General Safety and Compliance Information for Everyone

General Safety and Compliance Information for Everyone

Each and every employee of UNL plays an important part in establishing and maintaining a safe work place and protecting our environmental resources. UNL is subject to a myriad of occupational safety, biosafety, radiation safety, and environmental compliance standards and regulations. The compliance status of the institution collectively is dependent on the actions of each individual in our community. This section of the Virtual Manual is intended to introduce you to those occupational safety and environmental protection considerations that apply to each and every employee.

Occupational Safety

Nebraska Title 230, Chapter 6, Workplace Safety Consultation Program, was established by the legislature in 1993 pursuant to Neb. Rev. Stat. §48-443. This law and implementing regulations required Nebraska employers to establish effective Injury and Illness Plans, and clearly stated that, at a minimum, federal Occupational Safety and Health Administration (OSHA) regulations and standards would be considered when evaluating workplaces.

The NU Board of Regents Safety Policy was adopted in response to this law and articulates the Institution's commitment to prevention of occupational injuries and illnesses, and emphasizes that each employee must practice the highest degree of concern for the safety of fellow employees, students, patients, and the general public. This policy mandated each campus develop and implement a safety program, including operation of a campus-wide safety committee. The foundation for UNL's safety program is the UNL Injury and Illness Prevention Plan (IIPP), which EHS offers as a web-based training course, Core-Injury and Illness Prevention Plan, required for all employees who receive a paycheck from UNL. The UNL committee that supports this policy is called the Chancellor's University Safety Committee (CUSC) and is described in the EHS SOP, Chancellor's University Safety Committee (CUSC). Information regarding committee activities, including minutes and membership are posted on the EHS web page (http://ehs.unl.edu/committees/). Key components of the UNL IIPP include hazard identification and control, provisions for responding to imminent hazards, employee training, safety inspections, accident reporting and investigation, recordkeeping, and safety committees. These components of the UNL IIPP are summarized in the following sections:

  1. Hazard Identification and Control

    One method used to identify workplace hazards is regular audits/surveys, which is described in more detail in a later section titled "Safety Inspections." In addition, EHS provides a Job Safety Assessment tool which guides the user through identification and documentation of environmental, equipment/tool/mechanical, chemical, biological, and ergonomic hazards. Once these hazards are identified, they can be controlled through engineering and administrative controls (as described later) and appropriate Personal Protective Equipment (PPE).

    Some hazards are common to all UNL work places, such as fires, bomb threats, natural gas leaks, and natural emergencies/disasters. UNL's Emergency Planning and Preparedness web site is dedicated to emergency preparation and mitigation. All employees are encouraged to visit this site and sign up for UNL Alert, a service which sends emergency messages to devices you specify. UNL Alert is designed to help facilitate early notification during emergencies. Because institutional procedures are rather generic, they must be supplemented with individual department/work place procedures. For example, an individual department procedure will specify the tornado shelter location for that building, whereas the campus wide tornado procedure does not identify specific shelter locations.

    The EHS web-based Core-Emergency Preparedness training module, required for all employees who receive a paycheck from UNL, effectively compiles information from the UNL Emergency Planning and Preparedness web site (mentioned above) for emergency situations UNL employees are mostly likely to encounter. The following EHS SOPs are designed to assist in local emergency planning efforts:

    Of particular and recent concern has been the threat of a pandemic flu event. EHS provides the following guidance with respect to that particular hazard:

    Other common hazards include electrical and fire hazards, ergonomic stressors, slips/trips/falls, indoor air pollutants, and motor vehicle operation. Guidance on appropriate hazard control techniques for electrical and fire hazards are provided in the EHS web-based training modules for Fire Extinguisher Training and General Electrical Safety Awareness Training. An overview on each of these topics may be found in the following EHS SOPs:

    A significant number of musculoskeletal injuries are reported by UNL employees each year, resulting in hundreds of thousands of dollars of loss. Often, these injuries occur as a result of improper lifting techniques, repetitive stress, strain, or poor work space design. The following SOPs provide guidance on avoiding these types of injuries:

    Slips/trips/falls is another classification of injury that occurs in large numbers and at great expense at UNL. Guidance on avoiding this type of injury is provided in the following EHS SOP:

    While indoor air quality (IAQ) concerns rarely result in injury/illness, they occur regularly at UNL. The following SOP describes what actions to take when you have an IAQ concern, as well as steps that can be taken to prevent deterioration of the quality of the indoor environment.

    Motor vehicle operation poses risk of serious injury and property loss. General safety considerations include:

    • Consistent use of seat belts by all occupants
    • Operation only by licensed drivers; preferably drivers who have had a recent safe driving course
    • Maintaining the vehicle in reliable condition and adherence to recommended maintenance schedules
    • Observation of vehicle load ratings and distribution
    • Following all driving regulations, including posted speed limits
    • Avoiding operation during severely inclement weather
    • Completion of UNL Transportation Services required training if operating a 15-passenger van

    After augmenting the general institutional procedures/information referenced above with work area or task specific risk mitigation strategies, the next step is to inform individually affected employees. The EHS SOP, Communication of Work Area Safety Information provides additional discussion and a helpful checklist. One method used to inform employees of potential hazards is through door postings. The EHS SOP, Door Postings for Potentially Hazardous Locations, describes the door posting methodology, which employs either: 1) a combination of words (e.g., noise, biological agents, flammable liquids, compressed gases, magnetic fields, etc.) or pictograms (standard symbols for each type of hazard); or 2) a National Fire Protection Association (NFPA) diamond. In general, the word/pictogram system is used for laboratory-type occupancies while the NFPA diamond is used for non-laboratory spaces.

  2. Hazards Mitigation & Imminent Hazards

    Of course, identification and communication of a hazard is only part of the answer. After a hazard has been identified, a risk mitigation strategy must be developed and implemented. The risk mitigation strategy will incorporate one or more of the following (in order of preference): 1) substitution or elimination (i.e., substituting a non-toxic chemical for a toxic chemical); 2) engineering controls (i.e., using chemical fume hoods for processes that generate vapors); 3) administrative controls (i.e., written operating procedures, training), and; 4) personal protective equipment (i.e., splash goggles, gloves, etc.). Supervisors are responsible to develop appropriate risk mitigation plans and to train employees under their supervision to the risk mitigation plans. Employees are responsible to adhere to the established risk mitigation plans. In the case of hazards that present risk of serious adverse consequences, risk mitigation plans should be documented. EHS SOPs may be used where appropriate, but must be supplemented with site/task-specific procedures when insufficient to adequately control the hazard. Risk assessment is a methodical process consisting of the steps listed below. As previously discussed, the EHS SOP, Job Safety Assessment is a tool that can be used to assist in the hazard identification and control process.

    • Identify the hazards. Consider anything that may cause harm such as health and physical hazards of chemicals, electricity, working from ladders or at heights, ergonomic stressors, etc.
    • Evaluate the risk. Consider the likelihood of an adverse event (whether the risk is of personal injury, property damamge, or environmental damage) and the possible magnitude of an adverse event.
    • Evaluate control strategies (substitution/elimination, engineering controls, administrative controls, personal protection equipment).
    • Document and implement effective control measures to reduce the risk. Train employees to the risk mitigation plan/procedures.
    • Update the risk mitigation plan in response to process changes, near-miss incidents or accidents, or as more effective control measures become available.

    The following EHS SOPs and web-based training provide general Personal Protective Equipment selection guidance:

    In the case of an uncontrolled and imminent hazard that poses an immediate threat of injury, illness, death, and/or significant damage to property, the IIPP vests every employee with responsibility and authority to: stop the operation (if under the employee's immediate control); notify potentially affected employees of the hazard, or; report the danger to a supervisor having jurisdiction over the area and/or EHS.

  3. Employee Training and Medical Surveillance

    The success of any safety and compliance initiative requires an effective training program. EHS offers various training programs based on need. Not all persons require the same training. At a minimum, all UNL employees must complete EHS Injury and Illness Prevention Plan and Emergency Preparedness training, available as web-based or instructor-led classes. Other required training may include but is not limited to: Chemical Safety, Bloodborne Pathogens, Radiation Safety, Respirator Use, Powered Industrial Trucks, etc. EHS also offers web-based training modules that are not specifically required by regulation, but are strongly encouraged for affected employees. Examples include General Electrical Safety and Ladder Safety. The Training Needs Assessment describes what training applies to whom. Special training consideration and requirements apply to employees who are assigned to alternate work sites, see EHS SOP, Safety Training for Employees Who Are Assigned to Alternate Work Sites.

    Most employees are not subject to medical surveillance requirements because they are not exposed to significant hazards that are expected to result in occupational injury/illness. However, certain prospective and current employees of UNL are subject to post-offer, pre-employment and/or continuing medical surveillance exams. Consult UNL Human Resources regarding the post-offer, pre-employment medical qualification program. Consult your supervisor or EHS regarding the need for regular medical surveillance exams. Persons commonly subject to routine medical examinations include certain pesticide applicators, users of hearing protective devices, and licensed asbestos workers.

  4. Safety Inspections

    EHS conducts routine audits of all UNL work locations. However, the people who actually work in a specific area are in the best position to provide regular and routine surveillance for uncontrolled hazards. The IIPP charges all persons with responsibility for routine auditing to detect and abate hazards. The following EHS SOPs provide short checklists that can be used to conduct such audits:

  5. Accident Reporting and Investigation

    Employees who suffer an occupational injury or illness may be eligible for workers' compensation benefits. However, benefit eligibility cannot be established until the following forms are completed and submitted to the UNL Benefits Office: First Report of Alleged Occupational Injury or Illness, Workers' Compensation Incident Report, and Employee's Choice or Change of Doctor Form. Following receipt of a report of occupational injury, EHS will conduct an accident investigation to determine root cause(s) and corrective action(s) to prevent similar incidents in the future. The EHS SOP, On-the-Job Injuries, provides further information on this topic.

    If an employee is subject to work restrictions due to an occupational injury, the Release to Return to Work Form should be completed by the attending physician and provided to the supervisor.

  6. Safety Committees

    In addition to the campus-wide Chancellor's University Safety Committee, many departments have formed unit safety committees. Consult with your department regarding unit safety committee activities. Resources available for unit safety committee use can be found on the EHS web page at http://ehs.unl.edu/committees/.

    Other campus-wide safety/compliance related committees include:

    • Institutional Biosafety Committee (IBC), which oversees research, teaching, and clinical activities involving recombinant or synthetic DNA, pathogens (human, animal, plant), and biologically derived toxins.
    • Radiation Safety Committee (RSC), which oversees activities involving ionizing radiation.
    • Institutional Animal Care and Use Committee (IACUC), which oversees activities involving live vertebrate animals.
    • Institutional Review Board (IRB), which oversees research involving human subjects.

Environmental Protection/Compliance

UNL is subject to certain waste management regulations, which require special handling and disposal of materials that may harm the environment. Materials as seemingly innocuous as aerosol cans containing whipped cream are regulated when disposed! Generally speaking, EHS provides pickup and management services for all potentially regulated waste streams. The process for requesting EHS service is described in the EHS SOP, Hazardous/Radioactive Material Collection Procedures.

The following EHS SOPs discuss proper management of commonly generated/encountered items/materials/wastes:

Failure to comply with waste management regulations can result in civil penalties and/or criminal prosecution. The United States Environmental Protection Agency (EPA) has authority to levy fines up to $32,500/day/violation! The EPA routinely audits campus operations for compliance with hazardous waste regulations. Be prepared in case you are the subject of such an audit by reviewing the EHS SOP, State or Federal Hazardous Waste Inspections.

The Nebraska Department of Environmental Quality (NDEQ) required UNL to obtain a permit for discharge of storm water from the Lincoln Campuses. The objective of the permit is to reduce the amount of pollutants carried to receiving streams during storm events. Examples of potential pollutants include fluids from leaking automobiles, sediments from disturbed soils, nutrients and pesticides from lawn care, and de-icing compounds. A key component of UNL's Storm Water Management Plan includes the detection and elimination of illicit discharges. The campus community can assist in this effort by reporting potential illicit discharges to EHS. More discussion on this topic is provided in the following EHS SOPs:

Other types of discharges to surface waters may also be subject to permit requirements. Consult EHS before engaging in any activity that introduces water or other materials to the storm sewer system (e.g., connecting foundation drains, dewatering excavations, installing cooling towers or boilers, or heat pumps, etc.)

Asbestos

At UNL, asbestos is present in many buildings in the form of pipe, duct, and boiler insulation, fireproofing, floor tiles and mastics, ceiling textures, roofing materials, laboratory countertops, and other building components. These and other items (i.e., fire curtains, wire insulation, etc.) that contain greater than 1% asbestos are referred to as "Asbestos Containing Materials (ACM)." Certain building materials that have not been tested to determine their asbestos content and which were manufactured prior to 1980 are presumed to contain asbestos. These materials are referred to as "Presumed Asbestos Containing Materials (PACM)."

While exposure to asbestos is a serious health concern, current risk assessment data indicates that when properly managed, undamaged ACM in buildings does not present a significant health risk to building occupants. ACM becomes a health concern when it is subject to forces that cause individual asbestos fibers to release from their matrix and become airborne. This state of ACM is referred to as "friable."

If you think you may be working on or near ACM or PACM and your intended work could cause disturbance of ACM or PACM such that it may become friable, STOP. Consult with UNL's Building Systems Maintenance (BSM) department. They maintain data related to ACM and PACM in each UNL building. Any work that may disturb ACM or PACM must be conducted only by Nebraska licensed workers and under the authority/oversight of BSM or other recognized authority.

If you are a maintenance or custodial worker, your supervisor will provide you with information on presence of ACM/PACM in your assigned work areas and procedures/precautions for work activities to avoid ACM/PACM disturbance. In addition, you should complete the EHS web-based Asbestos Awareness Training. This training teaches participants how to recognize ACM/PACM and implement precautions to avoid disturbing ACM/PACM. This training should be completed before an employee is assigned to work that could disturb ACM/PACM and annually thereafter.

Sometimes, you may see warning signs and workers who are conducting asbestos removal or repair activities in your building. These projects are carried out in a manner to prevent uncontrolled release of asbestos fibers to the building environment. The EHS SOP, Asbestos Facts provides additional information about asbestos and frequently asked questions regarding asbestos abatement projects at UNL facilities. Anyone observing damaged materials that may contain asbestos is asked to promptly notify BSM.

All employees who conduct custodial and light maintenance activities and operations that, if done improperly, could disturb ACMs should take the EHS web-based Asbestos Awareness Training module. Training should be taken upon initial employment and annually thereafter.

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