July 30, 2013
Injury and Illness Prevention
USC is committed to excellence in environmental health and safety stewardship on our campuses and in the larger USC community. This policy outlines safety responsibilities and requirements placed on all USC personnel (faculty, staff, students, contractors, and volunteers)—to support injury and illness prevention, maintain a safe and healthful workplace, and ensure individual and institutional compliance with relevant 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.
Roles and responsibilities
All members 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.
Department heads/deans/managers and administrators are to ensure that areas under their management comply with USC environmental health and safety (EHS) policies, practices and programs. These responsibilities include, but are not limited to:
- Ensuring that personnel under their supervision have appropriate authority to implement EHS 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 EHS performance or management;
- Informing contractors and visitors of applicable safety requirements; and
- Coordinating with EHS to address any safety concerns introduced by a department contracted or invited entity.
Principal investigators/supervisors/managers are responsible for implementing sound EHS practices that protect the health and safety of employees, students, volunteers, visitors and contractors under their supervision. These responsibilities include, but are not limited to:
- Implementing EHS policies, practices and programs;
- Ensuring that workers know and follow safety rules (see Communication section below);
- Promoting a safe work environment by:
- conducting risk assessments where applicable;
- establishing written procedures specific to facilities under their supervision;
- holding periodic safety meetings with personnel under their supervision;
- monitoring work practices and correcting unsafe acts;
- conducting regular safety and housekeeping inspections;
- ensuring identified hazards are corrected in a timely manner;
- submitting an inventory of hazardous materials, if applicable, to EHS annually;
- providing engineering controls and personal protective equipment where applicable, and requiring its 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 EHS training, and requiring all personnel under their supervision to complete required EHS training prior to commencing work with regulated or hazardous materials or duties, and as required thereafter;
- Stopping any work that poses an imminent hazard (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; and
- reporting to EHS occupational injuries, illnesses and incidents (e.g., hazardous material exposure, near misses)—at (213) 740-4321 (24 hours/day); and
- Conducting initial investigations to determine cause, and pursue corrections that would prevent, similar injuries or incidents (e.g., Workers’ Compensation’s USC Supervisor’s Report of Incident).
Employees/students/contractors/volunteers are responsible for complying with EHS policies, practices and programs. These responsibilities include, but are not limited to:
- 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 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.
Contractors are responsible for complying with EHS policies, procedures and programs that apply to their work or activities at USC. These requirements may include completing USC safety training.
Environmental Health and Safety (EHS) responsibilities include, but are not limited to:
- Providing support to university safety committees;
- Maintaining the university’s radioactive materials license and x-ray device registrations;
- Assisting in the development of EHS policies and practices;
- Monitoring compliance with university policies and programs, and EHS regulations;
- 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.
Safety committees are responsible for reviewing and making recommendations on safety matters and special areas of environmental, safety or health concerns. These committees include:
- The Radiation Safety Committee, which 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.
- The Institutional Biosafety Committee (IBC), which 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.
- The Chemical Safety Committee, which is responsible for recommending and enforcing university policies and procedures regarding the use, storage and disposal of potentially hazardous chemicals.
- The Diving Control Board, which oversees the safety of research-related underwater scientific diving.
Risk Management department responsibilities include, but are not limited to:
- 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;
- Recommending corrections to known hazardous conditions in conjunction with other departments.
University safety programs
USC safety programs are established to secure and protect the safety, health, and well-being of the university community, and to meet local, state, and federal regulatory standards. Programs that require communication on specific hazards include the Hazard Communication Program, the Chemical Hygiene Plan, and the Bloodborne Pathogens Program. All USC safety programs are accessible at the Environmental Health and Safety (EHS) website.
Communication about hazards
Supervisors and managers must communicate with their employees, students, contractors and volunteers about occupational hazards and appropriate protective measures, in a manner readily understood by all personnel. This communication system includes the following:
- Discussion with new personnel, prior to commencing work, regarding the safety hazards in the workplace and means by which they can be protected;
- Review of the provisions of this policy;
- System to report workplace hazards;
- Discussion of employee safety concerns, identified workplace hazards and corrective actions, as part of work meetings or in separate safety meetings; and
- Posting, discussing or distributing to staff safety information such as EHS Fact Sheets.
Department heads, 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.
Supervisors are responsible to assure 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:
- Job-specific health and safety procedures;
- How to recognize anticipated health and safety hazards;
- How to minimize through safety practices and use of protective equipment; and
- Emergency procedures and incident reporting.
Supervisors shall require those they supervise to complete any and all applicable safety training:
- When an employee is newly hired, or is given an 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 responsible for design, construction, or renovation of facilities shall work with EHS to ensure that health and safety reviews of facility concepts, designs and plans occur, so that facilities will 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 that attach to walls, and file systems that attach to walls and floors.
Supervisors shall conduct regular, periodic inspections of their workplaces to identify and evaluate workplace hazards and unsafe work practices. Inspection templates are available on the EHS 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 supervisor request, EHS will conduct an industrial hygiene exposure assessment for noise, temperature, chemical or radiologic hazards in the workplace.
EHS and Fire Safety shall conduct periodic safety audits according to the table below, to evaluate the effectiveness of the regular safety and housekeeping inspections conducted by supervisors. EHS and Fire Safety will provide safety audit findings and recommendations for corrective action to the appropriate department or school.
- PET Center
- BSL 3*
- Select Agents*
- High hazard areas*
- Highly regulated areas*
- X-ray equipment*
- Campus grounds
- Protocol review
- New labs
* Specific area inspection frequencies vary based on hazard level, code requirements and past findings.
The supervisor shall determine how to correct identified hazards and implement necessary corrections to protect individuals from the hazards as soon as feasible. The supervisor must report to his or her supervisor instances of unsafe conditions that the supervisor cannot correct. EHS, FMS or other university departments will provide assistance in developing appropriate corrective actions as needed. 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 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 EHS.
Any supervisor who becomes aware of a serious danger to the health or safety of an individual must promptly report the danger to EHS, 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 at (213) 740-4321 (24 hours/day).
The Director of EHS has the authority to shut down or stop any such university activity. If the hazard cannot be immediately corrected without endangering employees or property, then the supervisor or EHS 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, EHS or the supervisor shall immediately notify the appropriate administrator.
The supervisor must investigate occupational injuries and illnesses sustained by his/her employees and submit a completed Supervisor’s Report of Incident form to the Workers’ Compensation office within 24 hours of the injury. Injured employees or their representative must submit a completed Workers’ Compensation form to the Workers’ Compensation office within 24 hours of injury. Both forms are available from the Workers’ Compensation website.
The supervisor 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 (213) 740-4321 (24 hours/day).
The USC medical surveillance program, managed by EHS, provides evaluation and monitoring of the health 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.
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; and
- Scheduled and periodic workplace inspection records—including names of personnel conducting the inspection, any identified unsafe conditions or work practices, and corrective actions;
- Employee training records—including names of all attendees and instructors, training date, and material covered (also send a copy of safety training records to EHS).
Document templates are available on the EHS website.
Failure to Comply
Faculty or staff employees who violate this policy will be subject to appropriate disciplinary action, including termination or dismissal for cause in accordance with university policies.
Environmental Health and Safety (EHS)
Todd R. Dickey, Senior Vice President, Administration
University of Southern California