EDITORIAL: Compliance and Inspections
Compliance with laws, rules and regulations is just another part of doing business in academia, just as it is in the overall business world. This is particularly true when colleges and universities are involved in research. Along with these rules come the ever present reality of inspections by external agencies from Federal, State, and local authority. These include, but are not limited to the EPA, OSHA, NRC, DOT, NDEQ, DOL. If you don't know what this group of three and four letter abbreviations means, you probably are behind the power curve already.
Creighton University recently underwent an Environmental Protection Agency (EPA) inspection. It was unannounced as are all EPA inspections. It occurred on 9-11, and the inspection covered primarily the Resource Conservation and Recovery Act (RCRA). In very simple terms, and in general, this covers hazardous waste generation, management, and disposal. Creighton University is considered a Small Quantity Generator (SQG) of hazardous waste and that determination is based upon the quantities of waste generated over a given period of time. Inspection of hazardous waste generating areas included a number of laboratories, maintenance areas, paint and welding shops, photo processing areas, fine arts studios, and Varsity Press. Inspectors from the EPA can present themselves for inspection covering not only RCRA , but covering individual issues regarding air, water and soil. Iowa, Missouri, Kansas and Nebraska fall under Region 7 of the EPA.
The Occupational Safety and Health Administration (OSHA), may also inspect our university unannounced. OSHA comes under the Department of Labor (DOL). OSHA may decide to inspect workplaces when they receive report of an imminent danger situation or of failure to comply with Codes of Federal Regulations. This might include a variety of incidents such as an employee fatality, and employee complaint of unsafe working conditions, or failure to conduct mandated safety training for all employees. Some states such as Iowa have state OSHA controls. Nebraska however falls under Federal OSHA for review.
Shipment of various materials to and from our campus are regulated by the Department of Transportation (DOT). As with EPA and OSHA, the DOT can arrive and inspect at any time unannounced, and review training, documentation, procedure and other issues.
These and all of the other three and four letter agencies all present imminent liability potential if compliance with laws, codes, rules, and regulations are not followed. The EPA is currently targeting Colleges and Universities nation wide regarding the full spectrum of environmental concerns. Citations for violations of environmental law can result in large monetary fines that are determined based upon gravity of violation. OSHA may levy fines of up to $7,000.00 for each violation of standards considered serious, and up to $70,000.00 for each violation considered to be willful. The Department of Transportation may levy fines of up to $27,500.00 per day for violations.
So what is the moral of this editorial? Quite simply, it is to do the right thing, do it the right way, and comply with the law, with codes, regulations and standards. If you don't know what they are, make it a point to find out. All of the agencies that I have listed have extensive web sites. Take the time to review them and ask questions when you need clarification of a subject. Lastly, and as a bottom line, compliance needs to be just another part of the business of academia!
Is it really free?
Free does not necessarily mean without cost. It is tempting to accept "free" materials. However, "free" materials may generate unexpected and substantial disposal costs. When the study of and experimental material is involved, often the amount proferred is substantially more than actually needed. The excess amount is typically unusable for other purposes and will require disposal following the laws under the Resource Conservation and Recovery Act. It also increases the possibility of receiving unrecorded dangerous materials arriving on campus.
The amont of free material which may be accepted must be limited to the amount which is likely to be actually needed in the proposed program. Also, any of the risks involved with the chemical must be weighed against the benefits.
How to Reduce the Risk of Residence Hall Fires
Statistics show a decline in fires in college and university residence halls. But experts warn against complacency, saying that the only sure way to prevent fires is constant vigilance.
After a residence hall fire killed three students and injured 62 at Seton Hall University in January of 2000, administrators moved to ensure against a recurrence of such a tragedy. Strict behavioral policies accompanied construction work that added sprinklers to all residence halls.
Ten months later, a patrolling fire department officer encountered a party in the residence hall where the fatal fire of 2000 had occurred. Before the party, students had organized a Halloween decorating contest. Many rooms offered creatively carved pumpkins adorned with candles. Paper decorations flowed through all the rooms and doorways. Ankle-deep layers of hay covered he hallway floors. In short, the party defied all the rules aimed at prevention instituted after the first tragedy.
The fire department official, of course, shut the party down and demanded a thorough cleanup.
Vigilance Pays Off
" Preventing fire in campus housing takes constant vigilance," says Ed Comeau, publisher Campus Fire- Watch, a monthly electronic newsletter based in Belchertown, Mass. " A schoolís population changes every year, and institutional memories are short. Administrators must communicate policies and procedures effectively year in and year out."
Since 1973, 45 fires in residence controlled by colleges and universities have claimed the lives of 73 people.
While the threat of potentially fatal fires remains uppermost in the minds of fire-prevention experts, the number of fires in college- and university- controlled housing has declined through the past 20 years.
According to statistics assembled by the National Fire Protection Association (NFPA) of Quincy, Mass., fires in school, college and university residence halls, and fraternity and sorority houses fell from 2,500 in 1980 to 1,400 in 1998.
Why this decline?
"You can study incidents of fire in virtually any kind of structure and see a similar dramatic trend through the same period," Says Dr. John Hall, assistant vice president for fire analysis and research with NFPA. "The most likely explanation is a combination of factors, including better designs, changes in general public policies and safer behaviors." Fore example, continues Hall, fewer people smoke today and most public facilities have restricted where and when people can smoke. Nationally, there has been a general decline in arson, which is the chief cause of fires in campus residences. Policies against cooking in residence halls have come under tighter enforcement.
NFPA studies rank arson, cooking and smoking as the top three causes of resident hall fires between 1994 and 1998. Hall also sees the decline in reported numbers of residence hall fires as a result improved and more widely used fire detection and suppression systems, such as smoke alarms and sprinkler systems in public buildings. "Thanks to these systems, discovering and controlling a fire sometimes happens so fast that no one calls the fire department to report a fire,"
At Creighton University all seven of our residence halls have a complete fire panel control system. Each hall is monitored 24 hrs a day 365 days a year by Public Safety, offered with pull stations located at every exit along with heat and smoke detection in every hall. Three halls out of the total seven ( Kenefick Hall, McGloin Hall, and Swanson Hall) have a complete sprinkler suppression system installed, one other hall is partially sprinkled, and the three other halls have been inspected for a sprinkler system installation upgrade in the future.
Fire Safety Specialist
Excerpts from: College Planning & Management/ June 2002 magazine
- Carry a flashlight
- Walk, don't run.
- Stay on Sidewalks
- Obey traffic signals
- Stay in familiar neighborhoods
- Don't cut across yards or driveways.
- Wear a watch you can read in the dark.
- Make sure costumes don't drag on the ground.
- Shoes should fit (even if they don't go with your costume)
- Avoid wearing masks while walking from house to house.
- Carry only flexible knives, swords or other props
- Wear clothing with reflective markings or tape.
- Approach only houses that are lit.
- Stay away from and don't pet animals you don't know.
- Make your child eat dinner before setting out.
- Children should carry quarters so they can call home.
- Ideally, an adult should accompany young children of any age. If your children go on their own, be sure they wear a watch, preferably one that can be read in the dark.
- If you buy a costume, look for one made of flame-retardant material.
- Older children should know where to reach you and when to be home. You should know where they're going.
- Although tampering is rare, tell children to bring the candy home to be inspected before consuming anything. Look at the wrapping carefully and toss out anything that looks suspect.
- Make sure your yard is clear of such things as ladders, hoses, dog leashes and flower pots that can trip the young ones.
- Pets get frightened on Halloween. Put them up to protect them from cars or inadvertently biting a trick-or-treater.
- Battery powered jack o'lantern candles are preferable to a real flame. If you do use candles, place the pumpkin well away from where trick-or-treaters will be walking or standing. Make sure paper or cloth yard decorations won't be blown into a flaming candle.
- Healthy food alternatives for trick-or-treaters include packages of low-fat crackers with cheese or peanut butter filling, single-serve boxes of cereal, packaged fruit rolls, mini boxes of raisins and single-serve packets of low-fat popcorn that can be microwaved later. Non-food treats: plastic rings, pencils, stickers, erasers, coins.
According to the National Weather Service, 5,148 injuries and 908fatalities occurred due to severe weather in the United States in 1999, the latest year for which complete data are available. While 1999 weather-related injuries decreased from the 1998 total of 11,171, 1999 weather-related fatalities increased from the 1998 total of 687. In 1999, severe weather accounted for more than $12 billion in damage to crops and property.
Extreme heat was the number one weather-related killer accounting for 502 (55%) of the 908 weather-related deaths--nearly three times higher than 1998's fatality estimate of 173 and two and half times higher than the 10-year average of 194. A large portion of these fatalities occurred in Illinois with 138 deaths, Pennsylvania with 88, and Missouri with 77. The elderly are most at risk from heat. In 1999, 70- to 89-year-olds accounted for 47% of the 502 heat-related fatalities. Most deaths occurred in homes without air conditioning or adequate ventilation.
Tornadoes were the second leading cause of weather-related deaths in 1999. There were 1,343 recorded tornadoes, a 6% decrease from the 1,425 tornadoes in 1998. Tornadoes accounted for 94 fatalities, 10% of the total weather-related fatalities. Most of the tornado fatalities occurred in Oklahoma, which reported 42 fatalities in 1999. Of the 94 tornado deaths, 39 were in permanent homes and 34 were in mobile homes. Tornadoes accounted for 16% of the total damage to crops and property in 1999.
Floods, which include flash floods, river floods, and urban/small stream floods, accounted for 68 deaths, 7% of the total weather-related fatalities in 1999. This is 50% lower than the number of flood deaths in 1998. North Carolina recorded the highest number of flood fatalities with 24, followed by Pennsylvania and New Jersey with 6 fatalities each. Many of the deaths categorized as "in water" were due to being swept away by current after leaving a stalled vehicle. Flash floods accounted for 60 fatalities while river floods caused the remaining 8.
Lightning was responsible for 46 deaths and 243 injuries in 1999. The 1999fatalites were about 20% below the 10-year fatality average of 57. Florida ranked highest with five deaths in 1999, followed by North Caolina with four. Of those who died, 24 were outside, 9 were under a tree and 6 were on boats
Exerpt from: National Safety Council; Injury Facts, 2001 Edition
Top Five Hazardous Waste/RCRA Compliance Issues
1. Satellite Accumulation Area not at or near the site/point of generation. Yale University was fined for having satellite accumulation areas "across the hall" from the generation point. The EPA inspectors were concerned that non-lab personnel working in the area may not have knowledge of the hazards associated with the waste and, therefore, could have a higher potential for injury in the case of an incident. The EPA interpreted "at or near" to be on the same side of the hall and not through an area where untrained people could walk.
2. Satellite Accumulation Area not under control of the staff generating the waste. Satellite accumulation areas must be managed by the person(s) generating the waste.
3. Waste not properly labeled. The words "hazardous waste" must be on any waste container in storage along with the date the container was filled/placed in storage and all hazardous components by volume or percent.
4. Failure to determine hazardous waste. Basically a waste is a waste if:
It is a characteristic waste. (Ignitable, Corrosive, Reactive, Toxic)
It is a listed waste
It is inherently waste-like. (Looks like a duck, quacks like a duck, itís a duck!)
In other words, if it quacks you better call it a waste.
5. Open waste container. To an EPA inspector an open container is evidence of evaporation of a hazardous waste as a means of disposal. No waste containers should have tinfoil caps, funnels, or loose caps. On rare occasions some wastes form gases and can pressurize a closed container. Self venting lids may be obtained from Fisher Scientific. (Do not fill a container more than 80% full in order to allow for expansion and to prevent breakage or spillage due to temperature changes.) All waste containers must remain closed except when actively adding or removing waste.
Click It ... Don't Risk it!
Over 150 people have been killed on Nebraska roads so far this year, in over 80% of these fatalities, the victim was NOT buckled up. Minimize your chances of being included in this statistic and always wear your safety belt. Click It...Don't Risk It is a statewide campaign sponsored by the Nebraska Coalition to Save Lives through Safety Belt Usage. Watch for upcoming events and registration forms for a chance to win a Dodge Dakota truck. Creighton will be conducting two unannounced safety belt checks to achieve at least 80% safety belt use for staff, students and faculty. Watch for more information and flyers around campus. For more information contact Mindy Foster 546-6400 or firstname.lastname@example.org.
Hazardous Materials Manual
The Hazardous Materials Manual was written to offer guidance to the Creighton Community in the handling and disposal of hazardous materials. The Environmental Protection Agency regulates handling, storage, and disposal of hazardous waste from cradle to grave under the Resource Conservation and Recovery Act.
The manual covers waste streams generated by all departments of the university and is not limited to research or clinical areas. Topics include: required training, chemical storage and compatibility, aerosol cans, computer parts, and basic steps to comply with government regulations, etc. The manual can be viewed on line at http://www.creighton.edu/EHS. All university employees handling hazardous materials should take a moment to review this document.
Fire safety is a year Ėround concern, but most fires happen in the fall and winter months. Hereís a roundup of fall fire safety tips to keep your family safe and sound.
Cozy up to a safe fireplace
Fireplaces are involved in thousands of home fires each year, according to the National Fire Protection Association. The association offers safety reminders before you toss a log on the fire. For example, have your chimney inspected annually and cleaned when needed. Creosote, the buildup of deposits, is a top reason for fireplace fires. In addition, cracks can allow poisonous carbon monoxide to seep into your home. And finally, a thorough inspection will remove any animals that may have built a home in your chimney during the summer. The fire protection association also suggests the use of fireplace screens to keep sparks from floating out. In addition, donít leave your home or go out or go to bed with a fire left burning. And if your have a gas fireplace, have all the connections and lines checked.
"Burn only dry, seasoned hardwoods," says Julie Reynolds, assistant vice president for the fire association.
Change your clock and change your battery
Itís a rite of passage to change your clock in the fall, but itís also time to change the batteries in your smoke alarms. Be sure there are working smoke alarms on each floor of your home, particularly outside of sleeping areas. Approximately 20 percent of alarms donít work because of dead or missing batteries. In addition to replacing smoke alarm batteries every year, smoke alarms should be replaced every 10 years. Families should also keep Ė and learn how to select and use Ė a fire extinguisher in places where thereís a risk of fire, such as a home workshop or the kitchen. Install fire extinguishers near exits, and check them periodically according to manufactureís specifications.
Have an escape plan in place
Be sure your have a family fire escape plan, and practice it regularly. Have an escape route for each area of your home and a designated meeting place outside. Draw a map of the escape plan and make it easy for all members of the family to understand. Train every one to stay low to the ground when escaping a fire. If you must travel through smoke to your exit, crawl and keep your head at level of12-24 inches above the floor, Reynolds says. Windows may provide a secondary means of escape from a burning home. For two-story homes, you may want to purchase a non-combustible escape ladder thatís tested and listed by an independent testing laboratory. Store the ladder permanently near the window. Escape ladders are available at most hardware stores. Buy one that hooks hangs away from the house, rather than right up against it. And practice deploying the ladder and that includes practicing how to use it from a first floor widow. A real fire not the time to learn!
Keep Kids Safe From Fire
According to the National Fire Protection Association, 232 people were killed in 1998, and $235 million in property was destroyed in fires attributed to children playing with fire. These are preventable fires. Here are some fire safety tips for every household with children.
- Store matches and cigarette lighters up high and out of sight and reach of children, preferably in a locked cabinet.
- Teach children to tell an adult if they find matches or lighters.
- Identify and eliminate fire and burn hazards in your home.
- Be a role model with such items as candles and fireplaces. Never play with fire. Children emulate adult behavior.
- Teach your children how to report an emergency. Post 9-1-1 stickers and other emergency numbers near your telephones.
- Have your children memorize their home telephone number and address, including city and state. Plus, teach them to get out first and then call for help.
- Teach the "stop, drop and roll" technique for cloths on fire. For those who use wheelchairs, learn how to use a rug or heavy fabric to smother flames.
Winter Vehicle Emergency Kit
Every year we hear of the stranded auto in the snow, off the road, and of the often fatal results for the unprepared. If you get stranded in your vehicle, just what can you do? The experts say pack an emergency kit for your car. Probably the most important thing to remember is to keep warm. An extra blanket or two, gloves and boots make a good start. While not all inclusive, the following is a list that may be a good start:
* Extra clothing (socks, gloves (mittens are better than gloves), a stocking hat (heat escapes out of the top of the head), scarfs, etc.
* Thermal coveralls and/or a water repellent jacket or raincoat or poncho.
* An ice scraper to remove frost and ice.
* Extra window washer fluid.
* Flashlight with working batteries and an extra set of batteries.
* Empty coffee can with a quantity of candles and matches (for warmth)
* A sleeping bag and/or blankets
* Reflective emergency blinker.
* Reflective tape or brightly colored cloth or flag that can be attached to your antenna.
* A small shovel.
* Bag or two of sand, cat box litter, or traction mats.
* Tow rope, or tow chain.
* Pair of jumper cables.
* Basic first aid kit.
* Non-perishable food (like breakfast bars, hard candy, peanut butter, etc.) A coffee can makes a good container for the food.
* Toilet tissue or individual packets of facial tissue.
* Tools, duct tape, wire.
Cell phones are quite common today, and can save lives in emergency conditions, however, it may be wise to consider investing in a vehicle charge unit for your cell phone. The phone wonít do much good if the battery is run down. It is also wise to pay attention to highway signs that list radio stations that broadcast weather reports and highway conditions. Lastly, and probably most important, check the weather forecasts before you hit the road, and if bad weather or bad road conditions are forecast, stay put until conditions are more favorable.