What is the CEC?
The CEC is a document that the UT Southwestern Department of Environmental Health and Safety (EH&S) prepares and signs for laboratories to submit to the ***United States Department of Defense (DOD). The CEC is an assurance to the DOD that UT Southwestern complies with environmental laws, protects the outdoor environment (air, water, soil) and community (living organisms including people) from harmful chemicals and biological materials, and responds appropriately with corrective and/or emergency response action when needed.
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***also United States Army Medical Research and Materiel Command; USAMRMC
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Who signs the CEC?
The Facility Safety Director, Dr. Jose Lopez, signs the CEC. If needed, an Assistant Facility Safety Director can sign the CEC as designee of Dr. Lopez. Note that a signature on the CEC is not provided until the steps of the CEC-release process have been satisfied.
How do I obtain a signed CEC from EH&S?
Send an initial email to EH&S Staff: To Terry Capone, Copy to: Patrick Conley and Julien Farland. The subject line of the email should state, “DOD CEC Needed”. No information is needed in the body of the email. No attachments to the email are needed. The initial email serves as a simple alert to EH&S staff that a CEC is needed
EH&S staff will reply to the initial email with a boiler plate email containing information EH&S must convey to the Principal Investigator, questions that must be answered via a return email, and a request for submittal of at least the materials and methods section(s) of the DOD proposal for review by EH&S staff.
Upon review of the return email and the DOD proposal’s materials and methods section(s), EH&S staff will request that additional requirements be met, such as:
- provision of additional information to EH&S;
- completion of corrective action specified by EH&S;
- filing of one or more relevant Safety Plans with EH&S; and/or
- completion of additional safety and/or compliance training provided by EH&S.
Once all information has been provided and any needed corrective action, Safety Plans, and/or training has been requested by EH&S, a hardcopy signed CEC will be inter-campus-mailed or hand-delivered to the Principal Investigator or his/her designee.
Did I read that right? EH&S might ask me to take some corrective action, file one or more Safety Plans, or receive additional training, but I can still receive my CEC before any of these requirements are fulfilled?
Yes. EH&S will not hold up your DOD paperwork because you need to improve your daily operations in some manner. The full safety and compliance program at UT Southwestern has checks and balances designed to ensure that you operate safely and in compliance with all relevant laws. Any requests for corrective action, filing of Safety Plans, or additional training are based on standard operating procedures at UT Southwestern that apply to all work at UT Southwestern regardless of the funding source.
I have requested a CEC from EH&S before. Will I get the same boiler plate email mentioned above?
Yes. The boiler plate email helps fulfill certain DOD requirements. The information conveyed to the Principal Investigator in the initial EH&S email is important in validating statements made on the Facility Safety Director’s Assurance and on the Principal Investigator’s Assurance.
There are a few UT Southwestern groups that have a say-so in how I conduct my work. For the groups that are part of the UT Southwestern Department of EH&S, am I good-to-go with starting my project once I receive the CEC?
No. Receipt of the CEC does not allow you to by-pass other safety and environmental protection requirements at UT Southwestern. The CEC is “in addition to” rather than “in lieu of”. The CEC is a DOD requirement; not a UT Southwestern requirement. As per standard UT Southwestern EH&S procedures, all new research projects involving hazardous materials require approval by the applicable Safety Officer and/or applicable Committee prior to commencement of work. The previously mentioned requests you might receive (to take corrective action, to file one or more Safety Plans, to receive additional training) are a part of the process that leads to the necessary approvals.
Can I speed up the process of obtaining a CEC?
Not usually, but there is a special case where information provided upfront can speed up the CEC-release process: The DOD often requires submittals of a new CEC when funding is renewed for an existing project or when funding for a given project is transferred from one UT Southwestern Principal Investigator to another UT Southwestern Principal Investigator. If a previous CEC for the same project was signed by Dr. Lopez and released by EH&S within three years, an appropriate message in the body of the initial “DOD CEC Needed” email alerting EH&S staff of the situation might reduce some steps of the CEC-release process.
I am transferring a DOD research project from another institution and tHERE already submitted a CEC from that institution. Can I take a shortcut to obtain a new CEC signed by Dr. Lopez?
No. Transferred projects must go through the full CEC-release process.
I’ve received CECs signed by Dr. Lopez for five other DOD projects and I’m tired of reading that same boiler plate email and answering those same questions over and over again. Can EH&S release a signed CEC on my new project without me suffering yet again through the tedium?
No. All new and transferred projects must go through the CEC-release process. The CECs are project-specific; not Principal Investigator-specific. The full paper trail is needed to:
Can EH&S make this process any less tedious and still document compliance with DOD requirements?
The current procedure is the streamlined procedure developed and refined since 2001. EH&S will always look for ways to cut tedium further while ensuring full compliance with all rules and regulations of funding and government agencies.
