My research is not funded by NIH, why do I have to enroll in AEP?

The NIH Policy statement states the following: Recipients are responsible for meeting applicable Federal, State, and local health and safety standards and for establishing and implementing necessary measures to minimize their employees’ risk of injury or illness in activities related to NIH grants. In addition to applicable Federal, State, and local laws and regulations, the following regulations must be followed when developing and implementing health and safety operating procedures and practices for both personnel and facilities:

NIH requires compliance with OSHA and OSHA requires a medical surveillance program for employees working in hazardous environments.