Bentley University
PA-15: Workplace Health and Safety

Bentley doesn’t have a formal OHSMS in place. We do address elements of the OHSMS with some formal documentation. The elements of the OHSMS are listed below. Although we have parts of this system in place, it’s not formally documented in one specific OHSMS format and is overall generic OHS documentation. Some documents may not provide enough detail.
The operational elements of an OHSMS include:
• Risk assessment-We’ve completed risk assessments of union job tasks using a Job Hazard Analysis format combined with a Personal Protective Equipment Assessment to identify and mitigate risks to employees.
• Hierarchy of controls-We institute the hierarchy of controls by trying to implement engineering controls, administrative controls and then lastly PPE in that order when reviewing job tasks/projects but again not formally documented.
• Design review and management of change processes-We review design/change processes when changes in work affect safety and healthy but not formally. When changes that may affect safety and health occur, Facilities does address and try to plan for changes.
• Applicable life cycle phases-We review life cycle of equipment and have controls/timelines in place for replacement of equipment rather than installing after-market controls but I’m not sure this is a rigid timeline.
• Process verification-We have procedures in place for controls of operations and I know they’re documenting policies to assist with changes to facilities, documentation and personnel.
• Procurement-We do not have a formal process to assess health and safety risks/requirements and controls of procurement of supplies and equipment; however, I’ve been involved in assessing/addressing procurement of tables/chairs and ergonomic equipment from a manual material handling standpoint. I’m not sure what additional controls are in place with Purchasing for other supplies/equipment.
• Contractors-We have a documented contractor safety process with required contractor safety forms and training. This documentation is used to identify, document and control risks. The risk assessment is mainly the contractor’s responsibility but our contractor safety guidebook outlines Bentley’s requirements that complies with all regulatory body regulations/requirements.
• Emergency preparedness-We have an Incident Response Plan that outlines procedures, supplies/equipment, contact lists, org charts, maps for various potential emergencies. This is to prevent and minimize risks for these potential emergencies. University Police has drills and activities to test some of the plans but drills are not campus wide outside of the annual fire drills or what University Police takes part in. This Incident Response Plan is evaluated and updated as necessary.

Employees file an injury report form with their supervisor and that copy gets sent to our EHS professional. That person reviews the information and speak to the injured employee. The EHS professional collaborates with Human Resources and they file a Worker’s Comp claim form so the information is on file in the event that the injury leads to treatment beyond first aid or what is termed an OSHA recordable injury. The EHS professional maintains an excel spreadsheet of all injuries on campus. We classify these injuries/illnesses utilizing OSHA’s 1904.7 Record keeping and Reporting Occupational Injuries and Illness Standard. The injuries and illnesses must be reported to the Occupational Safety and Health Administration (OSHA) on a Form 300 (Log of Work-related Injuries and Illnesses) annually.