Environment, Health and Safety Office
MIT is entering its third year of implementation of a comprehensive Environmental Health and Safety (EHS) Management System (EHS-MS). Its foundation is an EHS policy adopted by the Academic Council in 2000 to reflect MIT's commitment to excellent EHS performance and to an integrated approach to environmental sustainability, good health and safety practices and EHS compliance. The EHS-MS also must satisfy the requirements of MIT's Consent Decree with the US Environmental Protection Agency and the Justice Department, resulting from a 1998 inspection. Major features of the system are now in place, and responsibilities under the new system are shared throughout the Institute.
The emerging system has been designed and is being implemented by faculty members and staff from departments, labs, and centers (DLCs) in partnership with the EHS Office, to ensure its usability and support of research and teaching at MIT. Its features have been endorsed by an Ad Hoc EHS Subcommittee of the Institute's EHS Council, consisting of senior faculty from highly regulated labs and programs. The key participants in this new system are department heads, principal investigators, managers and EHS coordinators of more than 50 DLCs with significant regulatory responsibilities relating to the use, handling, storage, and disposal of regulated materials and the minimization of environmental effects.
Beginning its third year of operation as a single office, the EHS Office is the steward of this system and is responsible for providing high quality and responsive EHS services to MIT's DLCs. The EHS Office includes professionals who are licensed and credentialed in a variety of EHS specialties. It supports the Institute's accountability for EHS legal compliance and positive health and safety initiatives, as well as environmental sustainability initiatives, to ensure the health and safety of the MIT community and the public and to protect the environment.
EHS Office and EHS-MS highlights from this past year, outlined below, include the appointment of a DLC EHS coordinator and an EHS Office lead contact for every DLC with significant regulatory responsibilities, the design of the EHS-MS training and inspection programs, and the development of the EHS Administrative Procedures Manual. The Environmental Virtual Campus (EVC), an innovative web-based environmental training tool to support best practices and compliance on college campuses, received the Environmental Business Council of New England's 2003 Outstanding Environmental Education Award. (See footnote.)
In the coming year, we anticipate a number of changes that will affect the scope and direction of work at the EHS Office.
- The Ray and Maria Stata Center for Computer, Information, and Intelligence Sciences will come online. Particularly the centralized receiving and shipping facility there will require new forms of rules and verification procedures concerning deliveries of all types of materials and constitutes a major new facility that will require EHS services.
- The Broad Institute, which has recently been spun off from the Whitehead Institute, is a major new interdepartmental center at MIT for genome research that will require a new commitment of resources from the EHS Office to support their large volume of research and analysis.
- Under the EPA Consent Decree and EHS-MS, the EHS Office will continue to implement the new MIT inspection/audit and training programs and PI/lab registration procedures.
- The office also will continue to focus on reorganization and streamlining of EHS functions. This includes continued close working relationships between the EHS office lead contacts and the DLC EHS coordinators. This will enhance the Institute-wide program to ensure compliance with local, state and federal EHS rules, as well as MIT's commitment to environmental sustainability, good health and safety practices.
- The office will continue to revamp internal emergency response systems and capabilities, a primary focus of the EHS Office in the next year. In addition, the EHS Office continues to lead or facilitate post-September 11 emergency preparedness planning and the extensive monitoring of the use of select agents and other toxins at the Institute.
Highlights of the Year
Organization
This year saw the full implementation of MIT's new organization structure under the EHS-MS. EHS coordinators were appointed by the major DLCs and they were partnered with a lead contact person from the EHS Office. Several workshops were conducted to train both groups on the new EHS-MS and to clarify respective roles and responsibilities. A majority of the DLCs have formed their internal DLC EHS Committees. A central focus of the new organization structure within the EHS-MS is the registration of principal investigators (PI), facility supervisors, and the laboratories and other facilities for which they are responsible. The registration process identifies the core potential hazards used in the space, the emergency contact for the space, and a PI-assigned EHS representative, as well as confirming that each DLC has implemented applicable EHS organization, training and inspection/audit components of the EHS-MS. The registration process is nearly complete for all of the highly and moderately regulated DLCs. Informational sessions have been conducted with the faculty to enlist their support and confirm with them their responsibilities in the new EHS-MS organizational structure.
Training
As part of the EHS-MS there is a requirement to identify the training that everyone needs based on the materialsthey use (radiation, chemical or biological) and the activities they perform. Technology now underpins our effort to make sure that lab personnel meet all training requirements. In order to determine EHS training requirements for people who work with regulated hazardous materials or in a potentially hazardous environment, a web-based training needs assessment is being used. Via the EHS DLC organizational structure, EHS coordinators ask principal investigators, EHS representatives, and everyone who works with regulated materials to register with the MIT EHS training system. Full implementation will be phased in throughout FY2004.
Based on user evaluation, the general chemical hygiene course was revamped in FY2003 and is ready for use in early FY2004. During the last year, we also developed a central training records database to be launched in September. Training reports are being developed with broad community participation and input from the EHS Working Committee. Currently available web courses include RCRA (Resource Conservation and Recovery Act), SPCC (Oil Spill Prevention), HAZCOM (Hazard Communication), and Chemical Hygiene. Web courses enable faculty, staff, and students to receive the regulatory required training at their own pace and at a convenient time to minimize interference with their daily activities. We plan to develop additional web-based courses in the next year, very likely in the areas of ergonomics, laser, and electrical safety.
The RCRA training plan was submitted to EPA in early May 2003 under the Consent Decree. Reviewers responded positively to the plan and supported the phased implementation.
Audit and Inspection Program
An extensive EHS audit and inspection program was developed and submitted to the EPA for review and approval in FY2003. It will be piloted and implemented in FY2004 in the DLCs. The process was designed by the Working Committee and the EHS Ad Hoc Subcommittee of researchers and EHS professionals and includes three levels of inspection and audit:
- Individual lab/space compliance and safety inspection. This is conducted by the PI or EHS representative on a weekly basis to reinforce training and measure compliance; record keeping will be optional but may be required if there are repeated compliances issues.
- DLC-wide compliance inspection of all lab and other spaces where potentially hazardous materials are stored and used. The DLC-EHS coordinator and members of the DLC EHS Committee conduct these inspections twice annually, with at least one inspection jointly conducted by the EHS Office lead contact with DLC personnel. Records of these inspections are required and will be kept both locally (DLC) and centrally (EHS Office).
- System implementation and operation audit by MIT. This is done by MIT's Audit Division and/or by an outside consultant approximately once every two years.
Security and Emergency Preparedness Programs
Planning by the Safety Operations Task Force (SOTF) continues to develop shelter-in-place plans for the MIT community should an emergency arise. Threat assessments of and enhanced emergency prevention and response plans for higher-risk facilities have been completed. MIT's emergency web site has been enhanced and is now updated with current news and preparedness information for the MIT community (see http://mit.edu/emergency/). MIT's director of EHS programs coleads this initiative with MIT's police chief, and EHS Office staff provides support.
MIT has moved with deliberate speed to appoint emergency preparedness coordinators (EPCs), responsible for bringing Institute and DLC emergency preparedness plans up to date. To date, 134 EPCs have been named, encompassing about 90 percent of MIT building locations. A small percentage of EPCs have multiple program or building assignments. The EPC's role includes developing a building plan for evacuation and other types of preparedness, and continual training and information about the plan provided to staff and faculty within each department, lab, and center. Both briefings and full training on preparing an emergency preparedness plan (EPP) are underway and will be completed in the summer 2003. This schedule and a model template of an EP plan are on the web for reference and for use by the EPCs.
Select Agent Program
The passage of the Public Health Security and Bioterrorism Preparedness and Response Act of 2002 resulted in new HHS and USDA regulations, promulgated in December of 2002, requiring tighter controls on the possession, use, transfer and disposal of certain biological agents and toxins (called select agents and toxins in the regulation) that have the potential to cause significant harm to the public, animal, and plant health. This act and the new regulations that are on a phased-in implementation schedule beginning in February 2003, have had a significant impact on a very small number of MIT laboratories, including the need to maintain strict inventory control on certain agents, the need to have FBI security risk assessments done on some researchers and the need to have specially secured research spaces. The regulations have separate campus-wide and Lincoln-wide toxin volume exemptions, and the EHS Office, with support by a faculty-led implementation task force, worked with Procurement to implement central purchasing through the EHS Office for all listed toxins to ensure that researchers who use these common toxins do not inadvertently exceed the volume exemptions and become subject to the regulations.
The EHS Office conducted several broad surveys of all laboratories potentially possessing or using these materials.
Construction Safety Program
This was the first full year of the EHS Office's collaborative effort with Facilities to provide EHS expertise to new construction and renovation projects. The objectives of the program are to protect the MIT community during construction and renovation activities on campus and to strengthen MIT's relationship with Cambridge authorities responsible for regulating these activities. This program involves an initial review of design and construction plans; close communication with Facilities project managers, contractors, and City of Cambridge Fire Department and Inspectional Services; and ongoing inspections of the construction sites. The advantages of the program include fewer regulatory inspections, fewer time delays, and cost savings. During the past year, 13 major projects and 300 renovations were reviewed. Three new buildings (Simmons, Pacific, and Zesiger) were brought online.
Communications, Outreach, and Awareness
The EHS Office implemented an extensive program to engage and communicate with both the MIT community and the larger community about MIT's environmental programs and activities, education and research efforts, and the EHS-MS. The EHS Office partnered with academic departments conducting research and offering courses in environmental issues to increase awareness of EHS issues. The cornerstone outcome of this effort is an environmental web site that serves as the portal for prospective students, alumni, current students, faculty, and staff for information about the environment at MIT, including academic, research, and service programs related to the environment, health and safety, and positive initiatives and compliance assistance. The web site went live in October 2002, integrating information about environmental research and teaching programs at MIT and EHS compliance and positive initiatives. After initial efforts to promote the web site, MIT received about 6,000 hits per month, divided roughly between 3,600 MIT users and 2,400 external to MIT. About 500 email queries were received during this past year, most of them concerning compliance issues. The EHS Office implemented Case Tracker to manage these queries allowing the efficient assignment and follow-up by appropriate EHS staff.
In addition, the EHS Office publishes a quarterly newsletter, EHS News & Views, disseminated to principal investigators and DLC staff, and in addition sends monthly updates to the EHS coordinators. A Tech Talk Report to the Community was distributed in March 2003 to mark the end of the second year of effort to develop the EHS-MS. The development of the system has been supported by informational and training presentations, beginning in July 2002, designed for DLC EHS coordinators. The EHS staff conducted a seminar during IAP 2003 to promote and help increase understanding of MIT's EHS management system.
Enhanced Delivery of EHS Services
Technology supports EHS services at MIT. Four web-based EHS regulatory training programs are now available. Submission and review of biological protocols and radiation authorizations are now conducted online, reducing the time from submission to final approval by approximately 20 percent, minimizing excessive paper generation, and increasing the efficiency of tracking and record keeping. OSHA-required injury and illness reports have been streamlined and made available online, increasing the level of compliance while reducing the burden on supervisors. The use of databases to document and perform trend analyses has been enhanced for several EHS programs including the routine inspections of food preparation areas; the validation of autoclave effectiveness; and the tracking of the results of annual (Cambridge Building Inspectional Services) and tri-annual (Factory Mutual Insurance Co.) building inspections to ensure facilities are in full compliance with life safety and fire codes. The hazardous waste online request service has been expanded from chemicals to include radioactive waste. Projects Tracker, a network-based solution used to track activities of EHS staff and communicate progress to supervisors, was implemented.
The Institute's laboratory biological waste disposal procedures were revised to eliminate the unnecessary and costly use of red/orange autoclave bags. Switching from the more expensive red bags to clear unmarked autoclave bags (and the resulting revision in handling procedures) was intended to prevent autoclaved laboratory waste from being mistaken for regulated medical waste. While retaining the appropriate steam sterilization of the lab waste and ensuring compliance with the state code, MIT was able to reduce disposal costs by more than $100,000 annually.
Supplemental Environmental Projects*
MIT's "Environmental Virtual Campus," a web-based compliance and good practices training tool for colleges and universities, won the 2003 Environmental Business Council of New England's Award for Outstanding Environmental Education. In a one-month period in July and August, the site received over 170,000 "hits" and saw visitors from more than 20 countries!
The Urban Focus Collaboration on Education sponsored three major programs with the City of Cambridge and the region this past year. In February, MIT hosted "The River is our Backyard: Water Quality in the Charles River," for students from the Morse Middle School. This involved research projects facilitated by MIT graduate students and faculty for Cambridge schoolteachers. In April, Cambridge Rindge and Latin 9th graders participated in MIT's "Alternative Energy Seminar: Power without Pollution." After a class-wide assembly, experts from MIT and a variety of nonprofit organizations lectured in nearly every physics class during the day. Finally, in May, Urban Focus sponsored a regional conference for science teachers in public and private schools in the region, the culmination of a year of research partnerships between MIT and Cambridge schoolteachers. Participants heard about MIT research as well as presentations on their fellowship research.
Positive EHS Initiatives and Collaborations
The following collaborative initiatives, involving many departments and programs at MIT, improved the safety and quality of life and reduced damage to the environment over the past year. These efforts benefit MIT, its neighbors and the region. Going well beyond regulatory requirements, these initiatives are intended to develop sustainable ways to safeguard the environment and the health and safety of the MIT community. Major initiatives include: construction and demolition (C&D) Debris recycling; silver and mercury recovery, CRT recycling and other pollution prevention activities; and recycling, with programs including special efforts on paper and commingles,yard waste and food waste composting; and a book reuse program. See the Environmental Programs Task Force annual report at http://web.mit.edu/environment/ for more information on these extensive Institute-wide activities.
Recycling
The EHS Office leads an EHS/Department of Facilities partnership created to coordinate efforts between departments to improve waste management and reduce costs. The first project in this partnership is an overhaul of all logistical processes related to the accumulation of trash and recycling. MIT's total trash fell by 224 tons, or 3 percent in 2002 compared to 2001. This decrease reflects both waste reduction initiatives implemented this past year and better recycling performance. Total tonnage recycled in 2002 increased by 336 tons (a 34 percent increase from last year) for a total of 1,329 tons. The recycling rate for 2002 was 16.2 percent, compared to a rate of 12.4 percent in 2001.
Support for EPA Charles River Initiatives
MIT has provided a boat for water sampling/cleanup activity. The EHS Office offers training to students interested in using the boat to pick up litter and trash in and around the river. A faculty member whose expertise is water resources is utilizing the boat to conduct investigations with his students. The EHS Office continues to work closely with EPA Region I staff to implement the Storm water Design Contest, which provides an opportunity to raise awareness about the Charles River Basin in the surrounding community.
Ergonomics
The EHS Office has collaborated with MIT programs and departments to reduce repetitive stress and other injuries and lost workdays. The intended outcomes are an increase in productivity, a reduction in medical and disability costs, and, more importantly, reduced pain and suffering by members of the MIT community. The Ergonomics Committee, an ad hoc collaborative effort involving the Libraries, Information Systems, Human Resources, Facilities, Lincoln Laboratory, the Whitehead Institute, and MIT Medical as well as a student representative, and led by the EHS Office, introduced a web based "stretch break" program, which encourages computer users to take breaks and guides them through a series of stretches. More than 600 computer users at MIT downloaded the program. A web-based training program has been selected and will be modified to meet MIT's needs.
DLCs with a high incidence of repetitive strain injuries collaborated with the EHS Office and Ergonomics Committee to develop programs to identify, correct, and prevent future injury. These involved detailed surveys and reviews of specific work sites and activities, the development of materials including PowerPoint presentations and videos, and the implementation of training.
Scope of EHS Office Activities
EHS Office activity metrics reflect the scope and intensity of services necessitated by both expanding research activity at MIT and a host of local, state and federal EHS regulatory requirements that relate to this research. As MIT's research volume increased by almost 12 percent in FY2002, EHS Office experienced at least a 10 percent or greater increase in activity. (See http://web.mit.edu/environment/ for detailed metrics concerning EHS activities.)
Many EHS activities fall into three major groupings:
- Surveys (typically involving measurements) to monitor the safe use of equipment and materials: Approximately 21,000 such surveys were implemented in 2002–2003 concerning equipment and safety practices related to the use of biological and radioactive materials, chemicals, recombinant DNA technology, and infectious agents.
- Inspections (involving detailed observations) conducted to verify the quality and compliance of EHS activity on campus and investigations initiated at the request of MIT programs and laboratories: Approximately 7,100 such inspections took place this past year encompassing the use and storage of hazardous waste, the use of ventilation hoods, and the use of recombinant DNA technology or infectious agents.
- Monitoring and prevention regarding a range of potential workplace hazards
and exposures: This includes chemicals, asbestos, blood borne pathogens,
workplace injuries such as repetitive strain injuries, and safe practices
during hot work. In 2002–2003, the EHS Office performed more than
3,800 lab analyses for chemical and biological materials, a 25 percent increase
over last year. The EHS Office facilitated more than 22,000 pick-ups of
chemical hazardous waste.
Approximately 500 asbestos abatement projects were monitored and completed, along with 260 asbestos surveys, representing a 10 percent increase in activity over last year. More than 6,000 faculty, staff, and students were trained concerning the use of biological or radiological materials, chemicals, hazardous waste, emergency response, and cutting and welding safety. The use of web-based training more than doubled from last year.
Regulatory Interactions
| OSHA | There was one complaint filed with OSHA. It was resolved with no citations issued. |
| NRC | Two routine inspections of the MIT Nuclear Reactor were conducted by the Nuclear Regulatory Commission. No notices of violations were issued. Two nonroutine inspections were also conducted at MIT, and similar inspections were conducted at other research reactors. The first was a high level NRC inspection to ensure implementation of Interim Compensatory Measures and subsequent issuance of NRC orders surrounding post-September 11 activities. The other involved technical specification review and procedural review for BNCT (Boron Neutron Capture Therapy) in the new Fission Converter Facility. |
| Cambridge Fire Department | Training for the Cambridge Fire Department Hazardous Materials Response Team was conducted for radiation safety, chemical and biological hazards, and air sampling techniques. Members of the EHS Office worked with the Fire Department on emergency planning procedures. Designated EHS staff were trained for confined space and high angle rescue. |
| Cambridge LEPC | Several members of the EHS Office participated as members of the Cambridge Local Emergency Planning Committee. The Institute participated in two disaster drills with the City. |
| Massachusetts DPH | A renewal application for MIT's broad scope license was prepared and submitted to the Massachusetts Department of Public Health's Radiation Control Program. The application qualified our current license as timely renewed, thus there were no interruptions in use of licensed material by our research community. The renewal application reflected recent changes in our organization, location, and personnel. The special nuclear materials license was amended to reflect the needs of a nuclear engineering project that utilizes enriched uranium, plutonium, and other transuranium isotopes. The Massachusetts DPH Radiation Control Program conducted a telephone inspection of the MIT and WIBR security programs in October 2002 as a result of the 9/11 terrorist attacks. |
| In April 2003, the Massachusetts DPH notified MIT that it had inspected the Johnson Athletics Center Ice Skating Rink and found certain violations. EHS Office staff worked with the EHS Coordinator for the Division of Student Life and the Skating Rink staff to correct the violations and notified DPH of these actions. | |
| Mass. DEP | The EHS Office interacted with the Massachusetts Department of Environmental Protection regarding many of MIT's 81 MCP (contaminated) sites, resulting from the location of our campus on urban fill. |
| MWRA | The EHS Office collaborated with the Department of Facilities to secure a permit from the Massachusetts Water Resources Authority for wastewater discharge for 500 Technology Square. |
More information about Environment, Health and Safety can be found on the web at http://web.mit.edu/environment/.
The projects addressed in this section were undertaken by MIT in connection with the settlement of an enforcement brought by the US Environmental Protection Agency and the US Department of Justice for alleged violations of the Federal Clean Water Act, The Clean Air Act, and the Resource Conservation and Recovery Act; there is no allegation of any actual harm to the environment.