Applies to: All USC and affiliated personnel (faculty, staff, students, contractors, volunteers, etc.)
Last Revised: 7/30/2013
Last Reviewed: 7/19/2021
2. Policy Purpose
To set forth the responsibilities and requirements for all USC personnel to implement injury and illness prevention measures, protect employees from workplace hazards including infectious diseases, and ensure individual and institutional compliance with environmental health and safety regulations. This policy is part of the University’s Injury and Illness Prevention Program (IIPP), as required by California Title 8, General Industry Safety Orders, Section 3203.
3. Scope and Application
This policy applies to all USC personnel located on University’s owned or leased property, or engaged in University business or activities in off-site locations.
|EH&S||USC Office of Environmental Health & Safety|
5. Policy Details
USC safety policies, practices and programs secure and protect the safety, health, and well-being of the University community, and to meet local, state, and federal regulatory standards. These policies provide guidelines and requirements for injury and illness mitigation measures along with response, investigation and remediation of occupational hazards and/or other unsafe conditions.
USC has established programs that require communication on specific hazards that include the Hazard Communication Program, the Chemical Hygiene Plan, the Bloodborne Pathogens Program, and others. All USC safety programs are accessible via the EH&S website.
Communication About Hazards
Supervisors and managers are required to communicate with their employees, students, contractors and volunteers about occupational hazards and appropriate protective measures. Communication should be done in a manner readily understood by all personnel, and using the following process:
- Discuss with new personnel, prior to commencing work, any safety hazards in the workplace and how they can protect themselves;
- Review the provisions of this policy;
- Explain the systems and processes used to report workplace hazards;
- Discuss any employee safety concerns, identified workplace hazards and corrective actions, during regular work meetings and/or in separate safety meetings; and
- Post, discuss and distribute safety information to staff (e.g. EH&S Fact and Guide Sheets)
Department leaders, deans, managers and administrators are responsible to assure that subordinate supervisors are trained or knowledgeable in the safety and health hazards to which personnel under their immediate direction and control may be exposed.
Managers and supervisors are responsible to ensure that employees, students, contractors, and volunteers whom they supervise receive training to identify and protect themselves from workplace safety hazards in their specific work area, in a manner readily understood by all personnel. This training includes:
- Injury & Illness Prevention Program
- Job-specific health and safety procedures;
- How to recognize anticipated health and safety hazards;
- How to minimize hazards through safety practices and proper use of protective equipment; and
- Emergency procedures and incident reporting.
Managers and supervisors shall require those they supervise to complete any and all applicable safety training:
- When an employee is newly hired, or is given a new assignment for which he or she has not been previously trained;
- When new hazards are introduced by new substances, processes or equipment;
- When the supervisor is made aware of a new or previously unrecognized hazard; and
- When safety performance deficiencies are identified.
Facility Design and Seismic Safety
Departments that are responsible for design, construction, or renovation of facilities shall work with EH&S to ensure that necessary health and safety reviews of facility concepts, designs and plans occur. This ensures that USC’s facilities meet health and safety regulations and design standards that support a safe workplace.
To prevent injuries in an earthquake, all schools and departments must secure equipment and furnishings against seismic shaking. Seismic mitigation requirements include the following:
- Bolt bookcases and shelving units over 48″ high to a wall;
- Install restraining lips on laboratory storage shelves;
- Restrain gas cylinders with two chains or cables;
- Store heavy items below shoulder height;
- Use seismic braces to secure desktop computers; and
- Obtain shake-resistant furnishings, such as shelving units and file systems that attach to walls and floors.
Managers and supervisors shall conduct regular, periodic inspections of their workplaces to identify and evaluate workplace hazards and unsafe work practices. Inspection templates are available via the EH&S website.
Inspection frequency should be proportional to the magnitude of risk posed in the particular workplace. Inspections are also required whenever new processes, procedures, equipment or substances present new health and safety hazards. Upon the request of a department supervisor / manager, EH&S will conduct an industrial hygiene exposure assessment for noise, temperature, chemical or radiologic hazards in the workplace.
EH&S and Fire Safety Emergency Planning shall conduct periodic safety audits to evaluate the effectiveness of the regular safety and housekeeping inspections conducted by supervisors. EH&S and Fire Safety Emergency Planning will provide safety audit findings and recommendations for corrective action to the appropriate department or school contacts.
Managers and supervisors are required to correct identified hazards and implement appropriate measures to protect individuals from the hazards as soon as feasible. If a manager or supervisor cannot remedy an unsafe condition themselves, then they must report it to their supervisor. EH&S, Facilities Planning & Management and other University departments will provide assistance in developing appropriate corrective actions as needed.
Managers and supervisors can use the following techniques to prevent unsafe practices:
- Tag unsafe equipment with proper signage;
- Stop unsafe work practices and provide re-training or discipline as appropriate;
- Reinforce and explain the necessity for the proper use of personal protective equipment (e.g., respirators, gloves, safety glasses) and ensure its availability; and
- Barricade areas that have chemical spills or other hazards, and report hazardous conditions to a supervisor, building coordinator, or EH&S.
Any supervisor or manager who becomes aware of a serious danger to the health or safety of an individual must promptly report the danger to EH&S, and to the persons who may be affected.
Any person who identifies a hazard or activity that poses an imminent hazard (likelihood of serious injury or death if not discontinued immediately) shall immediately notify the supervisor and report emergency conditions to the Department of Public Safety (DPS) at (213) 740-4321 (24 hours/day).
The Executive Director of EH&S has the authority to shut down or stop any such university activity. If a hazard cannot be immediately corrected without endangering employees or property, then the department supervisor or EH&S shall require all employees to evacuate from the area except for those knowledgeable, qualified, necessary, and equipped with proper safeguards to correct the condition. In such an event, EH&S or the supervisor shall immediately notify the appropriate University administrator.
Managers and supervisors are required to investigate occupational injuries and illnesses sustained by their employees, and submit a completed Manager’s Report of Incident form to the Workers’ Compensation office within 24 hours of the injury/illness or as soon as possible. Injured/ill employees or their representative must submit a completed Workers’ Compensation Claim form (DWC1) to the Workers’ Compensation office within 24 hours of injury or as soon as possible. Both forms are available via the Workers’ Compensation website.
Managers and supervisors must immediately report any serious injury, illness, or death of an employee that occurs in a USC workplace or in connection with USC employment to USC EH&S at (323) 442-2200 (24 hours/day).
The USC medical surveillance program, managed by USC EH&S, provides health evaluation and monitoring of University faculty and staff who are exposed to certain hazardous materials and situations as defined by law or University programs. Each supervisor must ensure that employees under their supervision participate in the medical surveillance program as applicable.
Managers and supervisors must keep documentation to demonstrate compliance with regulations and standards at least one year. Required documents include:
- Safety meeting logs;
- Employee reports of unsafe conditions or hazards;
- Accident, injury or illness investigation reports;
- Scheduled and periodic workplace inspection records—including names of personnel conducting the inspection, any identified unsafe conditions or work practices, and corrective actions; and
- Employee training records—including names of all attendees and instructors, training date, and material covered (also send a copy of safety training records to EH&S).
Failure to Comply
Those who violate this policy will be subject to appropriate disciplinary action, including termination or dismissal for cause in accordance with university policies.
Laboratory and hazardous material Standard Operating Procedures can be found at the EH&S Website: Standard Operating Procedures (SOP) | USC Environmental Health & Safety
USC EH&S Fact Sheets / Guide Sheets / Health Alerts:
Manager’s Report of Incident Form:
Employee Worker’s Compensation Claim Form:
All member of the University community are expected to:
- Take reasonable measures to protect the safety and health of the fellow members of the university community;
- Follow safe practices at all times;
- Act proactively to prevent accidents, injuries and illnesses;
- Communicate hazards to supervisors;
- Protect the environment; and
- Minimize safety risks to USC facilities and assets.
|POSITION or OFFICE||RESPONSIBILITIES|
|USC EH&S Department||– Maintaining and implementing this policy|
– Providing operational and administrative support for University safety committees;
– Developing EH&S policies and practices;
– Monitoring compliance with USC EH&S policies and programs;
– Maintaining the University’s radioactive materials license and x-ray device registrations;
– Developing and assisting with implementation of programs for the safe use of hazardous materials and equipment;
– Providing safety training and medical surveillance resources based on job requirements;
– Evaluating the effectiveness of health and safety programs;
– Distributing safety communications, such as injury reports;
– Acting to help stop any university-related activity that presents an unreasonable environmental health and safety risk;
– Providing guidance and technical assistance to supervisors and managers in identifying, evaluating, and correcting environmental, health and safety hazards, and in investigating accidents, injuries and illnesses;
– Providing hazardous waste disposal and emergency services for incidents involving hazardous materials; and
– Acting as university representative with regulatory agencies for environmental health and occupational safety matters
|School and Department Leaders (Deans, Supervisors / Managers, Administrators, etc.)||– Providing oversight and management of their operational areas and facilities to ensure compliance with relevant EH&S policies, practices and programs; |
– Ensuring that personnel under their supervision have appropriate authority to implement EH&S policies, programs and practices;
– Supporting the enforcement of corrective action arising from the failure to comply with appropriate safety practices;
– Supporting the recognition of excellent EH&S performance or management;
– Informing contractors and visitors of applicable safety requirements; and
– Coordinating with USC EH&S to address any safety concerns introduced by a department contracted or invited entity
|Principal Investigators, Supervisors and Managers||– Implementing EH&S policies, practices and programs that protect the health and safety of employees, students, volunteers, visitors and contractors under their supervision. |
– Ensuring that workers know and follow safety rules (see above Communication About Hazards);
– Conducting risk assessments where applicable (e.g., Laboratory Hazard Assessment Tool, Shop Safety Risk Assessment, and Job Safety Analysis);
– Establishing written Standard Operating Procedures (SOPs) specific to facilities under their supervision;
– Holding periodic safety meetings with personnel under their supervision;
– Monitoring work practices and correcting unsafe acts or behavior;
– Conducting regular safety and housekeeping inspections;
– Ensuring identified hazards are addressed in a timely manner;
– Submitting an inventory of hazardous materials, if applicable, to EH&S annually;
– Providing engineering controls, administrative controls, and personal protective equipment based on risk assessment, and requiring its proper use;
– Encouraging employees to inform their supervisor of health and safety concerns without fear of reprisal; and
– Responding to reported employee safety concerns and implementing corrective action;
– Participating in all required EH&S training, and requiring all personnel under their supervision to complete required EH&S training prior to commencing work with regulated or hazardous materials or duties, and as required thereafter;
– Stopping any work that poses an imminent risk (likelihood of serious injury or death if not discontinued immediately) to an employee, other individuals, or the environment;
– Regularly evaluating the safety performance of all employees, and recognizing employees who work in a safe and healthful manner;
– Providing training to employees with safety performance deficiencies;
– Disciplining employees for failure to adhere to safe work practices;
– Reporting occupational injuries, illnesses and incidents (e.g. hazardous material exposure, near misses, etc.) to EH&S at (323) 442-2200 (24 hours/day); and
– Conducting initial investigations to determine root cause, and pursue corrections to help prevent similar injuries or incidents from occurring.
|Employees, Students, Contractors, and Volunteers||– Complying with established EH&S policies, practices and programs.|
– Completing safety training prior to commencing work with regulated or hazardous materials or duties, and as required thereafter;
– Participating in all safety meetings for their work group;
– Following established safe practices in the laboratory, classroom, workplace and campus residence;
– Using proper engineering controls and personal protective equipment when required;
– Adhering to all health and safety-related signs, posters, warning signals, and directions;
– Becoming familiar with building emergency plans and assembly areas;
– Promptly reporting work-related injuries or illnesses, incidents (e.g., spills; near misses), potential hazards, and unsafe work practices to the instructor/supervisor; and
– Cooperating and assisting as necessary in accident and incident investigations.
Note: Contractors are responsible for complying with EH&S policies, procedures and programs that apply to their work or activities at USC. These requirements may include completing USC safety training.
|USC Safety Committees||– Reviewing and making recommendations on safety matters and specific areas of environmental, safety or health concerns.|
– Radiation Safety Committee is responsible for recommending and enforcing university policies and procedures regarding radiation safety and acting as the statutory radiation use review committee required by USC’s radioactive materials license.
– Institutional Biosafety Committee (IBC) is responsible for recommending and enforcing university policies and procedures regarding biological safety and reviewing recombinant DNA and synthetic nucleic acid research to ensure compliance with NIH Guidelines.
– Chemical Safety Committee (see Chemical Hygiene Plan, Section 3.1) is responsible for recommending and enforcing university policies and procedures regarding the use, storage, and disposal of potentially hazardous chemicals.
– Diving Control Board oversees the safety of research-related underwater scientific diving.
|USC Risk Management Department||– Coordinating, reporting, managing and maintaining records of non-occupational liability, and property insurance claims;|
– Maintaining insurance and other risk financing programs;
– Providing risk management information, education, and services to university departments; and
– Recommending corrections to known hazardous conditions in conjunction with other University departments.
9. Related Information
About EH&S: https://ehs.usc.edu/about/
Please direct any questions regarding this policy to:
|Environmental Health & Safety||(323) 442-2200||EHS@usc.edu|