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INDEX
Introduction Background Information Policy
Principal Investigator's and Supervisor's Responsibilities Compliance Guidelines Safety Communications
Employee Safety Training Resources Safety Education and Training
  Conclusions  
 

Introduction

As a new Science or Engineering faculty member, it is your responsibility to determine what Federal, State, and/or Local health and safety regulations impact you, your students, and your research before you begin your work at Lehigh University. Lehigh University Environmental Health and Safety (EH&S) office at 616 Brodhead Avenue deals with health, safety, and environmental issues and develops programs which will assist you in your compliance efforts. The purpose of this guide is to acquaint new Science and Engineering faculty members with programs and procedures which have been established to ensure a safe and healthy environment for all members of the Lehigh community.

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Background Information

The Federal Occupational Safety and Health Act charges employers with the responsibility to assure safe and healthful working conditions for all employees. It requires the employer provide each employee with a place of employment that is free from recognized hazards and that is in compliance with the standards established under the Act. The Act covers all private higher education institutions. In addition, subsequent legislation regulating organizations which handle hazardous waste and hazardous materials have either required compliance with the Occupational Safety and Health Act or set new standards of their own for health, safety, and emergency planning.

Collectively, this legislation requires every employer to establish, implement, and maintain an effective Environmental Health and Safety Program including, but not limited to: a written program for identifying and evaluating hazards; procedures for correcting unsafe conditions; a system for communicating with employees; regularly scheduled safety meetings; employee training programs; compliance strategies; on-going documentation/recordkeeping; and identification of a person responsible for program compliance.

Lehigh University is regulated under the Federal Hazard Communications Standard or OSHA Right-To-Know Law as it is more commonly named. The objective of this law is to transmit information concerning the nature of chemical hazards that employees may be exposed to in their work environment and what measures they can take to protect themselves.

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Policy

It is the policy of the University to maintain, insofar as it is reasonably within its control to do so, a Campus environment for faculty, staff, students, and the public that will not adversely affect their health and safety nor subject them to avoidable risks of accidental injury or illness. No student or employee will be required to perform any task which is determined to be unsafe or unreasonably hazardous.

To accomplish this, the University, its Departments, Centers, and Institutes will provide facilities and equipment that meet Federal, State, and Local health, safety, and environmental laws and regulations, and will promulgate appropriate policies, standards, and procedures for governing Campus health and safety programs.

While the overall responsibility for Campus health and safety rests with the President of the University, the immediate responsibility for workplace health and safety belongs to each Campus employee who performs a supervisory role. At Lehigh University, faculty members are regarded as supervisory personnel for their laboratories as well as students. In addition, individual employees are responsible for preventing Campus accidents. Accordingly, all faculty and staff are to ensure that safe and healthful conditions and practices are provided and followed within the areas under their control, and all members of the Campus community are to cooperate fully with all aspects of the various Campus health and safety programs.

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Principal Investigator's and Supervisor's Responsibilities
  1. Principal Investigators and Supervisors have primary responsibility for health and safety in their laboratories
  2. Develop local area procedures to ensure effective compliance with the Environmental Health and Safety Plan as it relates to operations under their control. Specific areas of responsibility include employee and student education and training, identification, and correction of unsafe conditions and recordkeeping.
  3. Develop and maintain written workplace procedures which conform to Campus and Departmental guidelines.
  4. Ensure that each employee and student adheres to adopted procedures.
  5. Instruct employees and students in the recognition and avoidance of unsafe conditions, including hazards associated with non-routine tasks and emergency operations. Permit only those employees or students qualified by training to operate potentially hazardous equipment. Do not assume that newly hired, newly assigned, or reassigned employees or students comprehend all safety procedures associated with the new job duties.

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Compliance Guidelines

All employees shall adhere to safe and healthy work practices defined by established campus and departmental safety and health guidelines. Failure to do so will result in the initiation of disciplinary measures.

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Safety Communications

Several methods of communicating with employees on matters relating to health and safety have been established. Managers and Supervisors will encourage employees to report any unsafe or unhealthful conditions they discover without fear of reprisal.

  1. President's Safety Policy Statement - The President has issued a safety policy statement which informs all employees of the University that safety is a priority issue.
  2. Employee Safety Training
    1. The University provides general training programs for employees on an on-going basis. Included are topics such as Asbestos, Bloodborne Pathogens, Chemical Hygiene, Cylinder Handling, Confined Space Entry, CPR, Environmental Preparedness, Prevention and Contingency (EPPC) Plan, DOT Training, Fire Safety, First Aid, Forklift, Laser Safety, Lockout/Tagout, Crane Safety, Noise, Radiation, Respirator, Right-To-Know, and Waste Disposal.
    2. Departments provide specific training programs for employees either on a periodic basis or prior to assignment on a job which is new or has been revised.
  3. Departmental Safety Meetings and Safety Inspection - Departments should schedule regular safety meetings at which safety and health issues are freely and openly discussed by employees of the Department. The Department should attempt to schedule the meetings at a time when most employees can attend and will keep minutes to document who was in attendance and what topics were discussed. In addition, safety inspections and reinspections of laboratories and research areas should be conducted on a routine basis.
  4. General Health and Safety Information - Environmental Health and Safety publishes various bulletins, advisories, procedures and written programs which are distributed to the affected Campus community and are available upon request by calling X84251.

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Employee Safety Training

Effective dissemination of safety information is key to the success of the Environmental Health & Safety Plan. It is necessary to provide training for employees concerning general safe work practices as well as specific instruction with respect to hazards unique to each employee's job assignment.

  1. General Safe Work Practices - Environmental Health and Safety has developed numerous training programs designed to meet general safe work practice requirements. These programs are elements of larger programs which service broad campus needs and are listed below:
    Asbestos
    Biosafety Bloodborne Pathogen Exposure Plan
    Chemical Hygiene
    Cylinder Handling
    Confined Space Entry
    Department of Transportation (DOT) Training
    EPPC
    Fire Safety
    Forklift
    Hearing Conservation
    Laboratory Fume Hoods
    Laser Safety
    Lockout/Tagout
    Overhead Crane Operation
    Personal Protective Equipment
    Radiation
    Respirator
    Right-To-Know
    Waste Generation
  2. Specific Safe Work Practices - Specialized training sessions dealing with an employee's unique job assignment must be developed by each Supervisor. It is the responsibility of each Supervisor to understand his/her employee's job tasks and related hazards and to provide adequate training.
  3. Scheduled Training -
    1. Each Supervisor should ensure that all new employees receive general and specific training prior to assignment on a new job.
    2. Supervisors should ensure that employees are trained whenever new substances, processes, procedures, or equipment are introduced into the workplace which represent a new hazard or whenever the Supervisor receives notification of a new or previously unrecognized hazard.
    3. All training should be documented in writing. Topics, participants, and dates shall be recorded and kept on file within each Departmental office.
  4. Long-Range Training Plan - Each Department should develop a long-range training plan which sets priorities for training sessions, including a schedule of presentations. Consideration should also be given to frequency required for retraining employees. These refresher programs should also be incorporated in the long-range plan.

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Resources

EH&S has developed written programs and handbooks which will assist the Principal Investigator/Supervisor in their training efforts. Copies of these programs are available by calling X84251.

  1. Laboratory Chemical Hygiene - The purpose of the written Chemical Hygiene Plan is to ensure that personnel working in laboratories are not overexposed to hazardous chemicals in the performance of their jobs. The Plan is designed to protect employees from recognizable health hazards associated with chemicals used in their laboratories. It has been designed to be in compliance with OSHA 1910.450 "Occupational Exposures to Hazardous Chemicals in Laboratories".

    The key regulatory requirements for laboratories are:

    • Hazard Communication . All faculty, staff, and students who may come into contact with hazardous chemicals in the labs must be informed about the particular hazards which may be posed and the methods by which they may deal with such material in a safety and healthful manner.
    • Labeling. Chemical containers must be labeled with the full chemical name and must include a warning sign and appropriate safety information.
    • Material Safety Data Sheets (MSDSs). Each academic Department must ensure that a MSDS for each currently used or stored hazardous substance in that Department is maintained and readily accessible to faculty, staff, and students. Copies of MSDSs not provided with the purchased chemicals can be obtained from the World Wide Web (WWW) or by contacting EH&S at X84251.
    • Hazard Identification and Correction. Supervisors are responsible for conducting scheduled, periodic inspections of workplaces to identify and evaluate workplace hazards and unsafe work practices. The frequency of inspections should be proportional to the magnitude required whenever new substances, processes, procedures, or equipment presenting new, categorically different health and safety hazards are introduced into the workplace.

      Unsafe conditions which cannot be corrected by the supervisor must be reported to the next higher level of management. Any supervisor who becomes aware of a serious concealed danger to the health and safety of individuals must report this danger promptly to EH&S and to the faculty, staff, and students who may be affected.

    • Training. Principal investigators and supervisors are responsible for informing and training employees and students about hazardous substances in their work areas. EH&S is working closely with Departments, Centers/Institutes by providing technical support, training materials, etc.
    • Chemical Storage. All chemicals (including gases) at Lehigh must be stored safely and in accordance with current regulations.
  2. Hazard Communication - The purpose of the Lehigh University Hazard Communication Program is to ensure that Lehigh employees are effectively informed concerning workplace health and safety hazards, especially chemical hazards. The written program addresses chemicals known to be present in the workplace to which employees may be exposed under normal conditions of use or in a foreseeable emergency. The Lehigh University Hazard Communication Program extends to all Lehigh employees.
  3. Radiation Safety - The Radiation Safety Program provides for the safety of personnel, students, and the public during operations involving ionizing radiation sources and x-ray producing equipment. Working in conjunction with the Radiation Safety Committee and guidelines approved in the University's State and Federal licenses, Environmental Health and Safety administers the Radiation Safety Program to ensure that all exposures to radioactive sources are kept to a level as low as reasonably achievable.
  4. Environmental Preparedness, Prevention and Contingency (EPPC) Plan - Copies of the EPPC Plan are available for review at the offices of EH&S and Facilities Services. The purpose of the EPPC Plan is to:
    1. Minimize hazards to human health or the environment from fires, explosions, or any unplanned, sudden or non-sudden release of hazardous waste, hazardous materials, or radioactive materials to air, soil or water.

      The provisions of the Plan must be carried out immediately whenever there is fire, explosion or release of hazardous waste, hazardous materials, or radioactive materials which could threaten human health or the environment.

    2. Establish procedures for the containment of hazardous waste, hazardous materials, or radioactive materials upon notification of an actual spill or discharge as a result of fire, explosion, or discharge within the physical boundaries of Lehigh University.
    3. Establish cleanup, disposal, and restoration actions in the event of an actual spill or discharge at the University.
    4. Comply with the requirements as set forth in Title 25, "Environmental Resources", Department of Environmental Resources, Environmental Quality Board, Chapter 75, "Solid Waste Management" 75.265, Paragraph (I) for the Commonwealth of Pennsylvania.
    5. Comply with the Clean Water Act and regulations set forth in 40 CFR 112.3 which calls for a Spill Prevention, Control and Countermeasure Plan.
    6. Comply with Title III, Sections 303 (a), (f) and (g) of the Superfund Amendments and Reauthorization Act (SARA) which require an Emergency Response Plan.
    7. Comply with OSHA 1910.120, Hazardous Waste Operations and Emergency Response.
  5. Respiratory Protection - The purpose of the written Respiratory Protection Program is to establish guidelines for the protection of University personnel from respiratory hazards through the proper use of respirators.

    Lehigh's policy is to control employee exposures to air contaminants through the use of engineering controls, ventilation technologies, and the substitution of less toxic materials. Respirators are required when the above control measures are not feasible or are being installed, in emergencies and when the exposure to air contaminants is likely to exceed an OSHA permissible exposure limit (PEL) and/or action level (AL).

  6. Laboratory Safety - The Laboratory Safety Handbook provides general safety rules and guidelines to ensure safe working conditions for all members of the Lehigh community and their visitors.

    Safe laboratory practice is an attitude, a knowledge, and an awareness of potential hazards. Safety is a mutual responsibility and requires the full cooperation of everyone in the laboratory. This cooperation means that each student, instructor, and researcher must observe safety precautions and procedures and should:

    1. Follow all instructions carefully.
    2. Become thoroughly acquainted with the location and use of safety facilities such as fire extinguishers, showers, emergency exits, and eye wash stations.
    3. Assure that necessary safety equipment is readily available and in usable condition.
    4. Become familiar with safety precautions and emergency procedures before undertaking any laboratory work.
    5. Become familiar with the method of operations and all potential hazards before beginning an experiment.
    6. Become familiar with Lehigh University's Waste Disposal Procedures and other programs developed by Environmental Health and Safety.
  7. Waste Disposal - Lehigh University's Waste Disposal Procedures provide guidance for the proper disposal of all hazardous, radioactive, and infectious waste generated on campus.
  8. Asbestos Operations and Maintenance Plan - In order to properly manage asbestos-containing building materials, a comprehensive Operations and Maintenance Plan (O&M Plan) has been developed.

    The O&M Plan includes general work practices and procedures designed to minimize and/or eliminate the exposure of building occupants, employees, and visitors to airborne asbestos fibers. Key components of the program include:

    1. Identification of asbestos-containing building materials.
    2. Extensive measures to minimize and/or eliminate exposure of students, faculty, staff, employees, service providers, and visitors to airborne asbestos fibers.
    3. Establishment of an University Asbestos Program Manager.
    4. Establishment of trained asbestos response personnel.
    5. Development of University safety guidelines and safe work practices.
    6. Continuation of the asbestos materials surveillance program.
  9. Control of Hazardous Energy Sources (Lockout/Tagout) - The written Lockout/Tagout Program establishes the minimum requirements for the lockout or tagout of energy-isolating devices. It is used to ensure that the machine or equipment is isolated from all potentially hazardous energy and locked out or tagged out before employees perform any servicing or maintenance activities where the unexpected energization, start-up, or release of stored energy could cause injury.
  10. Bloodborne Pathogen Exposure Control - The purpose of the Bloodborne Pathogen Exposure Control Program is to protect employees from exposure to bloodborne agents (HIV, HBV, etc.) and to ensure that all occupational and research activities are conducted in a manner consistent with Lehigh University's Bloodborne Pathogen Exposure Control Program and 29 CFR 1910.1030.
  11. Confined Space Entry - The purpose of the Confined Space Entry Program is to protect employees from those hazards of entry into and work within confined spaces and to ensure that all activities requiring entry into a confined space are conducted in a manner consistent with Lehigh University's procedures and 29 CFR 1910.146.
  12. Hearing Conservation - The purpose of the Hearing Conservation Program is to prevent occupational noise exposures which could lead to noise-induced hearing loss and to comply with existing federal occupational noise exposure regulations.
  13. Personal Protective Equipment - This program has been developed to protect employees from hazards associated with processes in the workplace environment, chemical hazards, radiological hazards, or mechanical irritants by providing personal protective equipment for eyes, face, head, and extremities. The purpose of this program is to ensure that protective clothing, respiratory devices, protective shields, and barriers are used and maintained in a sanitary and reliable condition. Under no circumstances, shall personal protective equipment devices alone be relied upon to protect against hazards; but, should be used in conjunction with equipment guards, engineering controls, and sound work practices.
  14. Laboratory Fume Hood Usage - Laboratory fume hoods are an important tool used to control exposures to chemicals in laboratories. A well-designed fume hood, when properly installed and maintained, can provide a substantial degree of protection for the experimenter, provided its proper use and limitations are fully understood. EH&S has developed a guidance document for fume hood use called, "Safety Rules and Practices for Laboratory Fume Hood Use" which should be consulted prior to using a fume hood.

    Lehigh University's Chemical Hygiene Plan includes, as a basic program area, the use of ventilation for controlling exposures to chemicals in laboratories. Annual Hazard Communication Training ("Right-To-Know") also includes a review of practices for the safe use of fume hoods. Each individual who works with chemicals in the laboratory must understand the basic methods for using a hood properly and verifying its performance.

  15. Fall Protection - The purpose of the Fall Protection Program is to provide guidelines for maximum protection for employees against falls from elevations.
  16. Laser Safety - The purpose of Laser Safety Guidelines is to familiarize University personnel with safety procedures involved with the use of lasers in teaching and research laboratories. These guidelines provide recommendations for the safe use of lasers and laser systems that are operated at wavelengths between 180 NM and 1MM.
  17. Fire Safety - Fire drills are conducted twice a year in dormitories and residential halls. In general, all personnel at Lehigh University are required to exit a facility whenever a fire alarm sounds. Personnel shall meet at a predetermined rally point outside of the building. Faculty members are responsible for ensuring their students exit the building when an alarm sounds during class and laboratory sessions. Re-entry into the building is not permitted unless the Fire Department deems the building is safe. Fire extinguisher training is conducted throughout the year. If there is a need for departmental training, please contact Environmental Health and Safety to make arrangements for a training session.
  18. Department of Transportation (DOT) Training - The U.S. Department of Transportation (DOT) has developed Hazardous Materials Regulations which govern the shipment of hazardous materials. A hazardous material is defined as any article, material, substance, or chemical which poses a danger to the handler of the material, to the general public, and/or to the environment. The hazardous materials classes include:
    • Class 1 - Explosives
    • Class 2 - Gases (Poison, Flammable, and Non-Flammable)
    • Class 3 - Flammable Liquids
    • Class 4 - Flammable Solids
    • Class 5 - Oxidizers and Organic Peroxides
    • Class 6 - Poisons
    • Class 7 - Radioactive Materials
    • Class 8 - Corrosives
    • Class 9 - Miscellaneous Dangerous Goods

    All Departments, Centers/Institutes involved in the shipping of hazardous materials by the US Postal Service, UPS, RPS, Federal Express, or other carriers must comply with DOT shipping regulations.

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Safety Education and Training

A broad array of safety education programs have been developed by the Environmental Health and Safety staff to assist Supervisors in meeting their training obligations. Topics range from general interest subjects on chemical safety and personal protective equipment to specialized sessions on radiation safety, cylinder handling, respiratory protection, confined space entry, hearing conservation, bloodborne pathogen exposure, fume hoods, etc. Specialized training sessions are also available upon request by calling X84251.

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Conclusions

As you can see, you have a great deal of health and safety responsibility for your laboratory and personnel. It is recommended that you request copies of programs from Environmental Health and Safety which impact your research/laboratory. At a minimum, the Chemical Hygiene Plan and Laboratory Safety Handbook should be consulted prior to beginning any research/teaching. At that point, a determination should be made as to which additional programs you will require to ensure regulatory compliance as well as the health and safety of your staff. If you have any questions about Environmental Health and Safety Programs, I can be reached by calling X84251.

WELCOME TO THE UNIVERSITY!

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