EHS Regulatory OverviewCollege and University Auditors of Virginia

May 21, 2012

EHS Functions

• Environmental Health & Safety– Environmental Compliance– Emergency Preparedness & Response– Fire Safety– Laboratory Safety –Occupational Health–Occupational Safety

EHS Mission

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

Requirements Framework

• Laws & Regulations• Executive Orders• Guidelines• Industry Standards • Best Practices• University Policies

Occupational Safety Requirements Framework

• OSHA State Plan States

• OSHA/VOSH: Workplace Safety & Health– Bloodborne Pathogens - Confined Spaces– Hazard Communications - Electrical Safety– Walking and Working Surfaces - Fall Protection– Personal Protective Equipment– and MANY more

• DHRM: Workers’ Compensation• NFPA/NEC: Electrical Safety

• CDC/NIOSH: – Respiratory Protection, Medical Surveillance

• NIH/OLAW: Animal Care Workers

• AAALAC /NRC: – Animal Care Workers, Vivarium Facilities

• ACGIH: – Chemical Exposure Limits, Noise, Temperature Extremes

• ANSI: Lab Ventilation

• ASHRAE: Ventilation

• EPA: Indoor Air Quality

Occupational HealthRequirements Framework

• OSHA/VOSH: Laboratory Safety and Chemical Hygiene, Laboratory Amenities/Equipment, Laboratory Safety Practices

• NRC/VDH: Radiation Safety Practices and Licensing

• CDC: Registration of Select Agents

• NIH: Biosafety Practices, Facilities, and Project Review

• DEA: Controlled Substances

• DOT: Hazardous Materials Transportation Security, Domestic Hazardous Materials Shipping

• IATA: International Shipping and Shipments by Air

• DHS: Chemical Facility Security

• ANSI: SEW, Lab Decommissioning

Laboratory SafetyRequirements Framework

• EPA/DEQ:– Air Emissions– Hazardous Materials & Waste– Spill Prevention and Controls– Pesticide Application– Storm Water Pollution Prevention– AST and UST

• Local POTW

Environmental ComplianceRequirements Framework

• IFC/VaSWFPC: – Fire Prevention– Fire Suppression Systems

• IBC• NFPA: – Specific Codes as Adopted by VaSWFPC

• DoEd: – Fire Statistics in Residence Halls

Fire SafetyRequirements Framework

• FEMA/VDEM: – Emergency Plans and Procedures, Emergency

Preparedness Guidance• Office of the Governor (Executive Order 41):– Emergency Preparedness via EOP

• DoEd: – Missing Students, Timely Emergency Notification

Emergency PreparednessRequirements Framework

Overarching Requirements

• OSHA General Duty Clause requires an employer to furnish to its employees:

"employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees..."

Overarching Requirements

• NIH Grants Policy Statement

“Grantees are responsible for meeting applicable Federal, State, and local health and safety standards and for establishing and implementing necessary measures to minimize their employees' risk of injury or illness in activities related to NIH grants.”

Risks

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

New Facilities

Successful Implementation

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

EHS Services Provided

– Building Evacuation Plans– University & Unit Level

Emergency Planning– Ergonomic Assessments– Exposure Monitoring– Fire Cause Investigation– Fire Drills– Fire Extinguishers: Installation,

Inspection, and Testing– Fire Protection Systems:

Inspection and Testing– Hazardous Materials Shipping

– High Hazard Area Inspections– Indoor Air Quality Investigations– Laboratory Project Review– Laboratory Signage– Mason Alert Emergency

Messaging– Medical Surveillance– Personal Protective Equipment

Selection– Training, Workshop, Emergency

Exercises– Waste Pickups and Waste

Container Distribution

Fire Safety

Overview of Regulations

• Virginia Statewide Fire Prevention Code• NFPA sections by adoption• International Fire Code (IFC)• International Building Code (IBC)

Systems Inspections / Testing

Fire Suppression Equipment Inspection Frequency

Equipment:

Inspection Frequency

Weekly Monthly Quarterly Annually Responsible Party

Portable Fire Extinguisher:   X     EHS

Smoke Alarm:       X Contractor

Fire Alarm:       X Contractor

Fire Pump Inspection: X       EHS

Fire Pump Test:       X Contractor

FDC and PIV:   X     EHS

FDC and PIV:     X   Contractor

Sprinkler System:     X   Contractor

Evacuation Route Signage:       X EHS

Enunciator Panel:       X Contractor

Fire Safety Plan:       X EHS

Building Inspection:       X EHS

Unique Equipment: Case by Case Basis EHS

Systems Inspections / TestingFire Safety Programs

Equipment:Inspection/Cleaning Frequency Testing/Certification Frequency

A B E R-2Resp. Party A B E R-2

Resp. Party

Back Flow Preventer

Monthly Monthly Monthly Monthly EHS Annually Annually Annually Annually EHS/FM

Building Inspection

Quarterly*Semi-

AnnuallyAnnually

Annually**

EHS/SFM NA NA NA NA NA

Check Valve  ? ? ? ? ? ? ? ? ? ?

Control Valves (sealed nonmonitored)!

Weekly Weekly Weekly Weekly EHS Quarterly Quarterly Quarterly Quarterly EHS

Control Valves (locked or tampered)

Monthly Monthly Monthly Monthly EHS Quarterly Quarterly Quarterly Quarterly EHS

Elevator Hoistway

NA NA NA NA NA Annually Annually Annually Annually EHS/C

Emergency Exit Signs

NA NA NA NA NA Monthly Monthly Monthly Monthly Occupants

Evacuation/Shelter Training***

Quarterly NA Quarterly Quarterly EHS NA NA NA NA NA

Fire Department Connection

Quarterly Quarterly Quarterly Quarterly EHS Five Years Five Years Five Years Five Years EHS/FD

Fire Alarm System

Weekly Weekly Weekly Weekly FM-FAS Annually Annually Annually Annually EHS/C

Systems Inspections / TestingFire Safety Programs

Equipment:Inspection/Cleaning Frequency Testing/Certification Frequency

A B E R-2Resp. Party A B E R-2

Resp. Party

Fire Drills Quarterly Annually Monthly Quarterly EHS NA NA NA NA NA

Fire Extinguishers

Monthly Monthly Monthly Monthly EHS Annually Annually Annually Annually EHS

Fire Pump^ Weekly Weekly Weekly Weekly EHS Annually Annually Annually Annually EHS/C

Hood System Cleaning****

Annually Annually Annually Annually EHS/CSemi-

AnnuallySemi-

AnnuallySemi-

AnnuallySemi-

AnnuallyEHS/C

Stand Pipes# Weekly Weekly Weekly Weekly EHS Annually Annually Annually AnnuallyEHS/C/

FDPIV (include in control valve)

Monthly Monthly Monthly Monthly EHS Quarterly Quarterly Quarterly Quarterly EHS

Smoke Detector (battery)

NA Weekly NA Weekly Occupants Annually Annually Annually Annually EHS

Automatic Fire Doors/Curtains/ Rollup

Semi-Annually

Semi-Annually

Semi-Annually

Semi-Annually

 FM Annually Annually Annually Annually  FM

Smoke Evac System (non-dedicated)

Weekly Weekly Weekly Weekly Annually Annually Annually Annually

Smoke Evac System (dedicated)

Weekly Weekly Weekly Weekly  Semi-

AnnuallySemi-

AnnuallySemi-

AnnuallySemi-

Annually 

Sprinkler System

Annually Annually Annually Annually EHS Quarterly Quarterly Quarterly Quarterly EHS/C

Inspection Records

Systems Inspections

Systems Inspections

Fire Drills

Annual Fire Drills • Based on occupancy• Must be documented

Group or Occupancy Frequency ExamplesAssembly Buildings

Group A Quarterly Patriot Center, Center for the Arts, Johnson Center

Educational / BusinessGroup B Annually Innovation Hall, Research I, Thompson Hall

Adult and Child CareGroup E Monthly Child Development Center

HotelsGroup R-1 Quarterly Each Shift The Mason Inn

Residence HallsGroup R-2 Four Annually Northern Neck, Commonwealth Hall, Wilson Hall

Other Compliance Issues

Issue Frequency

Tent Permits Occasionally

Hotwork Permits Weekly

Pyrotechnics Rarely

Special Events Occasionally

Building Fire Evacuation Plans Ongoing

Fire Safety Plans Ongoing

Emergency Key Inventory and Supply Ongoing

Knox Box Occasionally

Emergency Planning/Walk-throughs Occasionally

Challenges

• Record keeping– Electronic vs. hard copy– Records retention period– Access– Periodic audits

• Having enough personnel to complete work– Growth of the University– Adding additional inspections

and testing to schedule

Emergency Preparedness

Executive Order 41 – 9/30/11

• Appointment of Emergency Coordination Officer (ECO) and alternate.

• Must maintain and test specific plans• Mandatory training (within 90 days of employment)

1. DHRM-HR Policy – Preventing Workplace Violence2. Terrorism and Security Awareness Orientation3. ISC 100.b, 700.a, and 800 (for ECO and “other

appropriate personnel” “Include emergency preparedness in its strategic planning

and performance management process” Promote a “culture of preparedness”

Continuity of Operations Plan

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

Annual Preparedness Assessment

• Each agency must respond to a state preparedness assessment by Oct. 31st

• Given a grade that is reported on a letter to the College or University President

Emergency Action Plan

• Requirement for all colleges and universities• Board of Visitors must formally adopt the plan• Plan must be reviewed every four years• President and Vice President must annually– Review the plan – Certify in writing that the plan has been reviewed– Make recommendations to the plan as necessary

• Conduct a functional exercise!!!

Questions?

Julie ZobelAssistant Vice President, EHS

jzobel@gmu.edu (703) 993-8630

David Farris Director of Emergency Preparedness and Response

dfarris@gmu.edu(703) 993-2507

Environmental Health and Safety Officeehs.gmu.edu