St. Bernards Hearing Conservation Plan

PLAN REVIEW
Reviewer Date
Brian Parrie  4/23/2015

 

Contact: Mitch Hoard

(707) 443-2735

HEARING CONSERVATION

Purpose

Conservation of hearing is an important preventative measure at St. Bernard’s School. To reduce occupational hearing loss, all employees, who work in potentially noisy areas, are provided hearing protection, training and annual hearing tests. OSHA’s hearing conservation standard is covered in 29 CFR 1910.95.

Responsibilities

Management

Use Engineering and Administrative controls to limit employee exposure

Provide adequate hearing protection for employees

Post signs and warnings for all high noise areas

Conduct noise surveys annually or when new equipment is added

Conduct annual hearing tests for all employees

Conduct hearing conservation training for all new employees

Conduct annual hearing conservation training for all employees

Employees

Use school provided, approved hearing protection in designated high noise areas

Request new hearing protection when needed

Exercise proper care of issues hearing protection

Training

At time of hire and annually thereafter, all affected Employees must attend Hearing Conservation Training. The initial training is conducted as part of the New Hire Orientation Program by the Human Resource Department and consists of:

  1. Rules and procedures
  2. Where hearing protection is required
  3. How to use and care for hearing protectors
  4. How noise affects hearing and hearing loss

Engineering Controls

After it is determined that noise exposure above 85 dB (A) are present, engineering controls should be evaluated and implemented to reduce the noise exposure before administrative controls are initiated. Some examples of engineering controls include:

  1. Noise reducing baffles
  2. Compartmentalization
  3. Installing noise reducing gears
  4. Installing rubber pads under machinery

When new equipment or machinery are evaluated for purchase, the District’s Hearing Conservation contact should be consulted to conduct an evaluation from a safety and health standpoint. One criteria of the evaluation should include the amount of noise the equipment will produce and how it will affect the overall noise exposure.

Administrative Controls

After engineering controls are evaluated for effectiveness or feasibility, administrative controls should be considered to reduce noise exposure. Administrative controls include restricting exposure time or using personal protective equipment (PPE).

Personal Protective Equipment, such as earplugs or muffs, may be used to reduce the      amount of noise exposure. Each plug or muff has a noise reductions factor (NR) as evaluated by ANSI Standards (S3.19 – 1974 or Z24.22 – 1957). For example, if a work area has an ambient noise exposure of 96 dB (A), the hearing protectors should be rated 6 NR or better to be effective.

According to OSHA Regulations, each location with noise exposures of 85 to 89 dB (A) will provide hearing protectors for the Employee’s optional use. Noise exposures at 90 dB (A) or above require the mandatory use of hearing protection. Further, OSHA requires that a variety of hearing protectors be available for Employees to choose (both a variety of plug and muff type hearing protectors).

Types of Hearing Protectors

Hearing protection devices are the first line of defense against noise in environments where engineering controls have not reduced employee exposure to safe levels. Hearing protective devices can prevent significant hearing loss, but only if they are used properly. The most popular hearing protection devices are earplugs which are inserted into the ear canal to provide a seal against the canal walls. Earmuffs enclose the entire external ears inside rigid cups. The inside of the muff cup is lined with acoustic foam and the perimeter of the cup is fitted with a cushion that seals against the head around the ear by the force of the headband.

Use of Hearing Protectors

Management, Supervision and Employees shall properly wear the prescribed hearing protectors while working in or traveling through any section of a Location that is designated a High Noise Area. (excluding offices, break rooms, and rest facilities). The following rules will be enforced:

Personal stereos, such as Walkman’s, etc., will not be permitted in any operating area of school property.

Hearing protectors, at least two types of plugs and one type of muffs, will be provided    and maintained by the School.

  • Hearing protectors and replacements will be provided free of charge
  • Hearing protectors will be properly worn at all times, except in offices, break rooms, rest facilities.

Pre-formed earplugs and earmuffs should be washed periodically and stored in a clean area, and foam inserts should be discarded after each use. It is important to wash hands before handling pre-formed earplugs and foam inserts to prevent contaminants from being placed in the ear that may increase your risk of developing infections.

St. Bernards Facilities Safety Management and Fire Safety in Schools Plan

St. Bernards First Aid/CPR Plan

 

PLAN REVIEW
Reviewer Date
Brian Parrie 4/23/2015
   
   
   
   

 

 Contact: Randy Schantz

(707) 443-2735

  FIRST AID/CPR

Introduction

Medical advice and consultation on work-related health matters and first aid services to treat work related injuries must be readily available to employees. In addition, if the workplace contains materials that may be corrosive or injurious to the eyes or the body, a method of quickly drenching or flushing the eyes or body must be provided in the work area.  This program assists St. Bernard’s School in meeting those requirements.

References

OSHA Subpart K 1910.151

MN OSHA Instruction CPL 2-2.53

Applicability

Do any situations arise that require advice or consultation on matters of workplace health?

Could any situations arise that may result in injuries requiring first aid in the workplace?

Does the workplace contain materials that could injure the eyes or body?

Regulatory Requirements

  • The employer shall ensure the availability of medical personnel for advice and consultation on matters of workplace health.
  • A person or persons shall be adequately trained to render first aid in the absence of an infirmary, clinic or hospital in near proximity to the workplace.
  • First aid supplies approved by the consulting physician shall be readily available.
  • Suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use where the eyes or body of any person may be exposed to injurious corrosive materials. ANSI Standard Z358.1-1990 gives additional details on emergency eyewash and shower station requirements.
  • MN OSHA Instruction CPL 2-2.53 suggests that these guidelines be followed:

—    Near proximity to the workplace means four to eight minutes. If there is no hospital or clinic within this distance, the employer must designate a first aid provider on site.

—    If medical services are available within four to eight minutes, and the employer decides to use these services, a determination must be made as to whether or not a special agreement needs to be made with the medical facility in order to ensure the ready availability of medical personnel.

—    First aid training needs to be evaluated in relation to workplace hazards.

—    A recommended first aid kit list follows (employer still needs to seek a physician’s opinion).  Contact the First Aid program manager, «First_Aid», for kits and replacement supplies

A first aid kit shall contain sufficient quantities of individually sealed packages of at least the following types of items:

RECOMMENDED FIRST AID KIT CONTENTS 
ITEM NUMBER OF EMPLOYEES
1-50 51-100 101-200
Gloves, 4-pack 1 2 2
Gauze roller bandage 1” and 2” x 10 yds 2 2 2
Gauze compress bandage 3” x 3” individually packaged 10 20 30
Adhesive bandages, assorted sizes, individually packaged 16 32 64
Adhesive tape rolls 2 2 3
Scissors, blunt-nosed 1 1 1
Tweezers 1 1 1
Packaged antiseptic, aqueous mercury preferred (mercurochrome) 1 1 1
Mild soap, capped squeeze bottle 1 1 1
Elastic bandage, 4” 1 1 1
Resuscitation mouthpiece 1 1 1
Eyewash container (sterile) and neutral sterile solution (to wash eyes) 1 1 1
Empty plastic bag for application of ice (include “chemical ice” is ice is not available) 1 1 1
ABC’s of First Aid (handout on how to construct splint) 1 1 1
Bold instructions on how to call 911 1 1 1
Telephone numbers of the Poison Information Center and the consulting health care provider (include coin if pay phone may be used) 1 1 1

Please Note:  This is not an all-inclusive list.

Written Plan

Purpose

The purpose of this plan is to provide fundamental information to enable employees to protect themselves from various hazards and provide basic emergency procedures.  Questions regarding this plan should be addressed to the Program Manager.

Elements–First Aid/CPR

NOTE: Rescue breathing and CPR should be performed ONLY by qualified personnel.

There are many situations which occur during the work/school day that could potentially require first aid, including:

  1. Abdominal pain;
  2. Breathing emergencies and choking;
  3. Blisters and burns;
  4. Cuts, scrapes, and bruises;
  5. Drug-induced crisis;
  6. Earache;
  7. Exposure to the elements;
  8. Eye injuries;
  9. Head and spine injuries;
  10. Heart problems;
  11. Injury to muscles, bones, and joints;
  12. Nose injuries;
  13. Poisoning;
  14. Shock;
  15. Slivers;
  16. Sudden illnesses;
  17. Tooth problems;
  18. Throat problems; and
  19. Unconsciousness.

St. Bernard’s School will notify the parent or guardian of the student, or a designated contact of an employee, whenever there has been an accident, injury, or illness that requires either further medical attention or home rest. Typically, the first aid provider (school nurse/health aide) will make the decision to contact the above-mentioned persons.

There are some basic procedures to follow in each type of emergency situation. These procedures are designed for children and adults. Following are some basic steps to take in different emergency situations.

Procedures (in Alphabetical Order)

Abdominal Pain

Causes

Abdominal pain can be the result of a number of things like menstrual cramps, food poisoning, etc.

Care

  1. Have patient rest on cot; get the history of the illness (how, when, and where illness began).
  2. Take temperature.
  3. Attempt to locate area of pain. Ask if pain followed an injury. If pain is due to menstruation, offer hot water bottle. DO NOT give hot water bottle for any other kind of abdominal pain.
  4. Consider emotional reason for discomfort.
  5. Notify guardian or other contact person if pain persists or seems severe. If in doubt, always call the guardian of a child.

Breathing Emergencies and Choking

Detection

Some signs of emergency breathing situations include:

  1. Unusually slow or rapid breathing;
  2. Unusually deep or shallow breaths;
  3. Gasping for breath;
  4. Wheezing, gurgling, or high-pitched noises;
  5. Unusually moist skin;
  6. Flushed, pale, or bluish appearance to skin;
  7. Shortness of breath;
  8. Dizziness or light-headedness; and
  9. Pain in chest or tingling in hands and feet.

Care

Emergency breathing situations may include victims who are choking, hyperventilating, or unconscious. For choking victims, determine if the victim is able to cough or speak; encourage him/her to continue coughing. If object does not come up, call for emergency medical assistance. Be prepared to initiate rescue breathing and/or CPR (if trained).

Asthma Attack

  1. Call 911 if attack is severe (person has feeling of suffocation, pale bluish lips, skin, or fingernails).
  2. As soon as symptoms appear, have person rest in quiet area, seated with shoulders relaxed. Encourage person to slow his/her breathing down. Provide prescribed medicine or inhaler, if possible.
  3. Anxiety will increase breathing difficulty; comfort and relax the person.
  4. Notify parents of child’s significant asthma episode.

Blisters and Burns

Care for Blisters

  1. Apply sterile non-adhesive bandage.
  2. Do not puncture blisters.
  3. Notify guardian to observe area if infection is noted.

Determining Severity of Burns

First Degree—reddened

Second Degree—blistered

Third Degree—white or charred

Critical burns include those burns:

  1. Involving breathing difficulty;
  2. Covering more than one body part;
  3. To the head, neck, hands, feet, or genitals;
  4. To a child or an elderly person; or
  5. Resulting from chemicals, explosions, or electricity.

Care for Mild Burns

  1. Do not use ointments or salves.
  2. Stop the burning.
  3. Immerse in cold water (not ice water) for 10 to 15 minutes or until pain subsides.
  4. Cover burn with dry, clean dressings to help prevent infection; bandage loosely. Do not break any blisters or remove tissue.
  5. Raise area of burn above heart, if possible.

Care for Deep or Extensive Burns

  1. Treat for shock (except for facial burns).
  2. Have victim lie down with legs elevated; keep him/her warm and quiet. (Facial burn—sit or prop victim up; observe continuously for breathing difficulty.)
  3. Call 911.
  4. Do not immerse an extensively burned area or apply ice water over it as the cold may intensify shock reaction. Apply cold pack to face, hands, or feet if necessary.
  5. Cover burn with dry, clean dressings to help prevent infection; bandage loosely.
  6. Don’t put ointment on burn; don’t put pressure on burn.
  7. Don’t break blisters or remove pieces of cloth stuck to burn.

Care for Chemical Burns

  1. Call 911.
  2. For chemicals burns to the skin or eyes, flush burn with large amounts of water for 15 to 20 minutes.
  3. If only one eye has been affected, flush from the nose outward to prevent contaminating the other eye.
  4. Have the victim take off clothes with chemicals on them.
  5. Apply sterile dressing.
  6. If extensive, refer to Care for Deep or Extensive Burns.

Care for Electrical Burns

  1. Never go near a victim whom you think has been injured by electricity until you are sure the power is turned off. Electrical burns are often deep and tissues beneath them may be severely damaged.
  2. If there is a downed power line, wait for the fire department and/or the power school. If there are people in a car with a downed wire across it, tell them not to move and to stay in the car.
  3. Check breathing and pulse if victim is unconscious. Check for possible fractures.
  4. Cover an electrical burn with a dry, clean dressing, but do not cool the burn.
  5. Keep victim from getting chilled.

Cuts, Scrapes, and Bruises

Explanation

These types of injuries generally damage the soft tissue of the body. This tissue includes skin, fat, and muscles.

Types of Injuries That Generally Require Stitches

The following injuries generally require stitches:

  1. Bleeding from an artery or uncontrolled bleeding;
  2. Wounds that show muscle or bone, involve joints, gape widely, or involve hands or feet;
  3. Large or deep puncture wounds;
  4. Large or deeply embedded objects;
  5. Human or animal bites; and
  6. Wounds that, if left unattended, could leave conspicuous scars, such as those on the face.

Care for Bruises

  1. Apply direct pressure to reduce bleeding under the skin.
  2. Elevate the injured area to reduce swelling.
  3. Apply cold to control pain and swelling.

Internal Bleeding

Some closed wounds can be very serious and need immediate medical attention. If a victim is in severe pain or can’t move a body part without hurting, this may indicate a serious wound. While waiting for medical help, watch for signs of shock and keep the victim from getting chilled or overheated.

Care for Minor and Small Scratches

  1. Wash with soap and water.
  2. Apply sterile dressing as needed.
  3. If the wound is a result of an animal bite, notify police. When circumstances indicate, animal should be confined and tested for rabies.

Care for a Major Open Wound

  1. Have victim lie down to prevent fainting.
  2. Control bleeding by placing a clean covering over the wound and applying direct pressure.
  3. If you don’t think the wound involves a broken bone, elevate injured area.
  4. Apply a bandage snugly over wound.
  5. If bleeding cannot be controlled, call 911.
  6. Apply pressure on nearby artery (pressure point).
  7. Treat for shock; keep warm and quiet.
  8. Wash hands immediately after providing care.

Care for a Major Wound with Minimal Bleeding

  1. DO NOT use antiseptics or salves.
  2. Apply Steri-strip or butterfly dressing after bleeding stops.
  3. Notify guardian; advise medical care. Advise if tetanus booster is indicated.

Drug-Induced Crisis

Care

  1. In all suspected cases notify school administrator.
  2. If school nurse determines emergency care is unnecessary, student should be referred to the principal.
  3. If emergency care is necessary, call 911 and notify guardian.
  4. Check level of consciousness. If person is unconscious, call 911 for emergency medical assistance.
  5. Observe for breathing difficulty or respiratory arrest; be prepared to initiate rescue breathing or CPR (if trained) if person is not breathing.
  6. Check for high (greater than 120 beats per minute) or low (less than 60 beats per minute) pulse.
  7. If person is vomiting or semi-conscious, provide appropriate first aid.
  8. Observe for hallucinations.
  9. Observe for hyperactivity, aggressiveness, and paranoid delusions.

Important Points of Emergency Care

  1. Maintain an open airway.
  2. If convulsions are present, DO NOT try to restrain the individual. Remove nearby objects and place a soft towel, pillow under the head. DO NOT put anything in mouth.
  3. Get the person to relax physically and emotionally.
  4. Develop a positive attitude with the person. If there is no physical damage, reassure the person that the drug experience will subside and they will return to a normal state.
  5. Do not hesitate to contact a person in the school designated to deal with drug-induced crises.

Earache

Care

  1. Take temperature.
  2. If fever is present or pain is intense, call guardian and advise medical care.
  3. If a foreign body is inside the ear, notify guardian and advise medical care if object cannot be removed easily.

Exposure to the Elements

Heat-related Illnesses

Heat-related illnesses include heat cramps, heat exhaustion, and heat stroke. Heat cramps are painful muscle spasms. Heat cramps are the least severe of these illnesses and should be thought of as warning signs of a possible emergency. Cramps usually occur in the legs and abdomen.

Heat exhaustion is more severe than heat cramps and signs include cool, moist, pale, or flushed skin; headache; nausea; dizziness; weakness; and exhaustion.

Heat stroke is the most uncommon but most severe heat emergency, with signs including hot, dry skin; changes in consciousness; rapid, weak pulse; and rapid, shallow breathing.

Care for Heat-related Illnesses

  1. Get the victim out of the heat.
  2. Loosen tight clothing.
  3. Remove perspiration-soaked clothing.
  4. Apply cool, wet cloths to the skin.
  5. Fan the victim.
  6. If the victim is conscious, give cool water.
  7. Call for an ambulance if victim refuses water, vomits, or starts to lose consciousness.

Cold-related Illnesses

Cold-related illnesses include frostbite and hypothermia. Frostbite can cause the loss of fingers, hands, arms, toes, feet, and legs. Signs of frostbite include lack of feeling in the affected area and skin that appears waxy, is cold to the touch, or is discolored (flushed, white, yellow, or blue).

Care for Frostbite

  1. Handle area gently; never rub affected area.
  2. Warm the area gently by soaking the affected part in water, no warmer than 105º F.
  3. Keep the frostbitten part in the water until it looks red and feels warm.
  4. Loosely bandage the area with a dry sterile dressing.
  5. If fingers or toes are frostbitten, place cotton or gauze between them.
  6. Don’t break any blisters.
  7. Notify guardian and refer for medical care if swelling and blisters are present.

Care for Hypothermia

  1. Care for any life-threatening problems.
  2. Call local emergency number.
  3. Remove any wet clothing and dry the victim.
  4. Warm body gradually by wrapping victim in blankets or by putting on dry clothing, and then moving him/her to a warm place.
  5. Apply other sources of heat if available (chemical heat packs or hot water bottles, keeping a barrier between extra heat source and body).
  6. If victim is alert, give warm liquids to drink.

To Avoid Heat or Cold Emergencies:

  1. Avoid being outdoors on the hottest or coldest part of the day.
  2. Change your activity level according to the temperature.
  3. Take frequent breaks.
  4. Dress appropriately for the environment.
  5. Drink large amounts of fluids.

Eye Injuries

Care for Inflamed or Discharging Eyes

  1. Exclude from school, if student, until condition is improved or until physician gives permission to return.

Care for Foreign Body Embedded in Lid or Eyeball

  1. Do not attempt to remove object or to wash eye.
  2. Cover affected eye(s) loosely with clean dressing; avoid pressure on the eyes.
  3. Notify guardian and advise prompt medical care.
  4. Keep person lying down.

Care for Foreign Body on the Eye

  1. Have person blink eye several times.
  2. Flush the eye with large amounts of water.
  3. Attempt to remove with a moistened applicator.
  4. If not removed by these methods, apply dry protective dressing.
  5. Call guardian and advise prompt medical care.

Care for Injury to the eyeball (if the eyeball has been cut or injured)

  1. Have the person lie down to keep fluid from running out of the eye.
  2. Cover both eyes loosely with dry, sterile dressing.
  3. Notify guardian and advise medical care.
  4. Call 911 for assistance if severe pain is present or guardian cannot be reached.

Care for Sties in the Eye

  1. If draining, send person home.
  2. If sties occur frequently, suggest medical care.

Head and Spine Injuries

Detection

Some signals of head or spine injuries may include:

  1. Changes in consciousness;
  2. Severe pain or pressure in the head, neck, or back;
  3. Tingling or loss of sensation in the hands, fingers, feet, and toes;
  4. Partial or complete loss of movement of any body part;
  5. Unusual bumps or depressions on the head or over the spine;
  6. Blood or other fluids in the ears or nose;
  7. Heavy external bleeding of the head, neck, or back;
  8. Seizures;
  9. Impaired breathing or vision resultant of injury;
  10. Nausea or vomiting;
  11. Persistent headache;
  12. Loss of balance; and
  13. Bruising of the head, especially around the eyes and behind the ears.

Care for Spine Injuries

  1. Call 911.
  2. Minimize movement of head and spine.
  3. Maintain an open airway.
  4. Check consciousness and breathing.
  5. Control any external bleeding.
  6. Keep the victim from getting chilled or overheated.

Care for Headaches

  1. Take temperature.
  2. If there is history of recent head injury, call guardian.
  3. Instruct person to rest on cot; apply cold pack if comforting.
  4. If headache persists or if attacks occur frequently, advise medical care.
  5. DO NOT give aspirin or any other medication.

Care for Head Injuries–Minor

  1. Have person rest on cot for 30 minutes or longer.
  2. Apply cold pack to area.
  3. If no symptoms of nausea, vomiting, dizziness, unequal pupils, or blurred vision, person may return to normal activities.
  4. In the case of a child, notify guardian of all head injuries regardless of how minor they may seem.

Care for Head Injuries–Severe or Unconsciousness

  1. Call 911.
  2. Do not move person; minimize movement of head and spine.
  3. Maintain an open airway.
  4. Check consciousness and breathing.
  5. Apply cold pack to injured area and control any external bleeding.
  6. Treat for shock.

Heart Problems

Detection and General Care

The signals of potential heart problems include pain or discomfort in the chest that does not go away (ranging from discomfort to an unbearable crushing sensation), difficulty in breathing, pale skin, and/or sweaty face. Any chest pain that is severe, lasts longer than 10 minutes, or persists even during rest requires medical care at once.

When a victim shows signs of a possible heart attack, the victim should be told to sit down. Try to determine what problems the victim is having. Some victims will have medication and you can assist the person by getting the medicine. It is important to be calm and reassuring to the victim. If the victim is conscious, loosen tight clothing, keep the person quiet (do not allow them to walk), and do not give them liquids.

When the heart stops beating or beats too poorly to circulate blood properly, it is called cardiac arrest. A person in cardiac arrest is unconscious, not breathing, and has no pulse. When this happens, the victim needs cardiopulmonary resuscitation (CPR) immediately. This includes rescue breathing and chest compressions.

Care When the Heart Stops Beating and Breathing and Pulse are Non-Existent

  1. Send a responsible person to get the school nurse or other CPR-qualified person.
  2. Send responsible person to call 911 – give operator exact location of injured person.

Injuries to Muscles, Bones and Joints

Detection and General Classification

The four basic types of injuries to muscles, bones and joints are:

  1. Fractures,
  2. Dislocation,
  3. Strains, and
  4. Sprains.

Signs of these types of injuries may include pain, swollen, red, or bruised skin. The area may be twisted or bent strangely. There may be abnormal lumps, ridges, or hollows. The victim may hear a snap or pop or grating bones. Hands and fingers or feet and toes may feel numb or tingly.

Care for Injuries to Muscles, Bones, and Joints

  1. Treat for shock.
  2. Call 911 for emergency medical assistance if the victim’s head, neck, or back is injured; if the victim has any problem breathing; or if the victim is unable to move or use injured part without pain.
  3. Check for life-threatening conditions first.
  4. Make victim more comfortable, possibly supporting injured area with a pillow.
  5. If moving or transporting victim, immobilize injured part with a splint if possible.
  6. Apply ice and raise injured part.
  7. Make no attempt to reduce dislocation.

Care for Sprains and Strains

  1. For a strained or sprained back, apply cold periodically to injury for 72 hours.
  2. For sprains or strains (other than the back) elevate injured area and apply cold pack.
  3. Next, apply heat (this will help speed up chemical reactions needed to repair tissue).
  4. Apply elastic bandage for support if desired.

Nose Injuries

Care for Nosebleeds

  1. Seat person erect with head slightly forward. If person must recline, elevate head and shoulders.
  2. Instruct person to press firmly on middle partition of bleeding nostril(s).
  3. If bleeding persists (more than 15 minutes), call guardian and advise medical care.
  4. Instruct person not to blow nose or resume vigorous activity immediately.

Care for foreign body in the nose

  1. Call guardian and advise medical care if object cannot be removed easily.

Poisoning

Causes

Poisoning can be caused by many items, including foods, alcohol, medications, cleaning products, pesticides, plants, toxic fumes, fertilizers, insects, spiders, ticks, some marine life, snakes, and other animals.

There are four ways in which poisons may enter the body:

  1. Ingestion,
  2. Inhalation,
  3. Injection, and
  4. Absorption.

Detection

Some signs of poisoning may include:

  1. Nausea,
  2. Vomiting,
  3. Diarrhea,
  4. Chest or abdominal pain,
  5. Breathing difficulty,
  6. Sweating,
  7. Seizures, or
  8. Burns around the lips or tongue or on skin.

Care when you suspect someone has swallowed a poison

  1. Call your Poison Control Center or local emergency number.
  2. Try to find out what type of poison it was.
  3. Try to find out how much was taken.
  4. Try to find out when it was taken.
  5. Check the scene to make sure it is safe to approach and to gather clues about what happened.
  6. Remove the victim from the source of the poison if necessary.
  7. Check the victim’s level of consciousness, breathing, and pulse.
  8. Care for any life-threatening conditions.
  9. If the victim is conscious, ask questions to get more information.
  10. Look for any containers and take them with you to the telephone.

Care for Insect Bites and Stings

Serious collapse can occur within just five minutes; be prepared.

  1. Check health records to determine if individual is allergic or sensitive.
  2. Remove stinger by scraping it away with your fingernail or a credit card or use tweezers.
  3. Wash the site with soap and water.
  4. Cover to keep clean.
  5. Apply a cold pack to the area.
  6. If allergic symptoms develop, call 911 and guardian.

Care for Food Poisoning, Reactions, or Allergies

Food reactions and allergies usually occur within one hour of eating, and the most common reactions will be respiratory difficulty or hives.

  1. Notify guardian and recommend immediate medical attention.
  2. If unable to reach guardian, contact family physician.
  3. If severe allergic reaction, call 911—this could be a life-threatening situation.

Care for Poison Ivy or Poison Oak

  1. After immediate contact, wash area gently with soap and water.
  2. If weeping or broken skin areas are present, call guardian and advise medical care.

Recognizing Lyme’s Disease

Lyme’s disease is commonly carried by the deer tick, and the risk of contracting the disease is greatest between May and late August. Signs of an infection may appear a few days or weeks after a tick bite. It starts as a rash at the small red area at the site of the bite. It may spread up to 7 inches across. Sometimes the appearance may be like a bulls-eye.  In dark-skinned people, the area may look black and blue like a bruise. Other signs include fever, headache, weakness, and joint and muscle pain similar to the pain of flu. In advanced stages, it may cause arthritis, numbness, memory loss, problems in seeing or hearing, high fever and stiff neck.

Care for Ticks

  1. Do not try to burn off a tick or remove it by applying Vaseline or nail polish.
  2. Do not prick it with a pin.

Shock

Detection

Signs of shock include:

  1. Restlessness or irritability;
  2. Altered consciousness;
  3. Pale, cool moist skin;
  4. Rapid breathing;
  5. Rapid pulse;
  6. Low and falling blood pressure; and
  7. Dilated pupils.

Care

  1. Treat any severely injured person for shock.
  2. Call 911.
  3. Have the victim lie down; this may help minimize pain.
  4. Control any external bleeding.
  5. Help victim maintain normal body temperature.
  6. Try to reassure the victim.
  7. Elevate legs about 12 inches unless you suspect head, neck, or back injuries, or possible broken bones involving hip or legs. If you are unsure, leave victim lying flat.
  8. Do not give victim anything to eat or drink.

Slivers

Care

  1. Do not attempt to remove if deeply embedded; refer to physician.
  2. Treat as a puncture wound.
  3. Wash area with soap and water.
  4. Remove sliver if near the surface of the skin.
  5. Notify guardian if necessary.

Sudden Illnesses

Detection

Although there are many types of sudden illnesses, they often have similar signals.  Some of these signs include:

  1. Feeling light-headed, dizzy, confused, or weak;
  2. Changes in skin color (pale or flushed skin) and sweating;
  3. Nausea or vomiting; and
  4. Diarrhea.

Some sudden illnesses may also include:

  1. Changes in consciousness,
  2. Seizure,
  3. Paralysis or inability to move,
  4. Slurred speech,
  5. Difficulty seeing,
  6. Severe headache,
  7. Breathing difficulty, and
  8. Persistent pressure or pain.

Care/

  1. Help the victim rest comfortably.
  2. Keep victim from getting chilled or overheated.
  3. Reassure the victim.
  4. Watch for changes in consciousness and breathing.
  5. Do not give anything to eat or drink unless victim is fully conscious.
  6. Obtain history of illness (what, when, and where).
  7. Take temperature. If the temperature is 100º F or more, make arrangements for the victim to get home or to a medical facility.

NOTE:  Maximum stay in the health office is one hour unless home contact cannot be made, and no child shall be sent home to be alone unless the legal guardian assumes full responsibility.

Care for Vomiting

  1. Place the victim on his/her side and isolate person.
  2. Exclude them from school.
  3. Advise medical care if symptoms persist.

Care for Fainting

  1. Position him/her on the back and elevate the legs 8 to 10 inches if you do not suspect a head or back injury.
  2. Loosen clothing, provide fresh air, and keep person quiet.
  3. Be prepared for vomiting; turn head to the side.
  4. If the person does not feel better within the hour, call guardian.

NOTE:  If a person feels faint, have him/her sit and lower head between the knees.

Care for a Diabetic Emergency

Every person with diabetes should be known to nurse, or health service aid, and teacher so that emergency treatment can be carried out.

  1. Check health service for specific treatment of individual.
  2. Give the victim some form of sugar i.e., two large sugar cubes, half a cup of fruit juice, or half a can of pop (NOT diet).
  3. The person should improve within 10 minutes; give the person additional food and allow them to resume normal activities.
  4. Notify guardian after any insulin reaction.
  5. If person does not improve, call guardian or physician.
  6. Call 911 if person is losing consciousness or convulsing.

Care for a Seizure

  1. Do not hold or restrain the person or place anything between the victim’s teeth.
  2. Remove any nearby objects that might cause injury.
  3. Cushion the victim’s head using folded clothing or a small pillow.
  4. Remove glasses and loosen any tight clothing.
  5. Call 911 if:
  6. The person does not start breathing after the seizure; begin rescue breathing or CPR (if trained);
  7. The person has repeated seizures; or
  8. The person is injured during the seizure.
  9. After the seizure:
  10. Turn the person to one side to allow saliva to drain from mouth;
  11. Permit person to rest or sleep in health office if drowsy; and
  12. Notify guardian of each seizure and advise medical care when indicated.

Tooth Problems

Care for Toothache

  1. Rinse mouth with warm water.
  2. Notify guardian and advise dental care.

Care for an Abscess

  1. Notify guardian and advise dental care.

Care for a Chip or Fracture

  1. Save chipped part of tooth and put in water in small container.
  2. Notify guardian and advise dental care; send portion of tooth with person.

Throat Problems

Care for a Sore Throat

  1. Take temperature.
  2. Notify guardian and exclude from school if temperature is elevated.
  3. Advise medical care if sore throat persists.

Unconsciousness

Causes

Unconsciousness can be the result of asphyxia, deep shock, poisoning, head injury, heat stroke, heart attack, stroke, epilepsy, and chemical intoxication.

Care for Unconsciousness

  1. If breathing and pulse are present, treat for shock and call 911.
  2. If breathing and/or pulse are absent, proceed with either rescue breathing or CPR (if trained).
  3. CPR requires special training. If you have not had this training, immediately seek the assistance of someone who has been trained.

St. Bernards Employee Right-to-Know Plan

 

PLAN REVIEW
Reviewer Date
Brian Parrie 4/23/2015

 

Contact: Mitch Hoard

(707) 443-2735

EMPLOYEE RIGHT-TO-KNOW/HAZARD COMMUNICATION

Purpose

This document serves as a guide the Hazard Communication Program for St. Bernard’s School. It provides detailed safety guideline and instructions for receipt, use and storage of chemicals at our facility by employees and contractors. Reference: OSHA Standard 1910.1200.

Responsibilities:

1. Management

  1. Ensure compliance with this program
  2. Conduct immediate corrective action for deficiencies found in the program
  3. Maintain an effective Hazard Communication training program
  4. Make this plan available to employees or their designated representative

2. Shipping & Receiving Manager

  1. Ensure all received containers are properly labeled and that labels are not removed or defaced
  2. Ensure all shipped containers are properly labeled
  3. Ensure shipping department employees are properly trained in spill response
  4. Ensure Safety Data Sheets (SDS) are properly distributed

3. Purchasing Agent

  1. Obtain, from the manufacturer, SDS for chemicals purchased from retail sources

 4. Safety Manager

      1. Maintain a list of hazardous chemicals using the identity that is referenced on the SDS
      2. Monitor the effectiveness of the program
      3. Conduct annual audit of the program
      4. Monitor employee training to ensure effectiveness
      5. Keep management informed of necessary changes
      6. Ensure SDSs are available as required
      7. Monitor facility for proper use, storage and labeling of chemicals

5. School Nurse

        1. Ensure SDS are available for emergency medical personnel when treating exposed employees
        2. Provide information, as requested, concerning health effects and exposure symptoms listed on SDSs

6. Supervisors

      1. Comply with all specific requirements of the program
      2. Provide specific chemical safety training for assigned employees
      3. Ensure chemicals are properly used stored & labeled
      4. Ensure only the minimum amount necessary is kept at work stations
      5. Ensure up to date SDS are readily accessible to all employees on all shifts

7. Employees

  1. Comply with chemical safety requirements of this program
  2. Report any problems with storage or use of chemicals
  3. Immediately report spills of suspected spills of chemicals
  4. Use only those chemicals for which they have been trained
  5. Use chemicals only for specific assigned tasks in the proper manner

8. Contractors

  1. Comply will all aspects of this program
  2. Coordinate information with the Safety Manager
  3. Ensure Contractor employees are properly trained
  4. Notify the ERTK Contact Person before bringing any chemicals onto school property or facilities
  5. Monitor and ensure proper storage and use of chemicals by Contractor employees

General Program Information

This written Hazard Communication Plan (HAZCOM) has been developed based on OSHA Hazard Communication Standard and consists of the following elements:

  • Identification of Hazardous Materials
  • Product Warning Labels
  • Safety Data Sheets (SDS)
  • Written Hazard Communication Program
  • Effective Employee Training

Some chemicals are explosive, corrosive, flammable, or toxic. Other chemicals are relatively safe to use and store but may become dangerous when they interact with other substances. To avoid injury and/or property damage, persons who handle chemicals in any area of the School must understand the hazardous properties of the chemicals. Before using a specific chemical, safe handling methods and health hazards must always be reviewed. Supervisors are responsible for ensuring that the equipment needed to work safely with chemicals is accessible and maintained for all employees on all shifts.

Employee Training

  1. Initial Orientation Training
    1. All new employees shall receive safety orientation training covering the elements of the HAZCOM and Right to Know Program. This training will consist of general training covering:
      1. Location and availability of the written Hazard Communication Program
      2. Location and availability of the List of Chemicals used in the workplace
      3. Methods and observation used to detect the presence or release of a hazardous chemical in the workplace.
      4. The specific physical and health hazard of all chemicals in the workplace
      5. Specific control measures for protection from physical or health hazards
      6. Explanation of the chemical labeling system
      7. Location and use of SDS

2. Job Specific Training

    1. Employees will receive on the job training from their supervisor. This training will cover the proper use, inspection and storage of necessary personal protective equipment and chemical safety training for the specific chemicals they will be using or will be working around.

3. Annual Refresher Training

    1. Annual Hazard Communication refresher training will be conducted as part of the school’s continuing safety training program.

 4. Immediate On-the-Spot Training

    1. This training will be conducted by supervisors for any employee that requests additional information or
    2. exhibits a lack of understanding of the safety requirements.

Non-Routine Tasks

Non-routine tasks are defined as working on, near, or with unlabeled piping, unlabeled containers of an unknown substance, confined space entry where a hazardous substance may be present and/or a one-time task using a hazardous substance differently than intended (example: using a solvent to remove stains from tile floors).

Steps for Non-Routine Tasks

Step 1: Hazard Determination

Step 2: Determine Precautions

Step 3: Specific Training & Documentation

Step 4: Perform Task

The Department Supervisor and ERTK Contact Person will evaluate all non-routine tasks to determine all hazards present. This determination will be conducted with quantitative/qualitative analysis (air sampling, substance identification/analysis, etc., as applicable).  Once the hazard determination is made, the Department Supervisor and Safety Department will determine the necessary precautions needed to remove the hazard, change to a non-hazard, or protect from the hazard (use of personal protective equipment) to safeguard the Employees present. In addition, the Department Supervisor or Safety Department will provide specific safety training for Employees present or affected and will document the training using the Chemical Safety Training Checklist form that shall be marked “Non-Routine Task Training”.

Off-site use or transportation of chemicals

An SDS will be provided to employees for each chemical and each occurrence of use or transport away from the school facilities. All State and Federal DOT Regulations will be followed including use of certified containers, labeling & marking, securing of containers and employee training.

General Chemical Safety

Assume all chemicals are hazardous. The number of hazardous chemicals and the number of reactions between them is so large that prior knowledge of all potential hazards cannot be assumed. Use chemicals in as small quantities as possible to minimize exposure and reduce possible harmful effects.

The following general safety rules shall be observed when working with chemicals:

  • Read and understand the Safety Data Sheets.
  • Keep the work area clean and orderly.
  • Use the necessary safety equipment.
  • Carefully label every container with the identity of its contents and appropriate hazard warnings.
  • Store incompatible chemicals in separate areas.
  • Substitute less toxic materials whenever possible.
  • Limit the volume of volatile or flammable material to the minimum needed for short operation periods.
  • Provide means of containing the material if equipment or containers should break or spill their contents.

Task Evaluation

Each task that requires the use of chemicals should be evaluated to determine the potential hazards associated with the work. This hazard evaluation must include the chemical or combination of chemicals that will be used in the work, as well as other materials that will be used near the work. If a malfunction during the operation has the potential to cause serious injury or property damage, a Safe Operational Procedure (SOP) should be prepared and followed. Operations must be planned to minimize the generation of hazardous wastes.

Chemical Storage

The separation of chemicals (solids or liquids) during storage is necessary to reduce the possibility of unwanted chemical reactions caused by accidental mixing. Explosives should be stored separately outdoors. Use either distance or barriers (e.g., trays) to isolate chemicals into the following groups:

  • Flammable Liquids: store in approved flammable storage lockers.
  • Acids: treat as flammable liquids
  • Bases: do not store bases with acids or any other material
  • Other liquids: ensure other liquids are not incompatible with any other chemical in the same storage location.

Lips, strips, or bars are to be installed across the width of storage shelves to restrain the chemicals in case of earthquake.

Chemicals will not be stored in the same refrigerator used for food storage. Refrigerators used for storing chemicals must be appropriately identified by a label on the door.

Container Labels

It is extremely important that all containers of chemicals are properly labeled. This includes every type of container from a 5000-gallon storage tank to a spray bottle of degreaser. The following requirements apply:

  • All containers will have the appropriate label; tag or marking prominently displayed that indicates the identity, safety and health hazards.
  • Portable containers that contain a small amount of chemical need not be labeled if they are used immediately that shift, but must be under the strict control of the employee using the product.
  • All warning labels, tags, etc., must be maintained in a legible condition and not be defaced. Facility weekly supervisor inspections will check for compliance of this rule.
  • Incoming chemicals are to be checked for proper labeling.

Emergencies and Spills

In case of an emergency, implement the proper Emergency Action Plan

  1. Evacuate people from the area.
  2. Isolate the area.
  3. If the material is flammable, turn off ignition and heat sources.
  4. Only personnel specifically trained in emergency response are permitted to participate in chemical emergency procedures beyond those required to evacuate the area.
  5. Call for Emergency Response Team assistance if required.

Housekeeping

  • Maintain the smallest possible inventory of chemicals to meet immediate needs.
  • Periodically review stock of chemicals on hand.
  • Ensure that storage areas, or equipment containing large quantities of chemicals, are secure from accidental spills.
  • Rinse emptied bottles that contain acids or inflammable solvents before disposal.
  • Recycle unused laboratory chemicals wherever possible.
  • DO NOT Place hazardous chemicals in salvage or garbage receptacles.
  • DO NOT Pour chemicals onto the ground.
  • DO NOT Dispose of chemicals through the storm drain system.
  • DO NOT Dispose of highly toxic, malodorous chemicals down sinks or sewer drains.

Contractors

All outside contractors working inside School Facilities are required to follow the requirements of this program.

The School will provide Contractors information on:

  • Location of SDS
  • Precautions to be taken to protect contractor employees
  • Potential exposure to hazardous substances
  • Chemicals used in or stored in areas where they will be working
  • Location and availability of Safety Data Sheets
  • Recommended Personal Protective Equipment
  • Labeling system for chemicals

Definitions

Chemical: Any element, chemical compound or mixture of elements and/or compounds.

Combustible liquid: Means any liquid having a flash point at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3 deg. C), except any mixture having components with flash points of 200 deg. F (93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.

Compressed gas: Any compound that exhibits:

(i) A gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70 deg.F.

(ii) A gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130 deg. F. regardless of the pressure at 70 deg. F.

(iii) A liquid having a vapor pressure exceeding 40 psi at 100 deg. F.

Container: Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers.

Designated representative: Any individual or organization to whom an employee gives written authorization to exercise such employee’s rights under this section. A recognized or certified collective bargaining agent shall be treated automatically as a designated representative without regard to written employee authorization.

Employee: a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered.

Employer: A person engaged in a business where chemicals are either used, distributed, or are produced for use or distribution, including a contractor or subcontractor.

Explosive: A chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.

Exposure or exposed: An employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential (e.g. accidental or possible) exposure. Subjected in terms of health hazards includes any route of entry (e.g. inhalation, ingestion, skin contact or absorption.)

Flammable: A chemical that falls into one of the following categories:

  • “Aerosol, flammable” means an aerosol that yields a flame projection exceeding 18 inches at full valve opening, or a flashback (a flame extending back to the valve) at any degree of valve opening.
  • “Gas, flammable” means: (A) A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of thirteen (13) percent by volume or less; or (B) A gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air wider than twelve (12) percent by volume, regardless of the lower limit;
  • “Liquid, flammable” means any liquid having a flash point below 100 deg. F., except any mixture having components with flash points of 100 deg. F. or higher, the total of which make up 99 percent or more of the total volume of the mixture.
  • “Solid, flammable” means a solid, other than a blasting agent or explosive as defined in 910.109(a), that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard. A chemical shall be considered to be a flammable solid if it ignites and burns with a self-sustained flame at a rate greater than one-tenth of an inch per second along its major axis.

Flash point: The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite.

Hazardous chemical: Any chemical that is a physical hazard or a health hazard.

Hazard warning: Any words, pictures, symbols, or combination appearing on a label or other appropriate form of warning which convey the specific physical and health hazard(s), including target organ effects, of the chemical(s) in the container(s). (See the definitions for “physical hazard” and “health hazard” to determine the hazards which must be covered.)

Health hazard: A chemical for which there is evidence that acute or chronic health effects may occur in exposed employees. The term “health hazard” includes chemicals that are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, and neurotoxins, agents which act on the hematopoietic system and agents which damage the lungs, skin, eyes, or mucous membranes.

Identity: Any chemical or common name that is indicated on the material safety data sheet (SDS) for the chemical. The identity used shall permit cross-references to be made among the required list of hazardous chemicals, the label and the SDS.

Immediate use: The hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.

Label: Any written, printed, or graphic material displayed on or affixed to containers of hazardous chemicals.

Safety data sheet (SDS): Written or printed material concerning a hazardous chemical that is prepared in accordance with OSHA Standard 1910.1200 requirements.

Mixture: Any combination of two or more chemicals if the combination is not, in whole or in part, the result of a chemical reaction.

Oxidizer: Means a chemical other than a blasting agent or explosive as defined in 1910.109(a) that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.

Physical hazard: A chemical that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.

Pyrophoric: A chemical that will ignite spontaneously in air at a temperature of 130 deg. F. or below.

Specific chemical identity: The chemical name, Chemical Abstracts Service (CAS) Registry Number, or any other information that reveals the precise chemical designation of the substance.

Unstable (reactive): A chemical that 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.

Use: To package, handle, react, emit, extract, generate as a byproduct, or transfer.

Water-reactive: A chemical that reacts with water to release a gas that is either flammable or presents a health hazard.

Work area: A room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present.

Workplace: An establishment, job site, or project, at one geographical location containing one or more work areas.

SDS Information

Safety Data Sheets are provided by the chemical manufacturer to provide additional information concerning safe use of the product. Each SDS provides:

  1. Common Name and Chemical Name of the material
  2. Name, address and phone number of the manufacturer
  3. Emergency phone numbers for immediate hazard information
  4. Date the SDS was last updated
  5. Listing of hazardous ingredients
  6. Chemical hazards of the material
  7. Information for identification of chemical and physical properties

Information Chemical Users must know

1. Fire and/or Explosion Information

  1. Material Flash Point, auto-ignition temperature and upper/lower flammability limits
  2. Proper fire extinguishing agents to be used
  3. Firefighting techniques
  4. Any unusual fire or explosive hazards

2. Chemical Reaction Information

    1. Stability of Chemical
    2. Conditions and other materials which can cause reactions with the chemical
    3. Dangerous substances that can be produced when the chemical reacts

3. Control Measures

    1. Engineering Controls required for safe product use
    2. Personal protective equipment required for use of product
    3. Safe storage requirements and guidelines
    4. Safe handling procedures

4. Health Hazards

    1. Permissible Exposure Limit (PEL) and Threshold Limit Value (TLV)
    2. Acute or Chronic symptoms of exposure
    3. Main routes of entry into the body
    4. Medical conditions that can be made worse by exposure
    5. Cancer causing properties if any
    6. Emergency and First Aid treatments

5. Spill & Leak Procedures

    1. Clean up techniques
    2. Personal Protective Equipment to be used during cleanup
    3. Disposal of waste & cleanup material

Employee Use of SDS

For SDS use to be effective, employees must:

  1. Know the location of the SDS
  2. Understand the major points for each chemical
  3. Check SDS when more information is needed or questions arise
  4. Be able to quickly locate the emergency information on the SDS
  5. Follow the safety practices provided on the SDS

St. Bernards Emergency Action Planning Plan

 

PLAN REVIEW
Reviewer Date
Brian Parrie 4/23/2015
   
   
   
   

 

Contact: Randy Schantz

(707) 443-2735

 

                   EMERGENCY ACTION PLANNING

Purpose

The purpose of this program is to provide the needed tools to respond to emergencies that may occur in the school setting. St. Bernard’s School has developed a specific response plan for use to prevent and/or respond to emergencies that could occur. The plan is based on the requirements established by Minnesota Executive Order 93-27 and Model Crisis Management Plan. The plan was developed in coordination and cooperation of community leaders, local units of government, and State of Minnesota agencies.

A copy of the plan may be obtained from the school principal’s and/or district office.

 

St. Bernards Compressed Gas Safety Plan

PLAN REVIEW
Reviewer Date
Brian Parrie 4/23/2015
   
   
   
   

                                                                                                                            

COMPRESSED GAS SAFETY

Purpose

Assure that employees handling compressed gases are adequately trained in the inherent hazards of the cylinders and their contents, as well as proper handling, storage, and use according to OSHA requirements. Compressed gas cylinders can present a variety of hazards due to their pressure and /or contents. This chapter of the safety manual covers requirements that must be followed for the use of all compressed gases. In addition to the standard required work practices for inert gases, hazardous gases may require additional controls and work practices including, but not limited to, the use of gas cabinets, gas monitors, emergency shutoffs, proper equipment design, leak testing procedures, and the use of air supplying respirators for certain highly toxic gases.

Policy

It is the policy of St. Bernard’s School that all compressed gases be handled, stored, received and used in a safe manner consistent with this chapter.  Compressed air shall not be used for cleaning or blow-down activities unless air pressure is regulated to below 30 psig and areas have been isolated from pedestrian traffic.

Hazards

Numerous potential physical and health hazards are associated with compressed gases, including explosion, poisoning, impact by containers, fire, asphyxiation and exposure related illnesses.

Hazard Control

  • Engineering Controls – each gas application will have its own engineering controls depending on the types of hazards and application. Examples of engineering controls are:

Fume hoods

Gas Cabinets

Ventilation systems

Smoke detectors

Sprinkler systems

Flow Restrictors

Scrubbers

Leak Monitors

Gas cylinder storage areas

  • Administrative Controls – compressed gas program administrative controls include:

Employee training

Segregation of gas containers

Inspections and audits

Signs

Assignment and use of PPE

Identification of authorized employees

Procedures for receipt, use and storage

Compressed Gas Cylinders

  • Inspection of compressed gas cylinders. Each employer shall determine that compressed gas cylinders under his control are in a safe condition to the extent that this can be determined by visual inspection. Visual and other inspections shall be conducted as prescribed in the Hazardous Materials Regulations of the Department of Transportation (49 CFR parts 171-179 and 14 CFR part 103).

Where those regulations are not applicable, visual and other inspections shall be conducted in accordance with Compressed Gas Association Pamphlets C-6-1968 and C-8-1962, which is incorporated by reference as specified in Sec. 1910.6.

  • The in-plant handling, storage, and utilization of all compressed gases in cylinders, portable tanks, rail tank cars, or motor vehicle cargo tanks shall be in accordance with Compressed Gas Association Pamphlet P-1-1965
  • Safety relief devices for compressed gas containers. Compressed gas cylinders, portable tanks, and cargo tanks shall have pressure relief devices installed and maintained in accordance with Compressed Gas Association Pamphlets S-1.1-1963 and 1965 addenda and S-1.2-1963

Compressed Gas Use Applications

Prior to use of any compressed gas, a review of the applicable requirement in the Engineering Controls and Work Practices and Procedures section must be conducted.

  • Class 1 Application – Use of Inert Gases – Gases which are non-flammable and non-toxic, but which may cause asphyxiation due to displacement of oxygen in poorly ventilated spaces
  • Class 2 Application – Use of Flammable, Low Toxicity – Gases which are flammable (at a concentration in air of 13% by volume or have a flammable range wider than 13% by volume), but act as non-toxic, simple asphyxiants (e.g. hydrogen, methane)
  • Class 3 Application – Use of Pyrophoric Gases and Liquids – Gases or liquids which spontaneously ignite on contact with air at a temperature of 130 F or below.
  • Class 4 Application – Use of Corrosive, Toxic, and Highly Toxic Gases – Gases which may cause acute or chronic health effects at relatively low concentrations in air
  • Class 5 Application – Use of Compressed Gases in Fume Hoods

Gas Use Requirements – Engineering Applicability

Required Controls Class 1 Class 2 Class 3 Class 4 Class 5
Gas Cabinet
  • 1
Interlocks
  • 2
  • 2
  • 2
  • 2
  • 2
Emergency Off Button
Equipment Enclosed & Ventilated
  • 1
Smoke Detection
  • 2
  • 2
  • 2
  • 2
Sprinkler Protection
  • 3
  • 3
  • 3
  • 3
Emergency Power to Exhaust Ventilation
  • 4
  • 4
  • 4
Pneumatic Shutoff Valve
  • 5
Scrubber
  • 2
  • 2
Vacuum Pump Purge & Interlock
Flow Restricting Orifice
Ventilation Alarms
Eyewash & Showers
  • 6
  • 6
Purge Panel
Gas Monitor
  • 8
  • 8
  • 8
Piping & Fittings
Hardware

Gas Use Requirements – Administrative & Procedural Applicability

Notes

  • 1     Not required if flow-restricting orifice is installed in a cylinder valve. May be required for semiconductor applications
  • 2     Based on the outcome of hazard review
  • 3     Required in lab and inside gas cabinet for new installations
  • 4     For new installations
  • 5     Typically not required, may be required for semiconductor applications
  • 6     For corrosive gases
  • 7     See Fume Hood Use
  • 8     See Gas Monitoring for details
  • 9     See Hazard Review
  • 10    See Cryogenic Liquid

Engineering Controls / Design Considerations

This includes a listing of typical engineering controls, referenced in the matrix above. In some cases, Building Codes may require additional controls. Additional controls or deviations from the controls listed below may also be appropriate for the application such as those required by the OSHA Process Safety Management Program or EPA’s Risk Management Program. The appropriate controls should be identified through the hazard review process.

  1. Gas Cabinets – With the exception of cylinders containing a non-toxic, flammable gas, and cylinders used in fume hood applications, hazardous gas cylinders must be housed in gas cylinder cabinets. These cabinets must be equipped with sprinkler protection, and must be constructed and ventilated according to State code requirements. These requirements include, but are not limited to, the need to provide 200 fpm airflow at the cabinet window.
  1. Interlocks – In addition to automatic shutoff of gas flow due to loss of power or ventilation (described below), it will often be appropriate for an automatic shutdown of gas flow due to conditions such as high system pressure, high gas delivery pressure, loss of vacuum, loss of cooling, or other conditions identified through the hazard review process.
  1. Emergency Off – Where gases are used in gas cabinets, the emergency off buttons should be located at the lab doorway. Activation of this button will cause pneumatic valves to shut, stopping gas flow. Typically, this button should kill electrical power to hazardous lab equipment as well.
  1. Equipment Enclosures and Ventilation – Experimental apparatus using hazardous gases should be contained in an enclosed and exhausted tool enclosure. These enclosures must be connected to the exhaust ventilation system. Ventilation rates must be sized to allow for 100 fpm of airflow through the largest open enclosure door. Mass flow controllers carrying hazardous gases must be housed in a separate ventilated enclosure (or in an enclosed compartment of a larger tool enclosure) so that 100 fpm exhaust flow is available at the largest open door to the enclosure. All components should be readily accessible for maintenance.
  1. Smoke Detection – All labs using hazardous gases will have a smoke detector, which is connected to the building alarm system. In certain cases, it may be necessary to interlock smoke detector activation with the shutdown of hazardous gas flow.
  1. Sprinkler Protection – Where hazardous gases are contained in gas cabinets, sprinkler protection should be provided to the interior of the gas cabinet. In some cases, this protection is required by code. Sprinkler protection is recommended in all labs using hazardous materials.
  1. Emergency Power – Emergency power is recommended to power exhaust fans connected to hazardous gas enclosures. In certain cases, this protection is required.
  1. Pneumatic Shutoff Valves – All corrosive, toxic, flammable, and pyrophoric gases will contain a normally closed pneumatic shutoff valve, rated for at least full cylinder pressure, and located immediately downstream of the cylinder valve. This valve will shut in the event of power failure, remote actuation of an emergency off button (see this topic), or other appropriate conditions such as hazardous gas alarm activation.
  1. Scrubbers – When hazardous waste gases are generated, it is often advisable to treat/react these gases prior to exhaust from the building. This may involve the use of bubblers in a fume hood or sophisticated units for larger scale hazardous gas processes. Note that in some cases (e.g. minimal volumes of hazardous gases produced) scrubbers may be not necessary or even unadvisable. Where scrubbers are used, they need to be carefully reviewed as part of the hazard review. Maintenance requirements and procedures need to be clearly understood and followed.
  1. Vacuum Pumps – Vacuum pumps used for hazardous gases need to be carefully selected. Depending on the gases being pumped, special precautions may be necessary. For processes where pyrophoric gases are used, pumps need to be continuously purged with nitrogen, with loss of nitrogen flow causing the pyrophoric gas supply valves to close. Pumps used for oxygen service will need to be prepared for this services that includes the elimination of hydrocarbon oils for use due to flammability concerns. In some cases, such as the use of highly toxic gases, vacuum pumps will need to be housed in a ventilated enclosure.
  1. Flow Restrictors – A means to limit hazardous gas flow rates to just over maximum flow needed must be installed immediately downstream of each hazardous gas cylinder. For small-scale experiments, such as fume hood use, a needle valve is sufficient. For large cylinders a flow restricting orifice, installed by the gas supplier in the cylinder valve or installed in the gas purge panel is required.
  1. Ventilation Alarms – All ducts connected to enclosures used to exhaust hazardous compressed gas cylinders or gas-carrying components must be connected to a ventilation alarm. Typically, activation of this alarm will cause pneumatic gas supply shutoff valves to close.
  1. Eyewash and Showers – A safety shower or eyewash with a wand is required to be present in areas where corrosive gases are used or stored.
  1. Purge Panels – Where corrosive, pyrophoric, or toxic gases are in use, the gas installation must include means to adequately purge the area between the cylinder valve and the regulator with an inert gas prior to breaking these connections for maintenance or cylinder change. Inert gases used for this purpose must be used solely for this purpose and not connected to other apparatus. Failure to adequately purge cylinders can result in lack of ability to close the cylinder valve or “regulator creep” which allows full cylinder pressure to be transferred to the low-pressure side of the regulator.
  1. Piping and Fittings – All gas piping must be compatible with the gases used and capable of withstanding full cylinder pressure. For example, tygon tubing should never be used with hazardous gases or low hazard gases unless one end is open to atmosphere. Fittings should be selected based on the service needs. Face seal or welding fittings should be used for hazardous gas service wherever possible. All gauges and components subject to leakages that carry hazardous gases must be contained in an exhausted enclosure.
  1. Hardware – Never lubricate, modify, force, or tamper with a cylinder valve. Use the appropriate regulator on each gas cylinder. Adaptors or homemade modifications can be dangerous. Assure all components of the experimental apparatus that can handle full cylinder pressure or are otherwise protected. Oil or grease on the high-pressure side of oxygen, chlorine, or other cylinder of an oxidizing agent can lead to an explosion. Whenever back siphoning of chemicals into the cylinder might be a problem, use multiple traps or check valves.

Work Practices and Procedures

  1. Hazard Review – A hazard assessment is required for the following processes involving the use of hazardous gases:
    • New or relocated equipment using a toxic, corrosive, or pyrophoric gas.
    • New or relocated equipment using a flammable gas in a non-standard application analytical equipment fuel gases, welding, cutting, brazing, and small scale use in fume hoods are considered standard applications.
    • Existing gas installations should be self-inspected by the work area supervisor against the requirements listed in this section.
    • Existing installations using hazardous gases that are considered to present a significant risk or show design deficiencies will have a hazard review conducted.
  1. Training – All persons handling or using cylinders must have basic training. Review of the information contained in this section, review of any additional information in the written safety plan for all work areas, and hands-on assistance by an experienced gas user will meet this minimum requirement. Additional compressed gas safety training can be obtained through the Safety Department.
  1. Hazard Information – The gas user must be thoroughly familiar with the properties of each gas they are using. A review of a good quality SDS is necessary.
  1. Ordering – All gas cylinders used at the District may only be ordered and received through _______________. This allows for leak testing of highly toxic gases during the receipt process building.
  1. Receiving – Be sure the cylinder tag (don’t rely on cylinder stenciling or color coding) indicates the gas you have ordered. Hazardous gases (flammable, pyrophoric, toxic, corrosive) must be transported directly from the shipper to the end use location. No staging of hazardous gases is permitted. Low hazard gases (e.g. inert gases, oxygen, freon) may be stored temporarily in designated locations that provide means for securing cylinders with chains or straps.
  1. Leak Testing – Toxic, corrosive, and pyrophoric gases must be leak tested at the following intervals; receiving, installation, disconnect/shipping. Highly toxic gases are leak tested by the Safety Department prior to delivery to the user. The end user is responsible for other leak test intervals. It is key that toxic gases be leak tested prior to removal from their exhausted enclosures and subsequent transport.
  1. Storage — For short-term use of hazardous gases, always select the smallest returnable cylinder available. Non-returnable cylinders are strongly discouraged. If non-returnable cylinders must be used, you must have a way to treat the remaining contents of the cylinder so that the cylinder valve can be removed prior to disposal. In cases where the gas will be used over an extended period of time (several months to more than one year), you should order a gas quantity that will last for three to six months. Corrosive gases should be returned to the gas supplier within one year to avoid regulator and cylinder valve problems due to corrosion. In storage, restrain cylinders of all sizes by straps, chains, or a suitable stand to prevent them from falling. Segregate full cylinders of low hazard gases from “empty” cylinders awaiting return to the vendor. Assure hazardous gas cylinders are constantly stored in a suitable exhausted enclosure as described in Engineering Controls.

Do not expose cylinders to temperatures higher than about 50 C. Some small cylinders, such as lecture bottles and cylinders of highly toxic gases are not fitted with rupture devices and may explode if exposed to high temperatures. Never place cylinders where they may become part of an electric circuit. Avoid areas that are damp or subject to other corrosive materials. Do not store flammables and oxidizers together. Keeps cylinders in storage upright, secure, and interlocked into a compact group. Protect cylinders stored outside from standing water by providing proper drainage. Where outdoors storage is necessary, an overhead cover is necessary to avoid sunlight and rain.

  1. Transporting Cylinders – Hazardous gas cylinders must be transported directly from the gas supplier to the end user storage location, unless an exhausted and approved “staging” area has been constructed. Cylinders must never be transported without valve protection caps in place. Never move a cylinder with a regulator attached! Cylinders larger than lecture bottle size should be chained or strapped to a wheeled cart during transport to ensure stability. Transportation of cylinders must be done by trained personnel using approved trucks.
  1. Shipping – Promptly remove the regulators from empty cylinders, leak test hazardous gases, and replace the protective caps at once. Mark the cylinder “MT”. Never bleed a cylinder completely empty. Leave a slight pressure to keep contaminants out. Toxic, corrosive, and pyrophoric gases must remain in their exhausted enclosures until shipped back to the supplier.
  1. Changing Cylinders – Special procedures are required for changing toxic, corrosive, and pyrophoric gases and liquids. A proper cylinder purge panel is needed for high hazard gases, along with an adequate purge procedure. Persons changing gas cylinders requiring SCBA must work with a partner who is identically equipped.
  1. Changing Pump Oil – Hazardous gases may be absorbed into vacuum pump oils. Personnel performing vacuum pump oil changes on pumps used with highly toxic gases must use SCBA for pump oil change. Hot pump oil should be allowed to cool prior to c hanging.
  1. Other Equipment Maintenance Considerations – Consider equipment maintenance needs in advance. Consider reaction byproducts (e.g. use proper skin and eye protection when cleaning process chambers or vacuum pumps). “Low hazard” gases, such as freons, will generate chlorine and fluorine decomposition products. Be sure to LOCK OUT upstream gas lines leading to equipment prepared for maintenance. Compressed gases are a hazardous energy source requiring lockout procedure. Be sure to adequately purge lines following lockout procedures and before beginning maintenance.
  1. General Work Practices – Never use a cylinder that cannot be identified positively. Do not use compressed gas or compressed air to blow away dust or dirt (unless specifically equipped with a 30 psi or less diffuser for this application as used in machine shops). Flying dust and debris, as well as high-pressure air itself, can cause significant injury. When not in use, close cylinder valves. The main cylinder valve should be tightly closed, but needle valves should only be finger tight to avoid ruining the valve and/or valve stem.
  1. Emergency Procedures – Leaking cylinders should not be removed from their exhausted enclosures. Actuate remote emergency gas shutoff valve/button, if present. (Installed highly toxic gases, if properly installed, will have flow limiting devices and/or automatic cylinder shutoff valves in place to limit and shutoff the gas supply.) Close the main cylinder valve if a leak is stopped or slow, hazardous gases are contained in their enclosure, and it is clearly safe to approach. Do not extinguish a flame involving a highly combustible gas until the source of gas has been shut off, otherwise, it can re-ignite, causing an explosion. Cylinders leaking at the cylinder valve should be reported to Public

Safety (this should be reported as a “non-emergency” if the cylinder and gas are contained in an exhausted enclosure). If a hazardous gas is released into an unexhausted enclosure and the gas supply cannot be promptly cutoff, actuate the emergency evacuation procedure in your area and contact Public Safety. This procedure will also be initiated automatically if gas monitors trigger the building evacuation alarm. The Superfund Amendments and Re-authorization Act of 1986 (SARA Title III) states that releases of extremely hazardous substances must be reported to EPA.

Accidental discharge of cylinder contents is to be promptly reported to the Safety Department and area supervisor. Cylinders found to be leaking upon gas delivery should not be accepted from the gas supplier.

Gases for Welding and Cutting

OSHA lists requirements for oxygen-fuel gas welding and cutting in 29 CFR 1910 .253. Cylinder handling precautions, materials of construction, and additional requirements are listed. Persons who will be using acetylene, oxygen, and other fuel gases or those who are designing facilities and equipment for this purpose should review this information. Please see the Personal

Protective Equipment section of this manual for information on eye protection for welding and cutting operations. Be sure that all fuel gases are shut off at the cylinder valve after each use.

Cryogenic Liquids

All cryogenic liquids should be used with caution due to the potential for skin or eye damage due to the low temperature, and the hazards associated with pressure buildups in enclosed piping or containers. Portable containers should only be used where there is sufficient ventilation. Do not place containers in a closet or other enclosed space where there is no ventilation supply to the area. The buildup of inert gas in such an area could generate an oxygen deficient atmosphere.

A full face shield, loose fitting cryogenic handling gloves, apron, and cuff less slacks are the recommended equipment for transferring cryogenic fluids. Special vacuum jacket containers with loose fitting lids should be used to handle small quantities. Vacuum jacketed containers provided by the gas supplier will have overpressure relief devices in place. When plumbing cryogenic liquids, it is very important to include a pressure relief valve between any two-shutoff valves. Also, any space where cryogenic fluids may accumulate (consider leakage into enclosed equipment as well) must be protected by overpressure relief devices. Tremendous pressures can be obtained in enclosed spaces as the liquid converts to gas. For example, one cubic centimeter of liquid nitrogen will expand to 700 times this volume as it converts (warms) to its gaseous state. Lines carrying liquid should be well insulated. Containers to be filled with cryogenic liquids should be filled slowly to avoid splashing. Cryogenic containers showing evidence of loss of vacuum in their outer jacket (ice buildup on the outside of the container) should not be accepted from the gas supplier. Contact with air (or gases with a higher boiling point) can cause an ice plug in a cryogenic container. Should ice plugs be noted, contact the Safety department to obtain assistance.

Compressed Air Systems & Usage

Use compressed air as a cleaning method only when absolutely necessary. It involves a significant nu/mber of hazards not present with other methods.

Authorized uses include:

  • Paint spraying pneumatic controls
  • Pneumatic tools
  • Siphons

Compressed Air Usage

Only machinery that cannot be cleaned in any other way should be cleaned by compressed air.  Never use compressed air to clean equipment or parts that are contaminated by toxic materials.

Compressed air used for cleaning machinery or shop areas and/or operated from a hand-held nozzle or similar device must have a nozzle pressure of less than 30 psig, if the nozzle is deadened. This may be accomplished by the use of a pressure-reducing valve in the airline or by the use of air guns designed to reduce or relieve nozzle airline pressure to less than 30 psig. Wear eye protection when you must use compressed air for cleaning. Ensure people working around you are shielded from the air blast and flying chips.

 Air Receivers and Compressors

All air receivers or tanks (this does not include compressed gas cylinders, which must not be employed as air receivers) used for the storage of l cubic foot or more of compressed air at a pressure in excess of 50 psig. must be constructed in accordance with the American Society of Mechanical Engineers (ASME) Boilers and Pressure Code.

  • All safety valves must be installed and maintained in accordance with the ASME code. Air receivers and tanks are to be installed so that all drains handholds, and personnel access openings are easily accessible, and should be supported so as to allow sufficient clearance for complete external inspection.
  • Each air compressor system must be provided with a connection of the appropriate size for attaching an inspector’s test gauge when the system is in service.
  • Nothing must obstruct the connection of the inspector’s test gauge.
  • Provisions must be made for the removal of oil and water from the tanks. Drain valves must be located at the lowest point possible and a draining schedule established to prevent the accumulation of excessive amounts of liquid in the receiver.
  • Readily visible pressure gauges must be installed. Spring loaded safety devices with a total relieving capacity sufficient to prevent a rise in pressure of more than l0 percent above the maximum allowable working pressure of the receiver must also be installed.
  • At least one safety valve in each system must be set to operate at or below the maximum allowable working pressure.
  • Valves must not be installed between the air receiver and any of its safety valves. Daily testing of controlling and safety valves is required.
  • All safety appliances such as safety valves, indicating devices, and controlling devices must be constructed, located, and installed so that they cannot readily be made inoperative by any means, including weathering.
  • Hoses and lines used in any compressed air system must be rated to meet the maximum operating pressure (both static and transient) of the equipment or apparatus.
  • Hoses and lines should be properly assembled; incorrect fittings should be avoided.
  • A system should be designed with the least number of bends and the largest diameter feasible.
  • Additionally, hoses and lines should be protected from external damage, e.g., heat, abrasion and corrosion. To this end, they should not be placed where they can be trod on, tripped over, or driven over by personnel or equipment.
  • Vent pressure relief valves and rupture discs to a safe area, where personnel will not be affected, e.g. toward a wall.

St. Bernards Community Right-to-Know Plan

PLAN REVIEW
Reviewer Date
Brian Parrie 4/23/2015
   
   
   
   

                                                                                                                            

COMMUNITY RIGHT-TO-KNOW

Introduction

The Emergency Planning and Community Right to Know Act of 1986 established requirements for Federal, State, and local governments and industry regarding emergency planning and “Community Right-to-Know” reporting on hazardous and toxic chemicals. This was part of the Superfund Amendments and Reauthorization Act (SARA), the main purpose of which was to extend the Superfund for cleanup of hazardous waste sites throughout the United States. The law contained in its scope provisions on planning for hazardous chemical emergencies and to allow citizens the right to know about hazardous chemicals in their communities. These Community Right-to-Know provisions will help to increase the public’s knowledge and access to information on the presence of hazardous chemicals in their communities and releases of these chemicals into the environment.

The requirements of the law apply to any facility which stores hazardous substances in quantities equal to or greater than the regulated threshold planning quantity (TPQ) or other general limit which is applicable (500 pounds for extremely hazardous chemicals; 10,000 pounds for all other hazardous chemicals).

Applicability

Facilities Storing Extremely Hazardous Substances

If, at any time, St. Bernard’s School stores any of the 360+ extremely hazardous substances listed in SARA Title III above the threshold planning quantities (at any one time), the State Emergency Response Commission will be notified.

Emergency Notification

St. Bernard’s School will immediately notify the Local Emergency Planning Committees (LEPCs) and the State Emergency Response Commission (SERC) likely to be affected if there is a release into the environment of a hazardous substance that exceeds the reportable quantity for that substance. Substances subject6 to this requirement are those on the list of 356 extremely hazardous substances as published in Federal Register (40 CFR 355) as well as the more than 700 hazardous substances subject to the emergency notification requirements under CERCLA Section 103 (a) (40CFR 302.4). Some chemicals are common to both lists. The CERCLA hazardous substances also require notification of releases to the National Response Center (NRC), which affect alerts federal responses.

Initial notification will be made by telephone. Emergency notification requirements involving transportation incidents will be met by dialing 911, or in the absence of a 911 emergency number, calling the operator.

This emergency notification will include:

      • The chemical name;
      • An indication of whether the substance is extremely hazardous;
      • An estimate of the quantity released into the environment;
      • The time and duration of the release;
      • Whether the release occurred into the air, water, and/or land; any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for the exposed individuals;
      • Proper precautions, such as evacuations or sheltering in place; and,
      • Name and telephone number of contact person («Com_RTK»).

Chemical Inventory Form

For all chemicals reported under Section 311, St. Bernard’s School will report the past year’s quantities to the Emergency Response Commission (MN Tier Two Report).

Regulatory Requirements

Community Right-To-Know Requirements

There are two Community Right-To-Know reporting requirements within the Emergency Planning and Community Right-To-Know Act. Section 311 requires facilities that must prepare material safety data sheets () under Occupational Safety and Health Administration (OSHA) regulations to submit either copies of their SDSs or a list of SDSs chemicals to:

      • The LEPC,
      • The SERC, and,
      • The local fire department with jurisdiction over District facilities.

The initial step a facility coordinator should take in preparing for an emergency should be to inventory and quantify hazardous substances within the facility. The coordinator should begin by focusing on the list of extremely hazardous substances published in the Federal Register. This list is provided under the EHS title in the CHMP section of this program.

If an inventory of the facility’s chemicals indicates that a threshold planning quantity is reached, the District is then required to:

      1. Notify the Emergency Response Commission in writing within 60 days after acquiring any of the extremely hazardous substances above the threshold planning quantities, and
      2. Assign a Facility Emergency Coordinator.

Emergency Notification

Whenever a hazardous substance is released outside the control of the facility (air, sewer, land, or surface water), there are requirements to:

      1. Contact local emergency 911;
      2. Contact State Duty Officer (Metro 612-649-5451, outside Metro 1-800-422-0798);
      3. Contact National Response Center at 1-800-424-8802; and
      4. Submit an Emergency Release Follow-up Report to the Emergency Response Commission.

All spills and releases occurring in Minnesota that are outside the control of the facility should be reported to the State Duty Officer—regardless of whether or not the reportable quantity was reached. Minnesota has a “One Call” system that allows the State Duty Officer to make notification to all applicable state, county, and local agencies. If a spill or release occurs which has met or exceeded the reportable quantity, the caller is still responsible for notifying the 911 emergency system and the National Response Center.

The facility should contact local authorities to inform them of the need for emergency response. When contacting the state emergency response number, the facility should specify that the release is subject to Title III notification. The emergency notification must include:

      1. The chemical name or identification of any substance involved in the release;
      2. An indication as to whether the substance is on the list of extremely hazardous substances;
      3. An estimate of the quantity of any such substance that was released into the environment;
      4. The time and duration of the release;
      5. Whether the release occurred into air, water, and/or land;
      6. Any known or anticipated health risks (acute or chronic) and any advice regarding medical attention for exposed individuals;
      7. The proper precautions to be taken in the event of a release, including evacuation; and
      8. The name and telephone number of the person or persons to be contacted for further information.

As soon as practical after a release, an Emergency Release Follow-Up Report must be sent to the Emergency Response Commission, and must:

      1. Update information included in the initial notice and
      2. Provide information on:
        1. Actual response actions taken and
        2. Advice regarding medical attention necessary for exposed individuals.

Chemical List

Any facility required to prepare or have available SDSs under the Minnesota Employee Right to Know or the Hazard Communication Standard must report the following:

      1. Any extremely hazardous chemical that is stored in a quantity of 500 pounds or more or greater than the threshold planning quantity (TPQ). If so listed, look up on the list of extremely hazardous substances.
      2. Any hazardous chemical for which there is an SDS and which is being stored in a quantity of 10,000 pounds or greater.

Under the reporting requirements, the law states that a list of SDSs or a copy of the SDS sheets themselves must be submitted for any of the extremely hazardous substances above the TPQ, or other hazardous chemicals in excess of 10,000 pounds. Minnesota provides a Hazardous Chemical Report Form that may be submitted in lieu of the SDSs (in fact, a fee is charged if the Minnesota form is not used). This form is submitted one time and is only required to be updated if a new chemical is brought into the facility.

      • The chemicals which would potentially be found in quantities greater than 10,000 pounds for “ordinary” hazardous chemicals in a school district would be fuel oil, propane, butane, or diesel fuel.
      • The most commonly found extremely hazardous chemical in most schools is chlorine, which has a TPQ of 100 pounds. If liquefied chlorine in tanks is used for swimming pool chlorination, this limit would apply. Dry chlorine compounds, which may have 10% available chlorine, would also apply if stored in quantities greater than 1,000 pounds. This requirement is based on the actual weight of the specific hazardous chemical and not the total weight of a formulated product (e.g., 10% chlorine of 1,000 pounds total product equals 100 pounds of chlorine).
      • This chemical report form must be submitted to both the State Emergency Response Commission and the local fire department with jurisdiction over your facility.
      • Reporting requirements under Section 311 do not apply to:

—    Wood or wood products;

—    Tobacco or tobacco products;

—    Any food, additive, color, drug, or cosmetic regulated by the Food and Drug Administration; or

—    Any hazardous waste which is regulated by other regulations such as the Solid Waste Disposal Act;

—    Any fertilizer held by a retailer for resale;

—    Any solid substance in a manufacturer item which does not cause exposure under normal conditions of use;

—    Any substance to the extent that it is used for personal, family, or household purposes, or is present in the same form and concentration as a product packaged for distribution and use by the general public; and

—    Any substance to the extent it is used in a research laboratory, hospital, or other medical facility under the direct supervision of a technically qualified individual.

Chemical Inventory Form

      • All facilities that have completed an initial Chemical Report Form are also required to submit an annual inventory by March 1, which covers the previous calendar year.

—    This report covers any chemical stored at any time during that year which exceeded the threshold planning quantity or the general limit (over 500 pounds of extremely hazardous chemical or 10,000 pounds of other hazardous chemical).

—    Effective with the 1963 reporting year, the Emergency Response Commission will be electronically scanning data received under this Section.

—    Facilities that are current reporters will receive a Section 312 Tier Two Turnaround Report from the Commission.

      • Facilities reporting for the first time should request a new reporter package from the Commission. Tier Two forms will not be able to be supplied with this program because only originals from the Commission may be used.
      • The purpose of the Tier Two form is to provide state and local officials and the public with specific information on hazardous chemicals present in your facility during the past year. The Tier Two form must be submitted by March 1 of every year for the previous year and must include:

—    Chemical name or common name as used on the SDS,

—    An estimate of the maximum amount of the chemical present at any one time,

—    A brief description of the manner of storage of the chemical,

—    The location of the chemical, and

—    An indication of whether the administrator elects to withhold location information from disclosure to the public.

St. Bernards Confined Space Entry Plan

PLAN REVIEW
Reviewer Date
Brian Parrie 4/23/2015

 

Contact: Mitch Hoard

(707) 443-2735

CONFINED SPACE ENTRY

Purpose

The St. Bernard’s School Confined Space Entry Program is provided to protect authorized employees that will enter confined spaces and may be exposed to hazardous atmospheres, engulfment in materials, conditions which may trap or asphyxiate due to converging or sloping walls, or contains any other safety or health hazards.

Responsibilities

Management

  • Ensure proper training for entry and rescue teams
  • Provide proper equipment for entry and rescue teams
  • Ensure confined space assessments have been conducted
  • Ensure all permit required confined spaces are posted
  • Annually review this program and all Entry Permits
  • Evaluate Rescue Teams/Service to ensure they are adequately trained and prepared
  • Ensure rescue team at access during entry into spaces with IDLH atmospheres

Employees

  • Follow St. Bernard’s School program requirements
  • Report any previously unidentified hazards associated with confined spaces

Entry Supervisor

Entry supervisors are responsible for the overall permit space entry and must coordinate all entry procedures, tests, permits, equipment, and other relevant activities. The following entry supervisor duties are required:

  • Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure
  • Verify, by checking that the appropriate entries have been made on the permit, that all tests specified by the permit have been conducted and that all procedures and equipment specified by the permit are in place before endorsing the permit and allowing entry to begin
  • Terminate the entry and cancel the permit when the entry is complete and there is a need for terminating the permit
  • Verify that rescue services are available and that the means for summoning them are operable
  • Remove unauthorized persons who enter or attempt to enter the space during entry operations
  • Whenever responsibility for a permit space entry operation is transferred, and at intervals dictated by the hazards and operations performed within the space, determine that entry operations remain consistent with the permit terms and that acceptable entry conditions are maintained

The entry supervisor for St. Bernard’s School will be the Confined Space Entry Program Manager, «Confined_Space», unless otherwise designated.

Entry Attendants

At least one attendant is required outside the permit space into which entry is authorized for the duration of the entry operation. Responsibilities include:

  • To know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure
  • To be aware of possible behavioral effects of hazard exposure on entrants
  • To continuously maintain an accurate count of entrants in the permit space and ensures a means to accurately identify authorized entrants
  • To remain outside the permit space during entry operations until relieved by another attendant (once properly relieved, s/he may participate in other permit space activities, including rescue if they are properly trained and equipped)
  • To communicate with entrants as necessary to monitor their status as well as alert entrants of the need to evacuate
  • To monitor activities inside and outside the space to determine if it is safe for entrants to remain in the space
  • To order the entrants to immediately evacuate if the attendant:
    • Detects a prohibited condition,
    • Detects entrant behavioral effects of hazard exposure
    • Detects a situation outside the space that could endanger the entrants, or
    • Cannot effectively and safely perform all the attendant duties.
  • To summon rescue and other emergency services as soon as the attendant determines the entrants need assistance to escape the permit space hazards
  • To perform non-entry rescues as specified by that rescue procedure and entry supervisor
  • Not to perform duties that might interfere with the attendant’s primary duty to monitor and protect the entrants
  • To take the following action when unauthorized persons approach or enter a permit space while entry is under way:
    • Warn the unauthorized persons that they must stay away from the permit space,
    • Advise unauthorized persons that they must exit immediately if they have entered the space, and
    • Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space.

Entrants

All entrants must be authorized by the entry supervisor to enter permit spaces, have received the required training, use the proper equipment, and observe the entry procedures and permit. The following entrant duties are required:

  • Know the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure
  • Properly use the equipment required for safe entry
  • Communicate with the attendant as necessary to enable the attendant to monitor the status of the entrants and to enable the attendant to alert the entrants of the need to evacuate the space if necessary
  • Alert the attendant whenever the entrant recognizes any warning signs or symptoms of exposure to a dangerous situation, or any prohibited condition is detected
  • Exit the permit space as quickly as possible whenever the attendant or entry supervisor gives an order to evacuate the permit space, the entrant recognized any warning signs or symptoms of exposure to a dangerous situation, the entrant detects a prohibited condition, or an evacuation alarm activated.

Hazards

  • Explosive / Flammable Atmospheres
  • Toxic Atmospheres
  • Engulfment
  • Asphyxiation
  • Entrapment
  • Slips and falls
  • Chemical Exposure
  • Electric Shock
  • Thermal/Chemical Burns
  • Noise and Vibration

Hazard Control

Engineering Controls

  • Locked entry points
  • Temporary ventilation
  • Temporary lighting

Administrative Controls

  • Signs
  • Employee training
  • Entry procedures
  • Atmospheric monitoring
  • Rescue procedures
  • Use of prescribed PPE

Definitions

Confined space

A confined space:

  • Is large enough or so configured that an employee can bodily enter and perform work
  • Has limited or restricted means for entry or exit (e.g., tanks, vessels, silos, storage bins, hoppers, vaults, and pits)
  • Is not designed for continuous employee occupancy

Permit-required confined space (permit space)

A permit-required confined space is a confined space that has one or more of the following characteristics:

  • Contains or has a potential to contain a hazardous atmosphere
  • Contains a material that has the potential for engulfing an entrant
  • Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly covering walls or by a floor that slopes downward and tapers to a smaller cross-section
  • Contains any other recognized serious safety or health hazard

Each permit-required confined space will be marked “Confined Space—Entry Permit Required”.

Entry Standard Operating Procedures

A Standard Operating Procedure (SOP) has been developed for each space to standardize the entry procedure. The SOP outlines:

  • Hazards
  • Hazard Control and Abatement
  • Acceptable Entry Conditions
  • Means of Entry
  • Entry Equipment Required
  • Emergency Procedures

Permit-Required Confined Space Entry General Rules

During all permit-required confined space entries, the following safety rules must be strictly enforced:

  1. Only authorized and trained employees may enter a confined space or act as Entry Attendants.
  2. No smoking is permitted in a confined space or near entrance/exit area.
  3. During confined space entries, an Entry Attendant must be present at all times.
  4. Constant visual or voice communication will be maintained between the Entry Attendant and Entrants.
  5. No bottom or side entry will be made or work conducted below the level any hanging material or material which could cause engulfment.
  6. Air and oxygen monitoring is required before entering any permit-required confined space.

—    Oxygen levels in a confined space must be between 19.5% and 23.5%.

—    Levels above or below will require the use of an SCBA or other approved air supplied respirator.

—    Additional ventilation and oxygen level monitoring is required when welding is performed.

—    The monitoring will check oxygen levels, explosive gas levels, and carbon monoxide levels.

—    Entry will not be permitted if explosive gas is detected above one-half the Lower Explosive Limit (LEL).

  1. To prevent injuries to others, all openings to confined spaces will be protected by a barricade when covers are removed.

Confined Space Entry Procedures

Each employee who enters or is involved in the entry must:

  1. Understand the procedures for confined space entry;
  2. Know the hazards of the specific space;
  3. Review the specific procedures for each entry; and
  4. Understand how to use entry and rescue equipment.

Confined Space Entry Permits

Confined Space Entry Permits must be completed before any employee enters a permit-required confined space. The permit must be completed and signed by an authorized member of management before entry.

  • Permits will expire before the completion of the shift or if any pre-entry conditions change.
  • Permits will be maintained on file for 12 months.

Contractor Entry

All work by non-school employees that involves the entry into confined spaces will follow the procedures of this program. The information of this program and specific hazards of the confined spaces to be entered will be provided to Contractor Management prior to commencing entry or work.

Training

Training for confined space entry includes:

  1. Duties of Entry Supervisor, Entrant, and Attendants
  2. Confined Space Entry Permits
  3. Hazards of Confined Spaces
  4. Use of Air Monitoring Equipment
  5. First Aid and CPR Training
  6. Emergency Action and Rescue Procedures
  7. Confined Space Entry and Rescue Equipment
  8. Rescue training, including entry and removal from representative spaces

Confined Space Hazards

Flammable Atmospheres

A flammable atmosphere generally arises from enriched oxygen atmospheres, vaporization of flammable liquids, byproducts of work, chemical reactions, concentrations of combustible dusts, and desorption of chemical from inner surfaces of the confined space.

An atmosphere becomes flammable when the ratio of oxygen to combustible material in the air is neither too rich nor too lean for combustion to occur. Combustible gases or vapors will accumulate when there is inadequate ventilation in areas such as a confined space. Flammable gases such as acetylene, butane, propane, hydrogen, methane, natural or manufactured gases, or vapors from liquid hydrocarbons can be trapped in confined spaces, and since many gases are heavier than air, they will seek lower levels as in pits, sewers, and various types of storage tanks and vessels. In a closed top tank, it should also be noted that lighter than air gases may rise and develop a flammable concentration if trapped above the opening.

The byproducts of work procedures can generate flammable or explosive conditions within a confined space. Specific kinds of work such as spray painting can result in the release of explosive gases or vapors. Welding in a confined space is a major cause of explosions in areas that contain combustible gas.

Chemical reactions forming flammable atmospheres occur when surfaces are initially exposed to the atmosphere, or when chemicals combine to form flammable gases. This condition arises when dilute sulfuric acid reacts with iron to form hydrogen or when calcium carbide makes contact with water to form acetylene. Other examples of spontaneous chemical reactions that may produce explosions from small amounts of unstable compounds are acetylene-metal compounds, peroxides, and nitrates. In a dry state, these compounds have the potential to explode upon percussion or exposure to increased temperature. Another class of chemical reactions that form flammable atmospheres arises from deposits of pyrophoric substances (e.g., carbon, ferrous oxide, ferrous sulfate, iron, etc.) that can be found in tanks used by the chemical and petroleum industry. These tanks containing flammable deposits will spontaneously ignite upon exposure to air.

Combustible dust concentrations are usually found during the process of loading, unloading, and conveying grain products, nitrated fertilizers, finely ground chemical products, and any other combustible material. High charges of static electricity, which rapidly accumulate during periods of relatively low humidity (below 50%), can cause certain substances to accumulate electrostatic charges of sufficient energy to produce sparks and ignite a flammable atmosphere. These sparks may also cause explosions when the right air- or oxygen-to-dust or gas mixture is present.

Toxic Atmospheres

The substances to be regarded as toxic in a confined space can cover the entire spectrum of gases, vapors, and finely divided airborne dust in industry. The sources of toxic atmospheres encountered may arise from the following:

  • The manufacturing process (e.g., in producing polyvinyl chloride, hydrogen chloride is used as well as vinyl chloride monomer, which is carcinogenic)
  • The product stored [removing decomposed organic material from a tank can liberate toxic substances, such as hydrogen sulfide (H2S)]
  • The operation performed in the confined space (for example, welding or brazing with metals capable of producing toxic fumes)

During loading, unloading, formulation, and production, mechanical and/or human error may also produce toxic gases that are not part of the planned operation. Carbon monoxide (CO) is a hazardous gas that may build up in a confined space. This odorless, colorless gas that has approximately the same density as air is formed from incomplete combustion of organic materials such as wood, coal, gas, oil, and gasoline; it can also be formed from microbial decomposition of organic matter in sewers, silos, and fermentation tanks. Carbon monoxide is an insidious toxic gas because of its poor warning properties. Early stages of CO intoxication are nausea and headache. Carbon monoxide may be fatal at 1000 ppm in air, and is considered dangerous at 200 ppm, because it forms carboxyhemoglobin in the blood that prevents the distribution of oxygen in the body.

Carbon monoxide is a relatively abundant colorless, odorless gas; therefore, any untested atmosphere must be suspect. It must also be noted that a safe reading on a combustible gas indicator does not ensure that CO is not present. Carbon monoxide must be tested for specifically.

The formation of CO may result from chemical reactions or work activities; therefore fatalities due to CO poisoning are not confined to any particular industry. There have been fatal accidents in sewage treatment plants due to decomposition products and lack of ventilation in confined spaces. Another area where CO results as a product of decomposition is in the formation of silo gas in grain storage elevators. In another area, the paint industry, varnish is manufactured by introducing the various ingredients into a kettle, and heating them in an inert atmosphere, usually town gas, which is a mixture of carbon dioxide and nitrogen. In welding operations, oxides of nitrogen and ozone are gases of major toxicologic importance, and incomplete oxidation may occur and carbon monoxide can form as a byproduct.

Another poor work practice, which has led to fatalities, is the recirculation of diesel exhaust emissions. Increased CO levels can be prevented by strict control of the ventilation and the use of catalytic converters.

Irritant (Corrosive) Atmospheres

Irritant or corrosive atmospheres can be divided into primary and secondary groups. The primary irritants exert no systemic toxic effects (effects on the entire body). Examples of primary irritants are chlorine, ozone, hydrochloric acid, hydrofluoric acid, sulfuric acid, nitrogen dioxide, ammonia, and sulfur dioxide. A secondary irritant is one that may produce systemic toxic effects in addition to surface irritation. Examples of secondary irritants include benzene, carbon tetrachloride, ethyl chloride, trichloroethane, trichloroethylene, and chloropropene.

Irritant gases vary widely among all areas of industrial activity. They can be found in plastics plants, chemical plants, the petroleum industry, tanneries, refrigeration industries, paint manufacturing, and mining operations.

Prolonged exposure at irritant or corrosive concentrations in a confined space may produce little or no evidence of irritation. This may result in a general weakening of the defense reflexes from changes in sensitivity. The danger in this situation is that the worker is usually not aware of any increase in his/her exposure to toxic substances.

Asphyxiating Atmospheres

The normal atmosphere is composed approximately of 20.9% oxygen and 78.1% nitrogen, and 1% argon with small amounts of various other gases. Reduction of oxygen in a confined space may be the result of either consumption or displacement.

The consumption of oxygen takes place during combustion of flammable substances, as in welding, heating, cutting, and brazing. A more subtle consumption of oxygen occurs during bacterial action, as in the fermentation process. Oxygen may also be consumed during chemical reactions as in the formation of rust on the exposed surface of the confined space (iron oxide). The number of people working in a confined space and the amount of their physical activity will also influence the oxygen consumption rate.

A second factor in oxygen deficiency is displacement by another gas. Examples of gases that are used to displace air, and therefore reduce the oxygen level, are helium, argon, and nitrogen. Carbon dioxide may also be used to displace air and can occur naturally in sewers, storage bins, wells, tunnels, wine vats, and grain elevators. Aside from the natural development of these gases, or their use in the chemical process, certain gases are also used as inerting agents to displace flammable substances and retard pyrophoric reactions. Gases such as nitrogen, argon, helium, and carbon dioxide are frequently referred to as non-toxic inert gases but have claimed many lives. The use of nitrogen to inert a confined space has claimed more lives than carbon dioxide. The total displacement of oxygen by nitrogen will cause immediate collapse and death. Carbon dioxide and argon, with specific gravities greater than air, may lie in a tank or manhole for hours or days after opening. Since these gases are colorless and odorless, they pose an immediate hazard to health unless appropriate oxygen measurements and ventilation are adequately carried out.

Oxygen deprivation is one form of asphyxiation. While it is desirable to maintain the atmospheric oxygen level at 21% by volume, the body can tolerate deviation from this ideal. When the oxygen level falls to 17%, the first sign of hypoxia is deterioration to night vision that is not noticeable until a normal oxygen concentration is restored. Physiologic effects are increased breathing volume and accelerated heartbeat. Between 14% and 16%, physiologic effects are increased breathing volume, accelerated heartbeat, very poor muscular coordination, rapid fatigue, and intermittent respiration. Between 6% and 10%, the effects are nausea, vomiting, inability to perform, and unconsciousness. When the body’s oxygen level is less than 6%, the results are spasmatic breathing, convulsive movements, and death in minutes.

Mechanical Hazards

If activation of electrical or mechanical equipment would cause injury, each piece of equipment should be manually isolated to prevent inadvertent activation before workers enter or while they work in a confined space. The interplay of hazards associated with a confined space, such as the potential of flammable vapors or gases being present and the build-up of static charge due to mechanical cleaning (such as abrasive blasting) all influence the precautions that must be taken.

To prevent vapor leaks, flashbacks, and other hazards, workers should completely isolate the space. To completely isolate a confined space, the closing of valves is not sufficient. All pipes must be physically disconnected or isolation blanks bolted in place. Other special precautions must be taken in cases where flammable liquids or vapors may re-contaminate the confined space. The pipes blanked or disconnected should be inspected and tested for leakage to check the effectiveness of the procedure. Other areas of concern are steam valves, pressure lines, and chemical transfer pipes. A less apparent hazard is the space referred to as a void, such as double-walled vessels, which must be given special consideration in blanking off and inerting.

Thermal Effects

Four factors influence the interchange of heat between people and their environment. They are:

  1. air temperature
  2. air velocity
  3. moisture contained in the air
  4. radiant heat.

Because of the nature and design of most confined spaces, moisture content and radiant heat are difficult to control. As the body temperature rises progressively, workers will continue to function until the body temperature reaches approximately 102o F. When this body temperature is exceeded, the workers are less efficient and are prone to heat exhaustion, heat cramps, or heat stroke.

In a cold environment, certain physiologic mechanisms come into play, which tend to limit heat loss and increase heat production. The most severe strain in cold conditions is chilling of the extremities so that activity is restricted. Special precautions must be taken in cold environments to prevent frostbite, trench foot, and general hypothermia.

Protective insulated clothing for both hot and cold environments will add additional bulk to the worker and must be considered in allowing for movement in the confined space and exit time. Therefore, air temperature of the environment becomes an important consideration when evaluating working conditions in confined spaces.

Noise

Noise problems are usually intensified in confined spaces because the interior tends to cause sound to reverberate and thus expose the worker to higher sound levels than those found in an open environment. This intensified noise increases the risk of hearing damage to workers, which could result in temporary or permanent loss of hearing. Noise in a confined space that may not be intense enough to cause hearing damage may still disrupt verbal communication with the emergency standby person on the exterior of the confined space. If the workers inside are not able to hear commands or danger signals due to excessive noise, the probability of severe accidents can increase.

Vibration

Whole body vibration may affect multiple body parts and organs depending upon the vibration characteristics. Segmental vibration, unlike whole body vibration, appears to be more localized in creating injury to the fingers and hands of workers using tools, such as pneumatic hammers, rotary grinders, or other hand tools that cause vibration.

Other Hazards

Some physical hazards cannot be eliminated because of the nature of the confined space or the work to be performed. These hazards include such items as scaffolding, surface residues, and structural hazards. The use of scaffolding in confined spaces has contributed to many accidents caused by workers or materials falling, improper use of guardrails, and lack of maintenance to insure worker safety. The choice of material used for scaffolding depends upon the type of work to be performed, the calculated weight to be supported, and the surface on which the scaffolding is placed, and the substance previously stored in the confined space.

Surface residues in confined spaces can increase the already hazardous conditions of electrical shock, reaction of incompatible materials, liberation of toxic substances, and bodily injury due to slips and falls. Without protective clothing, additional hazards to health may arise due to surface residues.

Structural hazards within a confined space such as baffles in horizontal tanks, trays in vertical towers, bends in tunnels, overhead structural members, or scaffolding installed for maintenance constitute physical hazards, which are exacerbated by the physical surroundings. In dealing with structural hazards, workers must review and enforce safety precautions to assure safety.

St. Bernards Bloodborne Pathogens Plan

PLAN REVIEW
Reviewer Date
Brian Parrie 4/23/2015

                                                                                                             Contact: Randy Schantz

(707) 443-2735 

  BLOODBORNE PATHOGENS

Purpose

The St. Bernard’s School Bloodborne Pathogens Control Plan is designed to eliminate or minimize employee exposure to blood or other potentially infectious materials (OPIM). This plan includes an exposure determination for this workplace, the schedule and methods of implementation, and the procedure for the evaluation of circumstances surrounding exposure incidents.

Exposure Determination

Below is a list of job classifications with occupational exposure. Specific tasks/procedures in which occupational exposure occurs are included.

Job Classification: School Nurse

Specific tasks/procedure in which employees have occupational exposure:

  • First aid treatment
  • Cleaning up blood or OPIM spills
  • Disposing of waste contaminated with blood or OPIM

Job Classification: Custodian

Specific task/procedure in which employees have occupational exposure:

  • Cleaning up blood or OPIM spills
  • Disposing of waste contaminated with blood or OPIM

Job Classification: Secretary/Bus Driver/Coaches/Assistant Coaches/Trainers/

Physical Education Instructors/Paraprofessionals/Playground Supervisor

Specific task/procedure in which employee has occupational exposure:

  • First aid treatment
  • Cleaning up blood or OPIM spills
  • Disposing of waste contaminated with blood or OPIM

Job Classification: Laundry Personnel

Specific task/procedure in which employee has occupational exposure:

  • Laundering of waste contaminated with blood or OPIM

Job Classification: Specific Instructors—Art/Industrial Arts/Special Education

Specific task/procedure in which employees have occupational exposure:

  • First aid treatment
  • Cleaning up blood or OPIM spills
  • Disposing of waste contaminated with blood or OPIM

Of course, all personnel may have some chance of exposure during emergency situations (i.e., teachers, instructors). It is our policy, however, that all employees, except those listed above, are prohibited from administering the elements of this plan.  Instead, the procedure is to contact one of the employees listed above for further action, specifically the school nurse or an alternate in their absence.

In emergency situations, however, where a breakdown occurs in this system, and an employee is exposed to blood or another OPIM, actions shall be taken in accordance with this plan.

Job Classification: Biology Staff

Biology curriculum does not currently include blood-typing, whereby students and instructors lance the skin to produce a drop of blood for analysis under a microscope. These affected employees will be included under this plan should the biology curriculum change to include blood-typing.

Methods of Compliance

General

Universal precautions shall be observed. When differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious material.

Engineering and Work Practice Controls

  • Engineering controls shall be examined and maintained or replaced on a regular schedule to ensure their effectiveness.
  • Hand washing facilities, which are readily accessible to employees, will also be provided.
  • When provision of hand washing facilities is not feasible, an appropriate antiseptic hand cleanser in conjunction with clean cloth/paper towels or antiseptic towelettes will be provided. When antiseptic hand cleansers or towelettes are used, hands shall be washed with soap and running water as soon as feasible.
  • Employees will wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment.
  • Employees shall wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following the contact of such body areas with blood or other potentially infectious materials.
  • Contaminated needles and other contaminated sharps shall not be bent, recapped, or removed. Shearing or breaking of contaminated needles is prohibited.
  • Such recapping or needle removal must be accomplished through the use of a mechanical device or a one-handed technique.
  • Immediately or as soon as possible after use, contaminated reusable sharps shall be placed in appropriate containers until properly processed. These containers shall be:

—    Puncture resistant,

—    Labeled or color-coded in accordance with this standard, and

—    Leak proof on the sides and bottom.

  • Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.
  • Food and drink shall not be kept in refrigerators, freezers, shelves, and cabinets or on countertops or bench tops where blood or other potentially infectious materials are present.
  • All procedures involving blood or other potentially infectious materials shall be performed in such a manner as to minimize splashing, spraying, spattering, and generation of droplets of these substances.
  • Mouth pipetting/suctioning of blood or other potentially infectious materials is prohibited.
  • Specimens of blood or other potentially infectious materials shall be placed in a container, which prevents leakage during collection, handling, processing, storage, transport, or shipping.

—    The container for storage, transport, or shipping shall be labeled or color-coded and closed prior to being stored, transported, or shipped. When a facility utilizes Universal Precautions in the handling of all specimens, the labeling/color-coding of specimens is not necessary provided containers are recognizable as containing specimens. This exemption only applies while such specimens/containers remain within the facility. Labeling or color-coding is required when such specimens/containers leave the facility.

—    If outside contamination of the primary container occurs, the primary container shall be placed within a second container which prevents leakage during handling, processing, storage, transport, or shipping and is labeled or color-coded according to the requirements of this standard.

—    If the specimen could puncture the primary container, the primary container shall be placed within a secondary container, which is puncture-resistant in addition to the above characteristics.

  • Equipment that may become contaminated with blood or other potentially infectious materials shall be examined prior to servicing or shipping and shall be decontaminated as necessary, unless decontamination of such equipment or portions of such equipment is not feasible.

—    A readily observable label shall be attached to the equipment stating which portions remain contaminated.

—    This information will be conveyed to all affected employees, the servicing representative, and/or the manufacturer, as appropriate, prior to handling, servicing, or shipping so that appropriate precautions will be taken.

Personal Protective Equipment

  • When there is occupational exposure, provisions shall be made, at no cost to the employee, appropriate personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields, masks, eye protection, mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment will be considered “appropriate” only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee’s work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.
  • Use: The employee shall use appropriate personal protective equipment as determined by the employee’s professional judgment that in a specific instance its use would have prevented the delivery of health care or public safety services or would have imposed an increased hazard to the safety of the worker or co-worker. When the employee makes this judgment, the circumstances shall be investigated and documented in order to determine whether changes can be instituted to prevent such occurrences in the future.
  • Accessibility: Appropriate personal protective equipment in the appropriate sizes will be readily accessible at the worksheet or be issued. Hypoallergenic gloves, glove liners, powerless gloves, or other similar alternative shall be readily accessible to those employees who are allergic to the gloves normally provided.
  • Cleaning, Laundering, and Disposal: The employer will clean, launder, and dispose of personal protective equipment required, at no cost to the employee.
  • Repair and Replacement: The employer will repair or replace personal protective equipment as needed to maintain its effectiveness, at no cost to the employee.
  • Gloves: Gloves shall be worn when it can be reasonably anticipated that the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin, and when handling or touching contaminated items or surfaces.

—    Disposable (single use) gloves such as surgical or examination gloves shall be replaced as soon as practical when contaminated or as soon as feasible if they are torn, punctured, or when their ability to function as a barrier has been compromised.

—    Disposable (single use) gloves shall not be washed or decontaminated for re-use.

—    Utility gloves may be decontaminated for re-use if the integrity of the glove is not compromised. However, they must be discarded if they are cracked, peeling, torn, punctured, or exhibit other signs of deterioration or when their ability to function as a barrier is compromised.

  • Masks, Eye Protection, and Face Shields: Masks in combination with eye protection devices, such as goggles or glasses with solid side shields, or chin-length face shields, shall be worn whenever splashes, spray, spatter, or droplets or other potentially infectious materials may be generated and eye, nose, or mouth contamination can be reasonably anticipated.
  • Gowns, Aprons, and Other Protective Body Clothing: Appropriate protective clothing such as, but not limited to, gowns, aprons, lab coats, clinic jackets, or similar outer garments shall be worn in occupational exposure situations. The type and characteristics will depend upon the task and degree of exposure anticipated.
  • If blood or other potentially infectious materials penetrate a garment(s), the garment(s) shall be removed immediately or as soon as possible.
  • All personal protective equipment shall be removed prior to leaving the work area.
  • When personal protective equipment is removed it shall be placed in an appropriately designated area or container for storage, washing, decontamination, or disposal.

Protective Equipment by Job Classification

St. Bernard’s School has determined, in the “EXPOSURE DETERMINATION” section of this plan, that custodians, school nurse, secretaries, bus drivers, coaches, assistant coaches, trainers, physical education instructors, biology staff (when blood-typing), paraprofessionals, playground supervisors, laundry personnel, and specific instructors (art/industrial arts/special education) have been classified as having a potential exposure to blood or potentially infectious materials in our work place. Therefore, as a matter of policy, the school district shall provide and make available the following: Personal Protective Equipment:

  1. Gloves
  2. Gowns
  3. Lab Coats
  4. Face Shields (masks, eye protection, mouthpieces, etc.)
  5. Absorbent Toweling
  6. Antiseptic Towelettes
  7. Spray Disinfectant
  8. Container, bag within first barrier bag
  9. Secondary container, bag with color-coded markings
  10. Prepackaged Body Fluid Clean-Up Kits
  11. Prefabricated, commercially available Sharps Containers

Affected employees shall determine the extent of necessary Personal Protective Equipment on a case-by-case basis; however, it is a matter of policy for the school district to ensure that affected employees use the appropriate Personal Protective Equipment. Employee Training will assist in augmenting this policy.

Housekeeping

  • The work area shall be maintained in a clean and sanitary condition. Written schedules for cleaning and method of decontamination based upon the location within the facility, type of surface to be cleaned, type of soil present, and tasks or procedures being performed in the area will be implemented.
  • All equipment and environmental and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials.

A. Contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface may have been contaminated since the last cleaning.

B. Protective coverings, such as plastic wrap, aluminum foil, or imperviously-backed absorbent paper used to cover equipment and environmental surfaces, shall be removed and replaced as soon as feasible when they become overtly contaminated or at the end of the work shift if they may have become contaminated during the shift.

C. All bins, pails, cans, and similar receptacles intended for reuse which have a reasonable likelihood for becoming contaminated with blood or other potentially infectious materials shall be inspected and decontaminated on a regularly scheduled basis and cleaned and decontaminated immediately or as soon as feasible upon visible contaminated.

D. Broken glassware, which may be contaminated, shall not be picked up directly with the hands. It shall be cleaned up using mechanical means such as a brush and dustpan, tongs, or forceps.

E. Reusable sharps that are contaminated with blood or other potentially infectious materials shall not be stored or processed in a manner that requires employees to reach by hand into the containers where these sharps have been placed.

  • Regulated Waste

A. Contaminated Sharps Discarding and Containment

  • Contaminated sharps shall be discarded immediately or as soon as feasible in containers that are:
    • Collapsible,
    • Puncture resistant,
    • Leak proof on sides and bottom, and
    • Labeled or color-coded.
  1. During use, containers for contaminated sharps shall be:
  • Easily accessible to personnel and located as close as is feasible to the immediate area where sharps are used or can be reasonably anticipated to be found (e.g., laundries),
  • Maintained upright throughout use, and
  • Replaced routinely and not allowed to overfill.
  1. When moving containers or contaminated sharps from the area of use, the containers shall be:
  • Closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping; and
  • Placed in a secondary container if leakage is possible. The second container shall be:
    • Collapsible;
    • Constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping; and
    •  Labeled or color-coded.
  1. Reusable containers shall not be opened, emptied, or cleaned manually or in any other manner that would expose employees to the risk of percutaneous injury.

B. Other Regulated Waste Containment

  • Regulated Waste shall be placed in containers that are:
    • Collapsible;
    • Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping;
    • Labeled or color-coded; and
    • Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.
  1. Contaminated laundry shall be placed and transported in bags or containers labeled or color-coded. When a facility utilizes Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.
    • Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through of or leakage from the bag or container, the laundry shall be placed and transported in bags or containers that prevent soak-through and/or leakage of fluids to the exterior.
    • The employer shall ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.
    • When a facility ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in bags or containers which are labeled or color-coded.

Hepatitis B Vaccination/Post-exposure Evaluation and Follow-up

  • The Hepatitis B vaccine and vaccination series will be made available to all employees who have had occupational exposure, and post-exposure evaluation and follow-up will be made available to all employees who have had an exposure incident.
  • All medical evaluations and procedures including the Hepatitis B vaccine and vaccination series and post-exposure evaluation follow up, including prophylactics, will be:

—    Made available at no cost to the employee,

—    Made available to the employee at a reasonable time and place,

—    Performed by or under the supervision of a licensed physician or by or under the supervision of another licensed healthcare professional,

—    Provided according to recommendations of the U.S. Public Health Service current at the time these evaluations and procedures take place, and

—    Conducted by an accredited laboratory at no cost to the employee.

Hepatitis B Vaccination

  • Hepatitis B vaccination will be made available after the employee has received the training required.
  • Participation in a pre-screening program is not a prerequisite for receiving Hepatitis B vaccination.
  • If the employee initially declines Hepatitis B vaccination but at a later date, while still covered under the standard, decides to accept, it will be made available.
  • Employees who decline to accept Hepatitis B vaccination offered by the employer will sign a statement of such intent.
  • If the U.S. Public Health Service recommends a routine booster dose(s) of Hepatitis B vaccine at a future date, such booster dose(s) will be made available.

Post-exposure Evaluation and Follow-up

  • Following a report of an exposure incident, the employer will make immediately available to the exposed employee a confidential medical evaluation and follow-up to include at a minimum the following elements:

A. Documentation of the route(s) of exposure, and the circumstances under which the exposure incident occurred;

B. Identification and documentation of the source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law;

  1. The source individual’s blood shall be tested as soon as feasible and after consent is obtained in order to determine HBV and HIV infectivity. If consent is not obtained, the employer shall establish that legally required consent cannot be obtained. When law does not require the source individual’s consent, the source individual’s blood, if available, shall be tested and the results documented.
  2. When the source individual is already known to be infected with HBV or HIV, testing for the source individual’s known HBV or HIV status need not be repeated.
  1. Results of the source individual’s testing shall be made available to the exposed employee, and the employee will be informed of applicable laws and regulations concerning disclosure of the identify and infectious status of the source individual.

C. Collection and testing of blood for HBV and HIV serological status;

  1. The exposed employee’s blood shall be collected as soon as feasible and tested after consent is obtained.
  2. If the employee consents to baseline blood collection, but does not give consent at the time for HIV serologic testing, the sample shall be preserved for at least 90 days. If, within 90 days of the exposure incident, the employee elects to have the baseline sample tested, such testing shall be done as soon as possible.

D. Post-exposure prophylaxis, when medically indicated, as recommended by the U.S. Public Health Service;

E. Counseling; and

F. Evaluation of reported illness.

Information provided to the Healthcare Professional

  • The employer will ensure that the healthcare professional responsible for the employee’s Hepatitis B vaccination is provided a copy of this regulation.
  • The employer shall ensure that the healthcare professional evaluating an employee after an exposure incident is provided the following information:
    • A copy of this regulation;
    • A description of the exposed employee’s duties as they relate to the exposure incident;
    • Documentation of the route(s) of exposure and circumstances under which exposure occurred;
    • Results of the source individual’s blood testing, if available, and;
    • All medical records relevant to the appropriate treatment of the employee, including vaccination status, which are the employer’s responsibility to maintain.

Healthcare Professional’s Written Opinion

  • The employer will obtain and provide the employee with a copy of the evaluating healthcare professional’s written opinion within 15 days of the completion of the evaluation.
    • The healthcare professional’s written opinion for Hepatitis B vaccination shall be limited to whether Hepatitis B vaccination is indicated for an employee, and if the employee has received such vaccination.
    • The healthcare professional’s written opinion for post-exposure evaluation and follow-up shall be limited to the following information:
  1. That the employee has been informed of the results of the evaluation
  2. That the employee has been told about any medical condition resulting from the exposure to blood or other potentially infectious materials which require further evaluation or treatment. All other findings or diagnoses shall remain confidential and shall not be included in the written report.

Medical Recordkeeping

  • Medical records required by this standard shall be maintained.

Information and Training

  • Training shall be provided as follows:
    • At the time of initial assignment to tasks where occupational exposure may take place,
    • Within 90 days after the effective date of the standard, and
    • At least annually thereafter.
  • For employees who have received training on bloodborne pathogens in the year preceding the effective date of the standard, only training with respect to the provisions of the standard which were not included need be provided.
  • Annual training for all employees shall be provided within one year of their previous training.
  • Employers shall provide additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee’s occupational exposure. The additional training may be limited to addressing the new exposures created.
  • Material appropriate in content and vocabulary to educational level, literacy, and language of employees shall be used.
  • The training program will contain at a minimum the following elements:
    • An accessible copy of the regulatory text of this standard and an explanation of its contents;
    • A general explanation of the epidemiology and symptoms of bloodborne diseases;
    • An explanation of the modes of transmission of bloodborne pathogens;
    • An explanation of the employer’s exposure control plan and the means by which the employee can obtain a copy of the written plan;
    • An explanation of the appropriate methods for recognizing tasks and other potentially infectious materials;
    • An explanation of the use and limitations of methods that will prevent or reduce exposure including appropriate engineering controls, work practices, and personal protective equipment;
    • Information on the types, proper uses, location, removal, handling, documentation, and disposal of personal protective equipment;
    • An explanation of the basis for selection of personal protective equipment;
    • Information on the Hepatitis B vaccination, including information on its efficacy, safety method of administration, and the benefits of being vaccinated and vaccination will be offered free of charge;
    • Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials;
    • An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available;
    • Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident;
    • An explanation of the signs and labels and/or color-coding; and
    • An opportunity for interactive questions and answers with the person conducting the training session.

Record Keeping

Medical Records

  • An accurate record will be maintained and established.
  • This record shall include:
    • The name and social security number of the employee;
    • A copy of the employee’s Hepatitis B vaccination status including the dates of all the employee’s Hepatitis B vaccinations and any medical records relative to the employee’s ability to receive vaccination;
    • A copy of all results of examinations, medical testing, and follow-up procedures;
    • The employer’s copy of the healthcare professional’s written opinion; and
    • A copy of the information provided to the healthcare professional;
  • Medical records will be:
    • Kept confidential, and
    • Not be disclosed or reported without the employee’s express written consent to any person within or outside the workplace except as required by this section or as may be required by law.
  • The employer will maintain the records required for at least the duration of employment plus 30 years.

Training Records

  • Training records shall include the following information:
    • The dates of training sessions,
    • The contents or a summary of the training sessions,
    • The names and qualifications of persons conducting the training, and
    • The names and job titles of all persons attending the training sessions.

Availability

  • All records required to be maintained by this section shall be made available upon request to the Assistant Secretary and the Director for examination and copying.
  • Employee training records required by this paragraph will be provided upon request for examination and copying to the subject employee, to anyone having written consent of the subject employee, to the Director, and to the Administrative Secretary.
  • Employee medical records required by this paragraph will be provided upon request for examination and copying to the subject employee, to anyone having written consent of the subject employee, to the Director, and to the Administrative Secretary.

Transfer of Records

  • The employer shall comply with the requirements involving transfer of records set forth in 29 CFR 1910.20(b).
  • If the employee ceases to do business and there is no successor employer to receive and retain the records for the prescribed period, the employer shall notify the Director at least three months prior to their disposal and transmit the records to the Director, if required by the Director to do so, within the three-month period.

Employer’s Audit

  • An annual review of the Control Plan will be conducted.

Hepatitis B Vaccination Declination Form

I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection.

I have been given the opportunity to be vaccinated with hepatitis B vaccine at no charge to myself.

However, I decline hepatitis B vaccine at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease.

If in the future I continue to have occupational exposure to blood and/or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I may receive the vaccination series at no charge to me.

Please Print:

Name_____________________________________ Date of Birth________________

Social Security or Visa #_______________________ Employee #_________________

Department and Lab room #_______________________________________________

 

Principal Investigator____________________________________________________

Signature__________________________________ Date______________________

 

Contact «Bloodborne» if you have questions filling out this form

St. Bernards Bleacher Safety Plan

PLAN REVIEW
Reviewer Date
 Brian Parrie  4/23/2015
   
   
   
   

Contact: Randy Schantz

Bleacher Safety                    

PURPOSE

Recently, lawmakers from Minnesota asked the Consumer Products Safety Commission to issue guidelines to establish bleacher safety standards.  These guidelines would set the standards that companies would have to meet regarding the production, erection, and retrofitting of bleacher facilities, as well as inspection checklists to be sure that the bleachers are structurally sound.  Effective January 1, 2002, all bleachers will have to conform to the Uniform Building Code proposed in 2000.

GOALS OF PLAN

  1. Reduce/Eliminate accidents on school bleacher facilities.
  2. Increase/Maintain the protection of the individuals using the facility.
  3. Provide checklists and training for staff to perform regular bleacher safety inspections.
  4. Maintain appropriate documentation of training, inspections, and accidents that may occur regarding the use of the bleacher facility.

POLICY

It is the goal of the district to provide and maintain safe bleacher facilities for the public.  In order to meet this goal, the district has developed standard operating procedures to help maintain their facilities and protect the users.  These procedures will not necessarily eliminate all accidents and injuries, but it will make all attempts to reduce the possibility of them occurring.  District personnel will follow the following guidelines:

  1. Manufacturers specifications shall be followed when installing bleachers.
  2. Retrofitting bleachers will be done to meet the UBC guidelines for bleachers set forth in 2000.
  3. Trained employees will do all inspections, repairs, maintenance, and documentation.  These will all be done in accordance with current standards set forth by the C.P.S.C. and the U.B.C.
  4. Any accidents/injuries will be recorded.

TRAINING

To ensure proper and consistent inspections and maintenance are done, specific school personnel will be trained and understand the current guidelines regarding properly maintained bleacher facilities.  Properly trained school personnel and/or professionals will handle any issues regarding the repairing or erection of a whole/part of the bleacher system.  Any handling of the bleacher facility will be documented by the school district and kept on file in the BLEACHER SAFETY PLAN.

ACCIDENTS/INJURIES

The purpose of the Bleacher Safety Management Plan is to reduce/eliminate accidents and injuries and provides a safe bleacher facility.  When accidents or injuries occur, the school district sees that it is important to document the accident or injury and to take corrective measures if necessary.  All accidents/injury reports will be kept in the BLEACHER SAFETY PLAN.

AUDITS/INSPECTIONS

Audits and inspections are a vital part of the Bleacher Safety Management Plan.  In order to reduce/eliminate accidents and injuries, the district must thoroughly inspect the bleacher facilities based on UBC and CPSC guidelines and requirements.

  1. The safety audit is a one-time initial inspection to perform an in depth analysis of the entire bleacher facility.  It helps to recognize the need for repair, removal, or retrofitting of the bleacher system to meet the standards set forth by the Uniform Building Code (UBC), and the Consumer Product Safety Commission (CPSC).
  2. The safety inspections are routine inspections to be sure that the bleachers are maintained properly to provide maximum safety for its users.  A detailed checklist will be used for these inspections, and trained school personnel will keep documentation.

***  All audit and inspection forms will be kept in the BLEACHER SAFETY file or in the CUSTODIAL MANUAL.