimately responsible for enforcing consequences arising from poor EHS performance, moderately serious and/or very serious incidents. The DLC's EHS performance evaluation is included in the annual report to the President of MIT and/or to the relevant Dean's Office.  Finally, the DLC Head/Director is responsible for assuring contractors and visitors to the DLC, or acting on behalf of the DLC, are informed of MIT EHS requirements, and that the EHS Office is contacted, as needed, for any EHS concerns introduced by the Contractor/Visitor activities.


Principal Investigator (PI)/Supervisor - is responsible for compliance with EHS regulations and good practices in his or her laboratory or non-research facility and plays a critical role in the function of the EHS-MS. The PI/Supervisor has the responsibility to appoint an EHS Representative to assist in meeting his or her EHS responsibilities. If an EHS Representative is not appointed, the PI/Supervisor also acts as the EHS Representative. In the Department of Facilities and Division of Student Life, the supervisor acts as the EHS Representative. In addition, the PI/Supervisor has the authority and is responsible for:


  • insuring that assigned spaces where hazardous and/or regulated materials or equipment are used and stored are registered in the PI/Space Registration and updated when new hazards are introduced or processes change;
  • attending all required EHS training and assuring that all laboratory or facility personnel under his or her supervision are trained;
  • ensuring assessments are made, procedures established, and engineering controls and personal protective equipment are provided for safe work environment;
  • assuring that EHS inspections are conducted as required, and that any problems identified are addressed;
  • reporting injuries and incidents such as spills, and investigating to determine if action is needed to prevent similar injuries or incidents, contacting EHS Office as needed for assistance.
  •  

2.2.2 EHS Coordinators and Representatives


EHS Coordinator - receives authority from and acts on behalf of the DLC Head/Director to carry out EHS programs. The EHS Coordinator provides operational day-to-day oversight of the DLC's EHS-MS requirements. Please refer to EHS Team List for your DLC EHS Coordinator. In addition, the EHS Coordinator supports the EHS Representatives and PIs/Supervisors by providing additional authority and resources to address EHS issues, including regulatory deficiencies, training needs, and other EHS-MS needs. Specific duties of the EHS Coordinator include but are not limited to the following:


  • to serve as Co-Chair and a member of the DLC EHS Committee, and to retain records of EHS Committee meeting;
  • to convene a meeting of the DLC EHS Representatives and EHS Office Lead Contact at least annually and retain a record of the meeting(s). An EHS Coordinator who prefers to meet one-on-one, or with smaller groups of EHS Representatives instead of convening the entire group must work with the EHS Office to determine a sustainable strategy for including the EHS Lead Contact in these meetings.
  • to work with PI/Supervisors to register spaces and associated hazards in the PI/Space Registration;
  • to conduct inspections of DLC spaces, as required by EHS-MS, and to provide follow-up and assistance as needed to address inspection findings;
  • to serve as a contact for DLC EHS concerns, facilitating communication between DLC Personnel and EHS Office staff to address concerns.

EHS Representative - reports to and assists the PI/Supervisor in identifying and addressing EHS issues. The EHS Representative initiates actions where appropriate, and brings issues to the EHS Coordinator and PI/Supervisor when his or her authority is required to address an EHS issue. Note: In the Department of Facilities and Division of Student Life the Supervisor acts as the EHS Representative. Specific duties of the EHS rep include but not limited to:


  • assuring new personnel in the lab/work area complete their EHS Training Needs and complete required training prior to working with hazardous materials or performing hazardous tasks;
  • assisting EHS Coordinator in the maintaining PI/Space registration data (as outlined in section 3.2) and emergency contact information.
  • conducting weekly inspections in registered spaces and communicating the findings to the PI/Supervisor or the EHS Coordinator.

DLC EHS Committee - is a forum for single or multiple DLCs to review and discuss EHS regulations and practices and establish strategies to implement them in the DLC. This Committee is co-chaired by the EHS Coordinator and a senior faculty member, researcher or supervisor from within the DLC. The EHS Office Lead Contact and/or other EHS Team Members also participate in the committee in an advisory role. Each Committee meets annually at a minimum and keeps records of the meetings. In a DLC where the DLC Head / Director wishes to be actively involved with the DLC EHS Committee and act as the committee chair, the DLC's EHS Committee could consist of the DLC Head, DLC EHS Coordinator and EHS Lead Contact. Their meeting(s) that takes place during the course of inspections could be considered to satisfy the requirement for an annual committee meeting if a record is kept. In addition, the DLC EHS Committee provides guidance to the DLC EHS Coordinator and reviews operations within the DLC that may impact compliance with EHS requirements, EHS incidents and EHS-MS documents. DLC Heads/Directors have discretion to determine the extent to which they employ their DLC Committee to oversee EHS performance in their DLC.


 


2.2.3 Employees and Students


Employees and students are responsible for compliance with EHS regulations and requirements in their research, classroom work areas and residences. Specific responsibilities include:


  • completing EHS Training Needs and taking required training prior to commencing their regulated or hazardous work and duties. Updating the training as required;
  • following established procedures for working safely in the lab or work area;
  • using and maintaining personal protective equipment if provided;
  • reporting work-related injuries or illnesses, incidents such as spills, or near misses to PI/supervisor as soon as possible.
  •  

2.2.4 Contractors and Visitors


Contractors and Visitors are responsible for compliance with EHS regulations and requirements, as appropriate, based on their work or activities at MIT.   These requirements may include taking EHS training offered by MIT.  (For more information, see EHS and Security Information for Visitor/Contractor (PDF)).  DLCs are responsible for assuring contractors and visitors they coordinate are informed of MIT EHS requirements, and that the EHS Office is contacted, as needed, re: any EHS concerns introduced by the Contractor/Visitor and their activities at MIT.


 


2.3 EHS Programs Office and EHS Office


MIT's commitment to an effective EHS-MS is demonstrated through our documented policies and procedures that clearly define roles and responsibilities. (See Chart)


EHS Programs Office (EPO) - is responsible for participating in the establishment of MIT's EHS vision and leadership, and coordinating collaborative EHS initiatives among all constituents of the MIT community. The EPO with support from EHS Office reviews DLC appointments of EHS Coordinators and reports on EHS matters to the Institute Council on EHS. EPO serves as MIT's senior administrative office for EHS affairs and has access to the senior management at MIT, including offices of the President, Provost, Chancellor, and Executive Vice-President on EHS issues. EPO is responsible to represent the administration of the EHS management system including the EHS Office to the Institute leadership for matters of policy, budget, organization, and major process and technology programs.


EHS Office - provides technical expertise and EHS advisory services to the MIT community that collaborate and support regulatory compliance and improved EHS performance at the DLC level. EHS Office is responsible for tactical and operational implementation of the EHS-MS. This includes providing interim support for DLC EHS-MS operations to those DLCs working with potential hazards or regulated activities that have an open position for the DLC EHS Coordinator. It also includes monitoring DLCs that do not have spaces identified in PI/Space Registration in order to add them to the system if they do begin to work with potential hazards or regulated activities. The EHS Office is responsible for implementing the programs identified in the overall vision and strategy set by the EPO, and to promote day-to-day good practices, compliance related activities, and initiatives that advance MIT’s commitment to environmental sustainability and health and safety excellence. These services are designed to fully support all aspects of the Institute’s EHS-MS and enable continuous improvement of the system. The EHS Office consists of five technical programs and ten functional areas, which are:


Programs


  • Biosafety
  • Environmental Management
  • Industrial Hygiene
  • Radiation Protection, and
  • Safety

Service Teams


  • Organization
  • Inspection/Audit
  • Training
  • Emergency Response
  • Laboratory-Facility Design
  • Technology
  • Communication
  • Regulated Waste
  • Sustainability
  • Shipping Hazardous Materials

In addition, ongoing EHS staff development is a key component of the system and is monitored by the Director of the EHS Office and the Associate and Deputy Directors of the five EHS Programs. EHS Office services are further described in Section 5.2, EHS Office Programs, Services and Service Teams. EHS-MS is implemented and maintained by the Director of the EHS Office


EHS Office Lead Contact - is a representative from within the EHS Office who provides EHS expertise to an assigned DLC. The EHS Office Lead Contact partners with the DLC EHS Coordinator to deliver programs that meet EHS requirements applicable to that particular DLC. The EHS Office Lead Contact is also a member of the DLC EHS Committee. The EHS Office Lead Contact is supported by a team of subject matter experts from the EHS Office's areas of technical and functional expertise. See the DLC Coordinator Contacts page for a list of DLC Lead Contacts.


EHS Team - is a group of EHS professionals representing each of the five EHS Office programs that provide expertise and consultation in EHS matters to their assigned DLC. The EHS Lead Contact is the primary contact on the EHS Team for the DLC. See the DLC Coordinator Contacts page for a list of DLC Team Members.


2.4 Incentives and Consequences


MIT has established incentives and consequences to support EHS performance.


2.4.1 Accountability and Responsibilities


MIT's faculty, researchers, staff, and students are all responsible individually for implementing the EHS Management System, and for complying with MIT's high EHS standards as well as federal, state, and local EHS regulations, and other requirements. In addition, faculty, researchers, students and staff are expected to employ best feasible management practices to ensure a safe, healthy and environmentally sustainable campus.


The responsibility for satisfying MIT's EHS Requirements is designed to flow through the supervisory chain:


  • From individual researcher, student or staff member;
  • To Principal Investigators or other Supervisors, who are responsible for compliance with EHS Requirements by members of their labs or groups;
  • To DLC Heads/Directors, who are responsible for their DLC's performance;
  • To the Vice Presidents and Deans, who are responsible for their School's performance
  • To the EHS Council and other Committees, responsible for overall Institute performance and oversight, in close consultation with the EHS Office, and
  • To the Senior Officers of the Institute

2.4.2 Incentive Programs


MIT has two recognition programs, "Appreciation" (spot) awards and "Infinite Mile" awards, to recognize excellent performance of academic and administrative employees in a particular area or a project to supplement the Periodic Performance Review process. 


Appreciation awards are small awards - such as thank-you notes, gift certificates, lunches and other small prizes - given at the time of a specific achievement to provide immediate and spontaneous recognition of an exceptional contribution by an individual and team. 


Infinite Mile awards are larger financial or non-financial awards that recognize excellent contributions to the objectives of each strategic area within the Institute. The Institute has been organized into a number of clustered groups to enable each area to customize and implement an Infinite Mile Awards program that reflects the work, values and/or behaviors specific to that area. DLCs include EHS performance as one of the criteria for determining these awards.


MIT also has an Institute-wide Rewards and Recognition Program (MIT Excellence Awards) to recognize excellent contributions to the values and goals of MIT's mission statement. An appointed Selection Committee chooses these awards annually with award categories such as "Making a Difference...in the Workplace." EHS contributions qualify for this award as well. 


There is another Award category, Greening MIT: protecting our planet, given to teams and/or individuals who:


  • Maintain and enhance MIT’s position as a leader in environmentally sustainable practices
  • Serve as a role-model and broadly influence others to adopt green habits
  • Implement new and effective green solutions at MIT
  • Create cost-savings for MIT through resource efficiencies and conservation
  • Contribute to the education and learning of our community in the areas of sustainability and environmental stewardship

MIT has a specific Institute-wide EHS Performance Award which is given to a DLC in two categories (large and small DLC). EHS training and Level II Inspection metrics are reviewed over the previous year to determine the highest performing large and small DLC. For training, a rolling average of completion rates for core courses is calculated. To be considered, a DLC must have no core courses below 90% completion. For inspections, having inspected at least 80% of the total DLC spaces during the last round is used as the performance metric.


2.4.3 Consequences for Poor Performance


MIT has established an organizational structure with designated staff such as DLC EHS Coordinators and EHS Office Lead Contact to support DLCs in complying with EHS regulations and good EHS practices.


Members of the MIT community, including faculty members, researchers, staff, and students, are responsible for complying with MIT's high EHS standards as well as federal, state, and local EHS regulations and good EHS practices. In the event any member of the MIT community fails to fulfill his or her responsibility, appropriate consequences, as described in the Corrective Actions and Consequences Framework / Guideline (PDF) document, apply. Consequences in all departments, labs or centers will be applied in a way that is consistent with MIT’s human resources or academic disciplinary procedures. Semiannually, EHS coordinators receive an email with performance metrics attached if either or both of the following two criteria were met:


  • <80% completion of Level II Inspections reported on the last inspection round
  • <80% EHS Training completion in one or more core EHS courses.

If improvement in performance is not noted in the next round this is escalated to either the DLC Head or the relevant Dean's Office.


 


3.0 Getting Started (Preparation and Planning for EHS)


There are a number of environmental, health and safety (EHS) issues to consider in establishing a new laboratory or workspace at MIT. The following sections describe EHS Rules and regulations and MIT's requirements and provide guidance on meeting these requirements while getting started doing research or work at MIT. "MIT Quick Guide for PIs" from the MIT Office of Sponsored Programs (OSP) includes some but not all EHS requirements.


3.1 EHS Rules and Regulations


3.1.1 Identifying and Interpreting EHS Rules and Regulations


MIT's Environment, Health & Safety (EHS) Office manages environment, health, and safety programs and supports EHS performance including sustainability, good practices, and legal compliance throughout the MIT community. The EHS Office's Compliance Management Plan (PDF) identifies and interprets the laws, regulations, and other requirements that apply to MIT facilities and operations; describes the requirements of these regulations as applicable to MIT; and establishes a process for assigning an EHS Office staff member support and oversight responsibility to help ensure compliance with each requirement. Programs, Standard Operating Procedures (SOPs) and Standard Operating Guidance (SOGs) are developed and distributed by the EHS Office for use in communicating requirements to the MIT community.


3.1.2 Communicating EHS Rules and Regulations to Affected Parties


Communicating EHS expectations and regulatory requirements to the MIT Community


MIT communicates EHS regulatory requirements and accepted best practices to affected faculty, researchers, staff, and students through a variety of means.  The foundation of knowledge regarding regulatory requirements and MIT's EHS standards and best practices is established through education and training, described in Section 4, Training of this Manual.  It is important for new people to receive an orientation and to obtain EHS training before beginning work with or around potential hazards.


To support and reinforce training, and to communicate changes and best practice, the EHS Office develops and maintains an EHS Communications Plan.  This plan helps to ensure development, proper targeting and systematic delivery of critical information regarding EHS matters. The plan identifies communication resources and tools available at MIT for use by EHS personnel.


A key resource for communicating EHS requirements and expectations at MIT is the EHS Office website.  This website has content on a variety of topics and on services available for supporting EHS at MIT, and it includes access to written documents such as this manual, the Chemical Hygiene Template, the Hazard Communications Program, various SOPs/SOGs describing requirements and expectations related to EHS regulations and their implementation at MIT. 


Communication is fostered by the EHS organizational structure described in Section 2, Roles and Responsibilities. Within this structure, information is transmitted from the EHS Office via the EHS Lead Contacts and DLC EHS Team members to the affected departments through the DLC's EHS Coordinators. Information is exchanged using a variety of mechanisms, including email and written communications, quarterly EHS Coordinators meetings, periodic DLC EHS Committees meetings, and direct communications between EHS Coordinators and Lead Contacts. EHS Coordinators are the primary points of contact to distribute and communicate information throughout their DLC.


MIT's EHS standards and regulatory requirements are also communicated directly to affected parties through training, inspections, and audits. Education and training, addressed in Section 4, Training of this Manual, is an integral component of the EHS Management System and is a significant tool for introducing and reinforcing MIT's regulatory requirements and MIT compliance programs to individual faculty, researchers, staff, and students.


Inspections and audits, discussed in Section 6, Inspections and Audits of this Manual, further serve to communicate and reinforce regulatory requirements that are applicable to each laboratory or facility space. As each PI/ Supervisor registers space under his or her supervision in a central database and a hazard assessment is completed, MIT's standards and regulatory requirements that apply to each space are identified. The inspections and audits then help to ensure that the appropriate requirements are being met.


To facilitate communication regarding EHS matters, the EHS Office has established one phone number that can be used by MIT community members to reach any member of the office for urgent and non-urgent EHS matters, and an e-mail address, environment@mit.edu, that can be used for questions about non-urgent matters, or as a tool for the campus community to provide suggestions or express concerns.


More details regarding EHS Communications at MIT can be found in Section 8 of this manual.


MIT's EHS standards and expectations are communicated to contract service providers at the time of engagement through the use of the “Environment, Health and Safety Guidelines for Construction, Service and Maintenance Contractors.”  The EHS Office works with the Department of Facilities to assure guidelines are communicated to contractors hired by the Department of Facilities, and with EHS Coordinators and Building Managers for contractors hired directly by DLCs.


Communicating with Regulatory Agencies


MIT, as a complex, diverse organization, must communicate with a multitude of federal, state, and local regulatory agencies on a wide variety of topics and issues.


Any communications with regulatory or law enforcement agencies that concern environment, health and safety issues, or impact the whole Institute, including MIT policy, legal requirements, regulatory compliance, or the Institute's EHS performance, must be coordinated through the EHS Headquarters Office (EHO) and the EHS Office. These procedures are described more fully in an internal document.


Communications with regulatory agencies that are of a routine nature, such as those that occur as a normal part of the Institute operations, and either precedent-setting nor impact Institute-wide policies or issues, typically are conducted directly by employees with the relevant regulatory agency personnel.


There are regularly scheduled or unannounced visits by regulatory agencies to MIT and for those the EHS Office has developed an internal SOP for Regulatory Agency Visits. The SOP describes procedures for communications with federal, state, and local agencies, such as Environmental Protection Agency, Occupational Safety and Health Administration, Nuclear Regulatory Commission, Department of Environmental Protection, Department of Public Health, Cambridge Fire Department, and Cambridge Inspectional Services.


3.2 Principal Investigator (PI)/Space Registration and Hazard Identification


The PI/Space Registration Process is the primary point of entry into the EHS Management System for faculty and supervisors, and their associated use of potentially hazardous and/or regulated materials. This Process is the fundamental building block upon which the major system components of hazard / regulatory identification and assessments, training, inspections, inventory, and emergency preparedness are based. The PI/Space Registration database is updated at least annually.


The registration process creates an entry in the PI/Space Registration database for each laboratory or other facility space and associates with that space the names of the PI or supervisor (PI/Supervisor) and the EHS Representative, a description of the type of space (lab, storage, etc.), emergency contact information, and the core hazard/regulatory types found in that space, such as chemicals, biological materials, ionizing radiation sources, non-ionizing radiation sources, flammable liquids, highly reactive materials, and large oil volumes.   The emergency contact "Green Cards" that are posted outside lab spaces are generated from the information contained in the PI/Space Registration database.


3.3 Potential Hazards Identification


The Potential Hazards Assessment SOP is closely associated with the PI/Space Registration Process and is often completed simultaneously. The process results in a database called the Potential Hazards Inventory.


During the Potential Hazards Identification Process, the DLC EHS Coordinator and the EHS Office Lead Contact evaluate the space and activities conducted in that space to more specifically identify the various hazard types and safety equipment contained within. This process is grouped into seven categories (chemicals, chemical wastes, biological, radiation sources, non-ionizing radiation sources, safety equipment, and other) to determine where potential hazards/regulations are present in or applicable to the space. The information from this process assists the EHS Office in developing and implementing appropriate programs for periodic assessments and control of hazards, training, inspections, and prevention activities.


In addition to the Potential Hazards Identification Process, the EHS Office coordinates the annual chemical reporting that satisfies the requirements of Environmental Protection Agency (EPA) mandated SARA Title III inventory and "Chemical of Interest (COI)" survey for the Department of Homeland Security (DHS).  DLCs are required to keep a chemical inventory within their spaces including solvents and gases.


There are a number of other specific EHS programs at MIT that identify potential hazards and regulatory requirements, such as the Occupational Safety & Health Administration (OSHA) driven Chemical Hygiene Plan Program and the Hazard Communication Program, authorizations on the use of radioactive materials, registration of radiation producing machines, registration of non-ionizing sources such as lasers, magnets, and RF systems and a registration program for the use of biological agents and select agents.


3.4 Potential Hazards


Regulatory Activities and Materials Assessment and Control


The Potential Hazards Inventory is used by the DLC in coordination with the EHS Office as a starting point for identifying where hazard/regulatory assessments may be needed. Hazard/regulatory assessments are performed to determine what controls are needed to reduce, eliminate or mitigate a hazard, and comply with regulatory requirements. Hazard/regulatory controls are addressed in Section 5.1, Hazard Assessment and Control.


EHS Coordinators make initial hazard/regulatory assessments using guidance provided by the EHS Office. The EHS Lead Contact assists the EHS Coordinator as necessary, and generally takes primary responsibility for more complex hazard/regulatory assessments. If the assessment determines that controls are needed to reduce or eliminate the hazard or to meet MIT's EHS standards and/or regulatory requirements, recommendations are made to the appropriate parties, such as the DLC EHS Coordinator, PI/Supervisor, and/or Department of Facilities to address the hazards and requirements.


3.4.1 Standard Operating Procedure (SOP) Assessment


In some cases, a hazard assessment may determine that a Standard Operating Procedure (SOP) is needed to prevent potential regulatory violations or EHS incidents. This process of determining when it is necessary to create an SOP, Standard Operating Guidelines (SOGs) and fact sheets is, itself, documented in an SOP, Writing, Approving and Updating SOPs, SOGs and other Documents.


The standard format and a list of EHS-related SOPs, SOGs and other documents are available online at http://ehs.mit.edu/site/sop-list


3.4.2 Monitoring and Measurement


MIT conducts a variety of monitoring and measurement activities of workplace conditions to sustain compliance, protect student, staff, employee, and community health and safety, and to safeguard the environment. Because monitoring is often conducted to measure exposure to a hazard, monitoring and measurement activities are an important part of the hazard assessment process. Different groups at MIT perform monitoring and measurement activities, as described below.


3.4.2.1 Department of Facilities


  • The Department of Facilities conducts or oversees monitoring performed to assure compliance with some EHS regulations that relate to facilities operations such as wastewater testing to demonstrate compliance with the terms of MIT's MWRA permit;
  • monitoring required to comply with MIT's Title V air emissions permit, including continuous stack testing conducted at the Central Utility Plant;
  • keeping records of the gallons of paint used at the paint booth;
  • checking secondary containment areas at above ground fuel oil storage tanks;
  • monthly testing of emergency generators;
  • tracking of on-site emergency generator operations by recording operating time or gallons of fuel used, depending on the generator;
  • tracking refrigerant usage for chiller systems;
  • annual inspections of deluge showers, and
  • annual inspections of portable fire extinguishers.

3.4.2.2 Division of Student Life


The Division of Student Life conducts or oversees monitoring performed to assure compliance with some EHS regulations as well as ensuring safety to the MIT community by:


  • measuring carbon dioxide emissions at the Johnson Ice Rink after Zamboni use;
  • assist with sampling Zesiger Center Pool and Alumni Pool on a routine basis for fecal coliforms in order to meet Massachusetts regulations;
  • reviewing and monitoring various student projects depending on the location of said project;
  • evaluating Athletics events;
  • examining Campus Activities Complex events, and
  • assessing Dining Services events.

3.4.2.3 EHS Office


The technical programs and service teams within the EHS Office conduct a wide variety of initiatives and programs that involve monitoring and measurements to sustain regulatory compliance, proactively assess risk to the MIT community, and support a culture of safety. Service Teams are comprised of members from each Program within the EHS Office and occasionally DLC members. These are described below:


  • The Environmental Management Program (EMP) conducts services and activities to assure that air, water and waste discharges from MIT are protective of the environment and are compliant with all environmental regulations. EMP provides environmental oversight, advice, consultation training as well as direct operational services for environmental permitting, environmental data reporting, and responses to release / potential release of hazardous materials to the environment. EMP collects and manages all chemical hazardous waste generated at the Institute, and gathers data on the types and quantities of chemical hazardous waste generated. This data is assessed to identify chemical hazardous waste and other environmental training and program developments and compliance oversight, and positive and negative trends and changes, and to show any impacts of pollution prevention initiatives. EMP also compiles Greenhouse Gas (GHG) inventory for stationary and mobile sources on campus, collects commuting information for MIT staff and students for the annual Rideshare report to the Massachusetts Department of Environmental Protection (DEP); and gathers inventory data on certain chemicals to prepare the SARA Title III submittal required by the EPCRA regulations and to comply with Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS) program.
  • The Safety Program (SP) monitors OSHA-defined confined spaces to determine if they are safe for entry by workers. The Safety Program also conducts project evaluations for the Hot Work Permit Program, which may include a monitoring component. The Safety program also evaluates work areas for many traditional industrial safety issues such as emergency egress, Machine/Woodworking Shop Safety, Powered Industrial Trucks, Flammable Liquids/Gases/Solids, Portable Extinguishers, Building Inspections, Confined Space Entry, Fall Protection, Mobile Elevated Work Platforms, Student Projects/Events, Construction Safety, Injury Reporting, Lock Out/Tag Out, Electrical Safety, Lab Decommissioning Operations/ Planning, Personal Protective Equipment, Pressure Vessels, Emergency Preparedness Planning , Emergency Showers/Eyewashes, Special Events, Projects Involving Minors, Compressed Gases, Cryogenic Liquids, Campus Fire Safety, Lab and Facility Design, Life Safety/Fire Protection Systems, Walking/Working Surfaces, Vehicular Safety, Explosives Safety, Hoisting Equipment, Job Hazard Analysis.
  • The Industrial Hygiene Program (IHP) oversees programs related to evaluating and controlling exposures to hazardous chemicals, ergonomics, noise and heat. IHP oversees Institute's compliance for related OSHA regulations including: Chemical Hygiene Plan, Hazard Communications Plan, Respiratory Protection Plan, and OSHA permissible exposure limits. IHP also manages laboratory fume hood and workplace ventilation programs. IHP provides guidance to MIT on laboratory, HVAC design and other industrial hygiene related controls.
  • The Radiation Protection Program (RPP) has extensive ionizing radiation protection monitoring programs to assure compliance with applicable regulations and MIT's licenses for storage and use of radioactive materials. These programs include risk assessment for radioactive use protocols, training, program development and compliance, routine testing of laboratory surfaces for contamination, radiation worker monitoring of external dose through the use of dosimeters, potential internal dose through bioassay and whole body scans, effluent concentrations for volatile radionuclides, and environmental monitoring at designated local and perimeter sites. RPP collects and manages all radioactive waste generated at the Institute and files an annual report on the quantities and types with the applicable regulatory agencies. They also collect biosharps and biological waste through the Regulated Medical Waste program. RPP registers all radiation producing equipment including analytical, veterinary and medicinal X-Ray machines, and particle accelerators in accordance with the required state regulations. In addition, RPP has non-ionizing radiation monitoring programs that include registration and risk assessment associated with the use of class 3b and class 4 lasers, analytical magnets and MRI units, and RF sources including radar, microwaves, and telecommunications.
  • The Biosafety Program (BSP) oversees a monitoring program for biological research that tracks the use of recombinant DNA (rDNA), biological toxins, microbial pathogens, human materials, associated safety training and occupational health topics. Reported incidents, accidents, and exposures involving biological materials are closely tracked in order to identify trends and improve risk assessment. BSP also monitors autoclave validation and calibration to assure adequate function and for sterilizing biological waste, research and/or medical materials and equipment. This monitoring program is in place to maintain safety, regulatory, and accreditation criteria compliance. The purchase and receipt of regulated or more highly hazardous materials pertaining to biological research (e.g. select toxins and DEA Controlled Substances) are monitored by BSP in collaboration with MIT Sourcing & Procurement. BSP also monitors specific environments for biological contaminates.  For instance, BSP conducts water quality monitoring of the Institute's swimming facilities on a routine basis in collaboration with the Division of Student Life.  BSP also measures airborne mold levels as part of indoor air quality investigations. As requested, BSP staff will monitor for microbes on surfaces or in the air as a part of epidemiological investigations.
  • Organization Service Team provides oversight to assure EHS-MS organizational structure is implemented and maintained, and facilitates the DLC EHS Coordinator and EHS Lead Contact relationship through periodic meetings and communications. This team also oversees the PI/Space Registration process. This team also provides advice and direction regarding professional development needs of the EHS Office Staff and EHS Coordinators.
  • Inspection/Audit Team provides oversight to implementation and maintenance of the inspection and audit program. The team monitors inspection data from Level II inspections to identify trends and leading indicators of EHS concern.
  • Training and Development Service Team provides oversight for all EHS training needs, assists in the development of new EHS training courses, assists in the development and update of the EHS Training Needs, and tracks the maintenance of the database used for managing official training records.
  • Emergency Preparedness and Response Service Team provides oversight for the 24-hour emergency response services provided by the EHS Office; the coordination of the EHS responses with MIT's Emergency Response Group, and oversight of the emergency response follow-up process.
  • Laboratory and Facility Design and Construction Review Services Team formally collaborates with the Department of Facilities and DLCs to assure that EHS requirements and concerns are addressed systematically in new construction and renovation projects at MIT.
  • Technology Service Team has oversight for the development and maintenance of the technology needed to support EHS activities, including EHS web resources, the EHS Office intranet, and all databases associated with the EHS-MS.
  • Communications Service Team (CST) works to promote effective and timely communication among all the EHS stakeholders across the Institute and MIT community to improve EHS performance. More details about the CST are in Section 8.2 of this manual
  • Regulated Waste Service Team coordinates activities related to chemical, biological, radiological and universal waste at the Institute. It provides oversight of compliance issues and identifies and recommends opportunities for continuous improvement and waste reduction.
  • The Hazardous Materials Shipping Team (HMST) provides support and services to the campus community to help assure that hazardous materials and dangerous goods are shipped from MIT in accordance with regulatory requirements by personnel trained to do such shipments.  The shipping service provided by the team includes guidance on shipping requirements, packaging, labeling, and document preparation.  The team also provides some shipping training, and assures proper management of training records and shipping records.
  • Sustainability Team utilizes the EHS-MS to strengthen and introduce sustainable initiatives to campus, communicate updates on sustainable projects and opportunities as well as identify new areas of improvement, specifically as they apply to EHS. Examples include lab recycling, fume hood energy management, lab sustainability assessment and ride sharing opportunities with the EHS Office. Team members include representatives from each of the 5 EHS Programs and one EHS Coordinator.

3.4.3 Engineering Controls


When the hazard assessment process indicates a potential EHS regulatory impact, an evaluation to implement engineering controls to prevent or reduce workplace exposures or minimize compliance issues is conducted. These controls are designed to be part of the space (for new spaces) or retrofit (for existing spaces). Examples of engineering controls include: fume hoods, biological safety cabinets, glove boxes secondary containment for tanks and containers, neutralization systems for wastewater discharges, air cleaning systems, and others. These controls are typically implemented or overseen by the Department of Facilities, the EHS Office, or both, in conjunction with external consultants and/or contractors.


 


 


3.5 Emergency Preparedness and Response


MIT has an Emergency Response System that follows the National Incident Management System (NIMS) Protocol and responds to all emergencies and incidents on Campus. EHS has an Emergency Preparedness and Response System that is integrated into MIT’s response system and the overall structure and culture of the MIT community to respond to EHS emergencies on campus. A key component of this program is the Emergency Operations Plan.


The EHS Office provides full-time, around-the-clock emergency response support and service to the MIT community. Emergency EHS services can be obtained by calling the EHS Office at (617) 452-3477 (2-EHSS) during business hours or by dialing 617-253-4948 or x100 off hours. The EHS emergency response system consists of a rotating weekly five person roster made up of an individual from each of the five EHS Programs: Biosafety, Environmental Management, Industrial Hygiene, Radiation Protection, and Safety Programs. One person is assigned to be the Primary contact with the others providing support as needed. Refer to the MIT EHS Response System SOP. New employees are provided training and introduced into the system when approved by their Deputy Director. Annual refresher training is provided to members of the System reviewing current and introducing new protocols and discussing response issues to identify areas for improvement.


MIT's EHS Office has developed standard procedures for responding to spills of hazardous materials. The Spill Response Procedures SOP provides guidance on how to differentiate minor spills and major spills, and defines each type of spill to clarify response procedures. Major spills or releases require immediate notification to the MIT Police or the MIT Operations Center, or both, who are then required to contact the EHS Office and or the Cambridge Fire Department. The appropriate EHS on call program representative will determine whether external reporting is necessary.


3.6 Pollution Prevention


MIT has a robust agenda of positive environmental initiatives to make our campus more sustainable and to reduce pollution as described in this section. A pollution prevention program is an integral part of MIT's commitment to excellence in environment, health, and safety stewardship on our campus. To This end, the Institute adopts and implements policies and practices that reduce or eliminate the use of hazardous materials and the generation of waste streams (both hazardous and non-hazardous) whenever possible. The EHS Office is responsible for programs of regulatory compliance and sustainability (including Pollution Prevention) and approaches this work in a comprehensive and integrated manner. The EHS Office actively collaborates with the EHS Headquarters Office, the Department of Facilities, other Departments, Labs and Centers (DLCs) and student groups to reduce the volume and toxicity of the Institute's waste streams. Leveraging MIT's collaborative culture around the following goals frame MIT's Pollution Prevention Plan:


  • Conserve resources (water and energy), seeking planned reductions in MIT's consumption;
  • Reduce campus air emissions, including those from transportation, of greenhouse gases and regulated pollutants;
  • Increase the recycling and conservation of materials;
  • Reduce material and resource consumption including office and laboratory supplies;
  • Increase the use of environmentally friendly products and materials;
  • Reduce the volume and toxicity of our waste streams;
  • Inform our students, faculty and staff in sustainable concepts so that they may apply them in their professions;
  • Support community-wide and regional sustainability efforts; and
  • Establish procedures and targets for implementing sustainable design principles in new and renovated projects.

MIT implements a broad spectrum of pollution prevention projects in support of these goals (see Also of Interest). Members of the EHS Office, EHS Headquarters Office, Department of Facilities and other DLCs comprise teams that develop and steer pollution prevention efforts, engage stakeholders from DLCs and other groups who are potentially affected by or may bring expertise to the project, and determine metrics to assess the project's success in meeting pollution prevention goals. MIT's commitment to pollution prevention both contributes to and draws from the enthusiasm and momentum of groups within the Institute as well as the greater Cambridge/Boston community. 


Also of Interest


Green Chemistry


Green Chemistry Purchasing Wizard


Department of Facilities Sustainability Initiatives


MIT Office of Sustainability


3.7 EHS Planning


MIT's EHS Policy describes and communicates the Institute's commitment to excellence in environment, health, and safety stewardship. Consistent with this objective, the Institute directly considers and seeks to mitigate the EHS impacts of its operations by integrating EHS criteria into its planning and decision-making processes.


The EHS Office/EHS Headquarters Office (EHO), through the Managing Director for EHS Programs, participates in Institute-wide EHS planning and policy-making, and together with the Institute Council on EHS is responsible for overseeing overall EHS policy implementation, including regulatory compliance, and EHS initiatives. Members of the EHO and EHS Office conduct internal management review of the EHS Management System. In addition, the EHO is responsible for developing, implementing, and managing the vision, strategic direction, and oversight of the EHS Office. The creation of a high-level EHO, overseen by a senior administrator reporting directly to the Executive Vice President and Treasurer, with dotted line reporting to Provost, and Chancellor, demonstrates the Institute's commitment to environmental stewardship and compliance. This organizational structure effectively leverages MIT's resources to have lasting, Institute-wide impact, and is consistent with the objectives set out in the EHS Policy.


Further integration of EHS issues into MIT planning, decision-making, and operations is achieved through the use of specialized EHS Councils and Committees as outlined in Section 2, Roles and Responsibilities of this Manual. 


3.8 Integrating EHS into Operations


EHS considerations are integrated into Institute-wide operations at two levels. One level addresses existing physical spaces or buildings, and operations; the other addresses new or modified buildings and operations.


Existing Buildings and Operations.


The process for ensuring that EHS requirements are integrated into existing buildings and operations involves several linked components. These include EHS training; PI/Space registration; hazard/regulatory identification, assessment, and control; incident and non-compliance investigations; inspections and audits; and the EHS Office communications activities.


Through the corrective action process, EHS issues are identified, communicated, tracked, and remediated. This integrated and on-going process allows for identifying and acting upon opportunities for continual improvement of EHS performance. When a potential problem or opportunity for improvement is identified, the EHS Office conducts an investigation resulting in a communication or report to the DLC with findings and recommendations.


New and Modified Buildings and Operations.


EHS requirements and considerations are integrated into the planning, design, and construction of new and renovated buildings and operations through the Laboratory and Facility Design and Construction Review Process. For new spaces (including new construction, renovations, and space changes), the EHS Office works closely as a member of the design and construction project team with the Department of Facilities, the client DLC, and external designers and construction firms. EHS Office participation on the project team is through the auspices of the EHS Laboratory and Facility Design and Construction Review Services. Once a project is identified, the team leader assembles an EHS Project Review Team and assigns an EHS Project Liaison and EHS Construction Liaison.


The EHS Laboratory and Facility Design and Construction Review Services team leader provides direction and oversight to the review process and to the EHS Office Construction Safety Program; works with the overall Project Manager to resolve issues and report significant impacts to MIT management; and coordinates the transfer of EHS responsibility to the EHS Lead Contact and DLC EHS Coordinator following building commission and occupancy. 


3.9 Establishing and Updating EHS Objectives, Goals, and Action Plans


Taking MIT's EHS Policy to a greater level of specificity, Institute-wide EHS objectives are established in the MIT EHS Policy, and focus on EHS stewardship, sustainability, compliance, accountability, opportunity, and performance. The EHS Policy is reviewed periodically and modified, as needed, by the Institute Council on Environment, Health and Safety and approved by the Academic Council of MIT, if required.


The EHS Programs/EHS Headquarters Office (EPO) sets vision and high-level environment, health and safety objectives and goals for the central administration of MIT and brings Institute-wide goals and objectives to respective Institute Committees for endorsement.

In addition, if systemic compliance problems are identified within any DLC or contractor operations, the EHS Management Systems requires the development of an action plan to address the problem. The action plan must include steps to be taken to investigate and remedy the problem, including tracking and reporting status. The EHS Office and DLC EHS Coordinators and Committees monitor the implementation and effectiveness of these additional action plans.


The EHS Office works with key Institute administration to establish Institute-wide sustainability goals. The Pollution Prevention Plan helps establish interim performance targets and provides a general framework for developing sustainability action plans, setting targets and establishing timeframes for meeting P2 and sustainability goals. 


 


4.0 Environment, Health and Safety (EHS) Training


MIT personnel who participate in, or oversee activities that are regulated because of potential risks to the environment, health, or safety must receive training appropriate to the regulated activity. This training must be completed prior to beginning the regulated activity. 


Refresher training, also called retraining, may be required periodically if the trainee is engaged in specific activities. The EHS Office and DLC EHS Coordinators track the required training and retraining, and MIT personnel are informed when their retraining is due. The EHS Training Needs pairs regulated activities to training requirements. An expiration date is listed for those trainings where refresher training is required.


Individuals who intend to engage in EHS-regulated activity at MIT must determine their training requirements via the web-based EHS Training Needs. This includes MIT faculty, employees, researchers, students, and visiting scientists. The Department of Facilities, the Division of Student Life, the Division of Comparative Medicine, and the EHS Office use job title or function to determine training needs for employees instead of having them complete the online EHS Training Needs.   All Lincoln Laboratory employees are required to complete an annual Training Needs Identification questionnaire (Activity Selection) to determine their training needs.   Some non-research Lincoln employees that can be identified by an HR driven attribute (organizational assignment, staff category, job) are exempt from the activity selection requirement because their training needs can be identified and assigned based on this attribute (i.e. plumber, carpenter, security officer, etc.).


 


4.1 Determining Training Needs


The EHS Training Needs is a web-based tool used by MIT to identify individuals engaged in regulated activities; assess the types and levels of EHS risks they may encounter and regulations that apply to their activities; and create and track a customized training program for each individual. The assessment creates and tracks individual training programs based on different criteria such as departmental or EHS activity or job title.


4.1.1 EHS Training Needs by Activity


  1. A trainee is initially informed about EHS training requirements, and the need to complete them before beginning work with hazardous materials by his or her Principal Investigator (PI)/Supervisor, DLC EHS Coordinator, or EHS Representative.
  2. A trainee is then instructed to register through the Learning Center and create an EHS Profile to determine his or her EHS Training Requirements. The trainee is prompted through a series of questions that identify the specific activities that he or she will be engaged in. By identifying specific regulated activities, the EHS Training Needs is able to identify required training courses for individual trainees. The results of the EHS Training Needs are saved in the Institute's Learning Center.
  3. A trainee must complete the EHS Training Requirements before beginning work.
  4. A trainee must update his or her EHS Training Needs if the trainee's regulated activities change or he or she moves to a new laboratory, facility, or DLC.
  5. Training reminder e-mails are sent 30 days after the profile is completed and 30 days and 7 days before the retraining is due and 7 days after the training expiration.

The EHS Coordinator may assist a PI in completing the EHS Training Needs.


4.1.2 EHS Training Needs by Job Title or Function


The training system also supports the creation of a customized EHS training program based on an individual's job title or function. This approach is most appropriate for non-research employees at MIT, where training requirements are the same for all those with the same job title or function. This same group may also have limited computer access, so this approach ensures that all people, regardless of their access to computers, are captured in the Learning Center. The Department of Facilities, the Division of Student Life, the Division of Comparative Medicine, and the EHS Office, make use of this feature to delineate comprehensive EHS training requirements for their staff by job title.


  1. The DLC EHS Coordinator with EHS Office support creates an EHS curriculum and training program for each job title or function where EHS training is needed. These training programs are then uploaded into the Learning Center, a central repository for all training.
  2. The training and/or retraining is then scheduled and completed before regulated activities begin.

4.1.3 EHS Training Needs for Academic Courses


The training system has the ability to link training requirements for students registered in an undergraduate/graduate academic lab course. This capability provides instructors with the ability to monitor and run reports on the group of students enrolled in their courses. EHS Office personnel work with instructors to determine which EHS training modules are required for their courses. The training rules are then added to the Learning Center so that when students who are registered for that course go to the Learning Center the requirements are listed automatically without the need for doing the EHS Training Needs.


4.1.4 Special group-based training


The special group-based training requirements can be used when none of the other methods for determining EHS training requirements such as EHS Training Needs, department-specific training requirements, job title-based requirements, or academic course-based requirements are appropriate.


4.2 Required Training


There are certain regulated activities that require a participating individual to have specific training before engaging in that regulated activity. A few examples of these regulated activities and their training requirements are outlined below. A complete list of regulated activities can be found here.


Regulated Activity


Required Training Course


Retraining


Working with chemicals in a laboratory


General Chemical Hygiene


Initial Only


Lab-Specific Chemical Hygiene


Annual


Managing Hazardous Waste


Annual


Working with Class 3b or 4 lasers


Laser Safety Training


Initial Only


Working with radioactive materials


Radiation Safety Training


Biennial


Handling human materials


Bloodborne Pathogen Training


Annual


 


4.3 EHS Awareness


In addition to providing the regulatory-driven required EHS training, MIT's goal is to promote good practices to advance overall excellence in the workplace and learning environment. To this end, the Institute actively promotes training and awareness in elective practices that support implementation of the EHS Management System; the Institute's EHS policy; and MIT's goals for a sustainable campus.


MIT EHS has developed materials to inform PI's about changing EHS policies and about their EHS responsibilities. Best practices for developing a strong safety culture within their lab group are reviewed.


4.4 Obtaining Training


MIT has several mechanisms through which the required EHS training can be received. The course content in each of the methods remains the same for each required course. If only a classroom-based course is available to a trainee, then the trainee is directed via the web to the on-line class registration tool, or directed to a contact person to coordinate the training.


4.4.1 Web-based Training


If a web-based training course is available and allowed by their DLC(s), the trainees can enroll to launch the course after completing their EHS Training Needs. Regardless of the delivery method the core content is consistent. When the web-based training course is successfully completed, the results of the training are automatically captured in the Institute's Learning Center.


4.4.2 EHS Office and DLC Classroom Training


After completing their EHS Training Needs, the trainees can enroll in scheduled classroom-based training courses offered by both the EHS Office and specific DLCs. The content for these classes is broadly applicable throughout DLCs and is the same as the web-based training, but delivered in a classroom format where the trainee can interact with the instructor. The instructor is responsible for submitting training attendance documentation to the EHS or DLC Training Registrar for uploading to the Institute's Learning Center.


4.4.3 Laboratory/Workplace-Specific Training


Laboratory and/or workplace-targeted EHS training is provided directly by the PI/Supervisor, EHS Representative or other designated individual to meet these specialized training needs and requirements. The EHS Coordinator submits the training attendance documentation to the EHS Office for inclusion in the Institute's Learning Center.


4.5 Training Records


Information captured by the Institute's Learning Center system includes, but is not limited to:


  • trainee MIT ID number and Kerberos username;
  • the DLC(s) and PI(s)/Supervisor(s) for which the trainee works or studies;
  • the first and most recent date that the EHS Training Needs was completed;
  • the training requirements determined by the training needs;
  • required completion dates for each course; and expiration dates of the initial training if retraining is required.

All Lincoln employee training completion records and activity selection information is stored in the Lincoln Laboratory SAP Learning Management System (LMS.)  EHS training questions and training requirements mirror those found in the Campus EHS Training Needs.   


 


4.5.1 Access to Training Records


MIT uses a central 'roles' database to administer authorizations for access to secure information across the Institute. For the Institute's Learning Center, DLC Heads/Directors, DLC EHS Coordinators, EHS Coordinator administrative designees, and DLC PIs/Supervisors, have roles recognized by the system that enable them to access training information for their specific DLC. EHS Office Lead Contacts have access to the entire training records database. The roles database also designates different access permissions that can be granted to a person in a role, such as "view only", "run reports", or "maintain information". Having a flexible set of roles and permissions enables the system to be optimized to the work requirements in each DLC. To ensure proper controls, Department Heads/Directors, PIs/Supervisors, and EHS Representatives are not granted permission to update training records in the MIT Learning Center. Some DLC EHS Coordinators and their administrative designees are granted permission to update records for their DLCs.


4.5.2 Standard Training Reports


The ability to generate specific reports on training status is available via the Institute's Learning Center. Authorized DLC personnel can access training status information via a set of standard reports about trainees; trainee needs; courses that have not been completed; and courses that have been completed. These standard reports have been designed based on the needs and inputs of the following data users: EHS Representatives, PIs/Supervisors, DLC EHS Coordinators, EHS Office Lead Contacts, and other EHS Office personnel. DLC personnel can submit requests for additional types of training reports to the EHS Office Lead Contact via their DLC EHS Coordinator, who will then queue the request for future system development.


4.5.3 Archiving Training Information


Trainee data generated by the EHS training program is routinely archived and purged of outdated information to ensure a robust and accurate data set. The periodicity of archiving and purging is determined by the EHS Office to foster accurate information and to the extent feasible takes into consideration the annual academic year cycles for students and staff appointments, and the need for regular purging of inactive students, staff, and employees from the system. Up to twice a year, the EHS Training Reconciliation system will electronically initiates updating training affiliations data clean up by emailing the PI's EHS Training Reconciler(s) for his/her lab group(s) to have them validate the list of people working in the lab and then to have them unaffiliate those who are no longer working in their lab. EHS training records are archived and will be retained for a to-be-determined period according to regulatory requirements or MIT determined best practice, and then purged.


 


4.5.4 Training Reconciliation


Training Reconcilers, most often EHS Coordinators and EHS Representatives, can directly confirm and update the list of those who work in their labs and work areas who require EHS training. Twice a year the system emails the "Training Reconciler" for a PI or DLC to remind them to complete training reconciliation for their lab groups within 30 days. The Training Reconciler goes into the on-line Training Reconciliation system to confirm and update the accuracy of those who affiliated with their PI(s)/Supervisor(s) when completing the EHS Training Needs, adding anyone missing from the database and inactivating anyone no longer working in the area. When a person is added to the list, the system sends the new person an email as a reminder to immediately complete their EHS Training Needs. The default months for training reconciliation reminders are October and June. A DLC may change the months to the two best that fit their calendar. Training reconciliation can be done at any time but the default reminder cycle is as described above.


For those who still have active Kerberos usernames, their training records can be found in the Learning Center training reports and through MIT Data Warehouse training reports. Once a person’s Kerberos username is retired, their records can be found through an archive report.


 


5.0 Operations (EHS Services and Data Management)


The Environment, Health and Safety (EHS) Office develops and delivers EHS services to ensure compliance and promote best management practices throughout all the Institute's day-to-day operations. The services provided include: EHS program development and implementation; technical consultation and advice; and tactical and operational implementation of the EHS Management System (EHS-MS). Central to the EHS Office's function to ensure sound environmental practices, and a safe and healthy campus, is a focus on identifying, assessing, mitigating, and controlling the potential hazards and regulatory requirements associated with all the academic and operational activities of the Institute.


5.1 Hazard Assessment and Control


An essential component of the EHS Management System is the ongoing processes and procedures for identifying, assessing, mitigating, and controlling potential EHS hazards and identifying EHS regulatory requirements that exist throughout the MIT campus. These systems for identifying hazards and regulatory requirements include the PI/Space Registration Program described in Section 3, Getting Started, and the Inspection and Audit Program described in Section 6, Inspections and Audits.


5.1.1 Hazard Assessments


Hazard/regulatory assessments are performed within MIT spaces when:


  • data collected during the PI/Space Registration process identifies activities involving hazardous and/or regulated materials or practices;
  • Level II inspections identify a need;
  • required by a specific regulation;
  • a potential violation of regulatory requirements is identified and requires further evaluation;
  • an accident or incident occurs;
  • or requested by MIT faculty, staff or students.

Assessments are done by PI/Supervisors, EHS Representatives, DLC EHS Coordinators, or EHS Office professional staff. The objective of an assessment is to determine if improvements are needed in: guidance, procedures, training, engineering or administrative controls, facility or equipment maintenance, or enforcement of policies to reduce or eliminate EHS impacts.


Hazard/regulatory assessments by EHS Office staff are initiated through five primary channels:


  • a request from DLC personnel;
  • identified need as a result of the PI/Space Registration Program;
  • identified need as a result of the Inspection and Audit Program;
  • a requirement for an accident or incident investigation; or
  • Institute EHS Committees (CAB/ESCRO, RPC, RSC, CAC, etc.) process requests.

5.1.2 Hazard Control


When a hazard/regulatory assessment results in a determination that improved controls are needed, a report is written that includes recommendations for the type of controls needed. The report is sent to the affected party, (usually a PI/Supervisor), with a copy sent to the DLC EHS Coordinator. Controls may involve a need for action by the DLC, a need for EHS Office services, or a combination of both. When the DLC must take action, it is the responsibility of the affected party to ensure the controls are implemented. The DLC EHS Coordinator is responsible for providing assistance to the affected party and tracking action to ensure the controls are implemented. When there is a need for EHS Office services, the Director of the EHS Office ensures appropriate follow-up action is initiated.


5.2 EHS Office Programs, Services, and Service Teams


The services provided by the EHS Office promote day-to-day good practices, compliance-related activities, and initiatives that advance MIT's commitment to environmental sustainability and health and safety excellence. These services are designed to fully support all aspects of the Institute's EHS-MS.


EHS Office services are delivered to DLCs through teams of specially chosen professionals from each technical program area to create a customized service team for each DLC. The EHS Office is organized around five technical programs: Biosafety, Environmental Management, Industrial Hygiene, Radiation Protection, and Safety. The DLC can request services by contacting their EHS Lead Contact, contacting a member of the DLC EHS Team, or by calling the EHS Office (617-45(617) 452-3477) during office hours. Off hours, EHS services are available for emergencies and can be obtained by calling the campus emergency numbers: 100 or 617-253-1500. For details regarding the EHS programs and EHS services see: EHS brochure.


The EHS Office has also established cross-functional service teams to better leverage the diverse technical expertise of the EHS Office and address the requirements of the EHS-MS. The service teams include:


  • Organization Service Team

    This Team provides oversight to ensure EHS-MS organizational structure is implemented and maintained and facilitates DLC EHS Coordinator and EHS Lead Contact relationship through establishing periodic meetings and communications. This team also oversees the PI/Space Registration process. This team also provides advice and direction regarding professional development needs of the EHS Office Staff and EHS Coordinators.
  • Inspection/Audit Team

     This Team provides oversight for the implementation and maintenance of the inspection and audit program.
  • Training and Development Service Team

    This Team provides oversight for all EHS training needs, assists in the development of new EHS training courses, assists in the development and update of the EHS Training Needs, and tracks the maintenance of the database used for managing official training records.
  • Emergency Preparedness and Response Service Team

    This Team provides oversight for the 24-hour emergency response services provided by the EHS Office; the coordination of the EHS responses with MIT's Emergency Response Group; and oversight of the emergency response follow-up process.
  • Laboratory and Facility Design and Construction Review Services Team

    This Team formally collaborates with the Department of Facilities and DLCs to ensure that EHS requirements and concerns are addressed systematically in new construction and renovation projects at MIT.
  • Technology Service Team

    This Team has oversight for the development and maintenance of the technology needed to support EHS activities, including EHS web resources, the EHS Office intranet, and all databases associated with the EHS-MS.
  • Communications Service Team (CST)

    This Team works to promote effective and timely communication among all the EHS stakeholders across the Institute and MIT community to improve EHS performance. More details about the CST are in Section 8.2 of this Manual.
  • Regulated Waste Service Team

    This Team coordinates activities related to chemical, biological, radiological and universal waste at the Institute. It provides oversight of compliance issues and identifies and recommends opportunities for continuous improvement and waste reduction.
  • Hazardous Materials Shipping Team (HMST)

    This team provides support and services to the campus community to help assure that hazardous materials and dangerous goods are shipped from MIT in accordance with regulatory requirements by personnel trained to do such shipments.  The shipping service provided by the team includes guidance on shipping requirements, packaging, labeling, and document preparation.  The team also provides some shipping training, and assures proper management of training records and shipping records.
  • Sustainability Service Team

    This team utilizes the EHS-MS to strengthen and introduce sustainable initiatives to campus, communicate updates on sustainable projects and opportunities, as well as identify new areas of improvement, specifically as they apply to EHS.

5.3 Documents, Records, and Data Management System


The EHS Office currently has several systems for managing documents, records, and other data. The EHS Office in conjunction with the DLCs is continuously assessing and upgrading its information management systems to improve efficiency, accuracy, and the delivery of services. The EHS Office is also progressing towards the conversion of paper-based systems to more effective electronic systems that allow for better integration and accountability.


5.3.1 Documents


Core to the implementation of the EHS-MS is the concerted effort across the Institute to capture, codify, and disseminate written documentation on the EHS programs, services, and standard operating procedures available for addressing MIT's high EHS standards, EHS hazards and regulatory requirements, communicating regulatory requirements, and promoting the adoption of good EHS practices. The process for determining what written documentation is needed is described in Section 3.4.1, SOP Assessment. Once the need for documenting a procedure, activity, program or issue is established, there is a process in-place for determining the most appropriate type of document, and a process for planning the writing, reviewing, communicating, implementing, and updating the document. The different types of documentation include written program descriptions, standard operating procedures, standard operating guidelines, and fact sheets. The primary means of making these documents available to the MIT community is by posting them to the EHS Management System web site. They are linked in a multiple fashion so that individuals searching for information can readily find what they are looking for. There is a Document Control Program managed by the EHS Office. Reviews of all controlled documents are conducted periodically.


5.3.2 Records


Appropriate records are maintained to ensure compliance with EHS regulatory requirements, MIT's high EHS standards and good practices. Records may be maintained as either paper files or electronic files. The EHS Office recognizes that it is good business practice to retain records in a consistent, systematic and reliable manner so that they can be retrieved promptly when required for legal, regulatory or operational reasons. The EHS Office has determined the types of records that must be maintained, and the time period over which the records must be available. The EHS Records Management Program has been developed to provide management direction and support throughout the records lifecycle. The objectives and details of this program are covered in the EHS Records Retention Standard Operating Procedure, and Records Retention Schedule.


5.3.3 Databases and EHS Data Management


Currently, there are several enterprise database components that support EHS-MS activities on campus. They are the PI/Space Registration Database, described in Section 3, Getting Started, the MIT Learning Center Training Database, described in Section 4, Training, the Inspections Database, described in Section 6 Inspections and Audits, and the Incidents Database, described in Section 7.0 EHS Incident and Non-Compliance Investigations. The PI/Space Registration, MIT Learning Center, and Inspections databases can be accessed by DLC staff providing EHS support, such as DLC EHS Coordinators, and DLC EHS Representatives; and by EHS Office staff for purposes of entering information, viewing information, and reporting information. The Supervisor's Injury Report system is accessible to supervisors, or their designees to report injuries via the web, while the Non-injury Incidents database is maintained by EHS Office Staff.


Using the EHS Roles and Responsibilities Database, the EHS Office maintains a database of all regulatory program areas that clearly identifies the individual assigned to oversee that program. The EHS Office also has a number of databases that support the specific programmatic area activities, such as hazardous waste manifests, biological research protocols or authorizations for working with ionizing radiation. The purpose of these databases is to manage the information required to deliver the program-specific core services.


 


6.0 Inspections and Audits


The inspection, audit, and incident investigation programs provide a coordinated and consistent mechanism across the MIT campus for both local and central MIT EHS staff to assess performance, correct problems, and prioritize areas for improvement with respect to environment, health and safety. These programs also serve as an essential conduit for educating the MIT community in EHS issues, requirements, and good practices.


6.1 Inspection and Audit Program


At MIT, the Inspection and Audit Program consists of a three-tiered system for inspection and evaluation targeting all levels of organization throughout MIT for EHS concerns.


6.1.1 Local Periodic Inspections


The first tier (Level I) is a self-inspection program consisting of required weekly and periodic monthly inspections conducted by DLC EHS Representatives or their designees. Weekly Level I Inspections must be conducted in those areas which contain Satellite Accumulation Areas (SAA) while inspections of other labs or facilities will occur on a schedule determined by the EHS Office and DLC. A Level I Inspection Checklist has been developed for laboratories that include sections on environmental management, including satellite accumulation areas; health; safety; and emergency response. The EHS Office manages the Institute's "less than 90 day" hazardous waste storage areas that are also inspected on a weekly basis. If a problem is identified in this level of inspection action can be taken to correct the problem at the time of the inspection. For those findings not readily correctable, the PI or Supervisor must develop and initiate an action plan to correct the problem. The inspection process is designed to ensure that DLCs make consistent checks of key components in their work areas essential for maintenance of the EHS program, and foster good working habits with respect to the environment, health and safety. A review of the self-inspection system is performed when the more comprehensive Level II inspections are carried out. Records of these Level I inspections are not required to be kept, although some DLCs may elect to do so.


6.1.2 DLC-wide Inspections


The second tier is a DLC-wide inspection, called Level II Inspections, performed twice a year by a team consisting of the DLC EHS Coordinator and other parties selected by the EHS Coordinator. For some operational areas within the Division of Comparative Medicine, Division of Student Life and Department of Facilities inspections are done on an appropriate periodic basis as determined by the DLC and the EHS Office. At least once a year, one member of the team will be the EHS Lead Contact or other EHS office representative. A Level II Inspection SOP has been developed and must be followed when conducting this inspection. The DLC EHS Coordinator will provide a comprehensive report on findings and recommendations to the appropriate parties for action. In addition, as part of Level II Inspections, EHS Office staff may review some specific supplemental topics. These supplemental review components will be developed to assess different local program effectiveness. This may be done at the time of joint Level II Inspections with the EHS Coordinator, or independently. EHS Office staff will be responsible for compiling a report on these supplemental inspection topics. (See Inspections: Level I - Level II for inspections tools and guidance.)


6.1.3 Institutional Audits


The third tier is an Institute-wide or targeted systems or compliance audit examining the overall implementation and effectiveness of the EHS Management System. The MIT Audit Division and/or an outside consultant will audit MIT's EHS-MS at least biennially. A Level III SOP has been developed and is followed when conducting these audits. A summary of the audit results will be included in the annual EHS Programs Office and EHS Office report to the President and will be distributed to the Institute Council on EHS. The EHS Office oversees implementation of the recommendations emanating from the systems audit. In addition, as part of the process for evaluating the EHS Management System, there will be an internal management review conducted by members of the EHS Programs Office and EHS Office at least annually. At the time of the management review, the review team will:


  • Discuss the results of the most recent internal and external audits,
  • Incorporate the necessary changes resulting from the most recent audits into the EHS-MS,
  • Determine whether revisions to the EHS-MS Manual are needed, and
  • Coordinate the distribution of meeting minutes and action items of the annual review to appropriate members of the MIT community. 

 


7.0 EHS Incident and Non-Compliance Investigations


When accidents or incidents occur, or events of non-compliance are observed, it is important to investigate to determine the root cause or causes, and to initiate and confirm completion of appropriate corrective action.


7.1 Reporting and Recording


Accidents or incidents involving injuries, and illnesses to employees, are part of the OSHA reporting and record keeping procedures, as described in the Reporting Work-Related Injuries and Illnesses SOP.


Incidents involving potential harm to the environment, such as a major chemical or oil spill, are to be reported to the EHS Office immediately. Please see Spill Response Procedures SOP for definition of major spills. The EHS Office has in place procedures for emergency response and for notifying the appropriate agencies regarding such incidents. Procedures for contacting regulatory agencies are described in an internal document.


Accidents and incidents are investigated at different levels of detail, depending on their severity, as discussed in the Incident Investigation SOP. Emergencies are investigated by the EHS Office and selected DLC representatives to determine the cause of the emergency, equipment malfunction, or operating procedure problem. A Root Cause Analysis is completed to determine root causes or contributing causes of the incident, underlying factors, and the roles that design, skills, maintenance, and procedures played in the occurrence of the incident. The EHS Office develops a report with recommendations for corrective action, and coordinates with the affected parties to ensure that the corrective measures are carried out. When corrective action is required by the DLC, the EHS Coordinator is responsible for initiating and confirming completion of the corrective action. When corrective action is required by the EHS Office, or by the MIT administration, EHS Office management initiates and confirms completion of the corrective action.


For employee injury and illness, the DLC PIs/Supervisors investigate the accidents and complete the Supervisors' Report of Occupational Injury/Illness. The EHS Office and the DLC may investigate certain accidents in greater detail if needed.


7.2 Preventative and Corrective Actions


An After Action Review can be initiated by the Managing Director of EHS Programs, EHS Office Director, or Emergency and Business Continuity Planner for the Emergency Management Office after an incident to determine the level and quality of response from the DLCs involved as described in the After Action Review SOP. The After Action Review report is completed by a team assembled by the EHS Office after the incident and includes:


  • incident information (including non-compliance or non-conformance items),
  • date and time,
  • location,
  • contacts,
  • reporter,
  • description,
  • corrective action,
  • preventative action,
  • and verification of implementation.

Where corrective actions (including non-compliance or non-conformance items) are identified through the After Action Review, the After Action Review team and the DLC representatives are responsible for:


  • Identifying appropriate corrective and preventative actions (including modifying or creating procedures and work practices) in a written report,
  • Planning and implementing corrective and preventative actions, and
  • Verifying the completion and effectiveness of corrective and preventative actions.

 


8.0 Communications


Effective communication is an important part of the EHS Management System (EHS-MS). MIT has developed comprehensive communication mechanisms within the EHS-MS to ensure that the information needed to implement MIT's EHS Policy reaches the MIT community. The ultimate objective of these communication mechanisms is to promote the full integration of the MIT EHS Policy and EHS Management System into research and work processes to ensure compliance and promote achievement of MIT's high EHS standards. Clear and effective channels for communication are essential to ensure awareness and understanding of EHS regulatory requirements, the components and operation of the EHS-MS, and of the supplemental programs, plans, and procedures established at MIT to address EHS issues.


As a leading educational institution, MIT strives to serve as a role model for other institutions and the community at large. MIT is an incubator of ideas, including ideas regarding improved systems or technologies that may protect the environment or reduce the negative human impact on the environment. Communicating these new MIT ideas and approaches related to environment, health, and safety is one component of the EHS-MS communication system that can serve other institutions, neighboring communities, and beyond.


As an institution subject to EHS regulatory requirements, another important component of the communication program is to ensure MIT has well-defined procedures in place for communicating with the regulatory community. These procedures address communicating both compliance problems and achievements, as well as obtaining information for interpreting regulations or guidelines.


8.1 EHS-MS Organizational Structure and Communications


The MIT EHS-MS organizational structure was designed with the importance of effective communications in mind. A key aspect of the organizational structure is the EHS Coordinator and Lead Contact relationship. This relationship was created to facilitate important communications from the EHS Office to the DLC community, and vice versa. Another important aspect of the organizational structure is the creation of both MIT-wide and DLC-specific EHS committees. Each DLC must establish an internal EHS Committee, and the Institute has several key EHS committees, as outlined in Section 2, Roles and Responsibilities. These Committees provide an opportunity for the EHS Office to communicate EHS concerns, programs, projects, and regulatory updates, as well as provide an opportunity for DLCs to provide feedback regarding the impacts, effectiveness, and problems with both the EHS-MS and specific programs established to assure EHS compliance.


8.2 Communications Service Team (CST)


To ensure effective communication as part of the EHS-MS, the EHS Office has established a "Communications Service Team." The purpose of this team is to identify and plan for EHS-MS communication needs, and to initiate action or provide assistance to ensure these needs are met.


8.2.1 Communication Plan


The Communications Service Team determines the EHS communication needs for the MIT community based on input from within the EHS Office and the DLCs. Then the team develops a comprehensive Communications Plan for fulfilling those needs. The Plan identifies the stakeholders or target audience of the information, and the responsible parties charged with ensuring the communication is carried out. The Plan is reviewed and updated routinely throughout the year to ensure communication needs are addressed in a timely and effective manner.


8.2.2 EHS Newsletters


Past editions can be accessed on the EHS website.


8.2.3 Additional Activities


The Communications Service Team initiates and maintains ties to other communication resources on. Periodically, the Communications Service Team will submit information or articles to campus publications and websites to further understanding of EHS related issues. The Communications Service Team also acts as liaison to communications personnel in other departments and offices on campus, as well as the groups within the EVPT.


The Communications Service Team coordinates EHS Office participation in campus-wide fairs and activities, organizing volunteers and developing collateral as needed. Participation in these events is meant to promote awareness of the EHS Office, the EHS Management System, and EHS related issues.


8.3 EHS Communication Tools


Personal communication between EHS Office staff and EHS clients is recognized as the most effective form of communication. A variety of tools are also available through the EHS Office to promote effective communication and information sharing.


8.4 Communications with Regulatory Agencies


Effective communication with regulatory agencies is a critical component of implementing the EHS-MS. The Management System is designed to accommodate and facilitate two-way communications between MIT EHS personnel and local, state, and federal regulatory authorities. Open and clear channels of communication are important to convey information on compliance-related issues, good practices, and regulatory questions and interpretations.


Because timely and effective communication with regulators is crucial for effective EHS performance, communication requirements have been included in key standard operating procedures (SOPs) to clarify roles and responsibilities, and thresholds for contacting regulatory authorities. Communications for regulatory agent visits are addressed in SOP EHS-0006, "Regulatory Agent Visits". Communications with the Occupational Safety and Health Administration (OSHA) to report serious injuries or fatalities are addressed in SOP EHS-0008, "Reporting Work Related Injuries and Illnesses". Communications to appropriate regulatory agencies to report spills or releases to the environment are addressed in SOP EHS-0004, "Spill Response and Release Procedures". In addition, to enhance the effectiveness of regulators contacting MIT personnel, SOPs have been developed to ensure that regulators who call on MIT are quickly and efficiently routed to the appropriate personnel or resources. More detailed information on managing communications with regulators can be found in EHS Communications to External Parties SOP.


8.5 Community Involvement & Outreach.


MIT's EHS Policy clearly articulates the Institute's commitment to the well-being of the community in which it operates. Acting on this commitment, MIT participates in numerous community-focused activities that promote sound EHS practices and performance. The following select examples showcase the variety of MIT community-focused current or past EHS activities:


  • MIT Energy Initiative - Working with faculty and students, MIT administration has developed a collaborative campus energy program focused on reducing campus greenhouse gas emissions with a focus on energy efficiency, sustainable design, community engagement and outreach, and student research and learning opportunities. (http://energy.mit.edu/campus-energy)
  • Cambridge-MIT Clean Diesel Collaborative - MIT’s EHS Office has partnered with the City of Cambridge to win and implement an EPA Voluntary Diesel Retrofit grant to install advance pollution control devices on both City and MIT diesel vehicles to reduce harmful diesel emissions.
  • Cambridge Climate Protection Program - MIT is assisting the City of Cambridge to achieve the goals set by the Cambridge Climate Action Plan through existing and future environmental initiatives. MIT has developed classes and class modules that specifically engage students on exploring opportunities to reduce local greenhouse gas emissions.
  • Earth Day – Several MIT departments and student groups partner annually to host an Earth Day showcase of environmental activities and programs both at MIT and in the community. MIT’s Earth Day events are open to the public.
  • EPA P3 Program – MIT academic departments and the EHS Office are implementing the recommendations of EPA P3 (People, Planet and Prosperity) grant that funded the development and implementation of an innovative Green Chemical Purchasing Wizard and pollution prevention program aimed at reducing the toxicity of research chemicals.
  • Best Workplace for Commuters - MIT has been recognized by the EPA as a Best Workplace for Commuters for its comprehensive programs to increase commuter choices.
  • EHS Office Open House – The EHS Office hosted a public open house that offered educational displays and activities to inform the community about sound EHS practices in the home.
  • Cambridge GoGreen Award – MIT has been recognized on several occasions by the City of Cambridge's annual GoGreen Awards, including recognition for excellence in programs addressing climate and engergy, green transportation, storm water management, and waste reduction and recycling. (http://www.cambridgema.gov/CDD/climateandenergy/gettinginvolved/gogreenawards.aspx)
  • Efficiency Forward Program - MIT successfully completed the first three-year pilot of MIT Efficiency Forward – an industry-leading energy conservation and efficiency program that saves 34 million kWh annually and $50 million over the lifetime of projects. MIT and NSTAR announced their second three-year agreement in June 2013. (http://web.mit.edu/facilities/environmental/efficiencyforward/)
  • Cambridge Community Compact for a Sustainable Future - In May 2013, MIT, Harvard and the City of Cambridge launched a first-of-its-kind community compact to share expertise across the Cambridge community and advance sustainability. The compact is designed to encourage other institutions to join in the effort for greater impact. (http://news.mit.edu/2013/mit-signs-compact-for-sustainable-future-0506)
  • Cambridge’s Rodent Control Task Force- MIT EHS participates on the City of Cambridge’s Rodent Control Task Force, whichis organized to bring together City of Cambridge departments along with representatives of Universities in the city and residents.  The task force has a primary mission of working to control rodent populations in the city while coordinating as much as possible with landowners and residents.  MIT has an Integrated Pest Management (IPM) program and continues to make efforts to limit rodents on MIT properties.  We participate in this task force learning about Cambridge’s efforts and sharing our best practices.”
  • Cambridge City Council - In 2006, the City Council of Cambridge passed a City Resolution recognizing MIT’s leadership in environmental stewardship. The Resolution also thanked MIT for sharing their knowledge and experience with other institutions to promote sustainable practices.

Other current or past activities have included:


  • Environmental Virtual Campus*- A web-based "virtual campus" compliance assistance tool for use by colleges and universities.
  • Urban Focus: MIT-Cambridge Schools Collaboration on Education for the Environment*- A collaboration with the Cambridge Public School system to perform three urban environmental projects. The goal of this collaboration was to provide lasting benefits to the local urban environment as well as to develop enhanced environmental consciousness among local citizens..
  • Cambridge Public Schools Science Lab Project - A collaboration between the MIT EHS Office, Harvard University, and the Cambridge Public Schools to develop an EHS program for the Cambridge Public School science labs.
  • Cambridge Climate Action Initiative - MIT is assisting the City of Cambridge to achieve the goals set by the Cambridge Climate Action Plan through existing and future environmental initiatives.
  • Stata Center Biofiltration Stormwater System*- A biofiltration stormwater system for MIT's new Stata Center building that improves the health of the Charles River has been completed.
  • Vassar Street Utilities and Streetscape Projects - Installation of a bicycle lane, better sidewalks, trees, new steam and condense lines, hot water piping, telephone/data and electrical duct banks, fire protection water lines, water, sewer, and storm drain on Vassar Street. This includes the burial of overhead telephone and electric lines to incorporate the physical and aesthetic connections among MIT's buildings and public spaces. This project results in a greener, more pedestrian and bike-friendly streetscape. The project has begun phase two, which continues north of Massachusetts Avenue.
  • Participation on the Local Emergency Planning Committee for Cambridge - Examples of a short term project that the EHS Office was involved in was participation on the Cambridge Nanomaterials task force to determine appropriate policy and procedures for managing concerns regarding research with nanomaterials.

* This project was undertaken by MIT in connection with the settlement of an enforcement action brought by the U.S. Environmental Protection Agency and the U.S. Department of Justice for alleged violations of the Federal Clean Water Act, the Clean Air Act, and the Resource Conservation and Recovery Act. There was no actual harm to the environment.