The MIT EHS policy, adopted by the MIT Academic Council December 11, 2001, signals MIT's commitment to environmental, health, and safety stewardship in research, teaching and operations. The Policy was developed by an Ad Hoc EHS Subcommittee of MIT's EHS Council. Co-chaired by the Vice President for Research and Associate Provost and Managing Director for Environmental Programs/Senior Counsel, this subcommittee includes senior faculty and administrators. All of MIT's EHS activities - compliance, good practices and positive initiatives - are directed toward achieving the goals described by the policy.

MIT ENVIRONMENTAL, HEALTH AND SAFETY POLICY

MIT is committed to excellence in environmental, health and safety stewardship on our campus, in the larger community of which we are a part, and globally. This long-held commitment is demonstrated through our contributions to environmental, health and safety research and teaching, as well as through our institutional conduct.

MIT is committed to being at the forefront of large academic research institutions:

• in minimizing, as feasible, the adverse environmental, health and safety impacts of our facilities, activities and operations to protect human health and the environment (which is one way we define sustainability);
• in achieving and maintaining compliance with federal, state and local environmental, health and safety laws and good practices in all of our departments, laboratories, research centers, facilities and operations;
• in achieving a high standard of institutional accountability for environmental, health and safety stewardship, while maintaining the independence of research and teaching;
• in providing educational opportunities to our students and other members of our community, to reinforce the values exemplified in this policy and influence their activities during and after their tenure at MIT; and
• in measuring and continuously improving our environmental, health and safety performance.

GUIDING PRINCIPLES IN SUPPORT OF MIT'S EHS POLICY

General

1. The comprehensive treatment of the environment, health and safety (EHS) reduces duplication of effort, fosters a consistent treatment of these subjects, all of which are intended to protect human health and the environment, and produce the most effective and efficient approach and system for MIT.

2. The integration of compliance with initiatives to minimize the EHS impacts of MIT's activities, facilities and operations reduces regulatory burdens and reap greater EHS benefits.

3. The independence of research is essential, and, consequently, a proper balance must be achieved between local and central roles. Existing organization and positions are used to the maximum extent possible to achieve EHS stewardship initiatives, good practices, and compliance, in order to avoid unnecessary layering and creation of bureaucracy.

4. Opportunities are identified and taken to reduce the production of wastes and the use of toxic materials, to prevent pollution, and to conserve and reuse resources, as feasible, because these opportunities will satisfy regulatory waste minimization requirements, reduce regulatory burdens and reap greater EHS benefits.

5. Opportunities to educate the MIT community on means of reducing waste and toxic use, preventing pollution, and conserving and reusing resources are used whenever possible.

Environmental, Health and Safety Management System

1. The Institute performs its commitments, in part, through the design and implementation of a comprehensive EHS management system ("EHS-MS") that represents best practices and is a model for MIT and other academic research institutions.

2. The EHS-MS is distinguished by its integration of compliance with environmental, health and safety stewardship initiatives, educational programs and research.

3. The EHS-MS is distinguished further by its use of automation and systems integration to preserve the independence of research, while providing the necessary information to the EHS Office (comprised of the EHS service groups) on activities and materials in departments, laboratories and centers ("DLCs"), to ensure institutional oversight and accountability.

4. The EHS-MS automated and web-based systems are integrated with the Institute's financial, purchasing, sponsored programs, human resources, space planning and other information systems for these purposes.

5. The EHS-MS's automated systems are compatible with the Institute's existing primary automated systems to the greatest extent possible, and are designed and implemented to be as simple and straight-forward as possible for front-end users and to be sustainable over the long term.

6. Where the EHS-MS calls for uniform content (e.g., of training materials or audit checklists) and standard operating procedures, flexibility in delivery and implementation will be maintained to the greatest extent possible, to allow each DLC to deliver the uniform content and implement the standard operating procedures in a manner that will be most effective and efficient for that DLC. The EHS-MS provides for MIT EHS Office's support and oversight to achieve base standards.

7. The Institute Council on Environmental, Health and Safety is responsible for overseeing the implementation of the EHS-MS. This Council works closely with EHS Headquarters (EHSH) in performing this oversight function. The EHS-MS is reviewed periodically by the Institute Council on Environmental, Health and Safety, and DLCs, as well as by EHSH and EHS Office, to identify any improvements that are warranted in order to ensure that the EHS-MS is as effective and efficient as possible for MIT. The EHSH and EHS Office follows up on any recommendations for improvements and communicate with the reviewers concerning the actions taken or not taken and why.

Roles and Responsibilities

1. All constituents of the MIT community are engaged collaboratively in helping MIT to perform these commitments. Collaboration with the larger community and outside experts occurs, as appropriate, to establish a broad environmental, health and safety context for MIT's policy and practices.

2. Primary responsibility for EHS compliance and good practices must lie in DLCs in order to preserve the independence of research and teaching, to preserve the associated control by DLCs over their primary research and teaching activities, and to minimize any unnecessary, in-laboratory activities of the EHS Office. Within each DLC, appropriate individuals assume clear roles, responsibility and accountability for implementing the EHS-MS. DLCs manage performance of these responsibilities.

3. The EHS Office provides the service, resources and support that DLCs need to achieve EHS good practices and compliance. This means that the EHS Office is easily accessible and responsive to DLCs, and that the EHS Office provides resources for regulatory training, auditing, regulatory updates, and other resources in forms easily usable by DLCs. The EHS Office also assigned staff as liaisons to particular DLCs to foster the establishment of good working relationships and trust between DLCs and the EHS Office. Where there is a choice, the EHS-MS is designed to minimize labor burdens on DLCs through the use of automation or other means.

4. The EHSH and EHS Office is responsible for coordinating collaborative EHS stewardship initiatives among all constituents of the MIT community.

5. The EHS Office also is responsible for Institute EHS oversight and accountability. The EHS Office exercises this oversight responsibility in the spirit of service and support, not as the "EHS police" and is sensitive to the confidentiality of research. The EHS Office maintains and manages relationships with regulatory authorities and provides legal guidance on compliance and collaborate with DLCs to prevent violations through MIT's Legal Counsel, and by supporting training, auditing and the provision of compliance, stewardship and good practices resources.

6. Objectivity, avoidance of conflicts of interest and accountability is achieved through an organizational infrastructure in the DLCs, in the EHS Office and at MIT overall, that clearly delineates EHS responsibilities and establishes consequences for both good and poor performances; through the Managing Director for EHS Programs' reporting relationship to the Executive Vice President, the Provost and the Chancellor. MIT's Auditing Committee shall also have an oversight role.

7. Ideas for achieving better EHS results than can be achieved under existing regulatory requirements may be reviewed by the EHSH , EHS Office, Institute Council on Environmental, Health and Safety, and DLCs to determine whether they should be pursued with regulatory authorities.

Resources

1. Appropriate and necessary resources are provided to DLCs and the EHSH and EHS Office to achieve MIT's EHS goals and perform our commitments. Realistic assessments of resources needed for MIT's EHS-MS, including resources needed in DLCs and in the EHS Office, are undertaken periodically, taking into account the capacity of existing staff and systems, the effects of EHS responsibilities on DLCs' ability to pursue primary teaching, research and administrative imperatives, and what is affordable and feasible for MIT. EHS resource needs assessments are part of the annual and long-term operating and capital budgeting process.

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