Podunk University HazCom Compliance

Columbia Southern University

Podunk University HazCom Compliance

Podunk University is a campus located in Podunk, Colorado, and as each campus, is visited by many people every day; students attending classes, professors teaching their lessons, administrative personnel that work there, and other workers ensuring the proper campus operation, just to mention some of the people that daily are in campus. Podunk University, as each campus, has also a safety department that guarantees the safety and health of students, employees, and contractors. Unfortunately, here safety has never been taken too serious and during the last year and half the safety manager position has been vacant and safety is worsening. The dean recognized that this situation could not last too long and, to avoid citation, fines, and accidents, hired me as safety manager. I spent my first day walking through university facilities and departments, meeting people and introducing myself. During this initial audit I noticed several safety issues that have the potentiality to result in accidents and I decided to start addressing hazardous material usage and hazardous waste, because, in my opinion, they pose the greater danger from a safety standpoint and also from a compliance point of view.

1. My start point addressing hazardous materials and hazardous waste is to ensure the university is in compliance with OSHA requirements regarding Hazard Communication Standards, not only because it is mandatory to have a HazCom Program when dealing with hazardous chemicals, but also because it is necessary that employees know dangers surrounding them in order to prevent accidents and to comply with their right-to-know. As Haight suggest in his textbook “Obviously, to comply with the HCS, safety professionals first have to know and understand the regulations.” (Haight, 2012), and this is exactly my initial step; I will review federal and state regulation to make sure that my program will be in compliance with the requirements. Initially, I will also obtain a copy of the existing HazCom Program, if any, to see which sections I can use in my new program and which one I have to rewrite.

2. My initial HazCom efforts will be focused in identify key personnel which in each department will be responsible for conduct the chemical inventory and its update, once it will be completed. I will accomplish this task proceeding with a thorough walk through the campus to have a precise idea of the status of the site and to meet personnel of all departments. I will also request human resource department to provide me education background of employees for each department to see who has chemical acknowledgement and education that will allow to take leadership during the inventory. Once I identified the employees that will be responsible for the chemicals in use in their department, I will assign each one with the responsibility to conduct a precise inventory of chemicals in use, providing location and if they are classified as hazardous or non-hazardous. I will oversee all the process ensuring that it will be in compliance with the rules. When the inventory has been completed, my next task will be to write the HazCom Program. This written plan will have a general section that will address all the campus and detailed sections for each department because in this way it will be easier to track and address all chemicals. Once the written plan is completed I will move on labeling all chemicals and waste identified as hazardous, following the Global Harmonized System (GHS) as OSHA mandate. I will also provide employees with Material Safety Data Sheet (MSDS) for each chemical in use and I will make sure that they are available to workers at all time without any barriers. I will use electronic MSDS instead that paper ones, because the campus uses a large amount of chemicals, and I will make sure to have a backup plan that will power the computer in case of outage, making the MSDSs still available in case of emergency. My initial HazCom efforts will be completed providing training to all employees on this new plan and on all chemicals are being used in the campus. Training will be conducted by departments in order to specifically target employees, with the main focus to make it more effective. These initial efforts will be conducted within each department by key personnel previously identified. However, I will prioritize some departments more than others keeping into consideration type of dangers people are exposed and possible outcomes in case of accidents. I will start with the chemistry department because it has chemicals that have never been inventoried, therefore, nobody knows the type of danger chemicals in use there pose. I will proceed with biology department because they use a great quantity of hazardous substances. These two departments have my first attention because an accident here, such as spill of fire, can affect the whole campus affecting many people. My next target will be the automotive department, then physics department and finally math and English departments.

3. The automotive technology department deals with several chemicals that pose environmental, health, and safety danger. They have the same chemicals that can be found in each mechanical auto repair, such as waste oil, solvents, and brake linings. They also store used and new tires and they use several tools that constitute safety threats. The issues this department can have concerning Hazardous Communication Program are: inventory, labeling, MSDSs and training. They can have a poor inventory or even do not have one, thus employees do not know the danger chemicals they are using pose and also they are unable to locate them responding promptly in case of an accident. Another issue within automotive department can be chemicals labeling. Some containers could be not labeled or not labeled properly; the transition to GHS just ended and probably this department is not in compliance yet with the new system. MSDSs are another potential finding here; these documents can be incomplete or not readily accessible by all employees. Finally lack of training can also be an issue in this department because is possible that employees do not know how to read a MSDS or they do not know where these are located, or more serious, they do not know the dangers related to chemicals they are using.

4. The automotive department deal with several chemicals that have to be disposed according with OSHA and EPA regulations, on a federal level and also on a state level. These chemicals can be : degreasers, like Methylene chloride, also called dichloromethane, that is a volatile, colorless liquid with a chloroform-like odor (OSHA, 2003); waste engine oils and fluids, such as transmission fluid or brake fluid; new and used tires that poses a threat if not stored properly, because stagnant water can accumulate inside the disposed tires making them an ideal environment for mosquitoes, and also they pose a fire threat with subsequent fume release in case of accident; fumes exiting exhaust system of the engines can also be considered as hazardous waste present in this department. Proper insulation, storage and disposal of the chemicals above described are all issue related with HazCom waste.

5. The biggest issue with chemistry department is that there are chemicals here that have never been inventoried, therefore, there is no information about the substance in use and, potentially, they can be highly hazardous. Another issue is the new forensic program at CSI level. This program will include usage of chemicals, such as luminol, that according with its MSDS, can cause skin, eyes, and respiratory trait irritations (Cayman Chemicals, 2006). These chemicals have also to be labeled, they shall have a MSDS, and they have to be handled properly for disposal. In my plan, chemistry department is the first to be addresses and will have a specific training program due to the issues identified above.

6. The issues in the chemistry department regarding hazardous waste can be serious due to the number of hazardous chemicals they handle. One of the biggest issue could be that waste are not disposed separately but could be mixed, resulting in greater hazardous threat. In order to prevent this issue to happen it is necessary to have procedure in place that clearly indicates how to separate and dispose chemical waste. Another possible issue can be with the chemical labeling. In this department they deal with a large amount of substances and it is easy that some container or bin used for disposal is not properly labeled.

7. The Massive Arena is one of the original buildings in the campus and is finally undergoing an important renovation. The main problem identified is the presence of asbestos that is well recognized as a health hazard and its use is now highly regulated by both OSHA and EPA (OSHA, 1998). During renovation, asbestos fibers can contaminate the air, therefore, in the building plan this issue has to be properly addressed and the building has to be isolated and de-contaminated before proceeding with others renovation operations. Beside these considerations, it is also necessary to inform people regarding this hazard. The people that should be informed are senior managers, construction personnel, students and employees which their activities bring them close to the renovation site.

8. My main concerns with physics department are basically three: use of high-voltage equipment, use of lasers and use of LEDs lights. The use of all of these can cause serious injury or death, thus, it is necessary to address them specifically. Within this department I identified two potential weaknesses: training and usage of Personal Protection Equipment (PPE). Working with high voltage equipment requires a specific training and deficiency in it can cause serious accidents. While using laser, it is necessary to wear adequate PPE, such as eye protection for Class IIIB and Class IV lasers and skin protection for Class IV lasers (OSHA, Section III Chapter 6). Also LEDs light have to be disposed in accordance to EPA regulations because they contain lead and other dangerous chemicals.

9. Spill response plan and emergency plan is a serious topic that university has to address to be prepared in case accidents occur. Even with a solid prevention plan, accidents happen and the right response is vital to save lives and property. Each department of the campus deal with chemicals and issues with hazardous materials and hazardous wastes are present in each phase of chemicals life, from “cradle to grave” (Haight, 2012). The main concerns university has are in transportation, handling, storage and disposal of the chemicals. In order to be prepared facing these issues I will first write specific plans for the campus, referring to the following:  DOT (49 CFR): Part 130 ; Oil Spill Prevention and Response Plans (40 CFR): Part 68 ; Chemical Accident Prevention Provisions OSHA (29 CFR): General Industry: 1910.38 ; Emergency Action Plans, 1910.119 ; Process Safety Management of Highly Hazardous chemicals, 1910.120 ; Hazardous Waste Operations and Emergency Response, 1915.502 ; Fire Safety Plan, 1917.30 ; Emergency Action Plans, 1918.100 ; Emergency Action Plans Construction: 1926.35 ; Employee Emergency Action Plans, 1926.64 ; Process Safety Management of Highly Hazardous Chemicals, 1926.65; Hazardous Waste Operations and Emergency Response, 1926.150 ; Fire Protection. Once those plans are ready I will train employees and first responders on the plans so everybody will know how to respond in case of emergency.

10. Employees in math departments need some specific HazCom training on usage and disposal of dry markers that they are using on whiteboards. They also have to be trained on disposal of computer, so they can be aware of this serious environmental problem. The English department has lots of book that are good source of fire; therefore, I will train them on fire prevention and mitigation in case emergencies occur.

11. There are many resources available for safety managers to solve HazCom issues, but not all of them are trustworthy, therefore, it is a good practice always verifies the source of the information recollected. The best information addressing HCS are found in OSHA website and EPA website. I also refer to FEMA library anytime I need information regarding emergency response and DOT website if my dilemma regards transportation of hazardous materials.

12. Training is the main element of any program and dealing with hazardous material it is vital to save lives. As OSHA mandate, training not only has to be offered, but has to be effective (Haight, 2012); therefore, the way how training is provided is very important to comply with effectiveness requirements. Safety managers have several training methods that are all effective if used in the right way and with the right employees. When selecting the training methods, the main consideration has to be the audience. Computer based and web based training are good for employees with computer background and inclined to technology; instructors training is perfect to interact with students with limited access to technology. Another important consideration is the budget I have for training, because instructors are more expensive than technology. My final consideration concerns the equipment I have to provide training, because if I want to choose technology I have to have computer and software available to support this method, otherwise I have to choose instructor training that will need less resources and less space.

13. According to Haight, citing Grieff, adults retain 10 per cent of what they read, 20 per cent of what they hear, 30 per cent of what they see, and 50 per cent of what they both see and hear (Haight, 2012), therefore power point presentation are a powerful training method. However, to be effective there are some concepts to keep into consideration when developing training that uses power point presentation. The first thing to remember is again the audience. If our students do not have a high educational level they will be more focused on the design of the slides than on the message they contain, thus it is important to keep the presentation simple and direct to avoid distractions. Second important consideration about power point is that the slides are only supporting the presentation and not making it. Presenters have to use them as an aid and do not have to read them. Presentation has to be focused on the message to deliver and not on the slides to deliver the message. A power point presentation has to be interactive so it is a good idea to handout it in paper to the students so they can take notes on it. Last consideration is that slides do not have to be too busy and should contain as much visual as possible, like pictures, graphics and short videos.

14. OSHA mandate that “employers shall provide employees with effective information and training on hazardous chemicals in their work area” (OSHA 29 CFR 1910.1200 paragraph h). Hence, safety managers, to be in compliance with requirements and to provide a safe work place, need to test their training program ensuring that employees retained the information delivered. There are several strategies that can be used to check the training effectiveness. In first place, training has to be understood as a serious part of the job and not as a recreational activity; for this reason, it is necessary transmit professionalism, starting and ending classes on time and being always punctual; the information delivered has to be adequate in length and contents; and instructors have to be well prepared engaging the audience. In second place, quizzes to check learning have to be proportional to the outcome we want to obtain. They do not have to be too difficult but also not too easy and have to use all types of questions available, such as true or false questions, multi-choice, fill the blank, and matching. Once the training is completed and employees return to work, our training evaluation is not done yet, because it is necessary to interview the trainee after few days to ensure that their retention level is acceptable. Training has to be a continuous and ongoing process that starts exactly where it ends.

15. New material are developed all the time (Haight, 2012). These can solve some problems but can create other hazards. Every time a new material, or new technology is introduced it is necessary to conduct a safety analysis focused in determine if it eliminate or mitigate existing safety issue and if it does not create others unacceptable dangers. This study has to be conducted before the substance is used for different purposes other than test it. This responsibility can lay on the safety manager or can be assigned to an external contractor specialized in safety analysis. Once the safety manager or the contractor establish that the substance is acceptable, it is necessary to create a MSDS and a label according with the HazCom requirements if it is still hazardous material. The next step will be present it to the United States Patent and Trademark Office to obtain authorization to put it in commerce.

16. New chemical products that are intended to be marketed worldwide need to obtain an international patent that require strict tests involving several agencies. Even if it is patented in USA, country that adopted the Globally Harmonized System (GHS) and that has strict requirements regarding chemicals, this new substance still needs to adhere to international standards, such the European REACH standard and the International Standard Organization (ISO) requirements (Haight, 2012). The main concerns to be addressed will be international environmental standards, transportation requirements, storage and disposal issues, creation of a MSDS internationally valid, and adequate labeling provided in several languages.

17. As safety manager I have few concerns regarding the explosive property of this new substance when mixed with other chemicals. First of all, it should be stored in shelfs that raise it from the ground to avoid that other chemicals can enter in contact with it as result of accidental spills. It also has to be completely isolated from other activities and the storage area should be properly delimitated, secured and signaled. Another concern I have regards transportation. This chemical has to be transported by itself and never in conjunction with other chemicals and this has to be highlighted in the MSDS and in the shipping documents accompanying the substance. The professor that invented the material has to take the lead in the activities to determine the type of storage, transportation, and disposal precaution it is necessary to take and she is the first expert I would consult. I will also request advise from chemical engineers, fire experts specialized in explosives, and transportation experts to determine how this chemical can be moved.

18. Strong pathogens used in the microbiology department are a serious concern that have to be addressed in the Hazard Communication Program because employees and student need to know the hazards they are potentially exposed and due to the importance of the threat it is the responsibility of safety manager to go beyond the requirements. The new HazCom Program will be more focused in addressing health hazards than physical hazards due to these pathogens pose a greater danger to employees and students health on medium and long term than physical hazard. Another requirement that I will highlight in the new plan is the usage of proper PPE when in the exposed area. I will recommend to use at minimum level B protection inside the laboratory to raise to level A protection when necessary. The area also has to be isolated from the rest of the departments and to do so I will use the emergency response layout on regular basis, where the laboratory that uses pathogens will be the red zone. I will establish a decontamination zone and a warm zone before exit in the cold zone that will be the rest of the campus. Another important requirement of the HazCom Program will address the emergency response plan in case a release will occur in the laboratory. Another requirement will be the signals in usage in the laboratory and in the decontamination area to clearly delimits and warns about the danger existing in this area. Finally, the new plan will contain security measures focused in avoiding intentional attacks to the laboratory.

References

Joel M. Haight (2012). Hazardous Material Management and Hazard Communication from The Safety Professionals Handbook, 2nd edition

Florida Atlantic University. Hazard Communication Program (November 2015). Retrieved from http://www.fau.edu/facilities/ehs/info/Hazard-Communication-Program.pdf

Occupational Safety and Health Administration. Methylene Chloride (OSHA 2003). Retrieved from https://www.osha.gov/Publications/osha3144.html

Vince McLeod (09/01/2004). Chemical Safety in the Forensic Lab. Retrieved from http://www.forensicmag.com/article/2004/09/chemical-safety-forensic-lab

Occupational Safety and Health Administration. Safety and Health Topics. Laboratories. Retrieved from https://www.osha.gov/SLTC/laboratories/index.html

Cayman Chemicals (02/27/2015). Luminol Safety Data Sheet. Retrieved from https://www.caymanchem.com/msdss/16803m.pdf

Occupational Safety and Health Administration. Asbestos (OSHA 2014). Retrieved from https://www.osha.gov/SLTC/asbestos/

Occupational Safety and Health Administration. Laser Hazard Section III Chapter 6 (OSHA 2010). Retrieved from https://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_6.html

Michel Theriault (Nov 25, 2013). 5 Principles for Making PowerPoint Slides with Impact. Retrieved from http://www.forbes.com/sites/allbusiness/2013/11/25/7-principles-for-making-powerpoint-slides-with-impact/#1b460af4abcb

Transportation Safety Institute (TSI). Instructor Course Manual (2015).