Increased public concern over environmental issues and occupational safety has led to a major expansion of federal, state and county environmental health and safety laws. Of crucial concern to CSUSB is that over the past several years regulatory agencies have announced their intention to focus more compliance activity on academic institutions.
Numerous legislative bills that have passed in recent years, and those introduced as upcoming legislation, all combine to include the following requirements
- a written Environmental Health and Safety (E H & S) Policy;
- a responsible manager;
- communication with faculty and staff on matters concerning Environmental Health and Safety issues;
- inspection, identification and evaluating hazards;
- inventory and labeling of hazards;
- investigation and mitigation of hazards;
- employee and student training; and,
- record keeping.
Quite clearly, CSUSB needs to meet these challenges offered by new legislation and requirements. The following E H & S policy was designed specifically to address these regulations. And therefore should be accepted as an umbrella program which incorporates the elements of current requirements, while retaining flexibility needed to address future E H & S mandates as they arise.
Effective utilization of this policy would generate:
- cost avoidance, by utilizing existing personnel and resources;
- a clear definition of responsibility and accountability for the safety and health of students, employees and visitors;
- a uniform approach to problem solving; and,
- a decrease of administrative and criminal liability for the university.
1.00 REGULATORY AUTHORITY
Including, but not limited to: Code of Federal Regulations, California Code of Regulations, California Codes, Uniform Fire Code, Uniform Building Code, American with Disabilities Act, and South Coast Air Quality Management District.
2.00 ADMINISTERING AGENCY
Federal, State and Local agencies assigned to ensure compliance with all E H & S laws and regulations.
Although the provisions of this law and the implementing regulations apply only to employees. The University is committed to providing for the health and safety of students and visitors as well.
4.00 ENVIRONMENTAL HEALTH AND SAFETY POLICY
- 4.01 It is the policy of California State University San Bernardino (CSUSB), to maintain, in so far as it is reasonably within the control of the University to do so, a campus environment for students, faculty, staff and visitors that will not adversely affect their health, safety, and surrounding environment, or subject them to risks of accidental injury or illness. No student or employee will be required to perform any task, which is determined to be unsafe or unreasonably hazardous.
- 4.02 To accomplish this, departments will provide facilities and equipment that meet all federal, state and local environmental health and safety laws and will promulgate appropriate policies, standards, and procedures for governing the University's E H & S programs.
- 4.03 The ultimate responsibility for establishing and maintaining the E H & S program at CSUSB rests with the University. Basic policies which govern the activities and limitation of E H & S programs (Appendix A) are thereby established through the E H & S Department under the final authority of the President.
- 4.04 However, the primary responsibility for the workplace belongs to each university employee who performs a supervisory role. Accordingly, all faculty and staff are to ensure that safe and healthful conditions and practices are provided and followed within the areas under their control. Members of the campus community are to cooperate fully with all aspects of the various E H & S programs.
- 4.05 Specific responsibilities of all faculty and staff are directly proportional to their operational authority. The obligation implied of each individual for compliance with E H & S requirements for themselves and for one another is both obvious and unavoidable. In addition, it should be clearly understood that failure to comply with all regulations, procedures and standards can lead to disciplinary action. But, because of the wide diversity within the university, each department will have some latitude in formulating and implementing alternative methods when necessary, as long as the total E H & S program objectives are met.
When properly designated and implemented, an effective E H & S Program will assist management in determining what hazards exist in the workplace, how to correct hazards that may occur, and what steps to take to prevent them from occurring. The establishment of an effective system for providing employee injury and illness prevention, will achieve the following objectives:
- 5.01 Thorough regular self-inspections for compliance management will prevent many hazards from occurring.
- 5.02 Employees are to report potentially hazardous conditions without fear of reprisal and their reports will be given prompt and serious attention.
- 5.03 Workplace equipment will be maintained in safe and good working conditions.
- 5.04 Procedures to investigate any workplace accidents, near-miss incidents, and reported injuries and illnesses will be established by management.
- 5.05 Once identified, hazards will be corrected as expeditiously as possible.
- 5.06 Safe and healthful work procedures for each specific job performed by its employees, will be developed by the University.
- 6.01 UNIVERSITY ADMINISTRATION
The ultimate responsibility for establishing and maintaining effective policies regarding environmental health and safety issues specific to campus facilities and operations rests with the University President. General policies which given the activities and responsibilities of the E H & S program are thereby established under the final authority of the President.
- 6.02 HEALTH AND SAFETY COMMITTEES
Committees have been established to achieve and maintain beneficial relationships through continuing communications on issues relating to occupational health and safety. The committees discuss, explore, study, and make recommendations on the issues. Committees will also provide employees with the opportunity to voice concerns relating to hazards without fear of reprisal. Committees are established for specific areas or function as required and identified by the E H & S Department. Currently, committees (i.e. Art Safety Committee, Chemical Hygiene Committee, Facilities Services Safety Committee, SETC Safety Committee) consist of representatives from the E H & S department and department assigned designated safety coordinators.
The responsibilities of these committees are as follows:
- Meet quarterly;
- Prepare and maintain written records of health and safety issues discussed;
- Review occupational accidents and causes of incidents resulting in occupational injury or illness and where appropriate, submit suggestions to department supervisor for the prevention of future incidents;
- Review alleged hazardous conditions brought to the attention of any committee member. The committee may request that the University conduct an investigation to assist them in their study;
- Review results of periodic, scheduled work site inspections;
- Submit recommendations to assist in the evaluation of employee safety suggestions.
- 6.03 ENVIRONMENTAL HEALTH & SAFETY DEPARTMENT
It is this department's responsibility, under the guidance and policies of Administrative Council, to develop, implement and manage the E H & S programs. To effectively accomplish this goal, EH&S has the authority to request that Deans, Directors, Chairpersons, Supervisors, and other individuals abate unsafe and/or environmentally unsound conditions that are in noncompliance with federal, state and local laws. In addition to program areas in Appendix A, further responsibilities shall include, but are not limited to the following:
- Develop, implement, revise, maintain and provide leadership for E H & S programs;
- Provide consultation to Deans, Directors, Chairpersons and Designated Safety Coordinator's (DSC) regarding E H & S program compliance;
- Provide centralized monitoring of campus wide activities on a regular basis in the areas of E H & S compliance;
- Maintain centralized E H & S records, training and policies allowing required employee access;
- Develop and manage the DSC committees to ensure E H & S programs are communicated, implemented and evaluated;
- Review, formulate and adopt new codes, rules, and standards that govern the university;
- University liaison with governmental agencies;
- Provide support to administration on newly adopted regulatory requirements to assist the university in maintaining compliance.
- 6.04 DEANS, DIRECTORS, DEPARTMENT CHAIRS, DEPARTMENT HEADS
It is the responsibility of Deans, Directors, Department Chairs and Department Heads to develop department procedures and to maintain compliance with the E H & S Policy and other university health and safety programs as they relate to operations under their control. Specific areas include employee training and student education, identification and correction of unsafe conditions, and recordkeeping, specifically these individuals will:
- Develop and maintain written departmental procedures and ensure that supervisors and employees adhere to adopted procedures.
- Develop, implement and maintain an educational training program designed to instruct employees and students in general safe work practices as well as instructions specific to their job duties. Such education and training shall take place prior to the employee or student being assigned to potentially hazardous employment activities.
- Instruct employees and students in the recognition and avoidance of unsafe conditions, including hazards associated with non-routine tasks and emergency operations. Only those employees or students qualified by training will be permitted to operate potentially hazardous equipment.
- Develop a system of recordkeeping to document all employee and student educational training activities. Such records should include, but not be limited to:
- employees and students,
- incident reports,
- and complaints or grievances involving safety issues.
- Develop and maintain an inventory of hazardous materials present in all work areas within the department.
- Take corrective action for any health and safety deficiencies that are reported.
- Post appropriate safety notices and / or procedures in a conspicuous location.
- Develop methods, as appropriate, to inform employees of outside contractors working in areas under department jurisdiction of the hazards to which those employees may be exposed.
- Designate an employee to serve as Department Safety Coordinator (D S C), to act as liaison with the E H & S Office and advise the department supervisor about issues relating to environmental health and safety within the department.
- 6.05 FACULTY AND SUPERVISORS
It is the responsibility of faculty and supervisors to work directly with employees and students in the implementation of the E H & S Policy. These individuals will:
- Develop local area procedures to ensure effective compliance with E H & S programs as they relate to operations.
- Develop and maintain written workplace procedures, which conform to campus and departmental guidelines.
- Instruct employees and students in the recognition and avoidance of unsafe conditions, including hazards associated with non-routine tasks and emergency operations. Only those employees or students qualified by training will be permitted to operate potentially hazardous equipment. It is not to be assumed that newly hired, newly assigned or reassigned employees or students comprehend all safety procedures associated with the new job duties.
- 6.06 DEPARTMENT SAFETY COORDINATORS (DSC'S)
Department Safety Coordinators are appointed by each Dean, Director, Department Chair or Department Head and are critical to the effective implementation of this program while ensuring CSUSB's compliance.
- Department Safety Coordinators receive their authority directly from the Deans or Directors and, at their discretion, are thereby limited to specific assigned duties. Restrictions due to limited department and university resources for maximum implementation of all desired E H & S Programs, make it imperative that Department Safety Coordinators act at all times in full cooperation with their Deans of Directors.
- Periodic training sessions will be provided by the E H & S Department. In addition, meetings with the E H & S Department will ensure timely assistance and / or advice for compliance with E H & S required laws, standards and procedures;
- Department Safety Coordinators responsibilities normally will include:
- Liaison with the E H & S Department;
- Assist the Dean or Director in the development and implementation of E H & S Programs;
- Primary department resource person for coordinating E H & S activities;
- Conduct periodic inventory and inspections scheduled by the E H & S Department;
- Prepare written reports, recordkeeping, and recommendations towards complying with E H & S programs;
- Assist and expedite correction of identified deficiencies.
- 6.07 EMPLOYEES
These individuals will:
- Use common sense and good judgment at all times to avoid potential hazards that may exist or be created in the work environment;
- Read and comply with procedures and guidelines provided by their supervisors;
- Inform their supervisors of work place hazards without fear of reprisal;
- Attend established education and training sessions and be expected to understand and comply with all applicable safety requirements. Failure to comply with established safety rules may be reflected in performance evaluation and may lead to disciplinary action;
- Be responsible for asking questions of their supervisors when there is concern about an unknown or potentially hazardous situation;
- Be responsible to conduct themselves in a manner which promotes safety and avoids unsafe or unhealthful conditions.
- 6.08 STUDENTS
Students are expected to adhere to safety practices presented by faculty, technical staff, student assistants, graduate assistants or other authorized individuals. They also must report workplace hazards to their supervisors or other responsible parties.
7.00 COMPLIANCE GUIDELINES
All employees shall adhere to safe and healthful work practices as defined by established campus and departmental health and safety guidelines. Failure to do so may result in the initiation of disciplinary measures.
8.00 SAFETY COMMUNICATIONS
Several methods of communicating with employees on matters relating to health and safety have been established. Managers and supervisors will encourage employees to report, without fear of reprisal, any unsafe or unhealthful conditions they discover.
- 8.01 DEPARTMENT SAFETY MEETINGS
Departments will schedule regular safety meetings at which health and safety issues are freely and openly discussed by employees of the department. Management will attempt to schedule the meetings at a time when most employees can attend and will keep minutes to document who was in attendance and what topics were discussed, while providing copies to the E H & S Department.
- 8.02 EMPLOYEE SAFETY TRAINING
Departments will provide specific training programs for employees either on a periodic basis or prior to assignment on a new job or when work assignments change.
- 8.03 STUDENT SAFETY TRAINING
Faculty and staff are responsible for providing specific training programs (e.g., lab safety, art safety) applicable to the student prior to any activities.
- 8.04 HEALTH AND SAFETY MATERIAL/POSTERS
E H & S can provide departments with sources for a variety of posters and safety materials to be used in promoting a safe and healthful workplace and work practices. It is required that posters be displayed in highly visible locations within each applicable workplace.
- 8.05 SAFETY SUGGESTIONS
Any concerns or issues that an employee feels need attention may be referred to the EH&S Department (extension 7 5 1 7 9).
- 8.06 PRESIDENT'S SAFETY POLICY STATEMENT
The campus President has issued a safety policy statement which informs all employees of the University that safety is a priority issue among his / her executive level administrators. This policy urges all faculty and staff to actively participate in the E H & S program for the common good of the entire campus community.
A health and safety inspection program is essential in order to reduce unsafe campus conditions, which may expose faculty, staff, students and the public to incidents that could result in injury to individuals or property damage.
- 9.01 SCHEDULED WORKPLACE INSPECTIONS
- It is the responsibility of each department to ensure that regular and systematic workplace inspections be scheduled for all departmental areas. It is recommended that departmental safety coordinators be assigned to conduct these inspections.
- The frequency of regular workplace inspections is left up to the departments' discretion, with an annual minimum. E H & S recommends that all areas be inspected at least on a semiannual basis. Those departments engaged in hazardous operations are encouraged to conduct monthly inspections. Self-inspection checklists are provided in generic form to assist departments in developing their own checklist (contact E H & S at extension 7 5 1 7 9), or refer to specific programs. Copies of completed inspection forms shall be forwarded to E H & S.
- E H & S may conduct unscheduled inspections of any work areas on campus. These inspections will emphasize compliance with the various E H & S programs. Non-compliance will result in notices of deficiencies being issued.
- 9.02 UNSCHEDULED WORKPLACE INSPECTIONS
- Departments will conduct an immediate inspection whenever new substances, processes, procedures or equipment which represent a new potential health and safety hazard are introduced.
- Departments also will conduct an inspection whenever notification of a new or previously unrecognized hazard is received.
- E H & S may conduct periodic unscheduled inspections of any workplaces to help ensure the maintenance of a safe and healthful workplace. Non-compliance will result in notices of deficiencies being issued.
- Departments will notify E H & S and conduct a health and safety inspection in the event of an occupational injury, occupational illness, or exposure to hazardous substances as defined by Cal / OSHA.
10.00 ACCIDENT INVESTIGATION
- 10.01 Minor injuries incurred on the job will be reported to the immediate supervisor of the injured employee. An injury log will be kept on file in each department.
- 10.02 Serious occupational injuries, illnesses or exposures to hazardous substances, as defined by Cal / OSHA must be reported to E H & S and the campus Workers' Compensation Office no later than 8 hours after they become known. E H & S will contact Cal / OSHA as required by law. E H & S or the Worker's Compensation Representative, in conjunction with a representative from the injured employee's department, will investigate the circumstances of the incident to determine the cause.
- 10.03 For any work related injury or illness, the supervisor will complete "
11.00 HAZARD CONTROL PROCEDURES
Many hazards can be prevented from occurring through documented self-inspections. An effective hazard control system will identify hazards that exist or develop in the workplace, how to correct those hazards, and steps to take that will prevent their recurrence.
Upon completion of scheduled or unscheduled inspections, all findings will be prepared in writing and submitted to respective department heads and E H & S. Corrective action or a suitable timetable for elimination of a hazard (where appropriate) is the responsibility of the department supervisor.
Once identified, hazards will be ranked according the severity as defined in Table 1. Prioritization of abatement actions will be based on the ranking scheme. Serious violation and hazards should always be given top priority and be corrected immediately. Consideration should be given to stopping operations affected by the violations or hazards. All identified hazard will be issued a deficiency notice until it is abated.
|Order of Priority||Consequence (Severity)|
|1||Imminent danger exists. Capable of causing death, possibly multiple deaths, widespread occupational illness and loss of facilities.|
|2||Severe injury, serious illness property and equipment damage|
|3||Minor injury, illness or equipment damage may result|
|4||First aid care|
- 11.01 IMMINENT HAZARD SITUATIONS
Individuals conducting a safety inspection shall immediately notify the Department Chair/Head or the E H & S Department, as appropriate, if a condition exists that presents an imminent hazard to health or safety. The Department Chair / Head shall inform all employees of any such imminent hazard(s) that cannot be immediately corrected and ensure that all necessary precautions are taken to prevent mishaps.
An imminent hazard is any condition or practice that can be expected to cause death or serious physical harm before the hazard can be eliminated through normal corrective measures; e.g. an employee working on an electrical line without shutting off the power. A conspicuous notice or "red tag"" will be attached to the hazardous condition prohibiting use of the area, machine, or equipment which presents the hazard to employees or students. The "red tag" may not be removed until the hazardous condition no longer exists and required safeguards and safety devices are implemented. Only the E H & S Director or designee can remove a "red tag." Personnel who continue to use an item that has been so tagged, or who willfully remove a tag before the unsafe condition is corrected, may be subject to disciplinary action. Entry or use may be allowed with the E H & S Director's or designee's knowledge and permission, only for the sole purpose of eliminating the hazardous condition.
12.00 EMPLOYEE SAFETY TRAINING
Effective dissemination of safety information lies at the very heart of a successful E H & S Program. It is necessary to provide training for employees concerning general safe work practices (Safety Training Program) as well as specific instruction with respect to hazards unique to each employee's job assignment.
- 12.01 SPECIFIC SAFE WORK PRACTICES
Specialized safety training sessions dealing with an employee's unique job assignment must be developed by each supervisor. It is the responsibility of each supervisor to understand his/her employee's job tasks and related hazards.
- 12.02 SCHEDULED TRAINING
- Each supervisor will ensure that all new employees receive general and specific safety training prior to assignment on a new job. A completed training evaluation profile should be submitted with a position requisition.
- Supervisors will ensure that employees receive necessary training whenever new substances, processes, procedures or equipment are introduced to the workplace which represent a new hazard, or whenever the supervisor receives notification of a new or previously unrecognized hazard.
- All training will be documented in writing. Topics, participants and dates will all be recorded and kept on file within each department and a copy forwarded to the E H & S Department.
- 12.03 LONG-RANGE TRAINING PLAN
A long-range departmental training plan should be developed with the assistance of E H & S Department, which sets priorities for training sessions, including a schedule of presentations. Consideration should also be given to the frequency required for retraining employees. These refresher programs should also be incorporated in the long-range plan.
Many standards and regulations contain requirements for the maintenance and retention of records for occupational injuries and illnesses, medical surveillance, exposure monitoring, inspections, transportation, training, and other activities and incidents relevant to environmental health and safety. These records shall be maintained by each department with copies at the E H & S Department.
- 13.01 CAMPUS ACCIDENTS, INJURIES AND ILLNESSES
To properly protect the University, it is essential that records of all accidents, injuries and illnesses occurring either on University property or at off-campus University-sponsored events are maintained and analyzed by the E H & S Department. Complete records of all incidents involving bodily injury and/or property damage accidents involving faculty, staff, students, and/or the public are maintained and analyzed for accident prevention and campus liability purposes by E H & S and other designated departments. It is essential that all such incidents be reported immediately and / or in writing to the University Police or E H & S Department.
Reports of accident and injury incidents may be generated by, but not limited to, University Police (STD. Form 268 for accidents involving the campus community, traffic accidents, state driver accidents, etc.), Radiation Safety Office, Housing Office (resident accidents, intramural sports, etc.), Athletic Department and Student Health Center (student injuries, doctor's first report of industrial injury or illness, etc.). Statistics and other information from these department records will be available to department heads for use in accident prevention efforts. In addition, departments also should maintain and analyze records of accidents occurring in their own area of operations.
- 13.02 OCCUPATIONAL INJURIES AND ILLNESS
- The University will record and report to State Compensation Insurance Fund within five (5) days every employee injury or illness unless disability resulting from such injury or illness does not last through the day or does not require medical service other than minor first aid treatment.
- The University will maintain a master log and summary of occupational injuries and illnesses, located in the E H & S Department.
- Records of occupational injuries and illnesses will be kept on file in the E H & S Department and will be made available for review by Cal / OSHA at any time after for a period of three years.
- The Cal / OSHA summary for the previous year will be posted in conspicuous places throughout the campus for review by employees.
- 13.03 MATERIAL SAFETY DATA SHEET (M S D S)
As required by law, it is the responsibility of each department to ensure that they have an M S D S for all existing inventory and any new material orders. Each M S D S received by the campus must be maintained for at least thirty (30) years unless some record of the identity (chemical name if known) of the substance or agent, where it was used and when it was used is retained for at least thirty (30) years. Copies of all M S D S's must be sent to the E H & S Department for inclusion in the master log and business plan.
- 13.04 EMPLOYEE EXPOSURE RECORDS
Each employee exposure record will be preserved and maintained for at least thirty (30) years except for certain background data on workplace monitoring and certain biological monitoring results. Such records include workplace monitoring or measuring of a toxic substance or harmful physical agent; biological monitoring results which directly assess the absorption of a toxic substance or harmful physical agent by body systems; material safety data sheets; and, in the absence of the above, a chemical inventory or any other record which reveals where and when used and the identity of a toxic substance or harmful physical agent. It is the responsibility of departments (with E H & S coordination) using any regulated carcinogens to comply with the additional reporting and record keeping requirements under Cal/OSHA.
- 13.05 MEDICAL RECORDS
The medical record for each employee will be preserved and maintained for at least the duration of employment plus thirty (30) years except for certain health insurance claims records, first aid records or the medical records of employees who have worked for less than one (1) year if they are provided to the employee upon termination of employment. Such records include medical and employment questionnaires or histories; the results of medical exams and lab tests; medical opinions, diagnoses, progress notes, and recommendations; first aid records; descriptions of treatments and prescriptions; and employee medical complaints. All such employee medical records shall be kept confidential.
- 13.06 EMPLOYEE EXPOSURE AND MEDICAL RECORD ANALYSIS
Each analysis using exposure or medical records will be preserved and maintained for at least thirty (30) years.
- 13.07 DOCUMENTATION OF ACTIVTIES
- Essential records, including those legally required for workers' compensation, insurance audits and regulatory inspection shall be maintained for as long as required. The departments will keep records of steps taken to establish and maintain programs. They must include:
- Records of scheduled and periodic inspections to identify unsafe conditions and work practices. The documentation includes the name of the person(s) conducting the inspection, the unsafe conditions and work practices identified, and the corrective action(s) taken with copies forwarded to Environnmental Health and Safety. These records will be maintained at least three (3) years.
- Documentation of health and safety training for each employee. Specifically, employee name or other identifier, training dates, type(s) of training and the name of the training provider will be included with. Records will be three (3) years.
- Training records will be kept in each department and a copy in the E H & S Department.
14.00 EMPLOYEE ACCESS TO EXPOSURE AND MEDICAL RECORDS
The University recognizes that employees and their designated representatives and authorized representatives of the Chief of the Division of Occupational Safety and Health (Cal / OSHA) - have a right of access to relevant exposure and medical records. Such access is necessary to yield both direct and indirect improvements in the detection, treatment and prevention of occupational disease. Whenever an employee or designated representative requests access to a record, the University shall assure that access is provided in a reasonable time, place and manner.