The University of Memphis
Occupational Safety and Health Program
|Policy Statement||An Occupational Safety and Health Program will be established in accordance with policy guidelines set forth by the Tennessee Board of Regents. This program is intended to ensure that all University employees are furnished with a place of employment that is free from recognized hazards that are causing or are likely to cause death or serious injury or harm. In addition, this program will promote a safe and healthful working environment for all University employees. Occupational Safety and Health Standards for the State of Tennessee are adopted as the minimum safety and health standards for the University of Memphis.|
Administrative officials, department chairs, and directors are responsible for ensuring compliance with this policy.
The provost shall be responsible for the development and publication of procedures necessary to administer the Occupational Safety and Health Program.
| ||The Federal Occupational Safety and Health Act of 1970 was enacted to improve the general working environment and to provide, as far as possible, every working person in the nation safe and healthful working conditions. This Act provided an opportunity for the various states to develop their own Occupational Safety and Health Programs. In Tennessee, this was accomplished by the Tennessee Occupational Safety and Health Act of 1972.
The primary objective of the University of Memphis Occupational Safety and Health Program is to promote a safe and healthful working environment for all University employees. This is accomplished by integrating an effective safety and health program into the normal operation of campus activities. A vigorous program of education and evaluation shall be undertaken to, so far as possible, identify and eliminate conditions or actions that create an unsafe environment. The effectiveness of this program will depend largely upon the cooperation and active participation of the people it protects and serves.
Occupational Safety and Health Standards for the State of Tennessee and the State University and Community College System of Tennessee are adopted as the minimum Occupational Safety and Health Standards for the University of Memphis. In keeping with these standards, employees shall receive notification of their rights and duties through the State of Tennessee Occupational Safety and Health Poster. Employees shall be entitled to review the annual safety and health reports and to protest any portions deemed to be inaccurate or which fail to portray real and existing conditions.
|Duties and Responsibilities||DUTIES AND RESPONSIBILITIES:
The following general duties and responsibilities are not designed in any way to alter or detract from other assigned duties and responsibilities. Additional responsibilities are as listed under various subsections of this procedure.
1. The vice provost for research shall monitor and provide administrative guidance for the overall safety program.
2. Administrative officials, chairs, and directors of activities shall:
3. Supervisors, residence hall advisors, and director of residence life shall:
4. Employees shall:
To ensure compliance with occupational safety and health standards and other regulations covering personnel possessing or using biological agents, the University of Memphis has established a Biological Safety Committee. The purpose of this committee shall be to administer the development and implementation of the biological safety program for the University. The "Biological Safety Program" developed by this Committee shall serve as the University's procedure regarding the possession, storage, and use of biological agents. Copies of this program are available in the Environmental Health and Safety Office.
Departments with employees who are reasonably anticipated to have contact with human blood or other potentially infectious materials shall develop and implement an exposure control plan containing at least the elements required by 29 CFR 1910.1030. These plans shall be reviewed and updated at least annually, but more frequently as necessary. Signed and dated copies of the plans shall be on file in the Environmental Health and Safety Office.
The following units will provide administrative support for this program as listed.
1. The Department of Human Resources will be responsible for
2. The Employee Safety and Health Office will be responsible for:
3. The Environmental Health and Safety Office will provide guidance in developing departmental exposure control plans and will provide administrative support for this program.
Department/Activity heads shall decide if any spaces within their areas of responsibility are confined spaces that contain or have the potential to contain a hazardous atmosphere, contain a material that has the potential to engulf an entrant, has an internal shape such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section, or contains any other recognized safety or health hazard. Any area meeting the above criteria shall be classified as a permit-required confined space.
Employees entering permit-required confined spaces shall be provided with proper safety equipment and training on the nature of the hazards involved, the precautions to be taken, and the usage of required protective and emergency equipment. In addition, affected departments shall assure that a permit-required confined space program is developed and implemented according to 29 CFR 1910.146. Employee Safety and Health will assist in development of these programs.
Contracting firms performing work on University property shall comply with applicable occupational safety and health standards. The contractors shall provide fire extinguishers if they are required by their work. Physical Plant shall work with the Tennessee Board of Regents to promote compliance by firms performing construction, renovation, and other building and grounds repair/maintenance work. Procurement Services and applicable department/activity heads shall promote compliance by firms performing other types of contractual services.
|Department/Activity Safety Committee|
Departments and other activity units, especially those of considerable size and/or well-diversified working conditions, are encouraged to establish internal safety committees. The primary interest and concern of these committees should be the promotion of safe practices and procedures in the respective work areas and the positive support of the total university safety program.
|Emergency Exit Identification and Access|
No more than ninety (90) minutes before the scheduled commencement of indoor campus activity in which the crowd is expected to exceed three hundred (300), the administrative official, chair, or the director of activity responsible for said activity or his/her designee shall inspect every required exit, way of approach, and way of departure from the place of activity. If such inspection reveals that any means of egress is obstructed, inaccessible, locked, fastened or otherwise unsuited for immediate use, the scheduled program shall not begin, nor shall admittance to the place of assembly be allowed, until necessary corrective action has been completed.
Immediately before the start of the program, the administrative official, chair or director of activity or his/her designee shall orally notify all the attendees concerning the location of exits to be used in case of fire or other emergencies.
Accurate records of all inspections, corrections, and notifications pursuant to this procedure shall be kept and retained for at least two years. These records shall contain:
These records shall be available for review by representatives of Employee Safety and Health or other appropriate University Official(s) upon request.
|Fire Prevention and Safety|
All fires within the university community shall be reported to the Police Services (911 or 678-4357) which will notify the Memphis Fire Department. Police Services will also report each fire to Employee Safety and Health.
In case of a fire or a fire alarm, all personnel in the building shall evacuate the building. Personnel must remain outside the building until the fire department gives permission for reentry to the building. Any employee who fails to evacuate a building during a fire, false fire alarm, or fire drill shall be subject to disciplinary action.
Persons noting potential fire hazards should report the circumstances to Employee Safety and Health for investigation and recommendation of corrective action.
Fire safety equipment, such as extinguishers, hoses, and alarm systems shall be used for designed purposes only.
Empty or damaged fire extinguishers should be reported to Employee Safety and Health for immediate replacement.
Exhaust hoods over cooking facilities shall be maintained in satisfactory condition by the facility operator. In addition, Employee Safety and Health shall inspect these hoods monthly for grease accumulation and general cleanliness.
Fire drills should be conducted in each building at least semi-annually. A record of these fire drills shall be maintained by Employee Safety and Health.
Supervisors and classroom/laboratory instructors shall ensure that good housekeeping procedures are always followed and shall initiate immediate action to alleviate fire hazards or other conditions not meeting fire prevention standards.
If it is necessary to turn off or disconnect a fire water line, sprinkler system, standpipe system, fire hydrant, or fire alarm system, it shall be the responsibility of Physical Plant to notify the Memphis Fire Department and Police Services prior to such action. It shall also be the responsibility of Physical Plant to notify the Fire Department and Police Services after returning such systems to service.
|General Safety and Housekeeping|
Good housekeeping and adherence to good safety practices play an important role in organizational efficiency and safety. The following items are worthy of particular attention:
Those with direct responsibility for any of the above items, including Physical Plant employees, classroom/laboratory instructors, and other University personnel, are expected to exercise appropriate vigilance so as to maintain a safe and healthful workplace.
|Hazard Communication Program|
The University of Memphis, through the Hazard Communication Program and other means, complies with all applicable provisions of the Tennessee Hazardous Chemical Right-to-Know Law.
The program applies to all employees who may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency.
Each department that uses, stores, and/or creates hazardous chemicals shall maintain an up-to-date inventory of such items. Departments shall make inventories accessible to employees and shall provide the Environmental Health and Safety Office with updated copies of such inventories at least annually and upon making significant changes in quantities or types of hazards present. Material Safety Data Sheets (MSDS) will be used to evaluate whether supplied chemicals are hazardous. Where departments cannot decide if materials are hazardous based on the MSDS, the Environmental Health and Safety Office will assist in such determinations.
Chemicals produced on-site shall be evaluated to determine if they are hazardous.
Those listed in any of the following sources shall be considered hazardous:
In addition, statistically significant scientific evidence shall be identified and evaluated by criteria set forth in Appendix A of the OSHA Hazard Communication Standard (29 CFR 1910.1200). Until fully evaluated and determined to be non-hazardous, new chemicals shall be considered hazardous and appropriate precautions taken to protect personnel and facilities.
The Environmental Health and Safety Office is responsible for maintaining a master list of all hazardous materials used, stored, or created by University personnel or held at University facilities. For departments whose inventories are centrally maintained by Environmental Health and Safety (EH&S), EH&S is also responsible for providing each department with an annual printout of the department's hazardous materials inventory based on inventories reported by such departments.
Employees shall be notified of their rights under the Right-To-Know Law through posting of the "State of Tennessee Employee Safety and Health Notice" and through New Employee Orientation. (See Employee Safety and Health Office for this posting.)
The Environmental Health and Safety Office is responsible for the communication and implementation of the following requirements of the program:
1. Labels and Other Forms of Warning
Upon receipt, personnel within the receiving location shall inspect labels and other forms of warning for each incoming hazardous chemical to assure that each container is marked with the identity of the hazardous chemical(s) contained therein, appropriate hazard warnings, and the name and address of the chemical manufacturer, importer, or other responsible party. In addition, departmental supervisors shall assure that such labels are not removed or defaced unless the container is immediately marked with the required information. Hazardous chemicals transferred to portable containers that will be used by anyone other than the person transferring such material, or will be for other than immediate use, shall be marked with the identity of the hazardous chemical(s) and appropriate hazard warnings. Buildings containing 55 gallons or 500 pounds or more of a hazardous material will be placarded according to the Tennessee Hazardous Chemical Right-To-Know Law.
2. Material Safety Data Sheets (MSDS)
Procurement Services shall require suppliers to provide the Environmental Health and Safey Office with a Material Safety Data Sheet (MSDS) for each initial shipment of hazardous chemicals. The Environmental Health and Safety Office shall maintain a master file of these MSDS and supply copies to appropriate departments. Affected departments shall maintain readily accessible files of MSDS for use by employees. Where hazardous chemicals are obtained outside the purchasing system, departments shall assure that MSDS are obtained and that Environmental Health and Safety is supplied with a legible copy of such. An MSDS shall be made available to employees prior to use of any new hazardous chemical. For hazardous chemicals produced at the University, an MSDS may be issued or developed to satisfy the physical and health hazard communication requirements. All incoming MSDS will be checked for accuracy and any discrepancies reported to the supplier for correction.
3. Employee Information and Training
Affected departments shall provide information and training to all employees at the time of initial assignment. Departments shall provide additional information and training whenever new hazards are introduced into a work area, but shall provide retraining at least annually.
Employees shall be informed of the information and training requirements of the Tennessee Hazardous Chemical Right-To-Know Law, any operations in their work area where hazardous chemicals are present, and the location and availability of this hazard communication program, including inventories and MSDSs.
Employees shall be trained on methods and observations that may be used to detect the presence or release of a hazardous chemical; physical and health hazards of chemicals in the work area; measures employees can take to protect themselves from these hazards; and details of this program, including labeling systems, MSDSs and how to obtain and use appropriate hazard information. Employee training records shall be maintained by the Department of Human Resources.
4. Methods Used to Inform Employees of the Hazards of Non-Routine Tasks.
Employees involved in non-routine tasks (such as tank cleaning and maintenance) shall be informed of the hazards involved and trained at specific training sessions to ensure awareness of required information.
5. Methods Used to Inform Contractor Employees
Contractors who may be exposed to hazardous chemicals shall be informed both verbally and by means of an information sheet as to hazards involved before any work is accomplished. The department obtaining the services of the contractor shall be responsible for notifying the contractor employees.
|Construction-Related Communication||All renovations, construction projects, and maintenance operations with the potential to release more than de minimis amounts gases, vapors, fumes, dusts, or mists that may be harmful to personnel not directly involved in those projects shall include implementation of a standard operating procedure (SOP) designed to eliminate or reasonably minimize such exposure. Prior to initiating such work, a representative of the party or parties performing the renovation, construction, or maintenance operation shall inform non-involved persons in the vicinity of the work to be done and the methods implemented to minimize those hazards. Non-involved personnel shall also be provided with the name of a contact person and phone number to allow rapid notification of emergency situations. Where there is a dispute involving applicability of the de minimis classification to specific situations, Environmental Health and Safety shall be the arbiter.
Standard operating procedures should contain at least the following:
Personnel not involved in the renovation, construction, and maintenance operations shall be granted access to the SOP and shall be provided with copies of all applicable Material Safety Data Sheets in a timely manner upon request to the project supervisor.
The following examples indicate de mimimis amounts of air contaminants for personnel not involved in the project: drilling a small number of holes in non-hazardous construction materials, soldering a small section of pipe, using a spray cleaner to dust furnishings, etc.
The following are considered to release more than de minimis quantities of air contaminants: major roof repairs, painting of significant portions of rooms, power sanding a surface of more than 3 square feet, hand sanding entire wall surfaces containing silica, etc.
The primary safety compliance inspection program shall be conducted by the Employee Safety and Health Office. The frequency of the inspections shall be determined by the nature of operations, with those operations involving the greater potential hazards receiving greater emphasis. All locations, regardless of potential hazards, shall be inspected by the department head or his/her designee at least monthly and by the Employee Safety and Health Office at least annually.
Representatives of the Tennessee State Commissioners of Labor and Health and the Tennessee Board of Regents upon presentation of proper credentials to the provost or his/her designated representative, are authorized to:
Both University and employee representatives shall have an opportunity to accompany the designated officials or inspectors during any physical inspection of University property.
|Laboratory Chemical Hygiene Program|
To assure compliance with occupational safety and health standards covering employees engaged in the laboratory use of hazardous chemicals as defined in 29 CFR 1910.1450, the University of Memphis has established a Chemical Hygiene Committee. The purpose of this Committee shall be to administer the development and implementation of the chemical hygiene program for the University. The "Laboratory Chemical Hygiene Program" developed by this Committee shall serve as the University's procedure regarding the possession, storage, and use of hazardous chemicals in laboratories. Copies of this program are available in the Environmental Health and Safety Officer and in any department using hazardous chemicals in laboratories.
|Lock Out/Tag Out Safety Program|
Departments with employees who maintain or service devices where there may be exposure to the unexpected energization or startup of the equipment or release of hazardous energy shall provide training on recognition of applicable hazardous energy sources, the type and magnitude of energy available in the workplace, the methods and means necessary for energy isolation and control, and the purpose and use of energy control procedures. In addition, all other employees whose work operations are or may be in areas where energy control procedures may be utilized shall be instructed about the procedures and prohibited from attempts to restart to re-energize equipment that has been locked out or tagged out. Employee Safety and Health will assist in development of these programs.
Retraining shall be provided for all affected employees whenever there is a change in their job assignments, a change in machines, equipment or processes that presents new hazards, when there is a change in energy control procedures, or when there is reason to believe that there are deviations from or inadequacies in the knowledge or use of the energy control procedures.
|Medical and First Aid|
Employees who are injured on the job should utilize the services of an authorized medical services provider from the state workers' compensation preferred provider network. Additional information on this subject is found in University Operating Procedure 2A:12:03A.
1. Department/Activity Heads shall be responsible for ensuring the following:
2. The Director of Police Services shall prepare shift schedules to ensure that at least one (1) person qualified to administer first aid is always assigned to both the main and Park Avenue campus areas.
Departments with employees who are subjected to occupational noise exposure in excess of the limits set forth in 29 CFR 1910.95 shall implement a "Hearing Conservation Program" and an "Audiometric Testing Program" as required in that regulation. Employees covered under this requirement shall be provided with protection against the effects of noise exposure.
The University of Memphis operates under regulations established by the Tennessee Department of Environment and Conservation--Division of Radiological Health and the U.S. Nuclear Regulatory Commission. To insure compliance with all regulations regarding the use of radioactive materials and/or radiation-producing equipment, the Radiation Safety Committee has been established. The purpose of this Committee shall be to administer the radiation safety program for The University of Memphis. This committee has developed The University of Memphis "Radiation Safety Manual" which shall serve as the University's procedure regarding the use of all radioactive materials and radiation producing equipment. Copies of this manual are available for review in the Environmental Health and Safety Office or in any department that has radioactive materials and/or radiation producing-equipment.
Where engineering controls and work practices are not sufficient to effectively reduce occupational exposure to harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, respirators shall be used in accordance with 29 CFR 1910.134. This OSHA standard addresses required training, medical examinations, respirator selection and fit testing, and respirator maintenance and care. Affected departments shall develop and implement a written respiratory protection program conforming to requirements of 29 CFR 1910.134 prior to allowing employee use of respirators. No employee shall be authorized to use a respirator without compliance with the OSHA standard and the written respiratory protection program.
|Reporting of Accidents Involving Vehicles|
All vehicle accidents on campus and those involving University-owned vehicles shall be reported to Police Services at 678-4357. Police Services shall notify other offices or officials as appropriate.
|Reporting of Injuries and Illnesses|
Injuries and illnesses of employees that result from campus-related accidents and/or exposure to unsafe environmental conditions shall be reported to Employee Safety and Health. Accidents involving students should be reported to Police Services, who shall notify Employee Safety and Health. The "First Record of Injury or Illness" form is the only form authorized for reporting injuries or illness of employees.
The supervisor of the injured/ill employee shall complete the front of the form and forward it to Employee Safety and Health within 24 hours of the occurance of the injury or illness. The Employee Safety and Health Office shall ensure expeditious completion of the reverse side in all cases of reported occupational injury or illness.
|Storage and Use of Flammable and Combustible Liquids|
Department/activity heads and other supervisors (including class and laboratory instructors) shall ensure compliance with the following rules related to use and storage of flammable liquids (flashpoints below 100º F) and combustible liquids (flashpoints below 200º F but at or above 100º F).
Use of flammable and combustible liquids shall be limited to trained personnel, or persons under the direct supervision of a trained individual, such as a laboratory instructor or a qualified faculty member.
Storage of flammable and combustible liquids in buildings used primarily for office occupancy and/or traditional education operations shall be limited to that required for the operation of equipment, maintenance, demonstrations, laboratory work, etc. All subject liquids in laboratories and other inside points of use shall meet the following provisions:
|University Safety Committee|
A University Standing Committee on Safety and Security shall be appointed by the president and shall be responsible for the following functions:
This Standing Committee on Safety and Security shall prepare an annual report to the president during the month of July to include the following items:
The committee should meet at least quarterly but not less than semi-annually.
Requests for variances from the Occupational Safety and Health Act standards will be processed in accordance with procedures outlined in Section 13, Tennessee Occupational Safety and Health Act of 1972. Requests for variances from the Occupational Safety and Health Act, Public Sector Plan will be processed according to procedures outlined in III-9-5, Tennessee Occupational Safety and Health Act, Public Sector Plan. Requests for variances for the State University and Community College System of Tennessee Occupational Safety and Health Plan will be processed according to procedures outlined in Part I-D of the State University and Community College System of Tennessee Occupational Safety and Health Plan.
Preparation of variance requests will be the responsibility of the Office of the Vice Provost for Research and shall be submitted to the Provost for further action.
|Bloodborne Pathogen Incident Report||http://ehs.memphis.edu/BBPEPCattach2.pdf|
|First Record of Injury or Illness|
|Other Health and Safety Related Forms||http://ehs.memphis.edu/downloads.htm|
|What do I do if I am injured on the job?||If you are injured or have a job-related illness, contact the Benefits Section of the Department of Human Resources. Information on the website includes proper procedures for reporting injuries and illnesses, access to Workers' Compensation, and instructions for receiving medical treatment.|
|Whom do I contact with further questions?|
Chemical, Biological, and Radiation Safety:
Director, Environmental Health and Safety, 216 Browning Hall, 678-4672.
General Safety, Fire Safety, On-the-job Injuries:
Safety Officer, Employee Safety and Health, 291 Administration Building, 678-1625.
|Employee Health and Safety Office|
|Environmental Health and Safety Office|
|First Report of Accident Form|
|Radiation Safety Manual|
|Tennessee Board of Regents Guidelines|
|Tennessee Department of Environment and Conservation|
|University of Memphis Safety Manuals|
|U.S. Occupational Safety and Health Administration|
| ||UM1293 Rev.1 -- updated August 20, 2007
UM1293 - Issued: July 2, 2003 supercedes policy number 1:2A:04:01 and 2D:02:02D)
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