The University of Memphis

Occupational Safety and Health Program


Issued: September 18, 2017
Responsible Official: President
Responsible Office: Vice President for Business and Finance

Policy Statement

Policy Statement

An Occupational Safety and Health Program is hereby established to help ensure that all University employees are furnished with a place of employment that is free from recognized hazards that are causing or are likely to cause death or serious injury or harm. In addition, this program will promote a safe and healthful working environment for all University employees.  Occupational Safety and Health Standards for the State of Tennessee are adopted as the minimum safety and health standards for the University of Memphis.

Administrative officials, department chairs, and directors are responsible for ensuring compliance with this policy.

The Vice President for Business and Finance shall be responsible for the development and publication of procedures necessary to administer the Occupational Safety and Health Program.



The Federal Occupational Safety and Health Act of 1970 was enacted to improve the general working environment and to provide, as far as possible, every working person in the nation safe and healthful working conditions. This Act provided an opportunity for the various states to develop their own Occupational Safety and Health Programs. In Tennessee, this was accomplished by the Tennessee Occupational Safety and Health Act of 1972.

The primary objective of the University of Memphis Occupational Safety and Health Program is to promote a safe and healthful working environment for all University employees. This is accomplished by integrating an effective safety and health program into the normal operation of campus activities. A vigorous program of education and evaluation shall be undertaken to, so far as possible, identify and eliminate conditions or actions that create an unsafe environment. The effectiveness of this program will depend largely upon the cooperation and active participation of the people it protects and serves.

Occupational Safety and Health Standards for the State of Tennessee are adopted as the minimum Occupational Safety and Health Standards for the University of Memphis. In keeping with these standards, employees shall receive notification of their rights and duties through the State of Tennessee Occupational Safety and Health Poster. Employees shall be entitled to review the annual safety and health reports and to protest any portions deemed to be inaccurate or which fail to portray real and existing conditions.


Related Forms


Duties and Responsibilities


The following general duties and responsibilities are not designed in any way to alter or detract from other assigned duties and responsibilities. Additional responsibilities are as listed under various subsections of this procedure.

1.  The Director of Environmental Health and Safety shall monitor and provide administrative guidance for the overall safety program.

2.  Administrative officials, chairs, and directors of activities shall:

  • Provide a positive reference concerning the importance of the total safety program through individual interest, enthusiasm, concern, and support;
  • Ensure that employees comply with Tennessee Occupational Safety and Health Standards as related to their areas of responsibility;
  • Assess risks within their respective areas of responsibility;
  • Ensure identification of hazardous operations within their areas of responsibility;
  • Ensure that employees are informed of conditions that could result in their exposure to radiation, toxic materials, or other hazards in the performance of assigned jobs;
  • Establish an in-house training program to instruct employees in safety regulations and avoidance of unsafe conditions as applicable to their individual work environments. Training shall include instruction in the safe handling and use of equipment, materials, and personal protective equipment required for employees; and 
  • Acquire, maintain, and require the use of safety equipment, personal protective equipment, and other safety devices as needed.

3.  Supervisors, residence hall advisors, and Director of Residence Life shall:

  • Ensure that employees follow safe work practices and procedures and comply with applicable Tennessee Occupational Safety and Health Act standards in all phases of their work;
  • Assess risks within their respective areas of responsibility;
  • Initiate and follow-up on action to eliminate hazards and/or unsafe conditions within their individual areas of responsibility;
  • Ensure that appropriate personal protective equipment is worn in all operations where exposure to hazardous conditions exist;
  • Ensure that assigned employees receive documented training in job safety and that safety practices are part of employee performance evaluations;
  • Notify Environmental Health and Safety (EH&S) in a timely manner of any occupational-related injury or illness by using the First Report of Injury or Illness Form; and
  • Report imminent danger conditions or practices to department or activity head and EH&S. (Imminent dangers are those conditions or practices that can reasonably be expected to cause serious physical harm or death before such danger can be eliminated through normal procedures.)

4.   Employees shall:

  • Comply with rules, regulations, and instructions pursuant to occupational safety and health standards that are applicable to their own actions and job performance. An employee who fails to wear or use the prescribed safety or health equipment or who carries out duties in a way that is a hazard to him/herself, fellow workers, or the public is subject to dismissal after appropriate warning.
  • Attend safety training sessions, both formal and informal, as scheduled and familiarize themselves with occupational safety and health standards related to conditions and practices in their particular work areas.
  • Advise less-experienced workers concerning safe performance practices
  • Report unsafe conditions and practices to their immediate supervisor. Should the unsafe conditions or practices not be corrected within a reasonable period, the complaint should be reported to EH&S. If this does not result in resolution of the complaint, the employee may submit the complaint to the President via the Vice President for Business and Finance. If the complaint is not resolved at this level, the employee has further appeal rights as described in the Occupational Safety and Health Public Sector Plan of the Tennessee Department of Labor and Workforce Development.
  • Serve on Department/Activity safety committee and assist in formulating safety guidelines and rules within their areas of expertise upon request.
  • Stop associated work activities when an imminent danger exists.


Biological Safety

To ensure compliance with occupational safety and health standards and other regulations covering personnel possessing or using biological agents, the University of Memphis has established a Biological Safety Committee. The purpose of this committee shall be to administer the development and implementation of the biological safety program for the University.  The "Biological Safety Program" developed by this committee shall serve as the University's procedure regarding the possession, storage, and use of biological agents. Copies of this program are available in the Environmental Health and Safety Office.

Departments with employees who are reasonably anticipated to have contact with human blood or other potentially infectious materials shall develop and implement an exposure control plan containing at least the elements required by 29 CFR 1910.1030. These plans shall be reviewed and updated at least annually, but more frequently as necessary. Signed and dated copies of the plans shall be on file in the Environmental Health and Safety Office.

The following units will provide administrative support for this program as listed.

1.  The Department of Human Resources will be responsible for

  • Maintaining employee medical records for the period of employment plus 30 years;
  • Providing copies of medical records to employees, or to anyone having written consent of employees, or in the event that such records cannot be reasonably provided within fifteen (15) working days, inform employees within the fifteen (15) working days of the reason for the delay and the earliest date when the records can be made available;
  • Tracking employee's reported exposure incidents of blood or other potentially infectious material;
  • Receiving and maintaining employee's hepatitis B vaccine (HBV) declination forms; and
  • Ensuring employees receive a copy of the health care provider's written opinion within 15 days after completion of the evaluation.

2.  The Environmental Health and Safety Office will be responsible for:

  • Recording appropriate events in the OSHA 300 log,
  • Receiving and investigating accident reports, 
  • Maintaining a sharps injury log as prescribed in 29 CFR 1910.1030,
  • Providing guidance in developing departmental exposure control plans, and
  • Providing administrative support for this program. 

Confined Spaces

Department/Activity heads shall determine if any spaces within their areas of responsibility are confined spaces that contain or have the potential to contain a hazardous atmosphere, contain a material that has the potential to engulf an entrant, has an internal shape such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section, or contains any other recognized safety or health hazard.  Any area meeting the above criteria shall be classified as a permit-required confined space.

Employees entering permit-required confined spaces shall follow procedures outlined in the Confined Space Entry Program in accordance with 29 CFR 1910.146 and 29 CFR 1926.1201-1212. 

Contractor Compliance

Contracting firms performing work on University property shall comply with applicable occupational safety and health standards. The contractors shall provide fire extinguishers if they are required by their work. Physical Plant and Campus Planning and Design will promote compliance by firms performing construction, renovation, and other building and grounds repair/maintenance work. Procurement Services and applicable department/activity heads shall promote compliance by firms performing other types of contractual services.

Department/Activity Safety Committee

Departments and other activity units, especially those of considerable size and/or well-diversified working conditions, are encouraged to establish internal safety committees. The primary interest and concern of these committees should be the promotion of safe practices and procedures in the respective work areas and the positive support of the total University safety program.

Emergency Exit Identification and Access

No more than ninety (90) minutes before the scheduled commencement of indoor campus activity in which the crowd is expected to exceed three hundred (300), the administrative official, chair, or the director of activity responsible for said activity or his/her designee shall inspect every required exit, way of approach, and way of departure from the place of activity. If such inspection reveals that any means of egress is obstructed, inaccessible, locked, fastened or otherwise unsuited for immediate use, the scheduled program shall not begin, nor shall admittance to the place of assembly be allowed, until necessary corrective action has been completed.

Immediately before the start of the program, the administrative official, chair or director of activity or his/her designee shall orally notify all the attendees concerning the location of exits to be used in case of fire or other emergencies.

Accurate records of all inspections, corrections, and notifications pursuant to this procedure shall be kept and retained for at least two years. These records shall contain:

  • A brief description of the activity, performance (e.g., basketball game, movie, etc.), including date, time, and location;
  • The name and signature of the person or persons making the inspections or exit announcements; and
  • The date and time of inspections/announcements.

These records shall be available for review by representatives of Environmental Health and Safety or other appropriate University official(s) upon request.

Fire Prevention and Safety

All fires within the University community shall be reported to Police Services; Police Services will ensure that copies of such reports are forwarded to Environmental Health and Safety (EH&S).

In case of a fire or a fire alarm, all personnel in the building shall evacuate the building and congregate at the building's designated assembly point as found in the Crisis Management Plan.  Personnel must remain outside the building until the fire department gives permission for reentry to the building. Any employee who fails to evacuate a building during a fire, false fire alarm, or fire drill shall be subject to disciplinary action.

Persons noting potential fire hazards should report the circumstances to EH&S for investigation and recommendation of corrective action.

Fire safety equipment, such as extinguishers and alarm systems shall be used for designed purposes only.

Empty or damaged fire extinguishers should be reported to EH&S for immediate replacement.

Exhaust hoods over cooking facilities shall be maintained in satisfactory condition by the facility operator.

EH&S shall ensure that fire drills are conducted in each building at least annually, but more frequently when required by applicable fire code.  Records of these fire drills shall be maintained by EH&S.

Supervisors and classroom/laboratory instructors shall ensure that good housekeeping procedures are always followed and shall initiate immediate action to alleviate fire hazards or other conditions not meeting fire prevention standards.

If it is necessary to turn off or disconnect a fire water line, sprinkler system, standpipe system, fire hydrant, or fire alarm system, it shall be the responsibility of Physical Plant to notify the appropriate fire department and Police Services prior to such action. It shall also be the responsibility of Physical Plant to notify the fire department and Police Services after returning such systems to service.  When a required fire protection system is out of service for more than 4 hours during a 24 hour period, the fire department shall be notified and either the building evaculated or an approved fire watch posted until the system is returned to service. 

General Safety and Housekeeping

Good housekeeping and adherence to good safety practices play an important role in organizational efficiency and safety.  The following items are worthy of particular attention.

  • All classrooms, laboratories, offices, shops, storerooms, and passageways shall be kept orderly and free from unnecessary debris.
  • Flammable liquids shall not be used to clean floors, clothing or equipment.
  • Work tables, stools, benches, tools, and equipment shall be maintained in good repair.
  • Electrical and mechanical equipment shall have moving parts adequately guarded.
  • All electrical equipment shall be properly grounded.
  • Electrical cords shall not be spliced or connected together to increase length, extended and used outside the room in which the outlet is located, more than eight (8) feet in length for household type appliances, or ungrounded when in use.
  • Electrical extension cords shall not be used in the place of a permanent electrical connection. 
  • Unauthorized persons shall not tamper with electrical fuse boxes, alter existing wiring, or install new electrical wiring.
  • Installation of antennas must be approved by the assistant vice president of Physical Plant.
  • Installation of vending machines must be approved by the director of Auxiliary Services.
  • Floors shall be cleaned and waxed to reduce slipping hazards.
  • Trash containers in offices, laboratories, shops, and other work areas shall be emptied regularly.
  • Furnace, mechanical, and air handling rooms shall not be used as storage areas.  
  • All fire doors not interlocked with the building alarm system shall remain closed when not in use.  Such doors shall not be propped, wedged, or locked open.

Those with direct responsibility for any of the above items, including Physical Plant employees, classroom/laboratory instructors, and other University personnel, are expected to exercise appropriate vigilance so as to maintain a safe and healthful workplace.

Hazard Communication

Departments with employees who may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency shall follow 29 CFR 1910.1200 and the University's Hazard Communication Program issued by Environmental Health and Safety. 

Where employees work with hazardous chemicals in laboratories as defined in 29 CFR 1910.1450, this program is superseded by the Laboratory Chemical Hygiene Program. However, laboratories that ship hazardous chemicals off-site are considered to be either a chemical manufacturer or distributor; such laboratories shall ensure that all shipped chemicals are appropriately labeled and that a Safety Data Sheet (SDS) is provided as required in 29 CFR 1910.1200. 

Construction-Related Communication

All renovations, construction projects, and maintenance operations with the potential to release more than de minimis amounts gases, vapors, fumes, dusts, or mists that may be harmful to personnel not directly involved in those projects shall include implementation of a standard operating procedure (SOP) designed to eliminate or reasonably minimize such exposure.  Prior to initiating such work, a representative of the party or parties performing the renovation, construction, or maintenance operation shall inform non-involved persons in the vicinity of the work to be done and the methods implemented to minimize those hazards.  Non-involved personnel shall also be provided with the name of a contact person and phone number to allow rapid notification of emergency situations.  Where there is a dispute involving applicability of the de minimis classification to specific situations, Environmental Health and Safety shall be the arbiter. 

Standard operating procedures should contain at least the following: 

  • Provisions for notifying building occupants prior to beginning of work;
  • Provisions for increasing outside air in appropriate areas to dilute gases, vapors, fumes, dusts, or mist;
  • Provisions for placing work areas at negative pressure with respect to areas frequented by those not involved in the operation;
  • Provisions for shutting down air handlers when necessary;
  • Provisions for performing work with especially noxious or hazardous chemicals at night or on weekends; and
  • Methods for maintaining communication with building occupants during the project. 

Personnel not involved in the renovation, construction, and maintenance operations shall be granted access to the SOP and shall be provided with copies of all applicable Safety Data Sheets in a timely manner upon request to the project supervisor. 

Examples of de minimis and excessive amounts of air contaminants: 

The following examples indicate de minimis amounts of air contaminants for personnel not involved in the project: drilling a small number of holes in non-hazardous construction materials, soldering a small section of pipe, using a spray cleaner to dust furnishings, etc.  

The following are considered to release more than de minimis quantities of air contaminants:  major roof repairs, painting of significant portions of rooms, power sanding a surface of more than 3 square feet, hand sanding entire wall surfaces containing silica, etc.


The primary safety compliance inspection program shall be conducted by the Environmental Health and Safety Office. The frequency of the inspections shall be determined by the nature of operations, with those operations involving the greater potential hazards receiving greater emphasis. All locations, regardless of potential hazards, shall be inspected by the department head or his/her designee at least monthly and by Environmental Health and Safety at least annually.

Representatives of the Tennessee State Commissioners of Labor and Health upon  presentation of proper credentials to the Vice President for Business and Finance or his/her designated representative, are authorized to:

  • Enter any University work place or area where work is being performed by an employee; and
  • Inspect and investigate during regular working hours or at other reasonable times, within reasonable limits, and in a reasonable manner, any such work place and the equipment and materials therein and to privately question employees concerning the same.

Both University and employee representatives shall have an opportunity to accompany the designated officials or inspectors during any physical inspection of University property.

Laboratory Chemical Hygiene Program

To assure compliance with occupational safety and health standards covering employees engaged in the laboratory use of hazardous chemicals as defined in 29 CFR 1910.1450, the University of Memphis has established a Chemical Hygiene Committee. The purpose of this committee shall be to administer the development and implementation of the chemical hygiene program for the University. The "Laboratory Chemical Hygiene Program" developed by this committee shall serve as the University's procedure regarding the possession, storage, and use of hazardous chemicals in laboratories. Copies of this program are available in the Environmental Health and Safety Office and in any department using hazardous chemicals in laboratories.

Lock Out/Tag Out

Departments with employees who maintain or service devices where there may be exposure to the unexpected energization or startup of the equipment or release of hazardous energy shall follow the Lockout/Tagout Program in accordance with 29 CFR 1910.147. Hazardous energy sources include, but are not limited to, chemical, electical, fluids, gravitational, hydraulic, mechanical, pneumatic, pressurized water, and steam.

Medical and First Aid

Medical Services

Employees who are injured on the job should utilize the services of an authorized medical services provider from the state workers' compensation preferred provider network. Additional information on this subject is available from Human Resources.First Aid

1.  Department/Activity Heads shall be responsible for ensuring the following:

  • Physical Plant shall have at least one (1) person assigned to each shift who is qualified to administer first aid. Other department/activity heads are encouraged to follow this requirement where risk of injury is significant.
  • First aid supplies meeting or exceeding requirements found in American National Standards Institute (ANSI) Standard Z308.1 shall be readily available in each area where risk of injury is significant.
  • Suitable facilities shall be immediately available for flushing or quick drenching of the eyes and body in areas where the eyes or body of any person may be exposed to injurious corrosive materials.
  • Acquisition, possession, and use of Automated External Defibrillators (AEDs) shall be in accordance with the University's AED Program issued by Environmental Health and Safety.

2.  The Chief of Police shall prepare shift schedules to ensure that at least one (1) person qualified to administer first aid is always assigned to the Main, Park Avenue, Lambuth, and Law School campuses.

Noise Exposure

Departments with employees who are subjected to occupational noise exposure in excess of the limits set forth in 29 CFR 1910.95 shall follow the University's Hearing Conservation Program issued by Environmental Health and Safety.

Personal Protective Equipment

Personal Protective Equipment (PPE) is the last form of protection recommended to protect employees against specific workplace hazards. Employees who wear PPE are required to complete initial training and additional training when there is a change in workplace conditions, a change in PPE use, or inadequacies in an affected employee’s knowledge or use of assigned PPE. With the exception of very specific items that are often used outside the workplace and are taken by workers from jobsite to jobsite and employer to employer, purchase of required PPE is the responsibility of the employee’s department. Contact Environmental Health and Safety with questions and for assistance with selecting PPE and training employees.

Radiation Safety

The University of Memphis operates under regulations established by the Tennessee Department of Environment and Conservation--Division of Radiological Health, U.S. Nuclear Regulatory Commission, and Tennessee Department of Labor and Workforce Development.  To insure compliance with all regulations regarding the use of radioactive materials and/or radiation-producing equipment, the Radiation Safety Committee has been established. The purpose of this committee shall be to administer the radiation safety program for The University of Memphis.  This committee has developed a "Radiation Safety Manual" and a Laser Safety Program which shall serve as the University's procedures regarding the use of ionizing radiation and laser radiation.  Copies of these manuals are available for review in the Environmental Health and Safety Office or in any department that has radioactive materials, radiation-producing equipment, or Class 3B or Class 4 lasers.

Respiratory Protection

Where engineering controls and work practices are not sufficient to effectively reduce occupational exposure to harmful dusts, fogs, fumes, gases, mists, smokes, sprays, or vapors, respirators shall be used in accordance with the Respiratory Protection Program and 29 CFR 1910.134. 

Reporting Accidents Involving Vehicles

All vehicle accidents on campus and those involving University-owned vehicles shall be reported to Police Services. Police Services shall notify other offices or officials as appropriate.

Reporting Injuries and Illnesses

Injuries and illnesses of employees that result from work-related accidents and/or exposure to unsafe environmental conditions shall be reported by the employee and his/her supervisor to the Workplace Injury and First Notice of Loss Call Center at 1-866-245-8588.

In addition, the "First Report of Injury or Illness" form shall be used internally to document injuries and illnesses of employees. The supervisor of an injured/ill employee shall complete the appropriate sections of the form and forward the completed form to Environmental Health and Safety (EH&S) within 24 hours of the occurance of the injury or illness. 

Accidents involving students and visitors should be reported to Police Services, who shall notify EH&S. 


Storage and Use of Flammable and Combustible Liquids

Department/activity heads and other supervisors (including class and laboratory instructors) shall ensure compliance with the following rules related to use and storage of flammable liquids (flashpoints below 100º F) and combustible liquids (flashpoints below 200º F but at or above 100º F).

Use of flammable and combustible liquids shall be limited to trained personnel, or persons under the direct supervision of a trained individual, such as a laboratory instructor or a qualified faculty member.

Storage of flammable and combustible liquids in buildings used primarily for office occupancy and/or traditional education operations shall be limited to that required for the operation of equipment, maintenance, demonstrations, laboratory work, etc. All subject liquids in laboratories and other inside points of use shall meet the following provisions:

  • Containers of liquids with flashpoints below 140º F shall not exceed one (1) gallon capacity except that approved safety containers may be of two (2) gallons capacity.
  • No more than ten (10) gallons (total) of liquids having a flashpoint below 140º F shall be stored outside an approved storage cabinet or storage room unless in approved containers.
  • No more than twenty-five (25) gallons (total) of liquids having a flashpoint below 140º F shall be stored in approved containers outside an approved storage cabinet or storage room.
  • No more than sixty (60) gallons (total) of flammable or combustible liquid shall be stored in an approved storage cabinet.
  • Flammable and combustible liquids in excess of quantities set forth above shall be stored in an appropriate container inside a storage room.
  • Storage and use of flammable and combustible liquids in buildings other than those used primarily for office occupancy and traditional education operations shall be governed by regulations contained in 29 CFR 1910.106.
  • Flammable liquids shall not be used to clean floors, clothing, or equipment.
  • Approved safety containers shall be used for small quantities of frequently used flammable liquids.  However, glass or plastic containers of not more than one gallon capacity may be used if such liquids would be rendered unfit for their intended use by contact with metal or would excessively corrode a metal container to create a leakage hazard.
  • Flammable and combustible liquid containers shall be clearly marked with the name of the contents and appropriate hazard warnings.
  • Dispensing areas shall be well ventilated.
  • Flammable liquids shall not be dispensed into secondary containers unless the nozzle of the dispensing unit and the secondary containers are electrically bonded to prevent static discharge.  A wire connecting the dispensing nozzle and the secondary container shall satisfy this requirement.
  • NO SMOKING signs shall be prominently displayed in and near areas where flammable and combustible liquids are used or stored.
  • Flammable or combustible liquids shall not be used or stored  where they limit access to exits, stairways, or areas normally used for safe egress.
  • Environmental Health and Safety will provide guidance in fire-related matters.  

University Safety Committee

A University Committee on Safety shall be appointed by the president and shall be responsible for the following functions:

  • Review regularly the total University safety posture,
  • Review periodically the total University safety programs,
  • Evaluate proposed University safety programs,
  • Provide recommendations and guidance for training programs on safety related topics, and
  • Provide oversight of the University Hazardous Waste Reduction Plan.

This Committee on Safety shall prepare an annual report to the president during the month of July to include the following items: 

  • An outline of safety activities and accomplishments during the past year,
  • A summary of unresolved and/or new safety issues that should be considered and acted upon, and
  • The Committee's recommendations concerning priorities for various safety projects and programs for the coming year.  

The Committee should meet at least quarterly but not less than semi-annually.


Requests for variances from the Occupational Safety and Health Act standards will be processed in accordance with procedures outlined in Section 13, Tennessee Occupational Safety and Health Act of 1972.  Requests for variances from the Occupational Safety and Health Act, Public Sector Plan will be processed according to procedures outlined in III-9-5, Tennessee Occupational Safety and Health Act, Public Sector Plan. 

Preparation of variance requests will be the responsibility of the Office of the Vice President for Business and Finance and shall be submitted to the President for further action.

Related Forms

Bloodborne Pathogen Incident Report

First Report of Injury or Illness


Other Health and Safety Related Forms


What do I do if I am injured on the job?

More information is available from the Benefits Section of the Department of Human Resources. Information on the website includes proper procedures for reporting injuries and illnesses, access to Workers' Compensation, and instructions for receiving medical treatment.  

Whom do I contact with further questions?

EH&S Director at 901 678 4672 or Manager of Occupational Safety at 901 678 2740.



Environmental Health and Safety Office

Tennessee Department of Environment and Conservation


University of Memphis Safety Manuals

U.S. Occupational Safety and Health Administration

Revision Dates

  UM1293 - Revised September 18, 2017
UM1293 -- Revised September 16, 2015
UM1293 - March 24, 2014
UM1293 Rev.1 -- updated August 20, 2007
UM1293 - Issued: July 2, 2003 supercedes policy number 1:2A:04:01 and 2D:02:02D)

Subject Areas:

AcademicFinanceGeneralHuman ResourcesInformation TechnologyResearchStudent Affairs