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Comprehensive Safety Plan

1.0 Introduction

Radford University is committed to an environment that is free from recognized safety hazards and complies with applicable laws concerning hazardous chemicals, radiation, fire prevention, occupational health & safety, asbestos abatement, and handicapped accessibility. To effectively meet the goal of reducing accidents and illnesses the university has developed this Comprehensive Safety Plan. The Plan is managed by the Environmental Health and Safety Office and reviewed annually to meet the appropriate needs of the university. The purpose of the plan is to provide guidance and direction for the environmental health and safety program at the university.

2.0 Safety Policy

Protecting the health and safety of employees, students, visitors, and the environment is of primary concern to Radford University. This goal can be met by developing a comprehensive environmental health and safety program that strives to eliminate or reduce hazards. Radford University takes an active role in identifying hazards before injuries and illnesses occur. An effective safety program can benefit the university community by reducing illnesses and injuries to personnel, preventing property damage, and preserving the environment. Radford University will make every reasonable effort to promote, create, and maintain a safe and healthful environment through adherence to basic safety principles, sound management practices, and compliance with applicable federal, state, and local standards. A written Safety Policy, approved by the president of the university and the University Safety Committee, has been developed. The policy outlines the basic responsibilities for environmental health and safety concerns at the university. It stresses that every effort will be made to reduce accidents, confirms compliance with applicable health and safety regulations, and emphasizes the university's commitment to a safe and healthful operation.

3.0 Organization

University Safety and Health Committee

A University Safety and Health Committee has been developed to oversee the Environmental Health and Safety Program at the university. The Committee performs the following functions:

  • Reviews inspections, accidents, and employee complaints.
  • Recommends, reviews, and approves policies, regulations, and manuals.
  • Increases safety awareness and encourages compliance with safety rules.
  • Recommends corrective actions.
  • Monitors the operation of facilities and users.
  • Reviews violations for failure to comply with regulations.
  • Evaluates the effectiveness of the environmental health and safety program.
  • Analyzes accident and injury data with the goal of reducing accidents.

Members include the Fire Safety Inspector, Safety Manager, Environmental Inspector, Facilities Director, and representatives from academia, housekeeping, facilities management, laboratories, and the student body. Subcommittees concerned with specific hazards are formed from the main Committee as needed. Meetings are held quarterly.

Environmental Health & Safety Office

The purpose of the Environmental Health and Safety Office is to ensure the safety and physical well being of the faculty, staff, and students at the university. The program's overall objective is to reduce the number and severity of illnesses and injuries on campus by reducing or eliminating hazards. This objective is achieved through inspections, environmental surveillance, training, hazardous chemical management, and plans review. These efforts are channeled into several specialty areas including: fire protection, radiation safety, hazardous materials management, laboratory safety, occupational health & safety, asbestos management, and environmental health.

Environmental Health & Safety Manager

The University Environmental Health & Safety Manager ensures that faculty, staff, and students are provided with a working/living environment that is free from physical harm by identifying and correcting possible hazards related to the daily operation of the university. The Safety Manager develops, implements, and maintains university safety regulations to ensure compliance with applicable OSHA, NRC, EPA, DOT, NFPA, and State requirements. Reporting to the Director of Facility Planning & Construction,  the Safety Manager is responsible for managing the university's safety programs, including environmental hazards, asbestos, hazardous waste, emergency response, radiation safety, fire safety, general safety, and safety training.

Fire Safety Inspector

The University Fire Safety Inspector inspects all buildings on campus to ensure compliance with both state and OSHA fire code regulations. The Fire Safety Inspector prepares reports indicating areas that are not in compliance with applicable regulations, performs tests and inspections of fire alarm systems and fire protection equipment, and reviews construction proposals for code compliance. The Fire Safety Inspector reports to the Safety Manager.

Environmental Inspector

The Environmental Inspector ensures compliance with applicable environmental laws, maintains the university's Pollution Prevention Plan, provides assistance with OSHA, EPA, DOT inspections, performs industrial hygiene sampling, chemical hygiene inspections, and maintains and develops asbestos, lead paint programs. The Environmental Inspector reports to the Safety Manager.

Structure

The Environmental Health and Safety Office reports to the Director of Facility Planning & Construction who reports to the University President. The program is recognized and supported by top level management and appropriate funds are provided for environmental health and safety concerns.

Employee Participation

In order to have an effective health and safety program, employee participation and cooperation are essential. Employee support is actively sought through employee safety committees, suggestion programs, workplace inspections, participation in writing rules, and training sessions. Employee safety committees are actively encouraged and supported. Small employee safety committees are organized by the Safety Office to directly solicit employee input into the safety program. Employees select their own representatives and meet monthly or quarterly to discuss safety concerns with the Safety Manager.

An employee suggestion program has been created to allow employees to anonymously cite safety problems and offer corrective actions. Employees are encouraged to develop their own safety training sessions on a voluntary basis. Consideration is also being given to allowing employees to identify and correct hazards in their work areas by conducting routine inspections. Employee comments are actively sought by the Safety Manager when writing safety rules and regulations.

Memberships

The university is a member of the National Fire Protection Association, National Safety Council, American Society of Safety Engineers, and the American Industrial Hygiene Association.

4.0 Functions of the Safety Office

The Environmental Health and Safety Office conducts inspections, performs industrial hygiene sampling, recommends methods to correct hazardous conditions, develops procedures, provides training to employees and students, investigates accidents and occupational illnesses, maintains records, and monitors and evaluates program performance. The purpose of the program is to improve the safety and health of the work environment by reducing hazardous condition that can cause occupational illnesses and injuries. The safety office strives to accomplish its goals by gaining the cooperation of employees through guidance and counseling rather than enforcement. Top management has made the commitment to allocate resources, develop programs, provide training, and provide the necessary personal protective equipment to ensure a safe and healthy work environment.

Inspections

To ensure that the university's policy for a safe and healthy environment is carried out, the Environmental Health and Safety Office conducts periodic inspections of all campus facilities. The goal is to reduce accidents and injuries by eliminating or reducing safety and health hazards, and examining unsafe practices among employees. Inspections also ensure compliance with OSHA, NRC, NFPA, BOCA, EPA, and applicable state and local codes. At least every six months the Safety Manager and Fire Safety Inspector conducts a comprehensive safety inspection of all campus facilities. Certain high risk areas such as laboratories may be inspected quarterly. Informal cursory inspections may be conducted monthly. Written reports listing the problems discovered and recommended corrective actions are sent to the Department Head or supervisor in charge of the area. Work orders are sent to Facilities Management to correct problems that are their responsibility. Typically, imminent hazards must be corrected immediately, serious violations within 30 days, and non serious violations within 60 days. Departments are expected to use their own funds to correct minor problems or seek a budget adjustment for more expensive items. Re-inspections are conducted by the Safety Office to ensure that deficiencies are corrected.

Problems are resolved by written or oral consultation with employees, supervisors or department heads. It is rarely necessary to pursue matters to a higher level of authority. In some instances conflicts may be brought before a committee for resolution. For example, the Radiation Safety Committee must enforce NRC regulations on campus. Unsafe acts conducted by employees are discussed with the employee and/or immediate supervisor. The Safety Office has the authority to shut down operations that are an imminent hazard to life, limb, property, or the environment.

In addition to in-house inspections, the university is routinely inspected by the State Fire Marshal's Office and the Insurance Carrier. The university is also subject to unannounced inspections from the Virginia Department of Labor, State Bureau of Radiological Health, State Bureau of Hazardous Waste Management, the Nuclear Regulatory Commission, and the Environmental Protection Agency. Reports from these agencies are forwarded to the Safety Manager.

Written Safety Rules and Policies

To ensure safe work practices in all campus activities the Safety Manager ensures that appropriate environmental health and safety rules and regulations are written and communicated to employees and students. Written rules and regulations set standards for safe work practices, establish a basis for disciplinary actions, and demonstrate good intent and program control to regulatory agencies. Several safety manuals and procedures have been written for employees and are part of this Safety Plan. Greater emphasis in the future will be placed on developing safety rules and regulations for students who are engaged in hazardous operations. The Safety Manager also plans to conduct job safety analysis to develop safety procedures for specific operations and jobs. Input from affected departments is sought by the Manager when developing safety rules and regulations.

Safety Training

Ensuring that employees and students receive proper safety training is an important function of the safety program. The Safety Manager is responsible for ensuring that employees are adequately trained in safety practices. Professors are responsible for training students exposed to hazardous conditions. The Safety Manager works with professors to ensure that students receive proper training. Several safety training programs are OSHA mandated such as Hazard Communication, Bloodborne Pathogens, Respiratory Protection, Hearing Protection, Lockout/Tagout, Confined Space, and Laboratory Safety. These programs are normally developed and taught by the Safety Manager. Training is documented and conducted by lecture and safety video tapes. Employees have an opportunity to ask questions. In addition, the Safety Manager conducts training sessions in general safety topics such as ladder safety, office safety, slips and falls, safety equipment, and the use of personal protective equipment. On occasion safety training may be conducted by other qualified persons. Training is conducted when a new employee is hired or transferred to a new job, when new equipment is installed or a new task is assigned, or any time a lack of employee knowledge or skill is creating accidents or hazards. Supervisors are responsible for ensuring that employees posses the necessary knowledge and skills to safely operate machinery and equipment in their area.

The Safety Manager is developing a safety and health orientation program for all new employees. This program will instruct employees in the general health and safety regulations on the campus, employee rights, organization of the campus safety program, general emergency procedures, and the employee's responsibility in accident prevention. Specific training will be given before employees begin their new jobs.

Accident Investigations

All work related accidents and incidents are investigated or reviewed by the Safety Manager, in cooperation with supervision, to determine the causes and to recommend corrective actions to eliminate or minimize the event. An Accident Investigation Form (PDF) is used . All accident reports are filed with the Human Resources Department and a copy of the First Report of Injury is sent to the Safety Office for review. Emphasis is placed on the importance of reporting all accidents and incidents to supervision, whether they result in personal injuries, illnesses, property damage, or near misses. Accident investigations are based on fact finding, not fault finding. Based on the investigation conducted by the Safety Office the following actions may be taken:

  • A work order may be executed to make appropriate repairs to eliminate or control a hazard.
  • The employee may be counseled about safe practices.
  • A safety program may be created to include procedures and training.
  • Personal protective equipment may be issued.

Recordkeeping

Environmental health and safety regulatory agencies require employers to maintain certain records. The maintenance of good records is important in showing control over safety programs, defending the university against law suits, monitoring the effectiveness of the safety program, analyzing accident trends, and justifying program expenditures. The Safety Manager maintains employee training records, inspection reports, accident investigations, industrial hygiene reports, environmental reports, and hazardous waste manifests. The Human Resources Department maintains records on occupational injuries and illnesses (OSHA forms, 200 and 101), and medical records.

Program Monitoring and Evaluation

The Safety Manager and the Director of Facility Planning & Construction monitors routine activities of the safety program to ensure they are carried out as planned. The purpose of monitoring is to identify potential problems early so that appropriate corrective actions can be taken. The status of the following activities is routinely checked:

  • Routine inspections of facilities and equipment are performed at agreed upon frequencies.
  • Re-inspections are conducted in a timely manner to monitor progress toward compliance.
  • Accident and incident investigations are fully completed.
  • Proper training is given when new employees are hired or their job changes.
  • Rules and regulations are updated as needed.
  • Required records are kept up-to-date.
  • Regular safety meetings are held.

The direction, effectiveness, and efficiency of the safety program are periodically evaluated by the Safety Manager, Director of Facility Planning & Construction. Since the overall goal of the safety program is to reduce the number and severity of illnesses and injuries, the Safety Manager periodically examines accident reports to compare present statistics with the past. These data may point out areas of program success or failure and can be used to evaluate the effectiveness of the safety program. Additional funds staffing, or a change in direction may be indicated. In addition to an internal evaluation, the Safety Office mails an annual evaluation form to departments soliciting opinions and suggestions to improve safety services to the campus community.

5.0 Laboratory Safety

Program

Exposure to chemicals can cause serious health effects such as skin rashes, cancer, organ damage, and birth defects. In addition, some chemicals are safety hazards with the potential to cause fires and explosions. To protect employees and students from hazards associated with the use of chemicals in laboratories and to ensure compliance with OSHA standards the university has developed a comprehensive Laboratory Safety Program.

Chemical Hygiene Plan

The foundation of the program is a Chemical Hygiene Plan that describes the hazards associated with various classes of chemicals, safety procedures, personal protective equipment, safety equipment, and emergency procedures. The goal of the Plan is to reduce illness and injuries from exposure to hazardous chemicals used in laboratories. A copy of the Chemical Hygiene Plan is located in all laboratories that use hazardous chemicals. The plan has been approved by the University Safety Committee and the Laboratory Safety Committee.

Chemical Hygiene Officer

The Chemical Hygiene Plan requires that an individual be designated as a Chemical Hygiene Officer. This person is qualified by training or experience to provide guidance in chemical and laboratory safety. The Safety Manager will serve as the Chemical Hygiene Officer for the university. The Safety Manager inspects laboratories, using the laboratory inspection worksheet (PDF) for compliance with the Chemical Hygiene Plan on a quarterly basis.

Training

Training is also a key to assuring the safe operation of laboratory facilities. Students receive training in laboratory safety principles before working in laboratories. Professors are responsible for training students and assuring safe practices in laboratories. Students receive a handout that describes general laboratory safety procedures (PDF). The Safety Manager is responsible for ensuring that workers receive proper training in handling hazardous chemicals. Training materials are selected from the Chemical Hygiene Plan.

Laboratory Safety Committee

The University Health and Safety Committee regulates the safe use of chemicals in laboratories. A laboratory safety committee that reports to the main Committee is created as needed to handle specific concerns in laboratory safety (e.g., approval of the Chemical Hygiene Plan).

Spill Equipment

Several small kits for handling chemical spills are located throughout the facility. These kits contain materials such as spill socks and pillows, bulk absorbent materials, gloves, plastic bags, and scoops. Additional equipment is located in the Safety Office and the Emergency Response Van. Laboratory personnel are permitted to clean up small spills of relatively non-hazardous materials. Laboratory personnel are instructed to notify the Safety Manager for handling large spills. A mercury spill kit is also located in the Chemistry Department.

Personal Protective Equipment

Personal protective equipment is required when hazards cannot be controlled by engineering or work practice controls. Several types of personal protective equipment are available to reduce exposure to hazardous chemicals. These include eye protection, gloves, protective aprons, and respirators. Wrap-around plastic safety glasses and chemical splash goggles are available to students and workers for protection from potential splashes and explosions. These glasses are ANSI Z87.1 approved. Adequate gloves and aprons are available to protect personnel from contact with hazardous chemicals.

Respiratory equipment is NIOSH approved. Safety equipment is chosen in cooperation with the Safety Manager. It is the responsibility of the faculty teaching the course to ensure that students and laboratory assistants are trained and use the proper personal protective equipment.

Safety Equipment

The safe operation of a laboratory depends on the proper use of laboratory safety equipment. This equipment is designed to protect personnel from injury and minimize damage if an accident occurs. Essential to safety in a laboratory is adequate equipment to fight or prevent fires. Portable ABC fire extinguishers are located in all laboratories. A Class-D reactive metal fire extinguisher is located in the chemistry department. Two flammable liquids storage cabinets and an explosion proof refrigerator are located in the chemistry department. In addition, fire blankets are located in several laboratories. Safety showers and eyewash units are located in all laboratories using hazardous chemicals. Showers and eyewash units are tested every six months by the Safety Office. Eyewash units are tested weekly by laboratory personnel. An adequate number of first aid kits are available to laboratory personnel. First aid kits are inspected periodically and restocked by laboratory personnel. All safety equipment is purchased and located with the cooperation of the Safety Manager and/or Fire Inspector.

Laboratory Fume Hoods

Thirty-nine chemical fume hoods (PDF) are located in the Chemistry, Biology, and Geology Departments. Face velocities are tested every three months by the Safety Office using a Dwyer Thermal Anemometer. Acceptable face velocities are 100-125 fpm at a sash opening of 12-18 inches. Unacceptable face velocities are reported to Facilities Management for repair.  A laminar flow hood is located in the Biology Department. This hood is inspected yearly by a licensed contractor.

Flammable Liquids Storage

Bulk quantities of flammable liquids are stored in a flammable storage room. This room contains explosion-proof lighting, a separate ventilation system, and a sill across the door to contain spilled liquids. Two flammable liquid storage cabinets are located in the Chemistry Department. One liter of flammable liquids is allowed outside of the flammable storage cabinet.

Compressed Gases

Compressed gas cylinders are stored and handled according to OSHA regulations. Cylinders are secured by a chain. Oxidizers and flammable gas cylinders are separated by 20 feet in storage. Proper protective clothing such as goggles, face shields, rubber gloves, and aprons are worn when handling acid, alkaline, and toxic gases.

6.0 Biosafety

Microorganisms

Safe methods for handling Biosafety Level 1 and 2 infectious agents in the laboratory have been developed. Protection of personnel is provided by good microbiological techniques, the use of appropriate safety equipment, and proper waste management practices. Infectious microorganisms are handled according to procedures recommended by the CDC/NIH Biosafety in Microbiological and Biomedical Laboratories. Only Biosafety Level 1 and 2 microorganisms are used in teaching laboratories at the university. Standard microbiological practices are followed. Procedures that may create aerosols are performed in a biological safety cabinet. Waste is steam autoclaved. Instructors are responsible for ensuring that safe practices are followed.

Vertebrate Animals

The university is committed to maintaining high standards for the care and use of animals in research and teaching. A manual has been written that describes policies and procedures for the housing, care, and use of animals at the university. Radford University accepts the HHS Principles for the Care and Use of Laboratory Animal Subjects, and the NIH Guide for the Care and Use of Laboratory Animals. The Institutional Animal Care and Use Committee (IACUC) is responsible for assuring university compliance with these guidelines. Approval must be obtained from the IACUC before work with animals can begin.

Human Subjects

Procedures have been developed that require the review and approval of all activities involving the use of human subjects in research. Approval of the University's Committee for the Review of Human Subjects Research must be obtained prior to initiating a research project involving human subjects. Proposed research is reviewed based on three categories of risk developed by the U.S. Department of Health and Human Services.

7.0 Radiation Safety

Program

State and Federal regulations require that the use of radioactive materials and radiation producing equipment be licensed and carefully monitored. The purpose of the Radiation Safety Program is to ensure that faculty and students use radioactive materials and equipment safely in university laboratories, and keep exposures to radiation at a level that is as low as reasonably achievable.

Radiation Safety Committee

The Radiation Safety Committee regulates the safe use of radioisotopes, x-ray equipment, and non-ionizing radiation on campus. The Committee develops university regulations and oversees their use, approves all applications for the use of radioisotopes and x-ray equipment, and monitors the operation of the facilities and users. Members are selected based on their experience in the safe handling of radioactive materials, x-ray equipment, or non-ionizing radiation. An individual with administrative responsibilities serves as Chair of the Committee. The Radiation Safety Officer is an ex-officio member of the Committee. The Committee meets at least quarterly.

Radiation Safety Officer

The Safety Manager serves as the Radiation Safety Officer for the campus. The Radiation Safety Officer supervises the university's Radiation Safety Program and advises others in the safe use of ionizing and non-ionizing radiation. The Radiation Safety Officer is responsible for the purchase, receipt, and delivery of radioisotopes, inspecting equipment and laboratories to ensure safe practice and compliance with applicable regulations, personnel monitoring, maintaining licenses, and proper waste disposal.

X-ray Equipment

The Geology Departments maintains a closed beam analytical x-ray system that is licensed and inspected by the State. To be in compliance with State regulations, the university has developed an Analytical X-ray Equipment Safety Manual. This manual describes the radiation safety program and regulations for the safe use of the equipment. In addition, training material is included that describes the general properties of ionizing radiation, radiation detection equipment, personnel monitoring devices, biological effects, radiation hazards, and procedures to minimize exposure. Users of analytical x-ray equipment are required to read the manual and pass a test administered by the Safety Manager. Analytical x-ray equipment is inspected every six months by the Safety Manager to ensure compliance with State and university regulations.

Radioisotopes

To ensure that radioisotope are used properly at the university a Radioisotope Safety Manual has been written. This manual describes the radiation safety program at Radford University, fundamentals of radiation, safety procedures, methods to reduce exposure, and State and university regulations concerning the safe use of radioactive materials. Users of radioactive materials are required to read the manual and pass a written test administered by the Safety Manager. The safety manual also describes proper procedures for handling radioactive waste. Short-lived radioisotopes (less than 90 days) are held for decay and long lived isotopes are sent to a licensed facility. The radioisotope program at the university is licensed by the State Bureau of Radiological Health and the Nuclear Regulatory Commission and is subject to inspections from these agencies. The Safety Manager also conducts periodic inspections of facilities and users to ensure compliance with State and university regulations. Radioisotopes are currently not being used at the university

Lasers


A manual for the safe use of lasers has been developed. This manual is based on safety recommendations issued by the American National Standards Institute. Hazards associated with the use of lasers and safety guidelines are included. The laser safety program provides training to personnel and ensures that hazardous systems are operated safely. For example, all lasers must be registered with the Safety Office, Class III and IV lasers are required to be operated in a laser controlled area, and users must wear appropriate eye protection. Users of Class III and IV lasers are required to read the manual and pass a test administered by the Safety Manager. The Safety Manager conducts periodic inspections of laser systems to ensure compliance with the safety regulations in the manual.

Microwave Ovens

Microwave ovens are inspected annually in the Resident Halls by the Safety Office to ensure that leakage is below federal limits. Ovens not meeting leakage standards are removed from service.

Dosimetry program

Individuals exposed to radiation in excess of 10% of a legal limit receive a personal monitoring device. Thermoluminescent type dosimeters are used at the university. Badges are purchased from a certified dosimetry company and changed quarterly. The Safety Manager is responsible for managing the radiation dosimetry program at the university.

Radiation Monitoring Equipment

The Safety Manager conducts periodic surveys of facilities and equipment using a Ludlum Model 3 survey meter equipped with a low energy pancake probe. This instrument can detect alpha, beta, and gamma radiations. The instrument is calibrated yearly by a licensed facility.

8.0 Hazardous Waste Management

Program

Hazardous waste is strictly regulated by the Environmental Protection Agency under the Resource Conservation and Recovery Act. This Act mandates a "cradle-to-grave" system for managing hazardous waste. The purpose of the hazardous waste management program at Radford University is to protect human health and the environment from improper waste management practices.

The hazardous waste management program is designed to coordinate the collection, classification, analysis, packing, and shipping of waste chemicals generated at the university. The program is managed by the Safety Manager with the assistance of the Laboratory Manager. A Hazardous Waste Management Manual has been written that describes procedures to collect, store, and dispose of hazardous waste. Sections include responsibilities, waste reduction, definitions, restrictions, containers, proper storage, handling of hazardous waste, and procedures for chemical spills. Individual generators of hazardous waste are responsible for ensuring that waste is handled properly before pick up by the Safety Manager. Hazardous waste is disposed of at least twice a year by a licensed hazardous waste management service. Manifests are maintained by the Safety Manager. Required hazardous waste reports are completed by the Safety Manager.

Hazardous Waste Streams

The university is a small quantity generator producing between 100 and 1000 kg of hazardous waste per month. Several hazardous waste streams have been identified on campus. Departments producing hazardous waste include Printing, Art, Facilities Management, Chemistry, Biology, Boiler Plant, Drama, and Photography. The largest producer of waste is Facilities Management which generates approximately one 55-gallon drum of flammable liquids per month. Efforts are underway to reduce the quantity of these solvents. One approach being considered is the use of latex and low solvent paints. Darkrooms generate approximately 20 gallons of waste fixer per month. The university is planning to purchase a silver recovery unit to reduce the cost of disposal of this waste stream. Proper containers, labels, training, and a copy of the Hazardous Waste Management Manual are given to generators.

Emergency Response

Emergency procedures for hazardous waste spills have been written and are included in the Emergency Response Plan. Several spill kits have been distributed to departments using chemicals. Individuals involved in hazardous waste management are trained in the proper methods to handle a spill. The Safety Manager serves as the primary emergency contact in case of a spill.

Waste Minimization

A waste minimization plan has been written that outlines procedures departments can use to reduce the amount of hazardous waste generated at the university. This Plan is included in the Hazardous Waste Manual. Recommendations include the purchase of smaller quantities, using less toxic materials, recycling, maintaining a chemical inventory to reduce duplicate purchases, cleaning out old stocks to remove potential explosives, and the use of microscale techniques in laboratories. These procedures have been issued to all affected departments.

Training

The Safety Manager has taken the 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER) course. This course allows the Safety Manager to conduct training at the hazardous materials awareness, operations, and technician level. Police Officers and Facilities Management employees are trained at the awareness level. The Laboratory Manager is trained at the technician level. Generators are trained at the appropriate level depending on their involvement with hazardous waste.

Storage

Satellite storage areas are located in the Chemistry Department, Facilities Management, Art Department, and darkrooms. Waste is properly stored in these areas and then taken to two storage lockers behind the Boiler Plant before disposal by a licensed hazardous waste firm.

Infectious Waste

Infectious waste containing human blood or other potentially infectious materials are double bagged in red plastic bags and disposed by a licensed firm. Disposal sites are located in Student Health, and the Athletic Training Room. Infectious waste is either steam autoclaved or incinerated. Manifests are maintained by the Safety Office. Small quantities of infectious waste generated in microbiology laboratories are steam autoclaved on-site.

9.0 Fire Safety

Responsibilities

The Campus Fire Safety Inspector is responsible for ensuring that all university facilities comply with applicable fire codes. This is accomplished by on-site inspections, review of proposed construction plans, and ensuring that recommendations made by the Virginia State Fire Marshal's Office are completed. The Fire Safety Inspector also provides training in fire safety to all departments on campus, investigates fires on campus for cause and origin, and ensures that fire safety systems are properly installed, tested, and maintained in a safe and operational condition. The Fire Safety Inspector reports directly to the University Safety Manager.

Fire Safety Plan

A Fire Safety Plan has been developed for the university. The Plan is designed to provide instructions for identifying, monitoring, and addressing fire safety issues at Radford University. The Plan describes emergency procedures, drills, inspections, training, and procedures to use in the event of a fire. In addition, the Fire Safety Plan describes duties and responsibilities of building wardens, floor wardens, campus police, and provides for notification of campus administrators and decision making authority. The Plan is evaluated and revised annually by the Safety Manager and the Fire Safety Inspector.

Reporting a Fire


Pull alarm stations are located throughout the major buildings on campus. If an alarm is heard in the Residential Halls, the building and/or floor warden will call the fire department at 911 and the campus police at 1-5500. Building and/or floor wardens will assist in the evacuation of the floor, close all doors, keep all persons at a safe distance from the building, and direct the fire department to the scene of the fire. In academic buildings, the Fire Safety Inspector shall perform these duties. The senior fire safety person at the scene will decide when the building can be re-entered. Individuals in buildings without pull stations will call the fire department directly.

Fire Department

The Radford City Fire Department is located approximately two miles from campus. Traveling time is 3-5 minutes. The department maintains a full time staff of seven and a volunteer staff of  thirty. The Radford City Fire Department has two pumper trucks, a mini-pumper, one utility truck, a pickup truck, and a 95-foot aerial platform.

Drills


Fire drills in the residential halls are conducted monthly by the Resident Directors in cooperation with the Fire Safety Inspector and Building Wardens. The Building Warden issues a report to the Fire Safety Inspector. Fire drills in academic buildings are conducted as needed under the supervision of the Fire Safety Inspector.

Fire Suppression Equipment

The university maintains appropriate fire suppression systems in each building to include: fire extinguishers, sprinkler systems, standpipes, interior hose packs, automatic halon extinguishing systems, and fire hydrants strategically placed throughout the campus. Approximately 1000 portable fire extinguishers are located on campus. The Fire Safety Inspector is responsible for training, inspecting, testing, and refilling fire extinguishers. Fire extinguishers are inspected monthly. An inventory of all fire extinguishers on campus is maintained by the Fire Safety Inspector. Currently, code numbers are placed on all fire extinguishers. The possibility of using a bar-code system for marking extinguishers is being explored. Building and Floor Wardens assist the Fire Safety Inspector in the Resident Halls.

Approximately 50 standpipes are inspected every year for water flow by personnel in Facilities Management. Automatic sprinkler systems are located in the following buildings: Dalton, Russell, Norwood, Muse, Preston Stage, Porterfield Stage, Davis hall, and the Dedmon Center. All systems are inspected quarterly by an outside contractor. Fire suppression systems in the kitchens are inspected and cleaned by an outside contractor. Hoods and ducts are cleaned quarterly. Filters are inspected and changed as needed. Fusible links are replaced every six months. The Fire Safety Inspector conducts periodic inspections to oversee the work of the contractors.

Inspections of Buildings

All university buildings are inspected quarterly by the Fire Safety Inspector. These inspections include such items as fire extinguishers, fire alarms, and violations of fire and safety rules. In addition, annual inspections of heating units, electrical panels, large motors, and air-conditioning equipment are conducted by Facilities Management. Periodic inspections are also conducted by the State Fire Marshal's Office.

Reports

Deficiencies concerning unsafe conditions are issued to appropriate supervisors in Facilities Management for correction. Re-inspections are conducted monthly by the Fire Safety Specialist. Deficiencies not corrected are reported to the Safety Manager. Violations concerning unsafe acts are reported to the individual and his/her immediate supervisor. Failure to comply with fire safety regulations may lead to disciplinary actions including possible dismissal.

Building Wardens

A building warden is designated for each residential building. Trained by the Fire Safety Specialist, the building wardens provide safety education to residents, inspect buildings for compliance with fire regulations, assume responsibility for building evacuation, and offer assistance in case of fire. Residential buildings are also assigned floor wardens who assist in inspections, and evacuations. The Fire Safety Inspector serves as building warden for the academic buildings, with monthly inspections assigned to a building fire and safety Manager who is a building occupant. Monthly inspection reports are returned to the Fire Safety Inspector for review.

Evacuation Routes


Evacuation routes have been placed on each floor and in classrooms of every building showing emergency exits and escape routes, as well as locations of fire extinguishers and fire alarms. Posting evacuation plans in buildings improves awareness of fire evacuation routes. According to Campus surveys, 29% of administrative faculty, 35% of faculty, 44% of part-time faculty, and 30% of classified staff said they were not adequately informed of their building's emergency evacuation procedures.

Fire Detection Equipment

Fire alarm systems are installed, repaired, and routinely tested by the Safety Office and Facilities Management. Smoke detectors are located in all Residence halls. Hard-wired detectors are located in the halls and battery operated detectors are located in the rooms. Battery powered smoke detectors are located in off-campus buildings. In addition some smoke detectors are connected to fire doors. Battery-operated smoke detectors are inspected annually and the batteries changed. Hard-wired smoke detectors are inspected semi-annually. Overhead halon systems located in computer rooms are inspected every six months by an outside contractor.

10.0 Occupational Safety

Personal Protective Equipment

Procedures for the use of personnel protective equipment (PPE) have been written. PPE is required to protect workers from workplace hazards and contaminants when engineering and administrative controls are inadequate. The need for PPE is decided by the Safety Manager in cooperation with supervision. All PPE is approved by the Safety Manager. Management may determine specific types of safety equipment based on price, comfort, and style. Personnel are trained by the Safety Manager in the proper use and maintenance of PPE. Personal safety equipment, except safety shoes and prescription safety glasses, is supplied by the university at no cost to employees. Employees are expected to wear assigned PPE and are subject to disciplinary action for not wearing the equipment.

The following types of PPE are available to workers at the university:

1. Protective eye and face equipment is required where there is a reasonable probability of injury to the eyes. Tasks include using hand and power tools, handling toxic or corrosive chemicals, grinding, welding, and machine operations. Eye and face equipment meets the requirements of ANSI Z87.1.

2. Protective hard hats are worn whenever there is possible danger of head injury. Hard hats are worn to protect workers from falling objects such as tools, bricks, boards, equipment, building materials, and scaffolds. Protective helmets meet the requirements of ANSI Z89.1.

3. Proper safety shoes are required in areas where there is a reasonable probability of falling objects or slipping. Safety shoes with steel toes are worn by employees routinely exposed to objects weighing more than 15 pounds. Slip resistant shoes are required in areas that have a high potential for slippage, e.g., kitchens. Safety-toe footwear meets the requirements of ANSI Z41.1.

4. Hearing protective devices such as ear plugs, canal caps, and ear muffs are worn by employees exposed to noise levels above 90 dB TWA. Employees exposed to noise levels above 85 dB TWA are enrolled in a hearing conservation program. The Safety Manager conducts noise surveys of the workplace using a Simpson Sound Level Meter Type S2A to determine employee exposure.

5. Employees exposed to an elevated fall hazards higher than 6 feet are provided with safety harnesses securely attached to a lifeline or part of the structure.

6. Protective clothing is worn to protect workers from potential harm to the body from exposure associated with hazardous work. Employees who handle corrosive or toxic chemicals are issued suitable protective clothing.

7. Employees are protected by suitable gloves when it is necessary to protect the worker from rough, sharp edged objects, temperature extremes, toxic or corrosive chemicals, infectious agents, and energized electrical equipment. Rubber protective gloves used by electrical workers conform to ANSI standards.

Lockout/Tagout

The university has established a lockout/tagout program to ensure that equipment is isolated from potentially hazardous energy, and locked and tagged out prior to maintenance. The program includes procedures for shutdown, equipment isolation, lockout/tagout, release of stored energy, verification of isolation, and training. Tags, individual locks, gang locks, valve locks, plug locks, and chains have been purchased. Training is provided by the Safety Manager to ensure that the purpose and function of the energy control program are understood by affected employees. Periodic inspections are conducted by the Safety Manager to ensure compliance with lockout/tagout procedures.

Electrical Safety

This program addresses electrical safety requirements that are necessary for the safeguarding of employees in their workplaces. The program is designed  to address concerns that electricity is a serious workplace hazard, exposing employees to electric shock, electrocution, fires and explosions. This program covers electrical safety work practices for qualified and unqualified persons. Qualified persons are those who are familiar with the construction and operation of the equipment and the hazards involved. They are permitted to work on or near exposed energized parts and have been trained in avoiding electrical hazards. Unqualified persons are those with little or no such training.

Confined Spaces

Procedures have been written to allow workers to safely enter confined spaces. Confined spaces have small openings, are not meant for human occupancy, and may contain a hazardous atmosphere (e.g., manholes). Before entering a confined space the atmosphere is tested for oxygen, combustible gases, and toxic gases using a Lumidor GasPro Plus Monitor. Testing is performed by the Safety Manager or other qualified individual. All personnel involved in confined space work receive appropriate training in hazard recognition, personal protective equipment, communications equipment, and rescue procedures. Training is conducted by the Safety Manager. An entry permit is completed by a qualified person before entering the confined space. Appropriate rescue and ventilation equipment has been purchased. The Radford City Fire Department serves as the rescue team in case of an emergency. The Safety Manager visits sites to ensure that an entry permit has been completed and workers are wearing proper rescue equipment.

Fall Protection

A Fall Protection Program has been written for the university to ensure that employees are protected from fall hazards greater than six feet. Each year, falls consistently account for the greatest number of fatalities in the construction industry, and are a major concern in other industries. Events surrounding these accidents involve a number of factors, including unstable working surfaces, misuse of fall protection equipment, and human error. The use of guardrails, fall arrest systems, safety nets, covers, and travel restriction systems can prevent many deaths and injuries. A training program has been developed that covers fall protection systems such as guardrails, safety nets, personal fall arrest systems, warning line systems, safety monitoring systems, and covers. The proper use of safety harnesses, lanyards, rope grabs, and safety lines are also discussed and demonstrated.

Tools and Equipment

Accident prevention begins with the proper inspection use, and storage of tools and equipment. A program is planned to ensure that tools and equipment are used safely. The Safety Manager will develop procedures and train affected employees. Emphasis will be placed on selecting the right tool for the job, using tools correctly and safely, keeping them in good condition, and storing them properly. Power tools are inspected for proper cords, plugs, and grounding pins. Procedures and training are planned for safely using ladders, scaffolds, woodworking machines, and providing proper guarding on machines.

Materials Handling and Storage

Procedures have been written for materials handling and storage. The Safety Manager conducts training classes in proper lifting techniques and back injury prevention. An adequate number of material handling equipment is present such as carts, drum trucks, and hand trucks. The Safety Manager plans to conduct a Job Safety Analysis of tasks to ensure that materials are being handled properly. An ergonomics approach to materials handling is also being actively pursued. Examples include reducing the size of the load, changing the height of a pallet or shelf, or installing a mechanical lifting aid.

Powered Industrial Trucks

A program has been developed to ensure that forklift trucks, pallet trucks, and motorized hand trucks are operated safely. Only qualified operators who have received training in safe operations are permitted to operate powered industrial trucks on campus. Training is conducted by the Safety Manager and an experienced driver. The training program consists of a lecture on proper procedures, video tape, and an evaluation of driving skills. Authorized drivers must pass a driving test. Powered industrial trucks are inspected before operation and receive regular maintenance as recommended by the manufacturer.

DOT Drug/Alcohol Testing for CDL Drivers

The university has developed a program for CDL drivers on campus that is conformity with Department of Transportation Regulations. The program is designed to prevent accidents from the misuse of alcohol or use of controlled substances.  The rule requires that covered employees be tested for five specific drugs as well as alcohol, and sets the times, terms, and conditions of testing. Pre-employment, random, post-accident, and reasonable suspicion testing are required. It mandates privacy in collection techniques, confirmation of positive results, collection of split samples, and confidentiality of results. The program also include provisions for treating employees in need of assistance due to misuse of alcohol or illegal use of controlled substances.

Excavation/Trenching

A program has been developed to protect employees from hazards that may be encountered while working in trenches and excavations. The program includes provisions for employee training, hazard identification and control, and safe work practices that must be followed while working in an excavation or trench.

Welding, Cutting & Brazing

Welding, cutting, and brazing are hazardous activities that pose a combination of both safety and health risks to workers. The risk from fatal injuries alone is more than four deaths per thousand workers over a working lifetime. Radford University has developed a program to protect workers from the hazards associated with these operations. The program covers fire prevention, confined spaces, protection of personnel, and ventilation.

Pressure Equipment

All pressure vessels such as boilers are inspected yearly by a licensed state inspector. Records are maintained by Facilities Management. Compressed gas cylinders are stored in compliance with OSHA regulations. Flammable and oxidizing cylinders are separated by 20 feet or by a 5-foot high wall that has a half-hour fire rating. Cylinders are secured by chains or wire cage while in storage. Empty cylinders are separated from full cylinders. Periodic inspections are conducted by the Safety Manager to ensure compliance with OSHA regulations.

Vehicles

All vehicles are inspected routinely by Facilities Management to ensure safe operation. A safety checklist is being prepared for mechanics to ensure that proper routine maintenance is performed. The Safety Manager plans to conduct defensive driving courses for campus personnel. All university owned vehicles on campus have safety belts and drivers are required to wear them.

Contractors

Contractors are expected to abide by applicable OSHA, EPA, and State regulations while on campus. Contractors must take steps to protect the health and safety of employees, students, and visitors while performing their work. Contractors must enforce safety rules among their employees and obey university safety rules. The University Safety Manager has the authority to shut down work that is deemed an imminent hazard. The Purchasing Department has the authority to stop operations if a violation of university procedures is noted. Prior to a contractor beginning work, a precontract performance conference may be held. Special safety conditions or restrictions concerning the job are discussed with the Safety Manager as well as an evaluation of the safety program of the contractor.

Ergonomics

The university recognizes the importance of designing the job and workplace to fit the worker. This allows work to be done with a minimum of physical and mental stress. Improving the design of the workplace can improve employee morale, increase productivity, and reduce injuries. The university is committed to improving the ergonomic environment in the workplace. The Safety Manager manages the Ergonomics Program at the university by analyzing work methods and work places using basic ergonomic principles, identifying ergonomic problems, establishing priorities, and resolving problems with the assistance of supervision. The Safety Manager will perform an Ergonomic Task Analysis of the workplace with the goal of collecting data to identify problem work environments and processes. Emphasis is placed on manual material handling and repetitive motion injuries.

Building Codes

To ensure compliance with building codes, plans for capital outlay projects and major renovations are review by the State Division of Engineering and Buildings, Fire Marshal's Office, and Radford's Planning and Construction Department. Plans are reviewed at Radford University by a Registered Architect, Professional Engineer, Certified Plant Engineer, Certified Construction Specifier, and a Licensed Asbestos Inspector. In-house projects are reviewed by Facilities Management in cooperation with the Safety Office.

Americans with Disability Act

The Americans with Disabilities Act (ADA) prohibits discrimination against disabled persons in public activities, services, or programs and became effective in July 1992. Compliance with the ADA is handled by the Human Resources Department and Facilities Management. To comply with the Act, Radford University:

1. Reviews policies and procedures regarding employment to ensure equitable treatment and reasonable accommodations for disabled applicants and employees.
2. Reviews and updates job descriptions to reflect the essential functions of the job and the minimum qualifications, including physical requirements.
3. Provides education to supervisors responsible for hiring and making work assignments regarding their responsibilities for providing reasonable accommodations.
4. Modifies buildings, restrooms, sidewalks, etc. to provide access to disabled persons.

First Aid Kits

First aid kits are located throughout the university in the housekeeping closets. Kits are readily available for all laboratory personnel. First aid kits in Facilities Management are stocked by the Safety Office.

11.0 Occupational Health

In addition to making the workplace safe for workers, the Safety Office works with supervisors and management to ensure that the workplace is free from recognized health hazards.

Industrial Hygiene

The Safety Office monitors the workplace to determine conditions that may have an adverse effect on health, are uncomfortable or irritating, or that may effect the ability of workers to perform their normal tasks. Several instrument are available in the Safety Office to monitor the workplace. These include air monitoring equipment, noise meter, radiation survey meter, light meter, gas meters, and an air flow monitor.

Indoor Air Quality

The Safety Office is responsible for responding to indoor air quality complaints. All complaints are investigated and an indoor air quality questionnaire is completed by complainants. Facilities Management works with the Safety Office in alleviating air quality complaints. If indicated, the Safety Manager can monitor the air for suspected contaminants using a Lumidor Gas Monitor, a Sensidyne Gas Detector and an air sampling pump.

Respiratory Protection

Radford University has developed a respiratory protection program to permit employees to work safely in hazardous atmospheres. This is accomplished by ensuring that employees are properly trained, the correct respirator is selected, employees are medically able to wear respirators, and respirators are cleaned and maintained properly. Respirators are issued to prevent overexposure to chemical hazards and when necessary to protect the health of the employee. The Safety Manager supervises the respiratory protection program and decides the need and type of respirator used by employees. Only NIOSH approved respirators are used. The Safety Manager ensures that respirators fit properly and that employees are trained in the proper selection, use, and care of respirators. Employees are evaluated by a physician to determine if they are physically able to perform the work while wearing a respirator. This review includes a brief health history and a pulmonary function test.

Wellness Programs

The university has a comprehensive wellness program for all Radford University employees. The CommonHealth Program has been in place at Radford University since 1989. The program offers free medical screening and educational programs. The purpose of the program is to reduce injuries and absenteeism, increase productivity, improve morale, and provide social benefits to employees. Emphasis is placed on the development of good habits that affect health and personal well being such as nutrition/weight loss, exercise/fitness, smoking cessation, back strengthening, safety, and stress management.

Employee Assistance Programs

To help employees cope with personal problems that could affect job performance and safety, the Commonwealth of Virginia has developed a State Employee Assistance Service (SEAS). The SEAS is a confidential counseling, assessment, and referral service available to employees at the university to help employees resolve problems. Services offered include mental health, financial assistance, substance abuse, family concerns, legal assistance, and marital concerns. Entry into the program is voluntary and offered at no cost to employees.

Asbestos

The Safety Office maintains the asbestos program at the university and coordinates the asbestos abatement program. The objective of the program is to identify and maintain, in safe condition, asbestos-containing material (ACM) that remains in university buildings. The Program also addresses emergency response procedures, recordkeeping requirements, and procedures for cleaning asbestos floor tiles. The management of ACM is an involved and ongoing process with observations, assessments, and possible response actions occurring daily. The program is designed for quick reference by maintenance and housekeeping personnel, campus contractors and vendors, and university employees. All buildings on campus have been surveyed for ACM. Campus areas containing ACM are identified on floor plans. Warning signs have been placed at all entrances to mechanical rooms containing ACM.

Notification is given to appropriate departments when an abatement project is planned. All maintenance and custodial staff are given a two-hour asbestos awareness training program. Except for floor tile removal, the university's Facilities Management Department does not perform asbestos abatement activities. Most asbestos removal is contracted out to a licensed asbestos abatement firm. Air samples and bulk samples are performed by a contractor. Maintenance workers are advised of the proper procedures to follow when they contact ACM. When building renovation activities are planned, the supervisor in charge provides a detailed assessment of the project area to see if any ACM will be encountered.

Lead

A program has been developed to ensure that employees are not overexposed to lead. Overexposure to lead is one of the most common overexposures found in industry with most over-exposures found in the trades, such as plumbing, welding, electrical work, carpentry, and painting. Significant lead exposures can also arise from removing paint from surfaces previously coated with lead-based paint, such as in renovation and demolition. The program applies to all construction work where an employee may be occupationally exposed to lead. Construction work is defined as work for construction, alteration and/or repair, including painting and decorating. In addition, a lead paint disclosure program was developed for the university.

Silica

A program has been designed to reduce or eliminate workplace exposure to crystalline silica at the university. Exposure to crystalline silica can cause silicosis, a serious lung disease.  The Safety Office plans to inspect the following work operations to determine if employees are exposed to silica above the PEL:

  • Sawing, hammering, cutting, drilling, grinding, and chipping of concrete or masonry
  • Chipping, hammering, and drilling rock
  • Dry sweeping or pressurized air blowing of concrete, rock, or sand dust
  • Crushing, loading, hauling, and dumping rock
  • Sandblasting
  • Demolition of concrete and masonry structures
  • Concrete mixing
  • Working with ceramics, clay, and pottery

Bloodborne Pathogens

An Exposure Control Plan has been developed for the university. This plan identifies workers who are at occupational risk for contacting blood or other possible infectious materials. The plan includes methods for reducing exposure and requires the use of universal precautions, engineering controls, work practice controls, and the use of appropriate personal protective equipment. Affected employees are trained by the Safety Manager or other qualified person on the requirements of the Standard and HIV, HBV, and HCV. Hepatitis B vaccinations are offered to select employees at risk for contacting blood as part of their job duties. The following departments include employees who are at risk: Student Health, Police, Athletic Trainers, Housekeepers, Lifeguards, and Nursing. Appropriate engineering controls and personal protective equipment have been distributed to affected departments. The Safety Manager conducts periodic inspections to ensure compliance with the Exposure Control Plan.

Pesticides

Procedures have been developed for the safe use and storage of pesticides. All pesticide applicators on campus are certified by the State of Virginia. Pesticide applicators use the lowest toxicity material that will do an adequate job. Restricted use pesticides and pesticides that are carcinogenic are not used on campus. Pesticides are properly stored according to State regulations. Eyewash units and emergency showers are located in storage areas. Warning signs are posted when pesticides are used. Applicators wear proper personal protective equipment to include respirators, goggles, and protective clothing as recommended by the manufacturer. Applicators are trained in the safe use of respirators and other personal protective equipment by the Safety Manager. The Safety Manager also trains users on the hazards associated with the use of pesticides. Pesticide containers are triple rinsed and the rinsate is placed back in the sprayer.

Sanitation

Standard operating procedures have been developed for the Dining Services. Procedures have been written for inspections, recognizing food contamination, and pest contamination. In-house sanitation inspections are conducted monthly by the Nutritionist and/or Unit Manager. Items covered include, food, food protection, personnel, food equipment and utensils, garbage and refuse disposal, insect, rodent, and animal control, floors, walls, and ceilings, lightning, and storage of toxins. A copy of the inspection is sent to the Dining Services Director with appropriate measures taken to correct deficiencies. Managers conduct periodic training sessions with all employees on sanitary food-handling practices and personnel hygiene. Insect and rodent control is handled by continual turnover of inventory, frequent cleaning, good screens on windows and doors, and spraying with insecticides. Dining facilities are inspected every six weeks by the Health Department and consistently receive an excellent rating.

12.0 Hazard Communication

The purpose of the Hazard Communication Program is to inform non-laboratory employees of chemical hazards they may encounter in the workplace and to provide measures to minimize exposures. The goal of the Program is to reduce the incidence of illness and injuries from chemical exposure.

Program

A written Hazard Communication Program has been developed for the university . The Program includes provisions for labeling, Material Safety Data Sheets (MSDSs), chemical inventory, and employee training. The Program covers such areas as maintenance of a hazardous chemicals inventory, provision of MSDSs for all hazardous chemicals, and training of employees. All new employees are required to attend an orientation session on working with hazardous chemicals. The Hazard Communication Program and MSDSs for hazardous materials are available for inspection by employees. The Safety Manager manages, reviews, and updates the Program as necessary. In addition to the written program, a Hazard Communication Safety Manual has been written for non-laboratory personnel. This manual describes the hazards associated with various classes of chemicals and methods to reduce exposures. Training sessions are developed from the information contained in the manual. A copy of the manual is kept in all affected departments.

Chemical Inventory

Chemical inventories are maintained by all departments that use hazardous chemicals. Inventories are periodically inspected by the Safety Manager to ensure compliance. The university is actively pursuing a method to centralize the purchase, receipt, and delivery of chemicals to departments on campus. A centralized system would ensure compliance with regulatory agencies and reduce the generation of hazardous waste.

Material Safety Data Sheets (MSDSs)


MSDSs are maintained by all departments that use hazardous chemicals at the university. The Safety Manager periodically inspects departments to ensure that MSDSs are available for all hazardous chemicals. MSDS files are maintained in the following departments: Chemistry, Biology, Physical Plant, Housekeeping, Dining, Recreation, Athletic, Drama, Printing, Photography, Student Health, Geology, and Geography. To ensure compliance with employee right-to-know requirements, the Safety Office has contracted with a fax-on-demand service for MSDSs.

Labeling

It is the responsibility of department supervisors to check incoming chemicals to ensure that they are labeled properly. Chemicals will not be accepted unless they contain the name of the chemical, hazard warnings, and the name and address of the manufacturer. Department supervisors will also ensure that secondary containers are properly labeled. The Safety Manager periodically inspects departments to ensure that labeling requirements are being met.

Training

Employees exposed to hazardous chemicals outside of laboratories receive training on the Hazard Communication Standard, physical and health hazards associated with chemicals, and methods to reduce exposure. Training is conducted by the Safety Manager. Training is performed at the time off the employee's initial assignment and whenever a new hazard is introduced into the workplace.

13.0 Environmental Health

The environmental health program strives for a healthier and cleaner environment through programs of toxic pollution reduction, air, water, and solid waste management, recycling, and energy efficiency. The Safety Manager conducts yearly environmental audits to develop general strategies for implementing environmental improvements.

Pollution Prevention

The university produces many waste streams including hazardous waste, spills and leaks, water discharges, obsolete inventory, municipal solid waste, air emissions, energy waste, and evaporative losses. To manage these waste streams the university has developed a Pollution Prevention Plan. Pollution prevention emphasizes reducing or eliminating these wastes at the source through efficient use or conservation of raw materials and energy. This includes all pollution: hazardous and nonhazardous, across all environmental media (air, water, soil) and from all sources. The second priority is to reuse or recycle generated wastes. As a last resort, pollution should be disposed of in a manner that reduces risk to public health, safety, and the environment. This plan identifies current pollution prevention practices and recommends additional methods to reduce or eliminate wastes generated at the university.

Hazardous Waste

A wide variety of hazardous waste is generated by the university. Departments generating hazardous waste include chemistry, biology, printing, art, theater, darkrooms, and the physical plant. The university has developed a hazardous waste management program to ensure that hazardous waste is handled properly, and a waste minimization program to reduce the quantity and toxicity of hazardous waste. Hazardous waste is disposed of through a licensed firm by incineration when possible. Radioactive waste is held on site for decay. Infectious waste is steam autoclaved or incinerated by a licensed firm. Questions asked during the yearly audit include:

  1. Which departments on campus generate hazardous waste and how much?
  2. How is hazardous waste stored and disposed of?
  3. What are the costs associated with hazardous waste disposal?
  4. What is being done to minimize the quantity of hazardous waste generated?

Air Quality

Universities can contribute to air pollution through releases of carbon monoxide, nitrogen oxides, sulfur oxides, lead and particulant matter, and toxic air pollutants from laboratories and physical plant operations. Possible sources include laboratory fume hoods, paint booths, vehicles, boilers, and steam plants. The university actively pursues methods to reduce air pollution. For example, to reduce toxic vapors released during painting operations the university is increasing its use of low solvent and latex paints. Questions asked during the yearly environmental audit include:

  1. What departments and sources emit air pollutants? Are these releases above government limits? Does a report have to be generated under SARA Title III?
  2. Are permits needed from air pollution agencies?
  3. What is being done to reduce or control the quantity of air pollutants generated on campus? Are alternatives being considered?
  4. What quantity of each pollutant is being released?


Water Quality and Use


All water coolers on campus have been tested for lead levels. Water coolers exceeding legal limits have been replaced with non-lead lined coolers. Toxic chemicals are not poured down the drain or into the environment where they could pollute drinking water or endanger the groundwater. Toxic chemicals are disposed of through a licensed hazardous waste firm. The university actively explores conservation measures to reduce the amount of water used on campus. For example flow restrictors are used on showers, and irrigation water is pumped from the New River. The following questions are asked during the annual audit:

  1. How much water does the campus use annually? Has it increased or decreased over the previous year?
  2. What percentage of water is used indoors versus outdoors?
  3. Is there a system to monitor for leaks or water efficiency?
  4. What type of irrigation system does the campus use?
  5. Is there a water conservation program on campus?
  6. Where does the campus water supply originate? What is the status of that supply?

Swimming Pool

All lifeguards and managers have received training in CPR/First Aid and OSHAs Bloodborne Pathogen Standard. All individuals who handle chemicals wear appropriate personal protective equipment when handling chemicals and have received Hazard Communication Training.

Aboveground and Underground Storage Tanks

Radford University has AST systems at three areas: the Boiler Plant, the Dedmon Center, and the Facilities Management area. An Underground Storage Tank (UST) system is also operated at the Facilities Management area. Two 50,000-gallon aboveground No. 2 fuel oil tanks are located at the Boiler Plant. These tanks are situated in separate concrete containment dikes with capacities of 60,000 gallons. A 10,000-gallon aboveground No. 2 fuel oil tank is located at the Dedmon Center. This tank is situated in a concrete containment dike with a capacity of 12,000 gallons. A 2,000-gallon aboveground diesel fuel tank, a 500-gallon aboveground used oil tank, and a 10,000 gallon underground gasoline tank are located at Facilities Management. The UST is equipped with overfill protection, spill containment basin, and a leak detection system. The diesel tank is equipped with a level gauge and overfill protection system. The liquid level is visible during filling in the used oil tank.

Community-Right-to-Know Act

Under Section 312 of SARA Title III the university is required to file a yearly Tier II report for all hazardous chemicals that are present at the university in amounts greater than 10,000 pounds, or are on the SARA list of extremely hazardous substances and were present at the university in amounts greater than 500 pounds (55 gallons) or the SARA threshold quantity for the substance, whichever is less. In addition, the State Emergency Response Commission must be notified. To meet these regulations the Safety Manager is responsible for completing the Tier II report and the emergency notification report before March 1 of each year. The only chemicals the university is required to report are gasoline, fuel oil, and gas chlorine.

Energy Efficiency

The university actively pursues methods to decrease energy consumption on campus. For example, new energy efficient ballasts are used for fluorescent light fixtures, motion sensors are being placed in classrooms, incandescent lights are being changed to fluorescent, and energy conservation measures are used for chemical fume hoods. The Safety Manager asks the following questions during the annual environmental audit:

  1. How much energy is used on campus? Have there been any changes from the previous year?
  2. What conservation measures have been implemented? What measures are being considered?
  3. Are new buildings designed to be energy efficient? Is there a computerized energy management control system?
  4. What sources of alternate energy could be or are used?

Refrigerants

Radford University has developed a Refrigerant Recycling Program that is designed to reduce emissions of CFCs and protect the earth from the penetration of harmful ultraviolet radiation. Penetration of ultraviolet light can cause health and environmental concerns including increased incidences of skin cancers and cataracts and damage to crops and marine organisms. This program is designed to reduce emissions of CFCs and HCFCs to the lowest achievable levels during the service, maintenance, repair, or disposal of appliances at Radford University. A CFC Management Plan was also developed for the phaseout of CFCs. Strategies for maintaining, converting, or replacing existing equipment with appliances that use alternative refrigerants are included.

14.0 Emergency Preparedness

Emergency Response Procedures

An Emergency Response Plan has been developed to prepare the university to properly handle emergency situations that may occur on campus. The plan contains procedures for notifying appropriate personnel, defines responsibilities, and provides guidelines for handling most campus emergencies. The following types of emergencies are covered by the manual:

  • Bomb threats & explosions
  • Fires
  • Chemical spills
  • Radiological emergencies
  • Blood spills
  • Asbestos releases
  • Natural emergencies
  • Medical emergencies
  • Utility failures
  • Terrorism
  • Emergency recovery

Emergency Notifications

An Emergency Notification List and an Emergency Call List is included in the Emergency Response Plan. Phone numbers for Radford University personnel, local, state, and national agencies are included.   

Disaster Plan

A Disaster Plan has been written for the university and is included in the Emergency Response Plan. 

Hazardous Materials First Responders

All Safety Office personnel have taken the 40-hour HAZWOPER course and are qualified to clean up hazardous waste spills at the university and to train others at the hazardous materials awareness level. All Police Officers, several Facilities Management Plant employees, and select individuals across campus have been trained at the awareness level.

Confined Space Rescue Team

Radford University does not have an internal confined space rescue team. The Radford City Fire Department will serve as the rescue team for confined space emergencies.

CPR/First Aid/AED Training

The Safety Manager is an American Red Cross certified instructor and will coordinate CPR/First Aid training and AED training across the campus. An AED procedure manual has been written. Several individuals in Facilities Management, Athletic Department, and the Police Department have been trained.

ASTs

A Spill Prevention Control and Countermeasure/Oil Discharge Contingency (SPCC/ODC) Plan has been developed to provide university personnel with information necessary to prevent oil and fuel discharges from ASTs and to safely and properly respond to a spill incident.

15.0 Student Safety

Although OSHA regulations only cover employees, a campus comprehensive safety program should be extended to cover students as much as possible. The university has a morale obligation to ensure that the health and safety of students is not compromised. Laboratories and other work areas occupied by students comply with applicable OSHA regulations. Adequate safety equipment and personal protective equipment is designated for these areas.

Safety Procedures

Several procedures concerned with student safety have been written. The Safety Manager works with departments to develop adequate safety procedures for students who use hazardous chemicals and equipment. The following safety practices have been developed to protect students:

  1. Students using analytical x-ray equipment are required to read the Analytical X-ray Safety Manual and pass a test before using the equipment.
  2. Students using radioisotopes are required to read the Radioisotope Safety Manual and pass a test.
  3. Users of Class III and IV lasers must read the Laser Safety Manual and pass a test administered by the Safety Office.
  4. Currently, chemistry students are trained by their professor in basic safety procedures before the first lab and receive a handout about general safety practices. The Safety Manager plans to create a Laboratory Safety Manual for students from the Chemical Hygiene Plan. This will be made available to all professors and students who use chemicals for training purposes in the future.
  5. Procedures have been written for the use of Biosafety Level 1 and 2 organisms in microbiology laboratories. These procedures are provided to students before class. The Safety office has developed a complete Biosafety Manual that can be used by students taking Microbiology, Immunology, and Parasitology classes.
  6. Nursing and Medical Technology students receive training on OSHAs Bloodborne Pathogen Standard, HIV, and HBV. Training is performed by the Safety Manager or other qualified individual. Procedures concerned with the use of universal precautions in the clinical and nursing lab areas have been developed. All nursing students are required to use universal precautions when faced with clinical or lab exposure to blood or other potentially infectious body fluids. Nursing students are also required to have a physical examination and a complete immunization record on file with the School of Nursing. Vaccination for the hepatitis B virus is encouraged but not mandated.
  7. All art majors are required to take a university course in art safety. This course describes health hazards of art materials, tools, and processes used in art studios. Proper ventilation, personal protective devices, fire safety, and OSHA regulations are discussed.
  8. Procedures for using laboratory facilities in the Physical Sciences Department have been developed.
  9. Students in the Department of Health Services are instructed prior to using laboratories of the dangers of food services to include fires, falls, and cuts/abrasions. All students are instructed to report problems immediately to instructors.
  10. Students taking courses in the Department of Recreation are required to purchase and follow safety guidelines developed by various outdoor associations such as the Virginia Association for Outdoor Adventure Education, and the American Canoe Association.
  11. Students working with clients in the Department of Communication Sciences and Disorders receive handouts on HIV/AIDS.


In the academic area, there is a lack of consistency in the detail of safety guidelines and the methods of distribution of safety information to students among the departments. Detailed safety guidelines are needed in laboratories, health clinics, art studios, physical education activities, and other areas using hazardous materials. The Safety Manager plans to work with departments to generate additional safety guidelines for students and to assist in the development of appropriate training sessions. Many of these procedures and training materials can be developed from existing programs that have been written for employees.

Personal Protective Equipment

Students using hazardous materials or equipment are required to wear the same personal protective equipment used by employees. For example, students in chemical laboratories must wear appropriate eye protection, and respirators must be worn by certain art students. Usually the university supplies this equipment at no cost to students.

Accidents

An Accident Report (PDF)is completed for students involved in accidents in laboratories. A University Incident Report is completed for student accidents occurring in other areas. Copies of these reports are sent to Human Resources and the Safety Office for review. Students needing medical assistance are sent to the Infirmary. The Safety Manager investigates the accident and makes recommendations to prevent a recurrence of the incident.

Awareness Programs

Health and safety awareness programs are regularly scheduled for students at Radford University. The purpose of these programs is to promote a safer and healthier campus environment by helping students become aware of their behavior. Programs are periodically presented by the Dean of Students Office, Residence Life, and Center for Counseling and Student Development. Topics include alcohol and substance abuse, AIDS, sexually transmitted diseases, CPR, rape and assault, stress management, and other health and safety issues.