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SAFETY, OCCUPATIONAL HEALTH

ADMINISTRATIVE REGULATION - 4147

It is the policy of the Irvine Unified School District to provide each employee and student with a safe and healthy environment in which to work and learn. Accordingly, and in compliance with the Occupational Safety and Health Administration’s (OSHA) published Hazard Communication Standard - 29 CFR 1910.1200, the District herein establishes its hazard communication program which includes but is not limited to:

  1. Standardization of and control procedures for all chemicals in use within the District.
  2. Preparation and distribution of Material Safety Data Sheets (MSDS) for all chemicals in use within the District.
  3. Development and implementation of employee training and information programs regarding the hazards of chemicals and protective measures required for use and storage.

The purpose of the District’s Hazard Communication Program is to comprehensively address the potential hazards of chemicals in use within the District and to educate and inform all personnel concerned regarding the hazards and appropriate protective measures.

Copies of the District Hazard Communication Program will be held on file in the administrative office at each site and made available, upon request to employees, parents or students.

The Safety and Security Branch of the Maintenance and Operations Department is assigned overall responsibility for coordination of the Hazard Communication Program and individual site administrators will be responsible for implementation of the program at the site to include such actions as may be required to prohibit the introduction of undocumented chemical products.

HAZARD DETERMINATION

The initial hazard determination will be established by the Safety and Security branch in cooperation with the firm of Keenan and Associates, the District’s third party liability and workers compensation Administrator. Generally, any substance listed in 29 CFR 1910. Subpart Z, Toxic and Hazardous Substances: The American Conference of Governmental Industrial Hygienist (ACGIH), Threshold Limit Values for chemical substances and Physical Agents in the Work Environment, the International Agency for Research on Cancers’ (IARC) Monographs will be considered a health or physical hazard, and therefore, hazardous. Furthermore, any substance otherwise known to be hazardous will be incorporated in the District program.

SITE INVENTORY

Every hazardous substance known to be present at the site will be listed on a "Hazardous Chemical Inventory" which will be maintained as a part of the site’s Hazard Communication Program file. A material safety data sheet (MSDS) will be maintained for each chemical listed on the site inventory. The Hazardous Chemical Inventory list will serve as the index for the MSDS file. The identity of the hazardous chemical must be consistent with the same product name appearing on the inventory list, material safety data sheet, manufacturer’s label and/or District label.

MATERIAL SAFETY DATA SHEETS

A material safety data sheet (MSDS) must be held on file for each chemical listed on the site inventory. Each MSDS held will contain the following information:

  1. The identity used on the label. (Product name)
  2. The date of preparation of the MSDS or the last change of it.
  3. The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the MSDS, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.
  4. The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise IX or greater of the composition, except chemicals identified as carcinogens shall be listed if the concentrations are 0.1% or greater.
  5. The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer or employer preparing the MSDS.
  6. Whether the hazardous chemical is listed in the National Toxicology Program (NTP) "Annual Report on Carcinogens" (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) "Monographs" (latest edition), or by OSHA.
  7. The chemical and common name(s) of all ingredients which have been deter-mined to present a physical hazard when present in the mixture.
  8. Physical and Chemical characteristics of the hazardous chemical (such as vapor pressure, flash point).
  9. The physical hazards of the hazardous chemical including the potential for fire, explosion, and reactivity.
  10. The health hazards of the hazardous chemical. including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by the exposure to the chemical.
  11. The primary route(s) of entry, i.e. eyes, skin, nose, mouth etc.
  12. Emergency and first aid procedures.

LABELING

Hazardous chemicals will not be accepted at a site unless they are properly labeled with the following information:

  1. Identity of the product
  2. Appropriate hazard warning
  3. Name and address of the manufacturer, importer, or other responsible party

All District/site originated containers will be labeled with the following information:

  1. Identity of the chemical
  2. Appropriate hazard warning

Standardized District labels are in stock at both the Safety and Security office and school site science laboratories, both of which are responsible for reviewing and assuring that the label information is correct. Applied labels must remain intact and may not be defaced or removed from the container.

EMPLOYEE TRAINING

All employees, including temporary and substitute employees, who work with or have the potential for direct exposure to hazardous chemicals must be familiarized with the correct procedures for the handling and storage of these chemicals as well as any health and safety hazards to which they may be exposed as a result of contact with the chemicals.

Employee training must be accomplished as soon as possible after employment but in no case later than 30 days after assignment. Employees who have not received the required training must be under the direct supervision of a trained employee when handling chemical substances.

Employee training is established as an on-going process subject to annual refresher training and timely re-training to accommodate new chemicals or significant changes to existing chemicals which alter the exposure risks or increase any degree of hazard associated with normal use.

Employee training will become a matter of record and a verification of training signed by both the employee and the individual providing the training will be placed in the employee’s personnel file.

The Safety and Security Branch of Maintenance and Operations will be the overall coordinator of employee training and be responsible for such actions as may be required to ensure the quality and the effectiveness of the training program.

The employee training program will include, but not necessarily be limited to:

  1. An explanation of what a Material Safety Data Sheet is, its intended purpose and how to read and interpret the information provided on the Material Safety Data Sheets.
  2. An explanation of the information provided on the Material Safety Data Sheets:

• The health hazards associated with the use and/or exposure to the substance.

• Proper handling for safety to reduce the exposure.

• Personal protective equipment which is necessary or recommended during handling or use of the substance.

• Emergency procedures for spills, fires, first aid and disposal.

• Other safety precautions necessary to prevent or minimize exposure to the substance.

3. An explanation of the information on the container label.

4. An explanation of the right of the employee to obtain a copy of the Material Safety Data Sheets from the District and the procedure to be followed.

5. Specific safety training of non-routine tasks as determined by site administrator/ department head prior to employees undertaking these tasks.

Employees of vendors must receive training on the hazardous substances which they will come in contact with on the District premises. The Maintenance Department shall provide the substance inventory for the work area involved to the vendor prior to the vendors employees beginning work on District premises. Contracts with vendors shall state that their employees will be properly trained by the contractor before beginning work at the District.

PROGRAM RESPONSIBILITY

Responsibilities for employee training are assigned as follows:

  1. The Supervisor of Safety and Security is assigned overall program coordination responsibilities to include program quality control and compliance reporting and recording. Additionally, the Safety and Security Branch will act as the point of contact between outside agencies and the District in matters of program compliance and incident reporting.
  2. Site administrators are responsible for management of science labs and other such classroom related chemicals to include compliance with the mandates of the Hazard Communication Standard as applicable to certificated staff and students.
  3. The Supervisor, Custodial Services Branch, is responsible for training support of custodial personnel assigned to elementary and middle schools, Creekside High School, the District Office, Transportation and Maintenance and Operations. This includes substitute custodial pool personnel, as well.
  4. The Plant Supervisors at Irvine, University, Woodbridge, and Northwood High Schools will be responsible for the training and record keeping of assigned custodial and grounds maintenance personnel, as well as coordination of site chemical usage with the Safety and Security Branch.
  5. The Directors of Transportation and Food Services and the Supervisors of Building Maintenance and Grounds Maintenance Services will be responsible for training of assigned personnel as required, and the coordination of administrative and record keeping with the Safety and Security Branch.

HAZARDOUS CHEMICALS

The definition of a hazardous chemical according to OSHA is any chemical which is a physical hazard or a health hazard.

1. "Physical hazard" means a chemical for which there is scientifically valid evidence that it is:

  1. Combustible Liquid - any liquid having a flashpoint at or above 100°F, but below 200°F.
  2. Compressed Gas - a gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70°F; or exceeding 104 psi at 103°F regardless of the pressure at 70°F; or a liquid having a vapor pressure exceeding 40 psi at 100°F.
  3. Explosive - a chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.
  4. Flammable - a chemical (gas, liquid or solid) which can be ignited below 100°F by a spark, flame or static electricity.
  5. Organic Peroxide - an organic compound that contains the bivalent-O-O-structure and which may be considered to be a structural derivative of hydrogen peroxide where one or both of the hydrogen atoms has been replaced by an organic radical.
  6. Oxidizer - a chemical other than a blasting agent or explosive that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.
  7. Pyrophoric - a chemical that will ignite spontaneously in air at a temperature of 130°F or below.
  8. Unstable reactive) - a chemical which in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shocks, pressure or temperature.
  9. Water Reactive - a chemical that reacts with water to release a gas that is either flammable or presents a health hazard.

2. "Health hazard" means a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard," includes chemicals which are:

  1. Carcinogen - a chemical which is considered to be an agent causing or inciting cancer.
  2. Toxic or highly toxic agents - a chemical that has a median lethal dose or concentration.
  3. Irritant - a chemical which is not corrosive, but which causes a reversible inflammatory effect on living tissue by chemical action at the site of contact.
  4. Corrosive - a chemical that causes visible destruction of, or irreversible alterations in living tissue by chemical action at the site of contact.
  5. Sensitizer - a chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical.
  6. Target organ effects - a chemical which has effects on the hematopoietic system, lungs, skin, eyes or mucous membranes.

Reviewed August 2004