Responsibilities of the Director of Environmental Health and Safety

Federal Law

This law required DHS to establish risk-based performance standards for security of chemical facilities. The rule requires covered chemical facilities to prepare Security Vulnerability Assessments (SVAs) that identify facility security vulnerabilities. The rule also requires covered chemical facilities to develop and implement Site Security Plans (SSPs) that identify measures that satisfy the identified risk-based performance standards. It also allows certain covered chemical facilities, in specified circumstances, to submit Alternate Security Programs (ASPs) in lieu of an SVA, SSP, or both. In addition, the rule contains associated provisions addressing inspections and audits, recordkeeping, and the protection of information that constitutes Chemical-terrorism Vulnerability Information (CVI). On Nov. 20, 2007 DHS published the final rule, a revised Appendix A with the final list of chemicals covered by the new law.  The final appendix, unlike the proposed appendix, does not trigger reporting obligations based on possession of an STQ of "any amount." This change was due in part to comments upon the reporting burden of the interim rule.

US Army Medical Research and Material Command

Task:

Facility Safety Program Reviews and Approvals (every 5 years) - Develop a Facility Safety Plan that summarizes the university's safety program for affected research program. 

Date last renewed/submitted: 06/08
Next due date: 06/13

D.C. Department of Health, 20 DCMR 5601, Tank Registration
Task:
Underground Storage Tank fees - Register all underground storage tanks and pay a registration fee before depositing a regulated substance into the tank. 

Date last renewed/submitted: 11/30/08
Next due date: 11/30/09

D.C. Department of Health, 20 DCMR 6703.3, Financial Test of Self-Insurance
Task:
Underground Storage Tank financial assistance letter -  The chief financial officer must sign, within 120 days of the close of each financial reporting year, a letter of assurance to demonstrate that the university meets the financial test under 20 DCMR 6703.2(a) or (b).

Date last renewed/submitted: 9/30/08
Next due date: 9/30/09

Resources:

Campus Safety Health and Environmental Management Association (CSHEMA) website provides information sharing, continuing education, and professional connections to individuals with environmental health and safety responsibilities in educational communities.

MIT Environmental Virtual Campus website provides EHS departments with campus environmental management practices, including both regulatory compliance and non-regulatory "green" environmental practices.  Especially relevant is the information regarding underground storage tanks. 

updated 8/13/09 by JP to add policies
updated 11/10/09 PTH