Safety Policy

I.            Scope

This policy applies to all faculty, staff, students, researchers, contractors, and visitors affiliated with William & Mary. Each individual is responsible for conducting work, research, instructional courses, and activities in a manner that will not adversely impact themselves, others, the surrounding community, university property, or the environment.

II.            Purpose

William & Mary is committed to providing a healthy, safe, and compliant working, learning, and living environment for our campus communities.  This Whole University Policy establishes our leadership's commitment to organizational excellence, roles and responsibilities of our campus community members, and accountability for fostering a strong safety culture, while ensuring compliance with applicable federal, state, and local regulations; industry standards; and university requirements pertaining to safety and health.

III.            Definitions

Corrective action plan means identifying the steps to take to identify, address, and prevent the recurrence of a problem or non-conformance.

Hierarchy of controls means prioritizing hazard control strategies in the following order: elimination, substitution, engineering controls, administrative controls, and personal protective equipment, emphasizing that controls addressing hazards at their source are more effective than those relying on human behavior.

Medical surveillance program means the systematic monitoring of workers who are exposed, or potentially exposed, to occupational hazards, with the goal of preventing work‑related illness and injuries.

Risk-based assessments are a systematic approach to evaluating hazards or issues by prioritizing them according to the level of risk they pose, based on the likelihood of occurrence and the severity of potential consequences, ensuring decisions are driven by risk rather than treating all hazards equally.

Stop work authority means the ability to immediately halt work when a condition or behavior poses an imminent risk to people, property, or the environment exists.

Visitors are individuals not enrolled as students, faculty, or employees of the university who are on campus temporarily for personal, academic, or business-related reasons.

Volunteers are individuals who provide services or assistance to the university without financial compensation and who perform assigned duties under the direction or supervision of a university employee.

IV.            Roles and Responsibilities

A. Environmental Health & Safety Office

The Environmental Health & Safety Office (EH&S) is responsible for maintaining a comprehensive program that includes training, consultation, and inspections to protect the health and safety of campus community members during university-sanctioned activities. EH&S staff provide support to evaluate and measure hazards and ensure compliance with regulatory and university requirements. Responsibilities include:

• Ensuring written policies, procedures, and training materials for applicable health and safety regulatory standards are established, remain current, and are made available to the campus community.
• Supporting the identification, assignment, and compliance of mandatory safety training to support operations, research, teaching, and sanctioned campus activities.
• Maintaining up-to-date information online to ensure access to health and safety requirements, technical guidance, and other resources
• Facilitating communication with the campus community to support adherence with regulations, policies, programs, and standards.
• Providing routine and unannounced inspections and audits:
  • To monitor for compliance and to identify risk hazards
  • To provide risk-based assessments during inspections, facilitating timely corrective action
  • To implement necessary actions, including escalating notifications and enforcement for non-compliance and exercising Stop Work Authority in imminent hazard situations
  • To make recommendations for best practices and compliance with safety standards and regulations across university operations
• Working with individuals to develop reasonable corrective action plans
• Providing a process for responsible parties to update the status of issues requiring corrective action
• Conducting follow-up inspections within 30 calendar days to verify high-risk issues have been addressed
• Providing periodic reporting to university leadership to communicate occurrences, trending, and the state of compliance of the universitProviding a medical surveillance program when required for university employees or students
• Acting as the primary liaison with local, state, and federal officials regarding codes, regulations, and reporting requirements related to fire safety, laboratory safety, occupational health, and occupational safety
• Participating in and supporting in the efforts of compliance and safety committees
• Managing or assisting hazardous, biohazardous, radioactive, and universal waste streams

B. Facilities Operations

Facilities Operations is responsible for creating, maintaining, and continuously improving the university’s physical environment to enable excellence in teaching, research and public service.  Facilities Operations’ responsibilities include:

• Maintaining facilities and equipment within acceptable standards and compliance requirements
• Ensuring engineering controls actively used in buildings are maintained within compliance requirements or standards, marking units out of service that are not functioning adequately
• Responding in a timely manner to facilities-based issues creating a health and safety concern requiring corrective action

C. Departments and Department Chairs

Departments have primary responsibility to self-monitor for hazard identification, hazard mitigation, and compliance.  Research and academic department chairs and faculty are responsible for reviewing instructional activities, ensuring safety and health risks for students, staff, and participants are identified and mitigated.  Responsibilities include:

• Reviewing existing, revised, and new courses and associated activities for health and safety hazards, mitigation, and compliance
• Addressing safety and health considerations with new faculty and faculty with newly assigned curricula
• Ensuring involvement with applicable compliance committee(s) and adherence to the committee requirements and review process
• Seeking specialized expertise consultation as needed
• Facilitating resources for risk mitigation and compliance

D. Persons Responsible for Directing and Supervising Work

Persons responsible for directing and supervising work, such as, but not limited to, supervisors, instructors, faculty, and principal investigators (PIs), play a key role in oversight and instruction of employees, students, visitors, and work processes. These individuals have significant influence over the prioritization of safety and provide leadership in their respective areas. Responsibilities include:

• Maintaining safe conditions within area of responsibility and for the university
• Identifying hazards and ways to mitigate risk through the hierarchy of controls:
  • Elimination or substitution
  • Engineering controls
  • Administrative and work practice controls
  • Personal protective equipment
• Reviewing hazards and risk mitigation regularly and when conditions change
  Providing training aligned with hazard and regulatory requirements and establishing processes with documentation to verify compliance
• Ensuring employees, students, visitors, volunteers, and contractors have completed the necessary training to safely perform assigned tasks
• Ensuring required safety equipment, devices, and protective equipment are provided and properly used, including the establishment of standard operating procedures
• Coordinating or conducting inspections to detect potential hazards and address deficiencies
• Reporting all accidents and incidents, conducting prompt investigations, defining root causes, and implementing necessary corrective actions per current university procedures
• Implementing prompt corrective action when unsafe conditions are observed or reported and prompt disciplinary action when plans, policies, and procedures are not followed
• Responding in a timely manner to address safety complaints and non-compliance, as well as mitigating unsafe conditions
• Immediately responding to calls and emergencies within assigned areas of responsibility, serving as a subject matter expert, and coordinating with university and external emergency responders

E. Employees and Students

Employees and students are to be made aware of relevant safety requirements by their associated instructor, faculty, PI, supervisor or other persons responsible for directing or supervising work.  Responsibilities include:

• Complying with applicable university environmental health and safety policies, programs, and regulatory requirements
• Completing required training in a timely manner, by established deadlines
• Applying and complying with work practices learned in training
• Wearing and using personal protective equipment
• Promptly reporting all unsafe conditions or acts to a supervisor, PI, instructor, faculty or EH&S
• Immediately notifying their supervisor, instructor, PI, or the person responsible for directing and supervising their work of any personal injuries, illnesses, or incidents occurring on university property or while conducting university business
• Providing corrective action updates when safety compliance concerns have been identified
• Cooperating when inspections and audits are conducted

F.  Contractors, Volunteers, and Visitors

Third parties, including contractors, volunteers, and visitors, must act in a manner that does not endanger themselves or others while on university properties or while conducting university business or activities.  Responsibilities of individuals engaged in official university business on campus include:

• Complying with applicable university and regulatory requirements
• Completing training programs designated by their employer applicable to work being conducted for university business
• Completing any designated William & Mary training
• Wearing and using personal protective equipment designated by their employer
• Promptly reporting all unsafe conditions or acts to the university sponsor or Contract Administrator
• Immediately notifying the university sponsor or Contract Administrator of any personal injuries, illnesses, or incidents occurring on university property or while conducting university business

V.            Reporting, Enforcement, and Accountability

Non-compliance with this policy may result in disciplinary action up to and including termination or referral to Student Affairs for student non-compliance.   Retaliation is prohibited against any campus community member who brings forth a well-intentioned concern, seeks clarification, or participates in an investigation. 

VI.            Authority & Amendment

This policy was approved by the Executive Vice President for Finance and Administration on March 30, 2026. The Director of Environmental, Health & Safety Office is authorized to make minor or technical amendments in response to legal or regulatory developments.

This policy shall be reviewed every 3 years or following major organizational, legal, or regulatory changes.