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Environmental Health and Safety


Author(s): Ralph Allen - University of Virginia

This chapter is current as of May 17, 2017

Risk Control in Facilities Management


Facilities managers traditionally have been concerned with the fundamental operational factors of performance-cost and schedule. Risk is usually thought of as the opposite of benefit. Most managers want to be perceived as providing a benefit to their organizations and do not want to be thought of as risk managers. Yet it has become increasingly clear that managers who ignore risk, overly delegate its management, or handle it in a haphazard manner eventually experience problems. There is also increasing recognition that employee attitudes and perceptions about managers are based partially on their manager's approach to risk management. If employees are unhappy, then a health or safety issue can become a convenient means to gain a sympathetic audience and a platform from which managers and organizations can be criticized. This criticism may lead to investigations by regulatory agencies and eventually litigation. Another important factor that forces managers to foresee and manage risks is that it is considerably more expensive to remedy a problem than to do the job correctly the first time.

It is instructive to consider why managers have ignored or delegated the management of risk rather than placing it on a par with managing benefits. In his book Managing Risk: Systematic Loss Prevention for Executives, Vernon Grose suggested three reasons.1First, managers are generally positive thinkers; they may avoid thinking about what could go wrong. Second, managers may reason that as long as they have enough success, the problems might be ignored, cleaned up after the fact, or perhaps blamed on others. Finally managers may see their enterprises as an extension of themselves, and they manage risk just as they do in their personal lives. In our personal lives, we often trade risks without really considering them. A simple example might be speeding up to get through a yellow traffic light before it turns red. Time is too short to do the physics (time x speed = distance) or to weigh the cost versus benefits (probability of injury and additional insurance costs versus a few minutes of time).

Although people have the capacity to process, store, and analyze a great deal of information, it is impossible to carefully consider every risk situation in an increasingly complex environment. As a result of this information overload, humans have developed some shortcuts. People learn to categorize things, either by trial and error or through formal instruction, as, for example, "safe" or "unsafe" or "good" or "bad." Once something is categorized as safe, people no longer think about it, but proceed as though it were safe. Even jobs that some might consider unsafe become safe and commonplace for those who have performed the job successfully many times. In addition, people take many risks for recreation and participate in risky activities, such as skiing, hunting, and swimming, but are loath to accept risks that are beyond their control, such as toxic wastes in landfills and suspected carcinogens in food. These attitudes are inherent problems that managers face in adjusting personal, as well as employee, risk behaviors.

Risk Awareness for Better Management

Safety does not just happen; it must be cultivated by management. Managers and their employees need to communicate and work together if risks are to be managed effectively.

If a manager has little regard for an employee's health and well-being, then there is little motivation for the employee to satisfy the manager's desire to accomplish a goal with speed and efficiency. The attitudes of managers and supervisors toward their employees' personal safety have a great deal to do with the morale of those employees. Management studies and common sense suggest that prevention of serious problems costs less than cleaning up after an accident, particularly one that leads to regulatory enforcement and negative publicity.

Because resources within an organization are limited, managers must have a way to choose among many demands and priorities. A systematic approach to risk management therefore must include some means of ranking risks. Each manager must adopt a rational approach that fits his or her personality; this approach can range from ranking risk intuitively, to utilizing common sense and experience, to following a systematic mathematical approach of systems engineering. Managers generally have the most holistic view of an operation and can best consider most of the risks involved. In many cases, managers will have historical information, such as past loss reports and accident investigations. Some useful information also can be gained by asking "what if" questions to anticipate possible problems. Employee perceptions of on-the-job dangers also can be helpful and always should be investigated. Managers should engage in open, collaborative trading of risks. Planning and considering risks in an open manner allows employees to buy into a process by which limited resources can be used effectively to control the risks. In some cases, the mere act of openly discussing a risk can do a great deal to eliminate the problem by making employees more attentive.

Legal Reasons to Manage Risks

Many people argue about the proper or acceptable role of government in protecting an individual's own health and safety at the expense of personal liberty. Supreme Court Justice Stephen Breyer, in his essay on government regulation, "Breaking the Vicious Circle: Toward Effective Risk Regulation," points out that because anyone might be harmed by anything, it is not possible to regulate all of the risks that fill the world.2 This is not to say, however, that a lawyer might not attempt to litigate over an uncontrolled risk. For managers, the primary issue is negligence. An act may be interpreted as negligent, even if the risk was not understood, if there is some possible causal relationship between the act and an incident that resulted in damage or injury.

Because regulations provide a defined standard of conduct, behavior, or expectations, failure to meet these standards not only will make a manager negligent if an accident occurs, but also will be a violation even if no accident occurs. It is difficult to understand and comply with regulations. However, the consequences of ignoring regulations can be severe in both real costs (i.e., fines and liability awards) and in terms of the image of the institution.

Two major regulatory programs pertain to the safety of employees while on the job. The older of the two programs began with the 1902 Workers' Compensation Act and guarantees employees compensation for on-the-job injuries, including those from chronic exposures to hazardous materials, regardless of fault. The second major body of regulations began with the 1970 Occupational Safety and Health Act, which established minimum standards of safe working conditions for all employees. Initially the emphasis in safety was on compliance with the specific Occupational Safety and Health Administration (OSHA) regulations, but the recent trend has been to look more toward the overall effectiveness of the safety program, with an emphasis on educating employees about job safety. Numerous environmental regulations are aimed at protecting the environment. These regulations are discussed later in this chapter.

Most safety regulations start out as federal initiatives brought about by public pressure or lobbying groups, such as labor unions and environmental coalitions. After a law is enacted, one or more regulatory agencies must write, publicize, and implement detailed regulations, which are the agencies' interpretations of the law's intent. Although applicable to colleges and universities, new regulations often are written in broad terms for industry rather than for the facilities operations of a college or university. The applicability of some regulations depends on the size of the institution.

Once a federal agency finalizes a set of regulations, individual states may agree to implement federal programs using their own agencies. The state is required to establish regulations that are at least as stringent as those of the federal program. State regulators may, and often do, adopt more demanding regulations.

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Establishing Safety Programs for Facilities Management


Understanding Risk and Perception

Managers must develop a plan for their particular circumstances, but the following observations on risk, perception, and human behavior may help any manager analyze and handle risks that are within his or her control.

For some activities, risks are inherent or constant. Working with high-energy sources such as electricity, dealing with dangerous or highly toxic materials, or working in tenuous positions (e.g., high above ground or in confined spaces) are all cases in which risks are inherent and serious. The potential consequences in these situations are severe. These risks are perhaps the easiest for safety programs to address, in part because specific OSHA regulations often pertain to these activities. Other situations carrying inherent risks, such as ice on sidewalks, do not necessarily have severe consequences, but a little forethought can identify them even if they are unavoidable.

A constant factor that managers can anticipate as a cause for increased risk is change. Risk increases whenever a new procedure, tool, or product is used. Usually the risks are not known when something is new. This becomes an even more complex problem when something old and familiar changes to something new and unknown. Although change increases the chances of problems, a manager should realize that risk is always present when people do not know or are not aware of the potential problems. "Design safety margins" can be incorporated to compensate for ignorance, but it is better to create awareness and provide knowledge about avoiding problems. Managers who try to build a safety system based on strict guidelines are destined to fail. Thus, an important part of a complete risk program is to provide solid information and to challenge people to think about their risk activities. In several of the recent key OSHA regulations, the elimination of ignorance by means of specific training has been critical to controlling risk. Incidentally, training records are easy for regulators to inspect, and failure to provide the training is interpreted as an "intentional violation" of the regulation. Although training can address ignorance in some cases, it cannot eliminate uncertainty. In many cases, the information simply is not available or clear.

When considering the perceived risks of less familiar materials and the real risks associated with ignorance, remember that familiarity also can affect risks. For most people, the complex mathematical estimates and descriptions of risk have much less impact than firsthand experience. It follows that when someone has been doing a job or working with a particular material for years without any adverse consequences, it is hard for that person to imagine that it is anything but safe.

In addition to risks and problems that can be recognized easily, some conditions occur without a predictable pattern. These apparently unpredictable situations, or those beyond our control, are often called dynamic risks. Although managers may not be able to prevent the occurrence of dynamic risks, anticipation can reduce the consequences. If managers develop a work environment and culture in which employees are encouraged to think through a job and decide what might go wrong, significant awareness and benefit will occur. Getting input from employees helps focus their creativity in positive ways, and helps everyone succeed in reducing risks.

Following are ways that a manager and staff can identify, evaluate, and control risk:

  • Learn from your own experiences: Accident investigations should focus on the problems and processes, not who was responsible.
  • Learn from the experience of others: Statistics show common combinations of actions or situations that have higher probabilities of leading to serious consequences.
  • Use expert advice and become familiar with government regulations as strategies to help identify risks.
  • Find effective ways to encourage employees to express concerns and to train supervisors in foreseeing problems.
  • Perform work site evaluations and inspections.
  • Identify risks before an accident by developing scenarios of what might happen. This is sometimes called a job safety evaluation, and it need not be complex or difficult.

Effective Risk Management Programs

Many ideas can be discovered by looking at safety programs that have been effective. The first and most important factor is the participation of the people who are being protected. Everyone needs to be involved in risk evaluation and management, but supervisors are the most important employees for establishing and maintaining effective safety programs. First-line supervisors have some management responsibilities, and they are closest to the workforce and to the problems workers face. Upper-level managers are important because they establish the institutional priority to support the training of first-line supervisors. Managers must provide positive reinforcement for good supervisors as well as the resources necessary for their employees to carry out their work successfully and safely. Each manager must be clearly charged with carrying out programs in a safe and legal manner. If an individual is designated as the safety director, he or she should serve as a resource or a coach to assist these managers and should not be the entire safety program.

Beyond the human resource component, the most important factor in an effective safety program is communication. Safety committees can provide effective means of creating and enhancing communication. In many institutions, safety committees have not been used effectively and have gained a poor reputation. Rather than dwelling on the negative aspects that often discourage employees from taking an active role in a meaningful safety program, it is more useful to concentrate on the positive communication that can result. If management truly embraces two-way communication with staff, then managers should not strictly control the safety committee. Setting convenient meeting times and places, enabling staff to establish or at least help set the agenda, and encouraging two-way communication send a positive message to the staff. Safety committee meetings should be short and held frequently, and should have a varied agenda. Committees should include first-line supervisors and their staff. In some cases, the makeup, agenda, and implementation processes may be governed by union contracts or National Labor Relations Board rulings. When employees raise a safety issue, management should be responsive and explain the reason for its decisions. Rather than giving directives, management can use the committee to establish procedures and programs to deal with employee concerns. A shared vision that accounts for staff concerns and accomplishes organizational goals is easier to implement and benefits the entire organization.

Another important function of safety committees is to establish or suggest training requirements. Employee training should be provided in small doses on a variety of topics. Initially, management may want to develop an agenda of some topics and bring in presenters or videotapes. With encouragement, committee members can suggest topics and even be asked to make short presentations about issues in their areas. Accident investigations can be discussed to help develop training materials and identify areas where training is necessary. Accidents, as well as recommendations from accident reports, should be analyzed and discussed by the safety committee. The committee should discuss and evaluate possible changes in procedures, policies, or equipment to avoid repetition of accidents. Another area of training focus for committee members might include hints on how to inspect and evaluate risks in their own work areas, how to investigate accidents more thoroughly, and how to transmit what they have learned to their staff. It is clear that safety committee members can benefit from participation and can share their experience and knowledge with others. Rotation of membership is one way to spread participation to more of the staff. Evaluation of supervisors should reward good communication and concern for the safety of their staff. This includes active participation in safety committee activities.

The following lists summarize some of the organizational factors that have had positive and negative impacts on accident frequency and severity in a variety of settings:

Positive Impacts
  • Management commitment to safety
  • Proper tools, equipment, and work environment
  • Sustained safety training programs
  • Continued accident investigation with corrective follow-up
  • Monitoring hazardous behavior and accident-prone employees
  • Temporary accommodation of injured employees in light-duty capacities
  • Open communication lines between supervisors or management and employees
  • Enforcement of and compliance with state and federal regulations and standards
Negative Impacts
  • Lack of sincere management commitment
  • Broken or inadequate tools and equipment
  • Hazardous work environment (e.g., unkempt and old buildings)
  • Organization restructuring and financial restraints
  • No safety training
  • No accident investigation
  • No light-work accommodation
  • Negative supervisory attitudes
  • Noncompliance with or lack of enforcement of regulations
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Health and Safety Programs for Facilities Management Organizations


The demands of regulatory agencies do not always correspond to controlling the most serious risks for facilities managers. In some cases, however, when a health and safety program is mandated, the consequences of noncompliance can become greater. Experienced managers make themselves aware of regulatory requirements and allocate the resources necessary to develop compliant programs. It is important for upper-level managers to be aware of regulations and to know how they affect an institution. For example, in the United States, to know how Environmental Protection Agency (EPA) regulations on hazardous waste affect an institution, it is necessary to understand and use the EPA's definitions to determine how much waste the entire institution generates. Institutions should understand that regulatory agencies will take enforcement actions that single out managers who "should have known" but failed to implement mandated programs. These actions can be quite costly to an institution and to the individual, through personal civil lawsuits. Citation of violations can foster negative publicity, even when those who caused the violation are only contractors working for an institution. Finally, most regulatory violations are not discovered through normal agency inspections but rather through accidents or complaints received from employees or the community. When agency inspections do occur, much of the emphasis is on following a paper trail. Written procedures, documented programs, and training records become important. Although written material is critical during an inspection, a manager's goal should be to have a program that is effective in meeting the spirit of the regulations. If overall programs are effective, the possibility that an incident or complaint will set off the inspection process can be minimized. Again, the most effective method of risk control is to develop a workforce that is risk knowledgeable. Implementing good training programs remains the most useful tool for enhancing the overall safety of employees.

Regulatory Programs Emphasizing Training

In the United States, many regulatory programs emphasize training. Other countries have similar requirements. The list of regulations for U.S. colleges and universities (see figure 1) generally is derived from the Code of Federal Regulations (CFR), although state and local regulations often implement these federal mandates. Other parts of the CFR deal with training; however, the section with the most training requirements applicable to facilities operations is CFR 29, which is the basis for OSHA regulations. Figure 1 provides a brief description of the general content and circumstances or type of people who need training. This training can be implemented in a variety of ways, but it should be relevant to each institution's circumstances and should be documented. Figure 2 includes activities for which specific types of equipment may be installed, inspected, or used within the scope of facilities.

Figure 1. Mandatory Training for Selected Personnel

Title/Standard Number Description
1. Employee Fire Prevention and Emergency Plans
29 CFR 1910.38 (a)(5) and (b)(4)
A basic course on fire safety is required for all employees. A fire plan must be developed (required elements described by OSHA) and training must conform to these elements.
2. Portable Fire Extinguishers
29 CFR 1910.157G
If portable fire extinguishers are available, the building occupants must be trained in their use. Training should include flight-or-fight decision making and selection and use of extinguishers.
3. Occupational Health-Hearing Protection
29 CFR 1910.95(K)(1)-(3)
OSHA has established a permissible exposure limit of 90 dB and requires a hearing conservation program if noise levels for an eight-hour shift exceed 85 dB. If high noise levels are indicated and engineering controls cannot effectively attenuate the noise, then hearing protectors are required as well as training on the correct use of hearing protectors and participation in the hearing conservation program. Training is recommended for personnel assigned to repetitive work tasks generating high noise levels (i.e., generators, power tool operators, boiler operators).
4. Occupational Health—Ionizing Radiation
29 CFR 1910.97
Anyone working with or near radiation producing equipment or materials requires, at a minimum, some awareness training. Risks of radiation exposures and regulatory and administrative procedures should be covered.
5. Personal Protective Equipment
29 CFR 1910.132(f)
Training should include an overview of OSHA Personal Protective Equipment (PPE) Standard, including initial work environment hazards assessment with supervisor to determine PPE requirements. Type of PPE required and proper use and care of PPE must be covered for specific work duties.
6. Respiratory Protection
29 CFR 1910.134 (b)(3)
If respirators are available or used, managers need an overview of the OSHA Respiratory Protection Standard and elements of implementing a respirator program. Initial assessments of the work environment will determine if respirators are needed. Respirators may be required if engineering controls (i.e., fume hoods or other local exhaust ventilation) cannot be used to control potentially hazardous airborne contaminants. Qualitative fit testing and medical approval are required on initial assignment of respirators and annually thereafter for personnel assigned to wear negative-pressure air purifying respirators.
7. Lockout/Tagout Program
29 CFR 1910.147
Managers need an overview of the OSHA Lockout/Tagout Standard (LOTO). All personnel responsible for machinery and equipment shutdown for maintenance and service must be trained to understand and apply LOTO to control hazardous energy sources during machinery and equipment maintenance and service. In addition, OSHA requires training on standard operating procedures (SOPs) to perform LOTO. This training must be provided by department supervisory management familiar with applicable SOPs for all affected personnel. This includes personnel who must shut equipment down, as well as personnel who may be working on the equipment and will be affected by the shutdown.
8a. Asbestos Awareness
29 CFR 1910.1001
All facilities employees must be given a general awareness of asbestos containing materials (ACM), including history, health effects, use, recognition of damaged ACM, and description of the asbestos management plan and policy.
8b. Asbestos Task Force
29 CFR 1910.1001
Personnel required to work in asbestos "restricted access" areas should be instructed on proper use of PPE and procedures for safely working in asbestos-contaminated worksites.
8c. Asbestos Operations and Maintenance
29 CFR 1910.1001
Personnel who will repair/maintain or remove <10 ft. of ACM must take an Environmental Information Association certification course that presents all general awareness information as well as ACM repair/maintenance, small-scale abatement procedures, use of PPE, and respirator fit testing. This is a 16-hour course.
8d. Asbestos Abatement Workers
29 CFR 1926.1101
An Environmental Information Association certification course is required for all asbestos abatement workers. Covers all information in the awareness and operations and maintenance courses and presents one day of hands-on training in work site enclosure, decontamination unit, and negative air systems construction. This is a 24-hour course.
8e. Asbestos Abatement in "Your" Building
29 CFR 1910.1001
29 CFR 1926.58
Building occupants subject to future ACM abatement often develop a concern about activities associated with these projects. Although not required, an awareness course helps describe asbestos abatement procedures in layperson's terms for building occupants. The course discusses daily project inspection and air monitoring procedures.
9. Lead-based Paint and Lead Awareness Training
29 CFR 1910.1025
29 CFR 1926.62
Renovations/painting crew workers, supervisors, and superintendents need a general awareness of lead-containing products including lead-based paint (LBP) history, health effects, uses, university policies, personal hygiene, and removal procedures.
10. Hazard Communication Standard
29 CFR 1910.1200
Under the Hazard Communication Standard, all employees exposed to chemicals and chemical products must be informed about the potential hazards associated with chemical use. Training covers proper labeling, material safety data sheets, emergency procedures, and a description of the written program adopted by the institution.

11. Chemical Hygiene Plan—
Hazardous Chemicals in Laboratories
29 CFR 1910.1450
All laboratory employees using hazardous chemicals must receive training designed to reduce occupational exposures to hazardous chemicals in laboratories. Training covers first aid and emergency procedures in the laboratory, safe chemical storage, ways to clean chemical spills, hazardous waste management, and ways to report possible exposure. The written plan must include the way the institution will investigate exposures and provide medical monitoring.
12. Formaldehyde Employee Information and Training
29 CFR 1910.1048
Formaldehyde is frequently encountered in the workplace by laboratory workers, medical students, and research professionals. A comprehensive review of its toxic properties, monitoring requirements, and safe work practices are required by regulation
13. Confined Space
29 CFR 1910.146
This is mandatory for personnel who enter confined spaces, including supervisors responsible for entries into permit and non-permit-required confined spaces
(e.g., heating plant and utilities personnel).
14.Overview of Excavation
29 CFR 1926.650
Standard defines a competent person who understands these performance-based standards (vs. task-based), which apply when workers must be protected (when excavations are greater than 5 ft. in depth). Factors such as shoring procedures, emergency plans, inspections, etc., can be learned from written material or by training course.
15. Bloodborne Pathogens
29 CFR 1919.1030
Initial and annual training is required for all departmental personnel who may become exposed to blood-borne diseases in their routine work. The institution must devise a procedure to determine which employees may be exposed and offer them hepatitis vaccinations. Training should cover material required by OSHA Occupational Exposure to Bloodborne Pathogens and Draft Guidelines for Preventing the Transmission of Tuberculosis in Healthcare Facilities.

In each case, the regulation or the American National Standards Institute (ANSI) standard that is recommended also includes an element of training. The content of the training is not spelled out, as it is for those standards that apply to general programs. In most cases, it is reasonable to expect that individuals using such equipment be knowledgeable about the safe operation of the equipment. In addition to mandated training, in some cases, training is not yet a federal mandate, but the movement is toward developing such programs. Several of these areas are noted in figure 2.

Figure 2. Equipment for Which Training Is Mandated

Title/Standard Number Description
Fixed Extinguishing Systems
29 CFR 1910.160(b)(10)
Self-explanatory
Fire Detection Systems
29 CFR 1910.164(c)(4)
Self-explanatory
Operations—Powered Platforms
(Type F and Type T for Exterior Building Maintenance)
29 CFR 1910.66
Self-explanatory
Operations—Aerial Devices
29 CFR 1910.67
Self-explanatory
Operations—Fall Arrest Systems
29 CFR 1910.66, 29 CFR 1910.67
Self-explanatory
Servicing Rim Wheels
29 CFR 1910.177
Self-explanatory
Powered Industrial Trucks
29 CFR 1910.178
ANSI B56.1-1988 High Lift Low Lift Trucks
Power Actuated Tools
29 CFR 1910.243(d)
ANSI A10.3-1985 Safety Requirements for Power Actuated Fastening Systems
Training for the following must cover safe operation procedures and equipment inspections for equipment integrity and equipment safety:  
Machine Guarding
29 CFR 1910.212
Self-explanatory
Woodworking Machinery
29 CFR 1910.213
ANSI 01.1-1992 Safety Requirements for Woodworking Machinery
Abrasive Wheel Machinery
29 CFR 1910.215
ANSI B7.7-1990 Safety Requirements for Abrading Materials with Coated Abrasive Systems ANSI 7.1-1988 The Use, Care, and Protection of Abrasive Wheels
Electrical Safety-Related Work Practices
29 CFR 1910.331-335
ANSI/NFPA 70-1993 National Electrical Code; ANSI C2-1993 National Electrical Safety Code
Oxygen-Fuel Gas Welding and Cutting
29 CFR 1910.252(a)(4)
American Welding Society A6.1-1966 Cutting Recommended Safe Practices for Gas Shielded Arc Welding
Arc Welding and Cutting
29 CFR 1910.252(b)(1)(iii)
ANSI Z49.1-1988 Safety in Welding and Cutting
Resistance Welding
29 CFR 1910.252(c)(1 )(iii)
 

OSHA’s Electrical Safety Related Work Practices, 1910.331 through 1910.333, incorporates NFPA (National Fire Protection Association) 70E Standard for Electrical Safety in the Workplace. The relationship between the two organizations, OSHA and NFPA, goes back to 1976 when OSHA enlisted the assistance of a specially appointed technical committee to create a working standard for electrical safety.

The NFPA Standard outlines for the employer and employee how to determine electrical hazard exposures and how to protect the worker(s) who may be exposed to electrical hazards through the course of their work. The NFPA Standard provides the "how to" information for approach boundaries to prevent electrical shock hazards; electrical arc flash protection boundaries to prevent electrical arc exposures; and the requirements for an electrical arc hazard analysis to determine the proper level of electrical protective clothing that will lessen the degree of burn injuries in the event of electrical arc flash fire. Workplaces throughout the United States conscientiously apply NFPA 70E safety guidelines for best work practices in electrical safety.

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Regulation of Hazardous Materials


In the operation of an institution of higher education, a wide range of types and amounts of hazardous materials are utilized. For smaller institutions, the materials generated by the operation of the facilities, such as oils, excess paints, and small amounts of chemicals used in teaching laboratories, are all that need to be considered. For research institutions and medical facilities, however, the problems are much greater and more expensive to solve. Although the following describes some of the materials that are regulated, it is not definitive and does not provide detailed solutions. One general piece of advice is useful for managing all of these regulated materials: Be aware of where these materials are used in your institution, and be sure that they are being managed. Hazardous materials management begins with the purchase and continues while the material is being stored, used, and disposed. In some cases, responsibility does not end even with disposal. Attempts to solve one problem can create others. For example, in some states, the use of fluorescent bulbs to save energy results in hazardous waste disposal costs because the bulbs contain mercury and require collection. All of these factors should be considered and balanced.

OSHA regulates 29 specific chemicals, and exposure limits are established for hundreds more in 29 CFR 1910, subpart Z (Toxic and Hazardous Substances).3 Most facilities personnel do not work with chemicals or products over periods of time that could cause health problems.

Figure 3. Nonmandatory Areas of Training Recommended for Selected Personnel

Consideration Description
Employee safety and Workers' Compensation for supervisors and managers A short overview of the Workers' Compensation law; policies and procedures for claims process should be discussed with supervisors and managers.
Workers' Compensation for all employees The claims process should be described in detail from the time of the accident to final resolution. All rules and regulations are explained in a step-by-step procedure for all employees. This is a good opportunity to create general awareness.
Accident investigation for supervisors and managers Motivational overview of concepts and applications in other industries can aid supervisors and managers in conducting accident investigations.
Heat stress Employees who work in hot environments (and their supervisors) can be provided an overview of the signs, symptoms, and measurement techniques required to prevent detrimental effects of exposure to a hot and humid work environment.
Ventilation for contaminant control New facilities management employees (project managers and designers) can be provided a course designed to familiarize the architecture and engineering staff with pitfalls and frequently encountered design discrepancies submitted by contract architectural and engineering consultants (e.g., recurring flaws and system losses). The eternal philosophical issue of "pay me now or pay me later" should addressed.
Work (back) injury prevention-material handling Maintenance workers, material handlers, and groundskeepers should be given a presentation that includes descriptions of proper methods and realistic approaches to handling and moving materials correctly to prevent injury to back, shoulders, and wrists.
Office ergonomics--"Avoiding the Painful Desk Job" For computer users, this course should emphasize low-budget techniques and tips to assist in creating a user-friendly, ergonomically safe workstation.

Even short-term exposures to materials that are odorous, cause headaches or respiratory distress, or burn the skin can cause great concern on the part of employees and building occupants. Chemical exposures can be limited by ventilation design and operating procedures. For example, many cleaning products, paints, and solvents are likely to irritate building occupants and facilities staff if proper ventilation is not provided. The design of ventilation systems affects energy usage. Efforts to tighten buildings and recirculate air can lead to indoor air-quality problems. Many building materials, including glues, carpets, and other finishes, emit gases over time and create problems in well-sealed buildings. Ventilation must be adequate to avoid mold, mildew, and bacterial contamination, as sensitization to these indoor air problems is being diagnosed with increasing frequency.

The use of chemicals and chemical products requires compliance with the Hazard Communication Standard, 29 CFR 1910.1200.4 Personal protective equipment (PPE), such as gloves and splash-proof safety glasses, must be provided. Materials must be stored appropriately. The material safety data sheets required by the Hazard Communication Standard can identify both storage and PPE requirements and can be obtained from the product manufacturer. They can assist in comparing products to aid in the selection of the safest alternatives. Pesticides are one particular group of chemicals that must be considered carefully. These materials are highly regulated and may require specific licenses for those who are involved in their application. The use of contractors for pesticide application should be carefully controlled and coordinated to avoid problems with building occupants.

Polychlorinated biphenyls (PCBs) are specifically regulated materials that are used commonly as an insulating material in transformers and capacitors. Most of these materials should have been removed from most institutions. When they are encountered, however, PCBs must be monitored and disposed of as hazardous wastes.

Another specific set of regulations requires that all petroleum products stored in underground tanks be monitored to prove that the tanks are not leaking. If tanks have been leaking or begin to leak, then cleanup will be necessary. Old and unused tanks must be removed.

Finally, the presence of some materials can require continuous reporting, particularly if the amounts exceed certain threshold limits. Local emergency planning committees have been established under the Superfund Amendments and Reauthorization Act. It may be necessary to report such materials as swimming pool chlorination systems or ammonia in large refrigeration units to the local emergency planning committee. It is prudent to participate with such planning committees to ensure that plans are integrated to deal with fire or chemical spills at the institution. Requirements under Homeland Security regulations also may pertain to some of these materials.

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Hazardous Waste Regulations


A considerable number of wastes are heavily regulated, and for these wastes, disposal costs are often high. It is false economy to ignore these wastes. Cleanup costs and fines for illegal disposal will far outweigh any normal disposal costs. In some cases, disposal costs can be avoided by choosing other materials or by purchasing smaller quantities. The clearest way to minimize costs, when it is necessary to generate hazardous wastes, is to keep wastes segregated. For example, if lead-based paints are removed from wood by dry methods such as scraping, the volume of waste is lower and the disposal is less complicated than if solvents are utilized. Likewise, if wood trim covered with lead-containing paint is removed and mixed with other demolition wastes, an entire dumpster full of mixed building debris may require disposal as hazardous waste. Mixing cleaning solvents containing halogens (e.g., dichloroethylene) with hydrocarbons (e.g., used oil or alcohol) makes the disposal costs much higher. There are specific requirements for the disposal of any materials contaminated with radioactive nuclides. Handling these materials should be the responsibility of the institution's radiation safety office. In many states, wastes from hospitals, clinics, and some diagnostic or research laboratories (e.g., sharps, infectious waste, and chemotherapy waste) must be disposed of as regulated medical waste. In most cases, disposal requires incineration or some means of sterilization.

Chemical waste disposal is highly regulated, and improper disposal can result in large fines and criminal punishment. EPA definitions of hazardous waste are often surprising to many managers. For example, photographic developing solutions are hazardous because they contain silver. In addition, several characteristics, such as flammability, corrosiveness, reactivity, and toxicity, can delineate wastes as hazardous. Wastes from chemistry laboratories and many other institutional research laboratories must be collected and kept segregated to the greatest extent possible. One of the most expensive sources of hazardous waste is unused and unwanted materials, with disposal costs often exceeding the purchase price. Therefore, it is prudent to avoid purchasing excess quantities. Facilities managers should understand that any material used to clean up petroleum spills is classified as hazardous waste. When petroleum tanks are overfilled, the contaminated soil and anything used to absorb the ignitable petroleum must be disposed of as hazardous waste. It is best practice to promote spill prevention. It is sometimes possible to write contracts that make suppliers responsible for spill cleanups. All tanks require a specific “Spill Prevention, Control and Counter Measures” plan. Waste oils can be recycled, but great care must be used to avoid mixing other cleaning solutions and solvents with these oils. Finally, facilities managers need to recognize that fluorescent light bulbs (when mercury can be leached from them), ballasts (which contain PCBs), and batteries (not dry cell) are hazardous wastes. Fluorescent bulbs have been developed that keep the mercury from leaching out so that they are not hazardous waste, but the EPA still wants them treated as “Universal Wastes” and recycled rather than put into landfills.

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Environmental Regulations on University Activities


In addition to hazardous waste and community right-to-know regulations, the EPA is responsible for clean air and clean water standards, which affect most institutions of higher education. The application of the Clean Water Act varies depending on how much of the water system is operated by the institution. Water supplies must be tested for bacteria and for a number of heavy metals. Even if water is supplied, the plumbing may be a source of lead contamination from solders, of copper contamination from pipes, or of organic contamination from solvents, adhesives, and polyvinyl chloride pipes. Old plumbing systems are particularly susceptible to contamination problems, and it is useful to measure lead concentrations. Wastewater must be monitored in some cases. When water is treated by a municipal or regional facility, some institutions must have discharge permits, as well as required sampling and analysis of the waters going to the treatment facility. When an institution has a radioactive material usage license, the Nuclear Regulatory Commission may require some type of environmental monitoring to prove that radionuclides are not accumulating in water treatment sludge. Underground petroleum storage tanks may pollute underground water and therefore must be evaluated, monitored, and remedied.

Clean air standards apply to a number of university activities. Clearly, operation of a power plant or an incinerator for medical wastes (point sources) requires emission permits and perhaps emission monitoring. Currently, efforts are under way to evaluate the emissions from sources that are not point source. Some states already have requirements to account for the emission of chemicals from facilities. Laboratories attempt to reduce indoor air contamination by using fume hoods, but the chemicals then are dispersed into the air. The federal National Emission Standards for Hazardous Air Pollutants (NESHAP) already have been applied to the emission of radioactive materials. In this case, the amounts utilized in a particular facility determine whether airborne concentrations may be estimated, may be modeled using complex mathematical dispersion models, or may require specific sample collection and analysis. In the future, it may be necessary to evaluate fume hoods for the emission of any of a long list of chemicals. New clean air standards will require reporting of emissions from heating facilities (including small furnaces) and refrigeration units (for chlorofluorocarbons).

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Planning and Maintenance for Facilities


Whenever new facilities are developed or old facilities are remodeled, numerous building and life safety codes must be addressed. Code compliance is a complex problem that is made even more complex by the changes that occur over time. Usually, when the functional or programmatic use of a facility changes or when minimal remodeling occurs, new building codes will apply. Institutions that allow building use to change may find themselves in violation of the appropriate code unless some active evaluation and review process is in place. Several common problems develop at institutions because of limited space and relatively poor central control of space usage. First, hallways and many other locations are used as storage. Generally, this is in violation of fire codes that exist to ensure clear and accessible means of egress in the event of fire. Storage of old paper and other combustible material also can create a major fire risk. A second fire safety issue is the penetration of walls designed to limit the spread of fires. Remodeling, especially installation of telephone and computer network lines around buildings, can compromise fire walls. A program should be in place to train facilities staff, outside contractors, and building occupants about wall penetrations and the need to provide fire stopping (i.e., using proper materials and closing openings with fire-resistant caulks). At the same time, those involved in installing these cables and wires should be alerted to any asbestos in the area so that they can avoid releasing asbestos fibers. A third fire safety issue is the need to install and maintain fire alarm and suppression systems. Codes have become more demanding in requiring these systems. Remodeling may require retrofitting of fire alarm and suppression systems to meet the new codes. Such systems will limit fires and save lives, but they are expensive. In addition, newly installed systems must be maintained. In the case of alarm systems, care must be taken to choose the appropriate detectors. Once installed, alarms must be evaluated every time they are activated to identify defective or inappropriately chosen sensors. Procedures should be in place for temporary deactivation of alarms to prevent facilities workers or contractors from triggering alarms when engaged in such activities as welding, cutting wood, or even some cleaning processes.

In some areas, fire safety officials have become concerned about chemical fume hoods when flammable solvents may be present. Generally, the approach was to provide some protection of the exhaust ducts and fan motors to prevent explosions and the spread of fires. Avoiding leaks in these systems was critical to safe operation and to avoid contamination of mechanical spaces, where facilities personnel could be exposed. The current trend to equip fume hood exhaust systems with an automatic fire suppression mechanism is not only expensive, but also could be counterproductive if water-reactive materials are used in the hood. The issue of laboratory fume hoods and biological safety cabinets has become more important as employees have developed a greater concern about chemical exposures. Old airflow standards usually are inadequate for real protection, and increased airflow means greater energy costs.

Recirculating air emitted from laboratories is unwise, and care must be taken to avoid doing this accidentally. There are numerous examples of retrofitted fume hoods that have exhausted air close to building or air-handling system intakes, causing unplanned recirculation of toxic materials. Leaking systems create these problems as well. Proper design of systems includes appropriately sizing and installing fans, bending the air plenum in the appropriate direction for the fan, and exhausting the air high enough above a building so that the air is not re-entrained. Another issue is to protect heating, ventilation, and air conditioning (HVAC) workers by having clear mechanisms of communication between the faculty and students using the fume hoods and the workers maintaining them. A lockout-tagout procedure must be in place and must show the users clearly that a system is inoperable. In the case of biological safety cabinets, an annual certification process may be required. A similar annual functional evaluation of all fume hoods is appropriate.

Another aspect of HVAC systems is proper maintenance of systems and cooling towers. Growth of mildew and mold in systems can create problems for those sensitized to things such as mold spores. The entire system should be designed carefully (in new buildings) and evaluated (in older facilities). It is not uncommon for people to close fire dampers during tests and then fail to reopen them, causing an undetected airflow restriction. At times, remodeling and new uses of spaces can change the demands and performance of a system.

A final issue that should be of concern to all facilities managers is emergency preparedness and response. As indicated earlier, every institution should have a local emergency preparedness committee with which the manager can work to have contact with emergency responders. The institution's emergency plans should be dovetailed with those of the local emergency forces, and the local forces should be aware of the institution's resources (e.g., medical, radiation safety, hazardous materials specialists, communications, and facilities). Such planning and cooperation strengthen communication between an institution and local governing bodies.

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Utilization of Limited Resources


With the great number of regulatory requirements, it is hard for managers to decide how to address all of the issues and still provide an economical operation. Although it is tempting to ignore issues because the level of regulatory inspection is low, doing so is extremely risky. A better approach is to develop an overview in which all potential problems are listed, the magnitude of the impact on an institution's operations is evaluated, the range of costs is predicted, and potential partial solutions are implemented. An example of the latter approach is the management of asbestos. Removal of all friable and nonfriable asbestos may be desirable, but because of the high costs, it may not be possible. Establishing an operations and maintenance program allows asbestos-containing materials to be left in place. When an area is remodeled, asbestos then must be removed.

Many useful approaches can be found by sharing information between institutions. APPA, providing leadership in educational facilities, is a good source for information. APPA's website (www.appa.org); APPA's Code Talkers column in the bimonthly Facilities Manager magazine, which discusses government regulations and codes and standards; and the annual conference and seminars are examples of APPA's efforts to keep its members informed. Communication between institutions can help managers get new ideas and avoid "reinventing" a process. An environmental audit is useful to help managers evaluate the issues that are most important to their operations. This audit does not need to be a large-scale, expensive process. When line staff are included in the audit process, they become more aware of the issues, develop greater understanding, and become committed to institutional risk programs. It is important to have written material for some regulations; these materials do not need to be extensive legal documents, but rather should represent programs that meet the spirit of the law and that actually are used in daily operations. A manager can send no worse message to staff than writing programs to satisfy regulators but never implementing, supporting, or enforcing them. Regulators, too, will see through this and hold managers responsible.

One final issue that facilities managers should understand is the movement toward making institutions of higher education examples of and workshops for a sustainable environment. Many university presidents have signed what is called the American College & University Presidents Climate Commitment, administered through the Association for the Advancement of Sustainability in Higher Education (AASHE). To give this commitment more than just lip service, an institution must try innovative programs to improve the local environment. This means looking beyond proper waste disposal to methods of actually reducing waste. Another example is to look at landscaping issues not only in terms of the beauty that landscaping provides a campus but also in terms of long-term maintenance. Gas-powered leaf blowers pollute the air, are a source of noise pollution, expose staff to ergonomic and respiratory risks, and remove a natural source of nutrients from the soils. Although universities may be faced with addressing conflicting interests, even small victories send a message to students and the public that these issues are important.

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Notes


1. Grose, Vernon. Managing Risk: Systematic Loss Prevention for Executives. Arlington, Virginia: Omega Systems Group, 1987.

2. Breyer, Stephen. "Breaking the Vicious Circle: Toward Effective Risk Regulation." KF 3958 B74. Cambridge, Massachusetts: Howard Press, 1993.

3. 29 CFR 1910, subpart Z. "Toxic and Hazardous Substances." Occupational Safety and Health Standards for General Industry. Chicago: Commerce Clearing House, October 1, 1993.

4. 29 CFR 1910.1200. "Hazard Communication Standard." Occupational Safety and Health Standards for General Industry. Chicago: Commerce Clearing House, October 1, 1993.

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