EHS Regulatory Overview
College 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
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Laws & Regulations
Executive Orders
Guidelines
Industry Standards
Best Practices
University Policies
Occupational Safety
Requirements Framework
• OSHA State Plan States
• OSHA/VOSH: Workplace Safety & Health
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Bloodborne Pathogens
Hazard Communications
Walking and Working Surfaces
Personal Protective Equipment
and MANY more
- Confined Spaces
- Electrical Safety
- Fall Protection
• DHRM: Workers’ Compensation
• NFPA/NEC: Electrical Safety
Occupational Health
Requirements Framework
• 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
Laboratory Safety
Requirements Framework
• OSHA/VOSH: Laboratory Safety and Chemical Hygiene,
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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
Environmental Compliance
Requirements Framework
• EPA/DEQ:
– Air Emissions
– Hazardous Materials & Waste
– Spill Prevention and Controls
– Pesticide Application
– Storm Water Pollution Prevention
– AST and UST
• Local POTW
Fire Safety
Requirements Framework
• IFC/VaSWFPC:
– Fire Prevention
– Fire Suppression Systems
• IBC
• NFPA:
– Specific Codes as Adopted by VaSWFPC
• DoEd:
– Fire Statistics in Residence Halls
Emergency Preparedness
Requirements 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
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
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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
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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
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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
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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
Inspection Frequency
Equipment:
Weekly
Portable Fire Extinguisher:
Monthly
Quarterly
Annually
X
Responsible Party
EHS
Smoke Alarm:
X
Contractor
Fire Alarm:
X
Contractor
Fire Pump Inspection:
X
EHS
Fire Pump Test:
FDC and PIV:
X
X
Contractor
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 / Testing
Equipment:
A
Back Flow
Preventer
Monthly
Building
Inspection
Quarterly*
Check Valve
Fire Safety Programs
Inspection/Cleaning Frequency
Resp.
B
E
R-2
Party
Monthly
Monthly
Monthly
EHS
SemiAnnually*
Annually
EHS/SFM
Annually
*
Testing/Certification Frequency
A
B
E
R-2
Resp.
Party
Annually Annually Annually Annually EHS/FM
NA
NA
NA
NA
NA
?
?
?
?
?
?
?
?
?
?
Weekly
Weekly
Weekly
Weekly
EHS
Quarterly Quarterly Quarterly Quarterly
EHS
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
Quarterly Quarterly
EHS
NA
NA
NA
Quarterly Quarterly Quarterly Quarterly
EHS
Control Valves
(sealed
nonmonitored)!
Control Valves
(locked or
tampered)
Evacuation/Shelt
Quarterly
er Training***
Fire Department
Connection
Fire Alarm
System
Weekly
NA
Weekly
Weekly
Weekly
Monthly Occupants
NA
NA
Five Years Five Years Five Years Five Years EHS/FD
FM-FAS Annually Annually Annually Annually
EHS/C
Systems Inspections / Testing
Equipment:
A
Fire Safety Programs
Inspection/Cleaning Frequency
Resp.
B
E
R-2
Party
A
Testing/Certification Frequency
B
E
R-2
Resp.
Party
NA
NA
NA
NA
Fire Drills
Quarterly Annually Monthly Quarterly
EHS
Fire
Extinguishers
Monthly Monthly Monthly Monthly
EHS
Annually Annually Annually Annually
EHS
Fire Pump^
Weekly
EHS
Annually Annually Annually Annually
EHS/C
EHS/C
SemiSemiSemiSemiAnnually Annually Annually Annually
EHS/C
EHS
Annually Annually Annually Annually
EHS/C/F
D
Hood System
Cleaning****
Stand Pipes#
Weekly
Weekly
Weekly
Annually Annually Annually Annually
Weekly
Weekly
Weekly
Weekly
NA
PIV (include in
Monthly Monthly Monthly Monthly
EHS Quarterly Quarterly Quarterly Quarterly EHS
control valve)
Smoke Detector
NA
Weekly
NA
Weekly Occupants Annually Annually Annually Annually
EHS
(battery)
Automatic Fire
SemiSemiSemiSemiDoors/Curtains/
FM
Annually Annually Annually Annually
FM
Annually Annually Annually Annually
Rollup
Smoke Evac
System (nonWeekly Weekly Weekly Weekly
Annually Annually Annually Annually
dedicated)
Smoke Evac
SemiSemiSemiSemiSystem
Weekly Weekly Weekly Weekly
Annually Annually Annually Annually
(dedicated)
Sprinkler
Annually Annually Annually Annually
EHS Quarterly Quarterly Quarterly Quarterly EHS/C
System
Inspection Records
Systems Inspections
Systems Inspections
Fire Drills
Annual Fire Drills
• Based on occupancy
• Must be documented
Group or Occupancy
Assembly Buildings
Group A
Educational / Business
Group B
Adult and Child Care
Group E
Hotels
Group R-1
Residence Halls
Group R-2
Frequency
Examples
Quarterly
Patriot Center, Center for the Arts, Johnson Center
Annually
Innovation Hall, Research I, Thompson Hall
Monthly
Child Development Center
Quarterly Each Shift
The Mason Inn
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 Violence
2. Terrorism and Security Awareness Orientation
3. 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
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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
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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 Zobel
Assistant 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 Office
ehs.gmu.edu