The Catholic University of America

Responsibilities of the Director, Environmental Health and Safety

Water Pollution Control Act (Clean Water Act)

The Federal regulations are implemented by DC.  Regulatory requirements:

Connection/Use: One time reporting to DC is required for newly constructed facilities.

Discharge: Unless specifically authorized by WASA, the University may not introduce into DC's wastewater system any pollutant including but not limited to those that: 1) cause pass through or interference; 2) create a fire or explosion hazard; 3) have any corrosive property; 4) contain petroleum or non-biodegradable cutting oil; 5) have a specific gravity greater than 2.50; 6) are oxygen demanding pollutants; or 7) result in toxic, noxious or malodorous liquids, solids or gases. 

Trained Operators: The University must maintain/train Class A, B and C operators or tanks will be red tagged and cannot be operated. 

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for overseeing reporting, implementing processes and procedures, and training operators in compliance with the Clean Water Act.

Oil Pollution Act  

A non-transportation facility with capacity to store 1320 gallons of oil above ground or more than 42,000 below ground must prepare a Spill Prevention, Control, and Countermeasures (SPPC) Plan if the facility reasonably can be expected to discharge oil in harmful quantities into or upon U.S. navigable waters.  The plan must be approved by a licensed professional engineer unless the facility is a “qualified facility.”  The plan must include a site diagram, an inventory of all containers of 55 gallons or greater, and address secondary containment.  The storage site must be fenced entirely or guarded, and have adequate lighting to detect a spill when dark.  The regulations also require container inspection and integrity testing, recordkeeping, training for employees who handle oil, and annual discharge prevention briefings.

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for maintaining processes and procedures to implement the regulatory requirements, and for implementation, oversight and annual review of the University’s SPPC Plan.

Resource Conservation and Recovery Act (RCRA) – Underground Storage Tanks

The Environmental Protection Agency (EPA) and RCRA require the following pertaining to construction, certification, operation, inspection and reporting with respect to underground storage tanks (USTs):

Permits and inspections for construction and installation of USTs

Owner/operator certifications

Registration of regulated substances

Tank testing/monitoring

Leak detection/spill control mechanisms

Release response and reporting

Corrective action for spills

Recordkeeping regarding the above requirements 

Regulatory oversight of the above requirements is delegated to the DC Department of Environment's Bureau of Hazardous Materials and Toxic Substances, Underground Storage Tanks Management Division.  

The Director of EH&S is responsible for maintaining processes and procedures to implement and comply with the above regulatory requirements.

Resource Conservation and Recovery Act (RCRA) – Solid Waste Disposal

As a large quantity waste generator the University must:

Certify there is a program in place to reduce quantity and toxicity of waste to the degree economically practicable

Establish record-keeping practices for waste generated

Use appropriate containers and labeling practices for storage, transport or disposal, and use a manifest system. 

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for implementing and maintaining environmental safety and protection processes and procedures to meet the above requirements, and for ensuring proper management and disposal of all waste.

Comprehensive Environmental Response Compensation and Liability Act (CERCLA)     

CERCLA imposes the following requirements regarding storage, use and disposal of hazardous substances, as well as regarding the costs of removal and remediation and regarding mandatory recordkeeping:

Notification:  The University must notify the Administrator of the Environmental Protection Agency of the existence of a facility where hazardous substances are stored, treated or disposed of, as well as the amounts/types of substances at the facility, and any known, suspected or likely releases.  The University must notify the National Response Center of the release of any hazardous substance (unless reporting already made per RCRA).

Responsibility for Costs:  The University is liable for the costs of removal or remedial action, necessary costs of response consistent with the national contingency plan, and damages for injury, destruction or loss of natural resources.

Recordkeeping:  Records must be kept regarding the location, title, and condition of the facility, as well as regarding the identity, characteristics, quantity, origin, or condition of any hazardous substances kept.  Records must be kept unaltered and available for 50 years from date created.

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for implementing and maintaining policies and procedures to meet the above requirements, and for ensuring proper management and disposal of all substances.  With respect to disposal of computers and electronic equipment containing hazardous materials, the Director of EH&S oversees and coordinates disposal by the University’s Risk and Asset Inventory Administrator.

Hazardous Waste Management Act                             

The D.C. Act requires an Environmental Protection Agency (EPA) identification number and a permit in order to treat, store, dispose of, or transport hazardous waste.  To transport the University must have an additional permit, use proper packaging and labeling, use an EPA manifest, and verify that the recipient has EPA identification number.  In the event of discharge during transport, notice must be given to the National Response Center, the Coast Guard, the DC Mayor’s Command Center and the U.S. Department of Transportation.  DC also requires a spill prevention and cleanup plan approved by the Mayor, a permit for accumulated waste on-site over 90 days, and an annual certification. 

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for implementing and maintaining policies and procedures to meet the above requirements, for ensuring proper management and disposal of all waste, and for meeting all reporting obligations in the event of a discharge.

Medical Waste Tracking Act

Any medical (biological) waste generated must be tracked from "cradle to grave," and all records must be made available to the Environmental Protection Agency (EPA) upon request. Medical waste includes but is not limited to: Cultures of infectious agents, discarded vaccines, tissues, organs, body parts, blood products, sharps, soiled dressings and surgical gloves.

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for periodic monitoring to determine whether medical waste is being generated and tracked, and for ensuring appropriate disposal procedures are following in compliance with the Act.

Hazardous Materials Transportation Act

The Department of Transportation (DOT) requires that University personnel who transport or causes to be transported hazardous materials must file annually a registration statement (DOT Form F 5800.2) by June 30.  The Act further requires that the University ensure that packaging used to transport infectious substances be designed, constructed and maintained for impact resistance, strength, temperature exposure, and non-mixture to prevent identifiable release under normal transport conditions. The University must package compatible material according to corrosivity and permeability, and comply with allowable shipping methods for specific materials. There is no threshold amount to triggers these requirements.

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for ensuring University personnel who transport or cause to be transported hazardous waste file annual registrations, and for implementing procedures to meet the DOT packaging and shipping requirements for infectious substances.

Radioactive Material Storage (Atomic Energy Act) and Increased Controls for Radioactive Material Quantities of Concern (NRC Order EA 05-090)

If licensed to possess radioactive material, the University must:

Secure any licensed material stored in controlled or unrestricted areas against unauthorized removal or access, and

Control and maintain constant surveillance of licensed material that in controlled or unrestricted areas and that is not in storage

If the Nuclear Regulatory Commission (NRC) issues an order to the University regarding radioactive materials or devices kept in "quantities of concern," the University must implement increased controls as follows:

Only "trustworthy" and "reliable" persons allowed unescorted access, and anyone with unescorted access must be fingerprinted and undergo an FBI background check.  “Trustworthy and reliable” are determined by verification of employment history, education, and personal references.

The University must have a documented program to monitor and immediately detect, assess and respond to unauthorized access.

Portable or mobile devices must have 2 independent physical controls that form tangible barriers to secure against unauthorized removal.

Required documentation under the order must be treated as sensitive information, and must be kept for 3 years after no longer effective. 

The import or export of nuclear equipment or material requires a special license issued by the NRC.  Retransfers require authorization by the Department of Energy. The University must notify the NRC regarding regulated activities that have significant implication for public health/safety or common defense or security.  Transport of quantities of concern requires that the University as the licensee:

Use a carrier that utilizes a package tracking system, has a system to assure driver trustworthiness and reliability, and has the capability for immediate communication to summon assistance or response

Contact the recipient to coordinate expected arrival and confirm its receipt

Investigate delayed shipment

Provide 90 days advanced notice to NRC if the material exceeds 100 times the threshold quantity of concern

The Director of EH&S, overseeing and in coordination with the University’s Radiation Safety Officer, is responsible for implementing monitoring, security, transport and other internal controls pertaining to radioactive materials and, if applicable, those that qualify as “quantities of concern.”

Toxic Substances Control Act (TSCA)

The Act regulates the use, storage and disposal of certain chemicals, including polychlorinated biphenyls (PCBs).  The University must identify, inventory, mark and inspect quarterly PCB transformers, and must dispose of all PCB’s in accordance with hazardous waste requirements. Quarterly inspection reports must be maintained.  The University must submit to the EPA Regional Administrator by July 15th a written annual document log of the disposition of PCBs and PCB items.

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for ensuring identification, inventory, inspection and disposal of PCB’s in compliance with TSCA.

Emergency Planning and Community Right to Know Act (EPCRA)

The University must keep an inventory of hazardous chemicals and provide information to the local community about mixtures and chemicals present on campus, and meet the following reporting requirements:

Emergency Planning Notification requirement for chemicals listed on the extremely hazardous substances list

Emergency Release Notification Requirement for accidental chemical releases exceeding applicable minimal reportable quantities

Hazardous Chemical Storage Reporting Requirement for any hazardous chemical used or stored in the workplace.

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for the reporting requirements under EPCRA.

Chemical Facility Anti-Terrorism Standards

The Department of Homeland Security (DHS) issued risk-based performance standards for the security of chemical facilities based on storage of listed chemicals of concern. DHS regulations require covered entities to do the following:

Prepare, implement and submit to DHS Security Vulnerability Assessments (SVAs) which identify facility security vulnerabilities

Develop, implement and submit Site Security Plans (SSPs) which include measures that satisfy identified risk-based performance standards. 

The rule also contains provisions addressing inspections, audits, recordkeeping, and the protection of information that constitutes Chemical-Terrorism Vulnerability Information (CVI).

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for conducting inspections and assessments, developing security plans, and maintaining required documentation per DHS requirements.

Controlled Substances Act

The Act imposes the following requirements:

Registration:  The University must register with the Drug Enforcement Agency (DEA) in order to purchase, manufacture, distribute, import or export controlled substances.

Inventories: Initial inventory of all substances required on date substances first dispensed, manufactured, or distributed.  New inventories required every 2 years thereafter.  Inventories must be a complete and accurate record of all substances, and maintained in a written form at the registered location.

Storage and Security: Schedule I-II substances must be stored separately in a DEA-approved safe/vault/cage. Schedule III-V substances must be kept under lock and key (though less restrictive than for Schedule I-II substances).

Use and Transfer: Substances may only be used for authorized purposes.  Transfers must be authorized, and employees must report to University’s responsible security official any known diversion. Recordkeeping: Unless specifically exempted records must be kept for 2 years from date of inventory to account for substances used in any activity. 

Disposal: The University must list substances to be disposed of on DEA Form 41 and submit form to Special Agent in Charge of the area.

Reporting: An annual report of stock on hand must be filed by January 15th, and quarterly reports filed regarding acquisition and distribution. 

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for implementing processes and procedures to comply with the above requirements.

Operation of Biosafety Facilities [Biosafety in Microbiological and Biomedical Laboratories (BMBL) 5th Edition]

For activities involving infectious microorganisms and lab animals at Biosafety Levels (BLS) 1 and 2, the University must have biosafety measures such as:

Restricted access

Biohazard signage

Sharps protection

Biosafety and safety manuals

Physical containment devices

Personal Protective Equipment (PPE)

An organizational occupational health and safety plan

A medical surveillance program

Emergency procedures approved by the Institutional Animal Care and Use Committee (IACUC)

Procedures for decontamination

Appropriate waste transport 

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for implementing processes and procedures to comply with the above requirements.

Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT) Act

The University may not possess a biological agent or toxin, or delivery system of a type or quantity not reasonably justified by prophylactic, bona fide research or other peaceful purpose. “Biological agent” means a microorganism, virus, infectious substance, or biological product that may be engineered, or any naturally occurring, or a bio-engineered component of same capable of causing death, disease or biological malfunction in a living organism, or deterioration of food, water, equipment, supplies or material, or deleterious environmental alteration.  “Toxin” means the toxic material of living matter or infectious substances, or a recombinant molecule including any poisonous substance or biological product that may be engineered as a result of biotechnology produced by a living organism, or derivative of such a substance.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for conducting inspections and implementing processes and procedures ensure compliance with PATRIOT Act.

Clean Air Act

DC implements the Environmental Protection Agency (EPA) Title V air quality standards and emissions limits.  Per DC regulations, a stationary source (a building, structure, facility or installation) that emits or may emit any air pollutant regulated by the EPA must get a permit. Regulated pollutants include asbestos, lead compounds, chlorine, formaldehyde, hydrochloric acid, radionuclides, and mercury. If the University's stationary sources emit 25 tons or more of air pollutants per year, then written records of the nature and amount of emissions must be kept.  If the University has stationary sources emitting more than 100 tons per year, per Title VI the University must have monitoring devices.  Emissions of particulates from fuel burning equipment cannot exceed the DC limit, and performance testing for compliance is mandatory.

The Mandatory Reporting of Greenhouse Gases Rule, implemented pursuant to the EPA’s Clean Air Act powers, rule requires that the University submit an annual report on its greenhouse gas emissions.  Gases covered include: carbon dioxide (CO2) (a pollutant per the EPA); methane (CH4); nitrous oxide (N2O); hydro fluorocarbons (HFC); per fluorocarbons (PFC); sulfur hexafluoride (SF6); and other fluorinated gases and hydro fluorinated ethers.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for required monitoring, testing, and reporting under the Act and the Rule.

OSHA - Asbestos in Construction Standard

(Applies to construction only.)  No employee may be exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic cm of air as an 8 hour time-weighted average.  The University must monitor subject areas and potentially affected employees must be notified of results within 5 days. The University must use these safety procedures:

Demarcation and specific signage

Critical barriers for isolation

Hazard communication to potentially affected employees

Restricted access

Training for employees working with asbestos containing material (ACM) or who are likely to be exposed beyond permissible limits

Supervision of work by a competent person

Use of respirators

Engineering controls such as isolation processes, vacuum cleaners with HEPA filters, prompt clean-up procedures including wet clean-up, and use of leak tight containers

Decontamination procedures for entry and exit

The requirements above also apply to contractors.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for implementing and overseeing required monitoring and safety procedures per OSHA.

OSHA - Asbestos in General Industry Standard   

(Applies to occupational exposure other than construction.) The University must ensure that no employee is exposed to an airborne concentration of asbestos in excess of 0.1 fiber per cubic centimeter of air as an eight hour time-weighted average.  The University must perform initial monitoring where employees are or may reasonably be expected to be exposed at or above the exposure limit, and must promptly notify such employees of the results within 15 working days.  Required, repeated monitoring depends on the initial results.  Safety and compliance procedures required: 

Demarcation of regulated areas

Warning signage

Access by authorized personnel only

Provision of respirators and a respirator program

Training for employees exposed to exposure limits

Engineering controls and work practices such as wet method clean-up and exhaust ventilation

A written program to reduce exposure limits

Hazard communication to potentially affected employees 

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for implementing and overseeing required monitoring, safety and compliance procedures per OSHA.

OSHA - Lead in Construction Standard and DC Lead-based Paint Abatement Act of 1996                                               

(Applies to exposure to lead during construction only). The University must conduct lead exposure assessments for construction jobs (alternation, repair, demolition, painting, decorating) with possible exposure to lead to determine if exposure threshold met (i.e. > 50 micrograms concentration per cubic meter of air averaged over an 8 hours).  If the threshold is met, the University must notify affected employees, institute engineering and work practice controls to reduce exposure to permissible levels, and conduct repeat monitoring.  Also applies to contractors. 

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for implementing and overseeing required assessments, notification, controls and monitoring per OSHA.

OSHA - Lead in General Industry Standard

(Applies to occupational exposure to lead by employees in non-construction setting.) The University must ensure no employee is exposed to > 50 micrograms lead concentration per cubic meter of air averaged over an 8 hours.  Where there is potential exposure the University must make a determination as to whether employees are so exposed, and if so must notify the employee, institute corrective action via engineering and work practice controls, and repeat monitoring activities. 

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for implementing and overseeing required determinations, notifications, controls and monitoring per OSHA

Residential Lead-Based Paint Hazard Reduction Act

The act imposes the following requirements:

Lead-paint Activity: When performing any lead-based paint inspection, hazard screen, risk assessment or abatement, an Environmental Protection Agency (EPA) certified inspector must perform that activity in accordance with the testing, sampling and remediation requirements of the Act, and must prepare a report detailing the required steps undertaken for the activity.  All such reports must be maintained by the certified individual for 3 years.

Notification:  Annually, the University must provide an EPA-approved lead hazard information pamphlet, and disclosure of any known lead-based paint or hazards, to lessees of housing built prior to 1978 unless the housing is a “0 bedroom dwelling” such as a dormitory.

The Director of EH&S, in coordination with the Project Manager for Facilities Planning and Construction, is responsible for implementing and overseeing controls regarding lead-paint activity.  The Director of EH&S, in coordination with the Director of Housing, is responsible for issuing annual notifications.

OSHA - Welding, Cutting and Brazing Standard

Before welding or cutting ("hot work") is permitted, the area must be inspected by the individual responsible for authorizing cutting or welding operations.  That individual must designate precautions to be followed in granting authorization, preferably in the form of a written permit. Cutting or welding shall be permitted only in areas that are or have been made fire safe.  Appropriate PPE and clothing based on the type of work performed must be used. (Note: Per OSHA, to minimize carbon monoxide hazard, maintain 3-4 feet of clear ventilation space around generators).  DC also requires a permit from the Fire Marshall to perform hot work on campus.

The Director of EH&S, in coordination with the Occupational Safety & Health Specialist, is responsible for implementing and overseeing controls regarding the performance of hot work.

OSHA - Control of Hazardous Energy

The University must establish a program and procedures for affixing appropriate lockout or tagout devices to disable equipment to prevent unexpected energization, start up, or release of stored energy.  Program requirements:

Energy control procedures for shutdown and isolation for releasing and securing residual energy

Testing to verify energy control measure effectiveness

Training to ensure employees understand the program

Periodic inspections (at least annually) by an authorized employee other than those using the procedure being inspected; the University must certify the inspections were performed.

The Director of EH&S, in coordination with the Occupational Safety & Health Specialist, is responsible for implementing and overseeing controls to meet the lockout and tagout requirements.

OSHA - Guarding and Use of Hand and Portable Powered Tools

The University is responsible for the safe condition and guarding of portable powered tools and equipment, including tools furnished by employees. Examples of such tools include saws, drills, drivers, sanders, grinders, pneumatic tools, and explosive fasteners.  Before use the operator must inspect the tool to determine that it is clean and that all moving parts operate freely and free from obstructions.  Tools must be inspected at regular intervals and repaired in accordance with manufacturers’ specifications.  Tools that are found not to be in proper working order must be removed from service immediately. Tools must never be left unattended and where they are available to unauthorized persons.  All tools must be used with the shield, guard, or other safety attachments as recommended by the manufacturer. Operators must be safeguarded by means of eye protection and head and face protection where required by the particular working conditions.

The Director of EH&S, in coordination with EHS Program Manager, is responsible for implementing and overseeing controls and procedures regarding use of hand and portable powered tools.

OSHA's Hazard Communication Standard and Globally Harmonized Hazard Communication System

To comply with employees' right to know about the hazards associated with materials and substances they use on the job, the University must compile and maintain chemical inventories, and make Safety Data Sheets (SDS) readily available and accessible upon employee request.  OSHA issued proposed rules to adopt the “United Nations Globally Harmonized System of Classification and Labeling of Chemicals” (GHS), which was developed to provide a single, harmonized system to classify chemicals. GHS will address inconsistencies in hazard classifications and communications, and provide more consistent and accurate information to workers and employers. The GHS requires re-inventory and re-labeling of chemicals.

The Director of EH&S, overseeing and in coordination with the University’s third party contractor, is responsible for maintaining chemical inventories and overseeing the inventory and re-labeling of chemicals per OSHA and the GHS.

OSHA - Emergency Action Plan

The University must have a written emergency action plan kept in the workplace and available for employee review.  The plan must include:

Procedures for reporting a fire or other emergency

Emergency evacuation instructions

Procedures for critical operations personnel who remain on site

Procedures to account for all employees after evacuation

Procedures for employees performing rescue or medical duties

The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan

Training for designated employees who will assist in the orderly evacuation of other employees

The Director of EH&S is responsible for maintaining the Emergency Preparedness and Response provisions of the Environmental Health and Safety Manual, and for working with and supporting the Director of Public Safety, who is the Responsible Official for the Emergency Preparedness, Reporting, Response and Recovery Policy and the Emergency Response Plan.

OSHA - Bloodborne Pathogen Standard    

The University must maintain a written exposure control plan and provide appropriate instruction on precautions to all workers who might become exposed to blood or other potentially infectious materials. The regulation applies to any facility where occupational exposure, such as through first aid administration, can be reasonably anticipated.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for implementing the bloodborne pathogen exposure control provisions in compliance with OSHA.

OSHA - Personal Protective Equipment (PPE)

PPE is required to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing exposures to acceptable levels.  The University must assess the workplace to determine if hazards capable of causing injury or impairment through absorption, inhalation or physical contact are present or likely to be present that necessitate use of PPE. If so, the University must train each employee who is required to use PPE regarding when and what PPE is necessary, how it is to be used or worn, and its limitations.  Each employee must demonstrate an understanding of the training.  PPE must be provided, used, and maintained in a sanitary and reliable condition.  The University must pay for PPE, except footwear.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for implementing the PPE provisions in compliance with OSHA.

OSHA - Respiratory Protection Standard

The University must provide respirators when necessary to protect the health of the employee from occupational diseases caused by breathing air contaminated with harmful dusts, fumes, gases, vapors, etc.  The University must develop and implement a written respiratory protection program administered by a suitably trained program administrator.  The Program must provide procedures for the following:

Medical evaluations

Fit testing

Proper use of respirators

Maintenance schedules

Training of employees regarding respiratory hazards and proper use of respirators

Regular program evaluations

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for implementing the respiratory protection provisions in compliance with OSHA.

OSHA - Permit Required Confined Space

If the University allows employees to enter permit required confined spaces (those with a hazardous atmosphere or other health hazards or with potential for engulfing/trapping an entrant) it must inform exposed employees of the danger and develop a written permit-required confined space program.  The permit program must:

Implement measures to prevent unauthorized entry

Identify and evaluate hazards before employees enter them

Implement procedures and practices for safe entry operations

Provide and maintain PPE and testing, monitoring, lighting, and emergency equipment

The Director of EH&S is responsible for implementing the permit required confined space provisions in compliance with OSHA.

OSHA - Powered Industrial Trucks

The University must ensure that prior to operation of an industrial truck (fork trucks, tractors, platform lift trucks, motorized hand trucks) each operator is competent to operate the truck safely as demonstrated by successful completion of training and evaluation.  The University must certify that each operator has been trained and evaluated regarding use.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for training, evaluation and certification of operators in compliance with OSHA.

OSHA - Fall Protection

(Applies to construction only).  The University must determine if walking or working surfaces have strength and structural integrity to support employees safely.  The University must provide fall protection systems (guardrails, safety nets, fall arrest systems) where employees work 6 feet or more above edges, holes, ramps, walkways, openings or dangerous equipment, or are engaged in overhand bricklaying, roofing or precast concrete erection 6 feet or more above lower levels. If this is infeasible or creates a greater hazard an alternate fall plan must be developed.  If employees are exposed to falling objects the University must have each employee wear a hard hat and must implement toe boards, screens, or guardrail systems, erect a canopy structure, or barricade the area.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for maintaining the University’s fall protection provisions in compliance with OSHA.

OSHA - Aerial Lifts

The University must ensure that employees operating personnel-carrying devices (baskets or buckets) that is a component of an aerial device used to position workers has undergone operator training to ensure the devices are used properly.

The Director of EH&S, overseeing and in coordination with the University’s Industrial Hygienist, is responsible for maintaining the University’s aerial lift protection provisions in compliance with OSHA.

Reporting Occupational Injuries

The Occupational Safety and Health Act (OSHA) requires that employers with 11 or more employees report the total number of job-related injuries and illnesses that occurred in the prior calendar year on OSHA Form 300 to the Department of Labor no later than April 30th.  A log of injuries also must be kept, but need not to be provided to the government.  While the University is a SIC Code 82 institution and thus exempt from this OSHA requirement, the University files a Form 300 to satisfy the annual survey for the Bureau of Labor Statistics regarding occupational injuries and illnesses.

The Director of EH&S, overseeing and in coordination with the University’s EHS Program Manager, is responsible for maintaining job-related injury and illness data and for annual reporting.

D.C. Fire Safety Requirements and Fire Safety Reporting per the Higher Education Opportunity Act (HEOA) 

For any buildings owned by the University that consist of 3 or more stories D.C. requires that the University have at least 1 fire escape, and must provide, install, and maintain therein proper and sufficient guide signs, guide lights, exit lights, hall and stairway lights, stand-pipes, fire extinguishers, and alarm gongs and striking stations in such locations and numbers and of such type and character as the DC Mayor may determine. A Fire Plan is required for buildings of 6 stories or more.

The HEOA requires that the University test annually its emergency response and evacuation procedures and annually publish a campus Fire Safety Report that provides statistics on a dorm-by-dorm basis showing the number of fires, deaths, injuries, fire drills, property damage, type of fire detection systems, etc.

The Director of EH&S, in coordination with the Occupational Safety & Health Specialist, is responsible for implementing and overseeing fire safety controls to meet the requirements of the DC Act, for conducting fire alarm testing, and for supporting the Administrative Assistant in the Department of Public Safety who is responsible for the University’s Annual Security and Fire Safety Report.

Resources

Campus Safety Health and Environmental Management Association (CSHEMA) website provides information sharing, continuing education, and professional connections to individuals with environmental health and safety responsibilities in educational communities.

Related Policies

Annual Security and Fire Safety Report

Contractor Safety Guide

Emergency Preparedness, Reporting, Response and Recovery Policy

Emergency Response Plan

Environmental Health and Safety Manual

Environmental Health and Safety (website)

Laboratory Security Policy

Project Manager Safety Guide

Radiation Safety Manual

Safety and Protection of the Environment Policy