3.4 Potential Hazards

Regulatory Activities and Materials Assessment and Control

On this page:
3.4.1 Standard Operating Procedure (SOP) Assessment
3.4.2 Monitoring and Measurements
3.4.3 Engineering Controls

The Potential Hazards Inventory is used by the DLC in coordination with the EHS Office as a starting point for identifying where hazard/regulatory assessments may be needed. Hazard/regulatory assessments are performed to determine what controls are needed to reduce, eliminate or mitigate a hazard, and comply with regulatory requirements. Hazard/regulatory controls are addressed in Section 5.1, Hazard Assessment and Control.

EHS Coordinators make initial hazard/regulatory assessments using guidance provided by the EHS Office. The EHS Lead Contact assists the EHS Coordinator as necessary, and generally takes primary responsibility for more complex hazard/regulatory assessments. If the assessment determines that controls are needed to reduce or eliminate the hazard or to meet MIT's EHS standards and/or regulatory requirements, recommendations are made to the appropriate parties, such as the DLC EHS Coordinator, PI/Supervisor, and/or Department of Facilities to address the hazards and requirements.

3.4.1 Standard Operating Procedure (SOP) Assessment

In some cases, a hazard assessment may determine that a Standard Operating Procedure (SOP) is needed to prevent potential regulatory violations or EHS incidents. This process of determining when it is necessary to create an SOP is, itself, documented in an SOP.

In addition, MIT has defined a uniform format and procedure for developing, approving, and implementing SOPs to ensure consistency and quality across all efforts.

The standard format and a list of EHS-related SOPs are available online at mit.edu/environment/ehs/topic/sops.html

3.4.2 Monitoring and Measurement

MIT conducts a variety of monitoring and measurement activities of workplace conditions to sustain compliance, protect student, staff, employee, and community health and safety, and to safeguard the environment. Because monitoring is often conducted to measure exposure to a hazard, monitoring and measurement activities are an important part of the hazard assessment process. Different groups at MIT perform monitoring and measurement activities, as described below.

3.4.2.1 Department of Facilities

The Department of Facilities conducts or oversees monitoring performed to assure compliance with some environmental regulations that relate to facilities operations such as:

• wastewater testing to demonstrate compliance with the terms of MIT's MWRA permit;
• monitoring required to comply with MIT's Title V air emissions permit, including continuous stack testing conducted at the Central Utility Plant;
• tracking of on-site electrical generator operations by recording operating time or gallons of fuel used, depending on the generator;
• keeping records of the gallons of paint used at the paint booth;
• checking secondary containment areas at above ground fuel oil storage tanks;
• monthly testing of emergency backup diesel generators;
• tracking refrigerant usage for chiller systems.

3.4.2.2 EHS Office

The technical programs and service teams within the EHS Office conduct a wide variety of initiatives and programs that involve monitoring and measurements to sustain regulatory compliance and protect human health and the environment. These are described below:

• The Environmental Management Program (EMP) collects data on the types and quantities of hazardous waste generated at the Institute. This data is assessed to identify hazardous waste and other environmental training and program development and compliance oversight, and positive and negative trends and changes, and to show any impacts of pollution prevention initiatives. EMP also compiles information on automobile trips made by MIT staff and students to prepare the annual Rideshare report to the Massachusetts Department of Environmental Protection (DEP); collects inventory data on certain chemicals to prepare the SARA Title III submittal required by the EPCRA regulations; and others.
• The Industrial Hygiene Program (IHP) conducts monitoring and measurements to assure compliance with OSHA regulations for exposure to potentially hazardous materials, such as asbestos, formaldehyde, beryllium and lead. Asbestos monitoring is often performed in conjunction with building renovations to document employee protection, and proper management of asbestos waste. Chemical exposure monitoring is carried out as needed or requested. Specific examples of chemical monitoring initiatives, in addition to the programs mentioned above, include monitoring lead levels in the air at the firing range, and monitoring carbon monoxide and nitrogen dioxide levels at the ice skating rink after operation of the ice resurfacing vehicle.

Continuous monitoring systems are also in place where certain toxic gases are in use. If measurements exceed a pre-determined level, an alarm is triggered and the building is evacuated. There is a set procedure to follow to evaluate the situation before re-entry is permitted.

Noise monitoring is performed under MIT's Hearing Conservation Program.

IHP conducts a laboratory ventilation monitoring program for fume hoods and local ventilation systems. This program includes both an initial evaluation and ongoing measurements to assure systems are operating as designed, and their operation is sufficient to control the hazards.

• The Safety Program (SP) monitors OSHA-defined confined spaces to determine if they are safe for entry by workers. The Safety Program also conducts project evaluations for the Hot Work Permit Program, which may include a monitoring component. The Safety program also evaluates work areas for many traditional industrial safety issues such as emergency egress, emergency action planning, and fall protection.
• The Radiation Protection Program (RPP) has extensive monitoring programs to assure compliance with applicable regulations and MIT's licenses for storage and use of radioactive materials. These programs include radioactive protocols, training, program development and compliance, routine testing of laboratory surfaces for contamination, radiation worker monitoring of external dose through the use of dosimeters, potential internal dose through bioassay and whole body scans, effluent concentrations for volatile radionuclides, and environmental monitoring at designated local and perimeter sites. The Radiation Protection Program collects and manages all radioactive waste generated at the Institute and files an annual report on the quantities and types with the applicable regulatory agencies.
• The Biosafety Program (BSP) oversees a monitoring program for Biological RDNA select agent protocols, training, program development and compliance, and to assure adequate function of autoclaves used to sterilize biological waste, and research and/or medical materials and equipment. The Biosafety Program also conducts water quality monitoring of the Institute's swimming facilities on a routine basis, and conducts monitoring for mold as part of indoor air quality investigations. As requested, Biosafety staff will monitor for bacteria on surfaces or in the air as a part of epidemiological investigations, and inspect food preparation areas for safe and healthy operations.
• Organization Service Team

This team provides oversight to assure EHS-MS organizational structure is implemented and maintained, and facilitates the DLC EHS Coordinator and EHS Lead Contact relationship through periodic meetings and communications. This team also oversees the PI/Space Registration process. This team also provides advice and direction regarding professional development needs of the EHS Office Staff and EHS Coordinators.

• Inspection/Audit Team

This team provides oversight to implementation and maintenance of the inspection and audit program.

• Training and Development Service Team

This Team provides oversight for all EHS training needs, assists in the development of new EHS training courses, assists in the development and update of the Training Needs Assessment, and tracks the maintenance of the database used for managing official training records.

• Emergency Preparedness and Response Service Team

This Team provides oversight for the 24-hour emergency response services provided by the EHS Office; the coordination of the EHS responses with MIT's Emergency Response Group, and oversight of the emergency response follow-up process.

• Laboratory and Facility Design and Construction Review Services Team

This Team formally collaborates with the Department of Facilities and DLCs to assure that EHS requirements and concerns are addressed systematically in new construction and renovation projects at MIT.

• Technology Service Team

This Team has oversight for the development and maintenance of the technology needed to support EHS activities, including EHS web resources, the EHS Office intranet, and all databases associated with the EHS-MS. This team may continue in the EHS Office or its service maybe provided by a central Information Services and Technology group or a contractor over time.

• Communications Service Team

  This Team works to promote effective and timely communication among all the EHS stakeholders across the Institute and MIT community to improve EHS performance. Central to this objective is the development and oversight of the EHS Communication Plan and EHS Office Newsletter.

• Regulated Waste Service Team
  
  This Team coordinates activities related to chemical, biological, radiological and universal waste at the institute. It provides oversight of compliance issues and identifies and recommends opportunities for continuous improvement and waste reduction.

3.4.3 Engineering Controls

When the hazard assessment process indicates a potential EHS regulatory impact, an evaluation to implement engineering controls to prevent or reduce workplace exposures or minimize compliance issues is conducted. These controls are designed to be part of the space (for new spaces) or retrofit (for existing spaces). Examples of engineering controls include: fume hoods, secondary containment for tanks and containers, neutralization systems for wastewater discharges, and others. These controls are typically implemented or overseen by the Department of Facilities, the EHS Office, or both, in conjunction with external consultants and/or contractors.