School District Safety: 20 Key Components

Presented By:

Bill Freeman, Environmental Management Consulting Jodi L. Traas, Community Insurance Corporation

Objectives Outline the 20 key components needed for a

successful safety compliance program Provide essential information on each key

component Provide examples of actual practices Provide support materials and resources for

additional information

District Safety Committee Members

Safety Coordinator Human Resources Student Services Building & Grounds Police Liaison Officer District health professional Building administrators Employee Groups

Teacher, TA, Cooks, Custodial, Secretary, Bus Drivers

District Students Local Fire Department

Committee Meetings Purpose Serve as advisory committee with focus on all safety issues in

the district Combine Crisis Planning Committee & Safety Committee Frequency 4-8 times during the school year When Monthly (2nd Tues. 3:30 p.m.) In-service Days Early Release Days Agenda Identify Members (volunteer or assigned) Review Incidents since last meeting Information Items (newsletter) Discussion Items (continued items set a completion date) New Safety Issues Other/Accolades/Concerns

District Safety Plan (Required)

Safety Plan Document 2009 Wisconsin Act 309 Fire, tornado, armed intruder,

bomb threat drills Assess Buildings Train employees Medical Response Teams District - proactive stance Violence prevention Incident management Annual review of the plan Coordination with law

enforcement, fire departments, emergency government directors, local hospitals and paramedics

2009 Wisconsin Act 309 In May 2010, Wisconsin

passed Act 309 which mandates that schools take some action on four separate and distinct school safety issues:

1. anti-bullying efforts; 2. school safety drills; 3. school safety plans; 4. the sharing of pupil

information between schools, law enforcement, etc.

Bloodborne Pathogens

Hepatitis B, C and HIV HBV & HCV can live in a

dry environment for at least 7 days

Identify at-risk employees Hepatitis C Fact Sheet Annual Training (include

playground supervisors & first aid room providers)

Offer Hepatitis B vaccination

Exposure/follow-up Infectious waste procedures Maintain database

Lockout/Tagout

Written Program Departments: Maintenance,

Custodians, Transportation, Technical Education Classrooms

Identify multi-source energy equipment. Ex: compressors

Train on procedures for lockout, work with employees to properly lockout.

Notify other affected employees. Purchase equipment Check list

Compressed Gas Safety

Chemical-Physical hazards Hazard Controls (inspection, training,

storage, segregation) DOT Hazardous Materials Regs (49 CFR

parts 171-179 & 14 CFR part 103) Inspection of regulators, cylinders and

valves Safe Storage (secure, separate, label,

oxygen separate from flammables) Safe Moving (close valves, replace caps, never roll or drag cylinders, move one at a

time)

IPM – Integrated Pest Management Program (WDATCP)

Indoor-Outdoor Pest control

72 Hour posting Certified Applicators Documentation Consider prior notice

Hazard Communication Written Plan Program Coordinator Chemical Inventory (Maintenance, Science, Art, Pool, Technical Education, Theater) Material Safety Data Sheet (MSDS) Training Labeling National Fire Protection Association

(NFPA) & Hazard Material Identification System (HMIS)

GHS Pictograms

! Unstable Explosives

Flammable Gases, Liquids, Solids

Oxidizing Liquids, Gases, Solids

Acute Toxicity

Compressed Gases

Corrosives Acute Toxicity – Skin & Eyes Health Hazard

Environmental Hazard

New SDSs – 16 Categories

1.Identification 2.Hazard(s) Identification 3.Composition/information on ingredients 4.First-aid measures 5.Fire-fighting measures 6.Accidental release measures 7.Handling and storage 8.Exposure controls/personal protection (PELs)

9.Physical and chemical properties 10.Stability and reactivity 11.Toxicological information 12.Ecological information 13.Disposal considerations 14.Transport information 15.Regulatory information 16.Other information

Old HMIS/NFPA Hazard Ratings 0 = Minimal Hazard 1 = Slight Hazard 2 = Moderate Hazard 3 = Serious Hazard 4 = Severe Hazard

New GHS Hazard Categories Flammable Liquids (example) Category 1: Extremely flammable liquid & vapor Category 2: Highly flammable liquid and vapor Category 3: Flammable liquid and vapor Category 4: Combustible liquid

HMIS/NFPA & GHS Hazard Criteria Have Changed!

Personal Protective Equipment (PPE) Head-Feet-Hands-

Eyes PPE Assessment Provide & Train

Employees Included in Lesson

Plan Train Students Students in art,

science technical education and theater programs

Revise with changes

Respiratory Protection

Respirator assessment. Do you need a program?

Asbestos O & M program, district painter, aquatics director, auto

body shop requires this program. Identify employees. Create a written program; Annual physical (measure pulmonary

function, chest X-ray). Negative fit test. Facial hair not permitted

Hearing Conservation

What does OSHA/Department of Safety and Professional Services (DSPS) say?

At 85 dB (8hr. TWA) (50% Dose) Train employees Make hearing protection available Sample for noise levels Baseline & Annual Audiograms Notify employees of results Enter Standard Threshold Shifts

on OSHA 300 Log Departments: Technical

Education, Music Rooms, Maintenance Staff

What does OSHA/DSPS say? At 90 dB or more (100% Dose) - We must keep levels at or below 90dB - Or require hearing protection that will lower noise

levels to 90dB NRR - Noise reduction rating DO NOT Subtract the NRR from the noise level

WRONG (109 dB - 25 NRR = 84 dB) You must use the “Safety Factor” due to leaks in

the seal, vibration & improper insertion (NRR - 7) / 2 Example: NRR 25 ((25-7)/2=9) 109db – 9 = 100dB

Hearing Protection

Type Advantages Disadvantages Formable Ear Plugs (foam)

-Cooler, more comfortable under hot conditions -Can readily dispose of after each use -Lightweight

-Irritation to inner ear (for some people) -Sometimes fit problems

Reusable Ear Plugs (plastic)

-Cooler, more comfortable under hot conditions -Can be reused if cleaned properly -Lightweight

-Irritation to inner ear (for some people) -Sometimes fit problems

Ear Muffs -Easy to use no fit problems -Not as effective if anything (even glasses) breaks the seal -Heavier/Warmer than plugs

Department of Safety & Professional Services (DSPS) Accident and injury reduction program requires

OSHA 300 log posting (February 1 – April 30) and the creation of a Safety Committee.

DSPS requires summary form SBD 10710 or OSHA 300A be sent to them by March 1st the following year (as of 2004)

Incident Investigation

Eliminate Unsafe Acts, Eliminate Loss

1

29

300

700,000

Serious Injury

Minor Injuries

Non-Injury Incidents

Unsafe Behaviors

Accident Reaction

vs.

Accident Prevention

Managing Your Playgrounds Safely

CPSC–US Consumer Product Safety Commission (Pub. No. 325) Handbook for Public Playground Safety -2008 www.cpsc.gov

ASTM-American Society for Testing & Materials F1487-11

ADA/ABA Accessibility Guidelines http://www.ada.gov/2010ADAstandards_

index.htm by 3/15/12 NPPS-National Program for Playground

Safety www.uni.edu/playground/home.html CPSI – Certified Playground Safety

Inspector (conduct audit) www.nrpa.org

Causes of Public Playground Injuries

44% - Equipment Use & Supervision

36% - Poor Maintenance

10% - Improper Equipment

6% - Poor Installation

4% - Poor Layout

Major Cause of Death and Seriously Debilitating Injury

ENTANGLEMENT of clothing, strings or ropes (most common cause of fatalities)

FALLS to hard underlying surfaces (Most injuries occur from falls) HEAD ENTRAPMENT in

equipment openings STRIKE IMPACT by moving

swings or by tipped/loose equipment

Ergonomics – Science of Fitting Jobs to People Improve Efficiency Increase Production Capability Reduce Workplace Injuries Lower Workers’ Comp Costs Reduce Absenteeism

Muscular Skeletal Disorders

Musculoskeletal disorders (MSDs) are an injury or illness to soft body tissue such as:

Muscles Nerves Tendons Ligaments Joints Cartilage Spinal Discs

Guidelines for Safe Lifting The Spine’s Basic Functions

Provides support Protects the spinal

cord Provides flexibility for

bending and rotating

Resources Wisconsin Department of Safety & Professional Services http://dsps.wi.gov/ www.osha.gov State of WI Risk Management Website www.doa.state.wi.us/ Enter keyword: Safety & Loss Control Program

Sample Dept. of Commerce/OSHA written compliance programs Governor’s Executive Order #194

Regulatory checklists Manuals/guidelines Webcasts Tools for Safety Meetings/Discussions PowerPoint presentations, handouts, etc.

Confined Space Entry

Definition: (1) Is large enough and so configured that an

employee can bodily enter and perform assigned work; and (2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and (3) Is not designed for continuous employee occupancy

Note: Head entering space can be considered “entry” Refer to OSHA guidelines for identification.

Confined Space Entry Identify, Label and Train Develop and adopt a non-entry

or entry policy. If entry policy is adopted:

All Confined spaces are permit required unless they are reclassified as non-permit or one allowing alternate entry procedures

purchase meter to measure CO, H2S, explosive gases (LEL), oxygen content.

Communication of Hazards and sharing of testing data with contractors

Asbestos Asbestos Hazard Emergency Response Act (AHERA)-1989 K-12 Public and Private Schools

Including 4K, charter, alternative and leased space

Assign Designated Person Annual registration in October

Initial Inspection/Three year Reinspections/Six Month Surveillance Training

Two Hour for All Custodial Maintenance Staff 16-Hour for any staff who disturbs asbestos

Notification Annual Parent/Guardian Notice Contractor Notification

Operations and Maintenance Waste Manifests O&M vs. Planned Abatement

Response actions Recordkeeping Pre-Renovation Survey

Lead Water - Water Coolers - Safe Drinking Water Act (SDWA)

- Well Operator Certification are required - Private Well NTNC Systems Only >25 persons - Sample per WDNR Schedule - <15 ppb Paint Consumers Product Safety Commission - Regulates Paint at 600 ppm (.06%) after 1978

Lead DHS 163 Regulations Certification and Work Practices are based on:

Building Pre-1978, children < six years of age

- Definition of Work -Lead Hazard Reduction Activity-Rare -Routine Renovation-Common -Disturbance of 6ft2 per room or 20ft2 exterior -Window Replacement regardless of quantity EPA Lead Renovation, Repair and Painting Program: Began April 22, 2010 Testing or Assume

XRF Sampling Notification Certified Lead Company Certified Lead Renovator Work Practices Cleaning Verification Recordkeeping

Hazardous Wastes

Categories of Waste - Recyclables - Infectious Wastes - Hazardous Wastes - Other Regulated Materials (ORM) - Solid Waste/Refuse/Trash Potential Waste Streams - Solvents/Thinners - Paints

Hazardous Wastes

Potential Waste Streams (Continued) - Lead - Mercury - Floor Wax/Strippers - Computers - Shop Rags - Waste Oils - Fluorescent Light Bulbs - Antifreeze

Hazardous Wastes

Potential Waste Streams (Continued) - Tires - Ballast's - Asbestos - Acid Dilution/Nuet. Basins - Science Chemicals State Contract for Hazardous Waste Disposal

Waste disposal Recommendations

Mercury Regulation Effecting Schools

DPI Chapter 118.07(4m)

Effective October, 2010 No school board, private school, or charter school may

knowingly do any of the following: 1. Purchase or use free-flowing elemental mercury for

any purpose. 2. Purchase or use a mercury-containing compound or

an instrument or measuring device that contains mercury Effective January 1, 2012

3. No schools may knowingly store free-flowing elemental mercury, store a mercury-containing compound or an instrument or measuring device that contains mercury.

Oil Filters & Absorbents Disposal Regulation Effecting Schools DNR Chapter 287.07(4m)

Effective January 1, 2011 Used automotive engine oil filters and oil

absorbent materials are banned from Wisconsin landfills.

The ban specifically cover filters from motor vehicles, including: Cars, Trucks, Buses, Motorcycles, Snowmobiles,

Forklifts, Tractors, ATV’s and UTV’s Oil Filters not covered by the ban

Although oil filter from sources like hydraulic systems and other machinery are not covered under this ban, the Wisconsin DNR encourages them to be recycled as well.

New Tank System Training for Operators

Types of Facilities Impacted • New Requirements apply to:

• All facilities having a tank system permitted by DSPS. • Tank storing regulated substances, either in-use, or

temporarily out-of-use, whether new or existing. • UST’s storing heating/fuel oil for consumptive use on the

premises. • New Requirement does NOT apply to:

• Aboveground Tanks • Farm and residential UST’s which have a capacity of less

than 1,100 gallons and which are used for storing motor fuel.

• Tanks located at the US EPA superfund site.

Operator Classes (A, B & C) • Class A Operator: (Recordkeeping/Regulatory Responsibility)

• Basic tank system requirements for compliance and ensuring individuals are fulfilling operation, maintenance and recordkeeping requirements.

• Financial responsibility documentation requirements. • Notification requirements. • Requirements for reporting obvious and suspected releases. • Requirements for permanently closing a tank system and for placing a tank

system temporarily out of service. • Operator training requirements.

• Class B Operator: (Operation/Maintenance Responsibility) • Site specific operator training on the specific equipment at the operator’s

facility or a broader training on UST system components, materials, methods of leak detection and prevention and operation and maintenance of: spill prevention, overflow prevention, leak detection, corrosion protection, emergency response and product compatibility

• Reporting and recordkeeping requirements. • Class C Operator training requirements.

• Class C Operator: (Dispenser Responsibility) • Training to take appropriate action in response to the following: • Training to understand the required written instructions

Community Right-To-Know

EPA, LEPC, SERB Annual Reporting of Chemicals Stored in Excess of

10,000 lbs.. Reporting of Extremely Hazardous Substances Reporting Examples - Gasoline/Fuel Oil - 1,500 Gallons+ - Chlorine in Excess of 100 lbs. - Salt (Road) in Excess of 10,000 lbs.. Reporting Deadline - March 1st Reporting Fees

Indoor Environmental Quality Wisconsin Act 96 IEQ Model Plan

Develop plan May 2012 Implement Plan February 2013 See: http://dpi.wi.gov/sms/ieqhome.html

Indoor Air Quality Investigation/Evaluation: Provide reporting form Evaluate Symptoms Visual inspection of area Visual inspection of HVAC Evaluate Water Incursion Sampling if necessary (indoor & outdoor) Be prepared to deal with results Document!

Occupational Exposure to Hazardous Chemicals in Laboratories

Chemical Hygiene Plan coordinated by Chemical Hygiene Officer (CHO)

Training of Science Staff Fume hood testing, must exceed 100

linear feet per minute with hood sash set at 18”

This regulation presents the greatest liability to your district pertaining to Health and Safety

Recent focus of DSPS inspections