NORTHERN
VIRGINIA COMMUNITY COLLEGE
SAFETY
PROGRAM
A. Personal Protective Equipment Program (PPE) (OSHA 29 CFR 1910.132-140)
1) Each campus activity needs to assess for hazards in their area to determine if PPE is required.
2) Each Campus Facility Manager has a PPE program that can be used as a guide for others to develop. In addition, Campus Chemical Hygiene plans also have an appropriate protective equipment section identified.
3) Each job task should be hazard assessed by supervisor and employee.
4) If the hazard cannot be eliminated, protect against the hazard to avoid injury by procuring appropriate protective equipment.
5) Common sense is to be used as a guide in developing the hazard assessment, selecting PPE, hands-on training/retraining, communicating with the employee, wearing of the PPE, and certification/documentation.
6) Please note that the use of lifting straps does not take the place of proper lifting.
7) At Section D is a source list that can be used in conducting hazard assessments of the work area and/or individual tasks. As appropriate, agencies should add to the list to best cover the uniqueness of the organization.
B. Respiratory Protection/Fit program (OSHA 29 CRF 1910.134)
1) This is an integral part of the college/agency PPE program. Campus Facility Maintenance, College Vehicle Repair, and academic agencies such as Automotive.
2) Photography, and Science Labs, etc., are required to have agency unique programs. Science Labs incorporate the use of a respirator in respective Chemical Hygiene plans, under PPE.
3) Before using a respirator, an employee must pass an initial medical screening and physical. For asbestos work, an annual physical is required. For other respirator use, an annual follow-on physical is recommended.
4) Each employee using a respirator must be trained and fit-tested annually.
5) Fit-testing is normally conducted for all concerned during the one-day Asbestos O&M refresher course. Care and maintenance is also discussed.
1) Hearing protection is also an integral part of agency PPE program. There is always noise in the workplace. Noise can affect a person’s hearing; some people more so than others, no matter what the sound level.
2) When noise persists in the workplace at 85 decibels (db) over an 8-hour time weighted average day, the supervisor is required to set up a monitoring program.
3) All NVCC HVAC and Grounds equipment have been checked for noise levels. While the college/campus is not at the “85-db” level, all concerned should have noise protectors (PPE) available to the employee (and worn) to ensure that hearing noise is kept to a minimum (within reason) at all times.
4) Employees working around air handlers, using yard equipment or machinery in general, should continue to wear noise protectors that will, in fact, keep the noise-reduction rating far less than the 85-db level.
a. Noise protectors are especially important during fire drills and fire emergencies.
b. The alarms sound at a high, piercing level to get our attention; however, the noise hurts our ears and causes the ear pain (sometimes) much longer than the duration of the noise alarm.
c. When major HVAC equipment is replaced, or new “Grounds” equipment procured, and a decibel rating is not identified the supervisor needs to get the noise level identified.
1) Campus building occupants have a right to know of any asbestos in the workplace. Unless asbestos-containing material (ACM) is disturbed, there is little cause for alarm.
2) Each campus has access to a detailed survey to include an Operations and Maintenance Plan (O&M) for their activity. This survey and O&M Plan is normally kept in Campus Facility Maintenance.
3) Before any maintenance activity or renovation is conducted that may disturb ACM, the survey needs to be reviewed. If ACM needs to be disturbed, it will be abated by appropriate (contractor) personnel in accordance with OSHA guidelines.
4) Abatements are documented; accordingly, the O&M Plan is updated annually.
5) Each Campus Facility Maintenance has trained (O&M) emergency abatement personnel to perform jobs that are less than ten square feet or linear feet in size. These people use respirators and are required to be medically qualified to use this equipment.
6) The college has an abatement and an air-monitor firm under contract to perform asbestos abatement projects that are more than ten square feet or linear feet in size.
7) The college coordinates a 2-hour block of instruction on Asbestos Awareness for those in a need to know; and, a one-day refresher course in Asbestos O&M (hands-on training) annually.
1) Prior to any renovation, demolition or additions, campus Facilities shall ensure that there is no lead-containing paint present.
2) The college has under contract a licensed lead-based testing firm and a contractor to abate the lead, as appropriate.
3) Abatement of the lead-based paint is preferred; however, encapsulation is an option.
1) LO/TO is the control of hazardous energy such as electricity.
2) This is primarily for Facility maintenance, but this also impacts (selectively) in some academic departments, such as HVAC, Automotive, etc.
3) Campus Facilities has a plan; each department, as applicable, should have their own operative plan.
4) When there is a need to deenergize a circuit or piece of equipment, LO/TO procedures must be enforced, as appropriate. For example, even circuit-breaker panels need to be controlled. Lockout the panel or energy isolating device with assigned individual locks.
5) Supervisor shall conduct inspection at least annually with applicable technicians who use LO/TO methods to ensure that procedures and requirements of the OSHA Standard are being followed.
6) Certification of the inspections is required.
7) Training is required to ensure understanding; retaining is required when there are changes in job tasks or changes in machinery.
G. Confined Space Entry Plan, Permits Required (OSHA 29 CFR 1910.146)
1) The college does not conduct confined-space-entry work when permits are required. A local contractor will be called to do the work. Examples include neutralization tank maintenance, lowering oneself into a “manhole” or sewer, or any other activity that would include air-hazard monitoring.
2) Confined Space Entry Plan, NO Permit Required primarily affects Campus Facility Maintenance, but is good information for all.
a. Examples of this type activity include on going into a pipe chase, plenum air handler compartment, or any close/tight area.
b. There is a need to work in pairs.
c. Safety and communication are paramount.
d. Use lockout/tagout as appropriate.
H. Ladders and Ladder Safety (OSHA 29 CFR 1910.25 and 26)
1) Ladders are used every day, and safety is paramount when ladder work is being accomplished. Know Your Ladder.
2) Ladders should be inspected for serviceability before each use.
3) Do not use a ladder that is defective or in poor condition. If it can be repaired to its original condition, mark it and secure it away until it is repaired. If it cannot be repaired, dispose of it quickly and permanently.
4) Some ladder-safety/accident prevention guidelines:
a. Consider using the “buddy” system when employing step ladders over ten feet in height; single/straight ladders over 15 feet; and, any two-sectional ladders.
b.
Ensure the base of the ladder is secure. Take
precautions when positioning a ladder and working on the ladder.
Check for sturdiness before stepping on ladder.
c.
A rule of thumb in single or extension-ladder operation is to
position the base one-forth the base distance (from the vertical wall) relative
to the working length of the ladder. For
example, for a w0-foot ascent, the base should be five feet from the vertical
wall.
d.
Ladders shall extend at least three feet above the point of
support.
e.
The worker shall always face the ladder when ascending or
descending. Use both hands; do not
carry equipment while climbing.
f.
The top tow rungs of the regular step ladder shall not be used as
a step.
g.
Metal ladders shall never be used near electrical equipment.
h.
Rope off work areas around the ladder to protect the worker and
those people traversing around the area.
i.
Use the “buddy” system, as appropriate, using common sense as
a guide.
j.
Agencies using ladder should develop agency unique guidelines.
1)
Normally, contractors perform scaffolding and platform work for
the college.
2)
Campus Facility Maintenance people should continuously use the
“buddy” system when working on the roof, looking for roof leaks, or fixing
roof-top HVAC equipment.
3)
College employees shall stay no closer than 6 feet to the roof
edge; warning lines should be erected.
1) Indoor air quality requires a good heating and cooling system. Campus Facility Managers strive to provide the best comfort reasonable. Preventive maintenance is programmed.
2) Building occupants must do their part by contracting campus Facilities when there is, or appears to be, a heating, cooling, or water-leakage problem. In addition, all concerned should:
a. Strive to eliminate clutter.
b. Ensure air intakes/exhausts are not blocked with furniture, boxes, etc. Blocked vents tend to enhance carbon dioxide buildup.
c. Contact campus Facilities if there is lint or soot buildup on window blinds, exhausts, ceiling tiles.
d. Refrain from cooking in the office area.
e. Avoid keeping food or opened drinks in the office area.
K. Forklift Operations and Training Plan (OSHA 29 CFR 1910.178)
1) Distribution Center and Storeroom supervisors provide remedial training to personnel in the Distribution Center and Storeroom, as appropriate.
2) The training plan includes:
a. Individual evaluation of operators.
b. Reevaluation annually, National safety Council (NSC) certification or equivalent.
c. Hazard protection in general:
(1) The vehicle itself, in terms of visibility, tip-over hazards, instrumentation, and loading.
(2) Assessing workplace hazards. For example, surface conditions, Warehouse/Storeroom uniqueness, pedestrian traffic, unguarded docks, asymmetrical loads, and fall protection.
3) Documentation essential.
L. Driver Training & Defensive Driving
1) NVCC agencies that have vehicles assigned should establish an in-house driver training program that encourages all employees to drive defensively and courteously.
a. The training may include periodic “tailgate/on-the-spot” discussions on driving lessons learned and before, during, and after operation maintenance.
b. In addition, reviewing videos on driver training is also encouraged; e.g. winter driving.
c. Incorporation of items of reinforcement contained in ASPM, Section 17, Use of state Owned Vehicles, as appropriate, is suggested.
d. A National Safety Council pamphlet on driving was provided to campus Facility managers, and , Supervisors of Warehouse and Vehicle Repair to use as a guide in enhancing or developing their driver training effort.
1) Where there is an accidental or unintentional release of refrigerants to the air, the episode must be documented in-house. Facility Managers are cognizant of this concern.
2) The college has cooling refrigerants. If it has been determined that 15% or more of the refrigerant leaked into the air during a 12-month period, the college must correct the problem.
3) Details are covered on the EPA website: www.epa.gove/ozone/title6/608/leak
4) Ozone Protection Hotline: (800) 296-1996.
1) Department of Environment Quality (DEQ) has stated that subject tubing is not to be disposed of in normal landfills.
2) Fluorescent tubes with mercury may be disposed of through the universal-waste method; i.e.. legitimately recycled tubes. This is the college’s present practice.
3) Tubes may also be disposed of by crushing the mercury-containing lamps. This must be accomplished in a safe and controlled area/manner in order to minimize the release of any mercury to the workplace, complying with 29 CFR 1910.1000. These procedures must be documented, and the crushing must be done by a specifically designed piece of equipment; i.e., a fluorescent-tube crusher that can filter the mercury airflow.
4) Crushed lamps are disposed of as non-hazard waste and sent to an approved (lined) landfill site.
5) Additional information can be found on the web at:
a. www.deg.state.va.us/waste/flights.html
b. www.deq.state.va.us/regulations/waste60.html. Scroll down to Section 60; go to new search and put in fluorescent.
1) All Animal Science personnel are normally given a titer shot to ensure they are immune from rabies.
2) The titer test will be given every two years, unless otherwise specified. Booster immunizations will be provided as appropriate.
3) Copies of records and any documentation will be the responsibility of the Program Head, Animal Science.
P. Elevator Entrapments/Emergency Procedures
1) Each campus has emergency procedures in case of entrapments.
2) College employees are not to attempt evacuation.
3) When someone is trapped in a elevator, immediately contact the Campus Police who, in turn, will confirm entrapment and notify the first-responding fire station.
4) Contact Campus Facilities for assistance and follow-on elevator contractor support, and Business Manager.
5) Someone shall stay outside the elevator car, assuring the trapped occupant(s) that help is on the way.
1) In a classroom environment, 20 sq. ft. is allowed per occupant. For example: A 934-sq. ft. classroom can maintain 47 seats (934 divided by 20).
2) Classrooms shall not be oversubscribed.
3) Appropriate signage indicating maximum occupancy shall be affixed to the wall of the classroom, close to light switches.
1) Campus facilities, as appropriate, shall have a preventive maintenance program for all emergency generators, using the operators manual as a guide for hands-on detail; and, developing a preventive maintenance check list.
2) Load runs/transfer of power checks shall be done monthly, checking for proper operation, checking for leaks, fuel levels, corrosion, etc.
3) Some campuses, like Alexandria, have the “load runs” accomplished via contract. Woodbridge has the hot runs done weekly.
4) Backup documentation is maintained for easy reference.
1) Campus Facilities Managers, as appropriate, shall provide permit and approve within campus jurisdiction.
2) The College Building Inspector shall provide permits and approval for College/State projects.
3) College Vehicle Repair Supervisor shall issue permits under his jurisdiction.
4) A welding and cutting permits program shall be developed unique to each campus or agency, as appropriate.
a. Permits shall be issued to individuals capable of performing safe welding and cutting operations.
b. A working knowledge of the welding and cutting provision of the current Virginia Statewide Fire Protection Code is considered compliance with this requirement.
c. Records and listings will be maintained of all locations where cutting and welding operation are performed. These records shall be made available for the Fire Code Inspector.
1)
We are hearing more often, now, the terms cumulative trauma
disorder (CTD), musculoskeletal (MSD), repetitive motion, stress injuries, etc.
in lay terms, it means, “My body aches, hurts, or is stressed
beyond our individual body limits while I am working.”
2)
Ergonomics is considered the science of fitting the
job/task, within reason, to the person with the objective of preventing, or
reducing, or eliminating the strained or stressed body feeling.
3)
OSHA maintains that, “Where there is a mismatch between the
physical requirements of the job and the physical capacity of the worker,
work-related MSDS can result.” In
reality, those workers who repeat the same motion, work in awkward positions,
use excessive force, or lift heavy objects all day may develop muscular
disorders.
4) There are several steps to an effective ergonomics program:
a. A coordinated effort between supervisor and employee (management and employee participation.
b. Reporting of any hazards and providing information, as appropriate, to all concerned.
c. A hazard assessment of the way we do out work, its location, and how.
d. Training on what to look for: Causes, symptoms, etc., and getting the word out.
e. Ergonomics or MSD management.
f. Program evaluation and documentation.
5) The ergonomics program is considered a “living” document, and will change as more facts become know.
6) Section E provides more detail on ergonomics.