EHS External Audit update

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What is the EHS External Audit?

After failing an EPA inspection approximately 5 years ago, MIT was required to implement a plan to get the institute up to code, so to speak. The Institute was given a strict time frame in which to implement all necessary changes. These changes have been implemented in a stepwise fashion and involved a restructuring/consolidating of the EHS departments, as well as implementation of instute-wide training systems/protocols, better systems for distributing Safety information (EHS website, EHS Representatives, etc), and a framework for conducting regular inspections. Inspections are conducted at three levels. Level I inspections are conduct by the lab EHS rep. (Heather) weekly and have been in place for approximately 2 years. Level II inspections are conducted twice a year by John Fucillo and other EHS members (sometimes planned, sometimes surprise) and have been occuring for 1 year now. Level III inspections are conducted by people outside of the institute and this is what is meant by an external audit. MIT is to be audited in the Spring of 2006 (I believe by the EPA). In preparation for this, they are bringing in a group of auditors to do a pilot audit - this is the External Audit that will be occuring this fall. This is the big finale for all of the changes that have been occuring since the failed inspection.

What is the EHS Management System?

As I understand it, the EHS Management System is a broad term used to describe all of the policies/procedures MIT now has in place to record/keep track of what we are doing to meet EPA standards. This incldues the online training system, as well as the Level I, II, and III inspections, and space Registrations (tracking the hazards contained on a per room basis, as well as emergency contacts), etc.

What you need to know:

  1. The audit will be occuring in early November.
  2. This audit is a pilot that is being commissioned by MIT in preparation for the real audit which will be occuring in Spring 2006.
  3. You can prepare for a level III inspection in the same way you prepare for the biannual Level II inspections that are conducted by John Fucillo (and other EHS representatives). In other words, make sure your training is up to date, clearly label all chemicals, tightly seal all containers of liquids with caps or parafilm, biohazard labels on sharps containers, no food/drugs/chapstick visible in lab space, tidy SAAs, etc.
  4. Although the inspectors can enter any lab/space at MIT they want to, they will not be able to inspect the entire institute, so our lab may not be visited.
  5. If the inspectors do tour our lab, answer their questions to the best of their ability, you will not be penalized for not knowing an answer. If you do not know the answer, you might tell them who you would contact or what you would do to find out the answer (demonstrate that you know the resources that are available to you).
  6. UROPs should find their student advisor to help them answer any questions they may be asked.

For more information, please see the brochure put together by EHS, which is posted in the elevator or can be found on the wiki at The Auditors are coming to MIT - Audit FAQ.