Environmental Health and Safety in Higher Ed – How institutions can implement internal controls to protect their community
Publication Date: August 12, 2022
When you step on campus do you think about who and how your campus community is protected from the myriad environmental hazards potentially lurking in building, labs, and water fountains?
Colleges and universities have various environmental risks and events (e.g., water and air pollution, biohazardous materials and fire hazards) that must be managed daily. An institution’s Environmental Health and Safety (EH&S) function serves an essential role in supporting the mission of the institution with teaching, research, and service by providing safety evaluation and monitoring services to the campus community as a whole. EH&S works to ensure internal controls are formalized, comprehensive, and working effectively by performing a variety of activities including, but not limited to, laboratory inspections, monitoring existing hazards, identifying potential hazards, and reducing safety hazards.
In addition to the increasing safety concerns resulting from the 2020 global pandemic, there is an opportunity for Internal Audit to provide operational reviews of the current environment’s risk mitigating controls.
What is EH&S?
Environmental Health & Safety (EH&S) is the science and practice of preventing human injury and promoting well-being[1]. EH&S is a term used by laws, rules, regulations, professions, programs, and workplace efforts to protect the health and safety of the campus community. Other common ways to abbreviate EH&S are HSE or EHS&Q where the “Q” stands for Quality.
EH&S Responsibilities and Reporting Structure
EH&S functions are often the contact points for regulatory agencies and emergency response actions. EH&S is often responsible for educating the campus community on standards applicable to the institution.
EH&S is commonly tasked with:
- Serving as the oversight and authority for EH&S compliance.
- Implementing health and safety policies and procedures.
- Conducting inspections and monitoring procedures to identify existing potential hazards.
- Performing routine audits to measure compliance with regulations.
- Measuring and improving environmental health and safety performance across campus.
- Providing and supporting incident responses.
EH&S reporting structures look different at each institution. Some common reporting lines include:
- Campus Safety
- Campus Operations
- Facilities
- Risk Management
- Research
Risk Universe
Just as institutions differ in reporting structure, an institution’s EH&S risk universe will differ as well. The most important thing to remember before you audit your institution’s EH&S function is to consider the environment and what risks may be more important than others. For example, a large research institution with a medical school may present risks such as biohazardous chemicals or radioactive materials, while an institution located in the southeast may be at a high risk for a potential weather-related hazard. Below are a few types of risks to consider based on your intuition’s academic, risk and geographic environment.
Rules, Regulations, Polices and Procedures
EH&S is a highly regulated area with a number of laws and standards falling under:
- Environmental Protection Agency (EPA)
- Occupational Safety and Health Administration (OSHA)
- International Fire Code (IFC)
Specific topical areas may include, but are not limited to:
- Biohazardous materials in research and instruction
- Confined space entry
- Contractor safety
- Eye protection
- Fall protection
- Occupational exposure to hazardous chemicals
- Personal protective equipment, including COVID-19 exposure
- Radioactive materials
- Waste disposal
Since there are so many regulations to consider we recommend that you begin by reviewing your institution’s policies and procedures, as your EH&S function has likely already created internal controls for most key regulatory requirements.
Considerations for the Internal Audit Plan
Internal Audit can support the institution to better understand the design and effectiveness of the compliance framework, including internal controls, oversight, training, authority and applicable regulatory requirements. In addition, Internal Audit can perform testing procedures to determine the efficiency of controls in hazard identification, worker participation, laboratory safety and injury/illness prevention.
Common audit activities are often related to:
- Reviewing documentation (e.g., organizational charts, procedures, workflows, job descriptions, etc.) to understand current procedures.
- Conducting interviews with key stakeholder to better understand key processes and practices.
- Evaluating operations and internal controls in place.
- Performing testing procedures to determine the effectiveness of controls.
Conducting testing procedures is one of the most valuable ways to review and assess the current compliance environment at your institution and to evaluate the current internal control process for remediating EH&S related risks. For example, performing a walkthrough of campus research laboratories typically provides Internal Audit with informative observations or enhancement opportunities. While conducting the walkthrough, a checklist is recommended to encourage documentation of all findings. Taking pictures during this process is a great way to provide key process owners and leadership with significant supporting documentation.
Key checklist questions include:
- General work environment
- Laboratory safety plans
- Safety equipment
- Security
- Labels and signs
- PPE
- Chemical inventory waste and storage
Why is auditing your institution’s EH&S function important?
If there are instances of noncompliance with key regulations, the safety of the campus community may be at risk. The institution may also be assessed for financial, regulatory, health and safety damages. For example, without wearing proper PPE during research procedures, a student is at risk for severe injury or death. Further, by not labeling and disposing biohazardous waste correctly, the waste may become the source of infections. Potential harm could be carried to other students in the room through air pollution, toxic exposure, chemical burns or radiation burns.
Next steps
The EH&S function is responsible for providing a strong foundation of safety through a commitment to compliance and overall protection. Many individuals within the campus community may not think about EH&S, however everyone does appreciate a safe environment. Internal Audit can help provide operational reviews of the current proactive, monitoring and detective controls that mitigate risks. Consider adding a review of your EH&S function to your audit plan.
References
[1] Definitions of Environmental Health | National Environmental Health Association: NEHA