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EHS Regulatory Overview

This overview provides auditors with information on environmental health and safety (EHS) functions, requirements, and regulations at colleges and universities. It covers topics such as occupational safety, laboratory safety, fire safety, and environmental compliance.

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EHS Regulatory Overview

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  1. EHS Regulatory Overview College and University Auditors of Virginia May 21, 2012

  2. EHS Functions • Environmental Health & Safety • Environmental Compliance • Emergency Preparedness & Response • Fire Safety • Laboratory Safety • Occupational Health • Occupational Safety

  3. EHS Mission • EHS partners with various University officials, departments, and personnel to promote health, safety, environmental protection, emergency preparedness and compliance with applicable local, state, and federal regulations, guidelines, and best practices.

  4. Requirements Framework • Laws & Regulations • Executive Orders • Guidelines • Industry Standards • Best Practices • University Policies

  5. Occupational Safety Requirements Framework • OSHA State Plan States • OSHA/VOSH: Workplace Safety & Health • Bloodborne Pathogens - Confined Spaces • Hazard Communications - Electrical Safety • Walking and Working Surfaces - Fall Protection • Personal Protective Equipment • and MANY more • DHRM: Workers’ Compensation • NFPA/NEC: Electrical Safety

  6. Occupational HealthRequirements Framework • CDC/NIOSH: • Respiratory Protection, Medical Surveillance • NIH/OLAW: Animal Care Workers • AAALAC /NRC: • Animal Care Workers, Vivarium Facilities • ACGIH: • Chemical Exposure Limits, Noise, Temperature Extremes • ANSI: Lab Ventilation • ASHRAE: Ventilation • EPA: Indoor Air Quality

  7. Laboratory SafetyRequirements Framework • OSHA/VOSH: Laboratory Safety and Chemical Hygiene, Laboratory Amenities/Equipment, Laboratory Safety Practices • NRC/VDH: Radiation Safety Practices and Licensing • CDC: Registration of Select Agents • NIH: Biosafety Practices, Facilities, and Project Review • DEA: Controlled Substances • DOT: Hazardous Materials Transportation Security, Domestic Hazardous Materials Shipping • IATA: International Shipping and Shipments by Air • DHS: Chemical Facility Security • ANSI:SEW, Lab Decommissioning

  8. Environmental ComplianceRequirements Framework • EPA/DEQ: • Air Emissions • Hazardous Materials & Waste • Spill Prevention and Controls • Pesticide Application • Storm Water Pollution Prevention • AST and UST • Local POTW

  9. Fire SafetyRequirements Framework • IFC/VaSWFPC: • Fire Prevention • Fire Suppression Systems • IBC • NFPA: • Specific Codes as Adopted by VaSWFPC • DoEd: • Fire Statistics in Residence Halls

  10. Emergency PreparednessRequirements Framework • FEMA/VDEM: • Emergency Plans and Procedures, Emergency Preparedness Guidance • Office of the Governor (Executive Order 41): • Emergency Preparedness via EOP • DoEd: • Missing Students, Timely Emergency Notification

  11. Overarching Requirements • OSHA General Duty Clause requires an employer to furnish to its employees: "employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees..."

  12. Overarching Requirements • NIH Grants Policy Statement “Grantees 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.”

  13. Risks • Injury or Illness • Loss of Accreditation • Decrease in Grant Funding • Regulatory Fines • Reputation Damage • Property Damage • Delay New Academic Programs/Research or New Facilities

  14. Successful Implementation • Buy In • Structure • Outreach/Communication • Education & Training • Review & Monitoring • Customer Service Oriented Staff

  15. EHS Services Provided • Building Evacuation Plans • University & Unit Level Emergency Planning • Ergonomic Assessments • Exposure Monitoring • Fire Cause Investigation • Fire Drills • Fire Extinguishers: Installation, Inspection, and Testing • Fire Protection Systems: Inspection and Testing • Hazardous Materials Shipping • High Hazard Area Inspections • Indoor Air Quality Investigations • Laboratory Project Review • Laboratory Signage • Mason Alert Emergency Messaging • Medical Surveillance • Personal Protective Equipment Selection • Training, Workshop, Emergency Exercises • Waste Pickups and Waste Container Distribution

  16. Fire Safety

  17. Overview of Regulations • Virginia Statewide Fire Prevention Code • NFPA sections by adoption • International Fire Code (IFC) • International Building Code (IBC)

  18. Systems Inspections / Testing

  19. Systems Inspections / Testing

  20. Systems Inspections / Testing

  21. Inspection Records

  22. Systems Inspections

  23. Systems Inspections

  24. Fire Drills Annual Fire Drills • Based on occupancy • Must be documented

  25. Other Compliance Issues

  26. Challenges • Record keeping • Electronic vs. hard copy • Records retention period • Access • Periodic audits • Having enough personnel to complete work • Growth of the University • Adding additional inspections and testing to schedule

  27. Emergency Preparedness

  28. Executive Order 41 – 9/30/11 • Appointment of Emergency Coordination Officer (ECO) and alternate. • Must maintain and test specific plans • Mandatory training (within 90 days of employment) • DHRM-HR Policy – Preventing Workplace Violence • Terrorism and Security Awareness Orientation • ISC 100.b, 700.a, and 800 (for ECO and “other appropriate personnel” “Include emergency preparedness in its strategic planning and performance management process” Promote a “culture of preparedness”

  29. Continuity of Operations Plan • Required to meet VDEM guidelines/content • Updated annually • Brief applicable personnel with 60 days of hire • Conduct training for leadership and key personnel • Maintain a roster of key agency personnel • Conduct an annual test or exercise with AAR • Submit to VDEM April 1st for review

  30. Annual Preparedness Assessment • Each agency must respond to a state preparedness assessment by Oct. 31st • Given a grade that is reported on a letter to the College or University President

  31. Emergency Action Plan • Requirement for all colleges and universities • Board of Visitors must formally adopt the plan • Plan must be reviewed every four years • President and Vice President must annually • Review the plan • Certify in writing that the plan has been reviewed • Make recommendations to the plan as necessary • Conduct a functional exercise!!!

  32. Questions? Julie Zobel Assistant Vice President, EHS jzobel@gmu.edu (703) 993-8630 David Farris Director of Emergency Preparedness and Response dfarris@gmu.edu (703) 993-2507 Environmental Health and Safety Office ehs.gmu.edu

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