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Abstract: Environmental Health and Safety

Risk Control in Facilities Management

Facilities managers have problems if they ignore, overly delegate, or haphazardly manage risks. Employee perceptions include their approach to risk, and how a health or safety issue can lead to regulatory agency investigation and even litigation. Managers do not focus on risk as much as benefit (e.g., because of positive thinking, risk trade-offs based on personal experience, assumption that success dwarfs problems). Confronting data overload, people use risk shortcuts (e.g., past safety experiences; aversion of risks beyond their control).

Risk Awareness for Better Management. Manager attitudes toward worker safety significantly affect employee morale. Per studies, prevention of serious problems is cheaper than accidents and their results. Systematic risk management ranks risks by using intuition, common sense and experience, or systems engineering. Managers bring holistic views, historical information, and what-if questions to risk analysis; employees provide information about on-the-job dangers. Managers and employees must communicate to address risk, improve planning, and facilitate employee buy-in and greater worker attention to risks.

Legal Reasons to Manage Risks. Managers cannot control all risks but must recognize that failure to comply with regulations (standards of conduct, behavior, and expectations) is a legal violation in all cases and negligence if an accident occurs (with possibly severe real costs and image damage). Two major worker safety programs are the 1902 Workers’ Compensation Act, which guaranteed compensation for on-the-job injuries (including chronic exposure to hazardous materials), and 1970 Occupational Safety and Health Act (OSHA), which established minimum safe working standards, with an initial focus on specific regulation compliance but recent emphasis on overall program effectiveness and job safety education. Agencies interpret a congressional safety law by writing, publicizing, and implementing detailed regulations; some states adopt more stringent regulations. The applicability of some regulations depends on institution size.

Establishing Safety Programs for Facilities Management

Understanding Risk and Perception. Some risks are inherent (e.g., high-energy sources; highly toxic chemicals), sometimes with severe effects that OSHA regulates. Some inherent risks (e.g., icy  sidewalks)  are not severe but can be identified if not avoided. Change always increases risk (e.g., new  or  changed  procedures or tools increase risk); design safety margins and strict guidelines help, but a better approach is educating and challenging workers to think about task risks and avoid them. Several recent OSHA regulations require specific training to control risk; failure to train is an intentional violation, and records are easily  inspected.  Familiarity can affect risks because firsthand safe experience can trump estimates of risk. Managers cannot prevent dynamic (unpredictable) risks, but  effects  can  be reduced by encouraging employee input and a culture of analyzing jobs to anticipate what might go wrong.

Managers and staffs can identify, evaluate, and control risk by learning from experience, using expert advice, understanding regulations, encouraging employees to express concerns (and supervisors to foresee problems), evaluating and inspecting work sites, and identifying risks in advance via job safety evaluations (scenario creation).

Effective  Risk  Management  Programs.   Human resources are core to safety programs. Most important, the people protected must participate, but supervisors create and maintain programs; first-line supervisors are closest to workers; and senior managers create the supportive environment. Managers must provide resources and positive reinforcement, hold clear mandates, and work with any safety director.

Communication also is key. Safety committees have been ineffective in many institutions. Managers should not control them; places and times should be convenient; meetings should be short and frequent; staff should contribute to varied agendas; and two-way communication should be encouraged. Such committees can be governed by union contracts or NLRB rulings and should include first-line personnel, perhaps with rotating membership. Committees can establish procedures to address employee concerns, suggest training requirements (important function), analyze accidents and reports and make recommendations (e.g., new policies, equipment, inspections, training), and develop a shared vision.

Many organization factors have positive or negative impacts on accident frequency and severity.

Health and Safety Programs for Facilities Management Organizations

Managers must be aware of regulatory requirements, particularly health and safety programs (e.g., EPA hazardous waste regulations) where non compliance consequences are greater for the individual and the institution (e.g., agency enforcement actions, personal and institution lawsuits, negative publicity). Most violations are detected after accidents or complaints from workers or the community; regulatory inspections focus more on audit trails (e.g., written procedures, documented programs, training records). Effective safety programs are less likely to trigger the inspection process after an incident or complaint.

Regulatory Programs Emphasizing Training. Many

U.S. regulations applicable to colleges emphasize training, content, and trainees. Most derive from the Code of Federal Regulations; CFR 29 is the basis for OSHA regulations. Specific equipment can require safety training (content not specified), per regulations, ANSI standards, or trends. Training can be implemented in many ways but must be documented and relevant to the school. OSHA electrical safety practices (1910.331– 1910.333) incorporate the NFPA standard (70E), how to identify electrical hazard exposures and protect workers.

Regulation of Hazardous Materials

Hazardous materials use varies by institution (e.g., large, small, research, medical). Managers must be aware of materials and their management (e.g., purchase, storage, use, disposal). Non-mandatory training is recommended for select personnel. OSHA regulates 29 specific chemicals and sets exposure levels for  hundreds more. Even short-term exposure to chemicals can cause physical problems but can be limited by ventilation design (affecting energy use) and operating procedures. Requirements for Personal Protective Equipment (PPE) and chemical storage (29 CFR 1910.1200) are documented in material safety data sheets, available from manufacturers. For example, pesticides are highly regulated, can require licenses, and can need application contractors; PCBs are commonly used as transformer and capacitor insulating material but most have been removed; and underground oil tanks must be monitored for leakage, cleaned up if needed, and removed if old and unused. Continual reporting is required for some materials (e.g., if amounts exceed thresholds). Local emergency planning committees can require reports (e.g., on chlorination systems or large refrigeration systems with ammonia); and coordination on integrated plans is needed to handle fire or chemical spills. Sometimes Department of Homeland Security rules apply.

Hazardous Waste Regulations

Disposal costs for many heavily regulated wastes are high (but far outweighed by cleanup costs and fines for illegal disposal) but can be lowered by choosing other materials, purchasing smaller quantities, segregating wastes, and meeting specific requirements (e.g., radioactive nuclides, medical waste). Improper disposal of heavily regulated chemical, flammable, corrosive, reactive, or toxic waste can result in large fines and criminal punishment. Oil spills, contaminated soil, and cleanup materials are hazardous waste, so prevention is best (e.g., supplier contracts, tank plans, waste oil recycling). Ballasts (PCBs), fluorescent light bulbs (leachable mercury), and batteries (not dry cell) also are hazardous waste.

Environmental Regulations on University Activities

EPA clean water standards require testing water (if institution-supplied) for bacteria and heavy metals; measuring lead in plumbing pipes and systems; monitoring wastewater (e.g.,  discharge  permits, sampling, and analysis if waste goes to a municipal or regional treatment facility); monitoring the environment under a radioactive material use license; and evaluation, monitoring, and remedies for  underground  storage tanks. Clean air standards apply to power plants and medical waste incinerators (e.g., emission permits and perhaps monitoring),  chemical  emissions  (e.g.,  state laws on laboratory fume hoods), and radioactive material emissions (under NESHAP, based on  amounts  used); future requirements might require  evaluating  fume hoods for other chemicals or reporting heating facility  and refrigeration unit emissions.

Planning and Maintenance for Facilities

When facilities are constructed, remodeled, or used differently, new building and safety codes apply, so an evaluation and review process is needed. Common fire safety issues (because of limited space and poor central control) include hallways used for storage of possibly combustible items, blocking egress; breaches of walls (e.g., during phone and data line installation) designed to limit fire spread or containing asbestos; and installation and maintenance of fire alarm and suppression systems to comply with new codes (e.g., evaluation after activation; temporary deactivation procedures). Some fire safety officials are focusing on fume hoods (e.g., laboratory fume hoods, biological safety cabinets, airflow standards to stop toxic releases, proper system design, built-in suppression systems, HVAC worker protection through clear communications, lockout-tagout process, annual evaluation or certification). HVAC systems and cooling towers must be properly maintained (to prevent mold and mildew), designed, and evaluated. To address emergency preparedness and response, facilities managers should coordinate with local emergency forces.

Utilization of Limited Resources

When resources are limited, the best approach is to list all potential problems, magnitude of impacts, resolution cost range, and possible partial solutions. New ideas can be identified by sharing information between institutions (e.g., APPA website, Code Talkers column, annual conference and seminars). A simple environmental audit, including line staff, is useful to evaluate relative issue importance. Some regulations require written documentation, but the key is managers who implement, support, and enforce them. Facilities managers should understand the move toward a more sustainable environment (e.g., AASHE-administered Presidents Climate Commitment), looking beyond waste disposal to waste reduction.

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