ART SAFETY PROCEDURES for Art Schools and Art Departments By Michael McCann, Ph.D., C.I.H. Center for Safety in the Arts Copyright (c) 1992, 1997, 1998 Center for Safety in the Arts ALL RIGHTS RESERVED. No part of this book may be used or reproduced in any manner whatsoever without prior written permission from the publisher, except for excerpts used in training materials by the purchaser, or in the case of brief quotations embodied in critical reviews and articles. All inquiries should be addressed to: Center for Safety in the Arts, Mailbox 310, 2124 Broadway, New York, Ny 10023. PRINTED IN THE UNITED STATES OF AMERICA TABLE OF CONTENTS PREFACE CHAPTER 1. INTRODUCTION CHAPTER 2. A HEALTH AND SAFETY PROGRAM Goals of a Health and Safety Program Structure of a Health and Safety Program Health and Safety Committees Functions of a Health and Safety Program Art Department Procedures. Student Supervision Art Department Health and Safety Manual. References CHAPTER 3. HAZARD COMMUNICATION Who is Covered What is Covered Workplace Inventory Labels Material Safety Data Signs Training and Education Written Hazard Communication Program References CHAPTER 4. EMERGENCY PROCEDURES General Emergency Procedures Fire Emergencies. Regulations for Spills and Leaks Cleaning Up Spills and Leaks First Aid References CHAPTER 5. LAWS AND REGULATIONS Occupational Safety and Health Administration (OSHA) State Right-To-Know Laws National Institute for Occupational Safety and Health (NIOSH) Workers Compensation Laws Environmental Protection Agency (EPA) Americans With Disabilities Act (ADA) Negligence Lawsuits References CHAPTER 6. GENERAL PRECAUTIONS Know Your Materials Substitution Ventilation Storage and Handling of Toxic Chemicals References CHAPTER 7. PERSONAL PROTECTIVE EQUIPMENT General Procedures Respirators Gloves and Hand Protection Eye and Face Protection Hearing Protectors Other Personal Protective Equipment References CHAPTER 8. FIRE SAFETY Fire Emergencies Portable Fire Extinguishers Sprinkler Systems Storage and Handling of Flammable and Combustible Liquids Spraying Flammable and Combustible Liquids Compressed Gases Welding, Cutting and Brazing References CHAPTER 9. WASTE MANAGEMENT Wastewater Types of Hazardous Waste Waste Management Methods Waste Disposal Services Recommendations for Treatment or Disposal References CHAPTER 10. SAFETY Working Areas Materials Handling and Storage Machine and Tool Safety Electrical Safety References APPENDIX 1. CENTER FOR SAFETY IN THE ARTS APPENDIX 2. NYCOSH APPENDIX 3. RESOURCES Occupational Health Clinics Canadian Occupational Health Clinics Regional Poison Control Centers National Institute For Occupational Safety And Health (NIOSH) Occupational Safety And Health Administration (OSHA) EPA Regional Hotlines Safety Supply Sources Other Resources PREFACE Art Safety Procedures for Art Schools and Art Departments developed out of the many industrial hygiene consultationsthat I have carried out for art schools and college and university art departments over the last fifteen years. Usually, I was called in by the Art Department or Art School to make recommendations for ventilation, storage and handling, personal protective equipment, etc. However, what I almost universally found was a lack of health and safety programs and adequate procedures to make sure that health and safety hazards were identified and corrected on an on-going basis. This included no Material Safety Data Sheets, lack of approval mechanisms for new art materials and processes, lack of emergency procedures, lack of proper supervision of students, no training of students and teachers, etc. Most of these problems were also in violation of various federal and state laws. As a result, from the beginning, my consultation reports included a preliminary section on general recommendations for a health and safety program and safe procedures. With time, these general recommendations became more extensive as I tried to give art schools and art departments a more comprehensive health and safety program they could adapt to their institution. I finally decided that with reorganization and expansion, these general recommendations could constitute a separate health and safety manual that could be invaluable to art departments and art schools in setting up their own health and safety programs. Ann Toothaker of the Hudson Mohawk Association of Colleges and Universities was interested in the idea of such a manual for distribution to the various art departments in her Association. She provided some money from her grant from the New York State Department of Labor Occupational Safety and Health Training and Education Program to help develop a manual for New York State colleges in the Hudson Mohawk Valley. This manual is an expanded version of that manual. Acknowledgements Many of the chapters in this manual are adapted from various data sheets the Center for Safety in the Arts has produced over the years. In particular, the sections of Chapter 3 discussing the OSHA Hazard Communication Standard were adapted from a data sheet by Christine Proctor, M.S., C.I.H. Much of Chapter 10 on safety was adapted from material written by Angela Babin, M.S., Director of the Art Hazards Information Center of the Center for Safety in the Arts. The sections in Chapters 5 and 10 on waste management, and parts of Chapter 8 on fire safety were also adapted from data sheets co-authored with Angela Babin. I would also like to express my thanks to Ms. Proctor and Ms. Babin for their invaluable assistance in reviewing this manual and catching errors. CHAPTER 1. INTRODUCTION Over the last fifteen years, there has been growing concern about the hazards of art materials and processes. In fact, artists, art teachers, and even art students are developing many of the same occupational diseases as are found in industry. Of course this should not be entirely surprising, since artists use many industrial chemicals, often without knowledge of the hazards and how to work safely. These hazards are found in all different types of art media, as shown in Table 1-1, which is reprinted from the second edition of Artist Beware (Lyons and Burford, Publishers, New York, NY, 1992). Health and safety hazards in art schools and art programs in colleges and universities have resulted in injuries from fires and from accidents involving machinery, and occupational illnesses from exposure to toxic chemicals or other hazards. In certain cases, fatalities have resulted. Examples include bladder cancer in painters; lead poisoning in stained glass artists, potters, and enamelists; peripheral nerve damage in commercial artists; emphysema in acid etchers; aplastic anemia and leukemia from use of benzene; severe asthma among users of fiber-reactive dyes; cyanide poisoning and cadmium poisoning in jewelers, kidney damage from cadmium silver solders in jewelers; brain damage in silk screen printers; death of a weaver from anthrax; and metal fume fever in welders. In addition to possible injuries and illnesses, health and safety problems have legal implications. A variety of laws related to health and safety affect colleges and universities, including the Occupational Safety and Health Act, the Resource Conservation and Recovery Act, state workers' compensation laws, and local fire prevention laws. In addition, students, if injured due to the negligence of the teacher or college, can sue both the teacher and college. These laws are discussed in more detail in Chapter 6. A formal, effective health and safety program is a proven way to reduce the number of injuries and occupational illnesses. Aside from reducing the serious problems of loss of life and health, a health and safety program can reduce the number of workers' compensations claims and minimize the chance of lawsuits. An effective health and safety program is also important in accreditation of art schools. The National Association of Schools of Art and Design has made the adequacy of a health and safety program in college and university art departments a major factor in obtaining and keeping accreditation. Table 1-1. Hazards of Art Techniques CRAFT MATERIAL/PROCESS HAZARD Batik wax fire, wax fumes dyeing dyes Ceramics clay dust silica glazes silica, lead, cadmium, and other toxic metals slip casting talc, asbestiform materials kiln firing sulfur dioxide, carbon monoxide, fluorides, infrared radiation, burns Electroplating gold, silver cyanide salts, hydrogen cyanide other metals acids, electricity Enameling enamels lead, cadmium, arsenic, cobalt, etc. kiln firing infrared radiation, burns Forging hammering noise hot forge carbon monoxide, polycyclic aromatic hydrocarbons, burns Glassblowing batch process lead, silica, arsenic, other metals furnaces heat, infrared radiation, burns coloring metal fumes etching hydrofluoric acid, fluoride salts sandblasting silica Jewelry silver soldering cadmium fumes, fluoride fluxes, burns pickling baths acids, sulfur oxides gold reclaiming mercury, lead, cyanide Lapidary gemstones silica grinding noise, silica Lithography solvents mineral spirits,kerosene, gasoline acids phosphoric, nitric, hydrofluoric acids talc asbestiform materials inks see painting pigments photolithography solvents, dichromates Lost wax casting investment silica wax burnout wax fumes, carbon monoxide crucible furnace carbon monoxide, metal fumes metal pouring metal fumes, infrared radiation, burns sandblasting silica Neon signs neon tubes mercury, electricity, ultraviolet radiation, phosphors Painting pigments cadmium, cobalt, lead, manganese, mercury, etc. oils, alkyds turpentine, mineral spirits acrylics trace ammonia, formaldehyde Pastels pigment dusts see Painting pigments Photography developing bath hydroquinone, monomethyl- p-aminophenol sulfate, alkalis stop bath acetic acid fixing bath sulfur dioxide intensifier dichromates, hydrochloric acid toning selenium compounds, hydrogen sulfide sulfur dioxide, etc. color processes formaldehyde, solvents, color developers Relief printing solvents mineral spirits Screen printing pigments see Painting pigments solvents mineral spirits, toluene, xylene photoemulsions ammonium dichromate Sculpture, clay see Ceramics Sculpture,plastics epoxy resin amines, diglycidyl ethers polyester resin styrene, methyl ethyl ketone peroxide polyurethane resins isocyanates, organotin compounds, amines, solvents Sculpture, stone marble nuisance dust soapstone silica, talc, asbestiform materials granite, sandstone silica pneumatic tools vibration, noise Stained glass lead came lead soldering lead, zinc chloride fumes, burns etching hydrofluoric acid, ammonium hydrogen fluoride Weaving loom ergonomic problems dyeing dyes, acids, dichromates, Welding oxyacetylene carbon monoxide, fire and explosion, burns arc ozone, nitrogen dioxide, ultraviolet & infrared radiation, electricity, burns metal fumes copper, zinc, lead, nickel, etc. Woodworking machining toxic wood dust, noise, fire, injuries glues formaldehyde, epoxy paint strippers methylene chloride, toluene, methyl alcohol, etc. paints & finishes mineral spirits, toluene, turpentine, ethyl alcohol, etc. preservatives chromated copper arsenate pentachlorophenol, creosote Adapted from Artist Beware by Michael McCann (2nd ed., Nick Lyons Books, 1992) CHAPTER 2. A HEALTH AND SAFETY PROGRAM GOALS OF A HEALTH AND SAFETY PROGRAM The ultimate goal of a health and safety program is to reduce or eliminate occupational injuries and illnesses. However this goal, taken by itself, is insufficient. To provide a proper framework there is a need to develop clear and measurable objectives. These objectives then become a basis for assigning activities, allocating staff and funds, communicating information about the program and evaluating the effectiveness of the program. On this basis, more defined goals of a health and safety program would be: 1) to recognize hazards in the workplace, 2) to evaluate these hazards, and 3) to reduce the hazards to the extent possible. The various activities included in a health and safety program are all intended to effectively carry out the above defined goals. STRUCTURE OF A HEALTH AND SAFETY PROGRAM A formal health and safety program must have certain characteristics: * It must be recognized and supported by top levels of the administration. This is an essential step for the program to compete for funds and staff time, to exert authority and to initiate activities. * There must be specific individuals designated as responsible for the functioning of the health and safety program and who are accountable for its operation. * There must be defined, approved activities which are aimed at carrying out the objectives of the health and safety program. Administrative Support Without the active support of the administration, a health and safety program is doomed to failure. As mentioned it would not be able to compete for resources or effectively obtain the cooperation of other staff members. The most important visible step in showing administrative endorsement is the issuing of a policy statement by the Board of Trustees or other governing body of the institution. The policy statement should formally initiate the health and safety program, give its purpose, name the person responsible for the program, list the program functions, request the cooperation of all personnel, and indicate the Administration's intent to support the health and safety program and its initiatives. This policy statement should be posted and distributed to all personnel. (Figure 2-1 is a prototype policy statement.) ------------------------------------------------------------------------- Figure 2-1. Prototype Health and Safety Policy Statement The President of (college name), with the full endorsement of the Board of Trustees, states that it is the policy of (college name) to ensure that all students and staff have a safe and healthy learning and work environment, and to comply with all applicable safety laws and regulations. In order to provide and maintain this safe and healthy environment, I am appointing (name, title) as Program Administrator of the Health and Safety Program. The role of the Program Administrator is to assume responsibility for the Health and Safety Program, and to ensure that health and safety needs receive adequate priority in the overall administration of (college name). It is the policy of (college name) to purchase and use the least hazardous materials and processes available and feasible for intended uses, and to ensure that adequate precautions are taken when needed. We will also provide adequate education and training to all staff working with hazardous materials, in accordance with our Hazard Communication Program. We will also provide adequate education and training to all students in the hazards and precautions of the art materials and processes they will be using. It is the responsibility of Department Chairpersons and other supervisors to ensure that the Health and Safety Program is properly implemented. It is the responsibility of staff and students to follow safe working procedures, as determined by the Program Administrator. I urge all employees and students to cooperate in the implementation of this Health and Safety Program. It is my intention to ensure that appropriate measures are instituted to enforce this program. Signed, President, (college name) ------------------------------------------------------------------------ Responsibility for the Health and Safety Program A successful health and safety program should have two officers designated to perform distinctly different duties: 1) a Program Administrator, and 2) a Program Director. The program administrator has to represent and in essence lobby for the program at the top administrative levels and therefore should be a top administrative official, such as a Vice President. Since the health and safety program affects all levels of operation of an institution, it must not be placed under any one organizational line of authority, but must be independent of them. There should also be someone designated as health and safety program director to implement all the various aspects of the program. Many institutions have a safety officer on staff who may be fulfilling many of these functions. The health and safety program director should have additional knowledge and experience in industrial hygiene. These two active administrators will require the cooperation of everyone in the institution. The head of a department and other staff members have the responsibility to be alert to health and safety hazards, to inform the program director of these hazards, and to cooperate in the elimination of these hazards. HEALTH AND SAFETY COMMITTEES One of the most effective ways to involve others in the health and safety program is through the formation of a Health and Safety Committee. There could be an institution-wide Health and Safety Committee. For a small art school, this would be sufficient. However, for larger universities with a large staff, it would be advantageous to also form a separate art department Health and Safety Committee to specifically deal with the many hazards found in the various departments. Of course, there should also be a university-wide Health and Safety Committee. Function The major purpose of a Health and Safety Committee is to act as a conduit between the staff and the administration. Information on health and safety hazardsaccidents, recommendations, etc. are channeled to the administration from the staff through the Health and Safety Committee. Similarly, health and safety policy, rules, etc. are transferred to the staff via the Health and Safety Committee. In addition the Health and Safety Committee can participate in many of the activities of a health and safety program, such as inspections, accident investigation, education, developing recommendations, record-keeping, approving use of new materials, etc. Composition A Health and Safety Committee should be representative of all those working in the college or university - including teachers, technicians, maintenance, administration, and students - as well as people with health and safety responsibilities in the institution. Each committee member should have specific expertise and duties. The health and safety program director and program administrator should also be ex officio members. The optimum size for a Health and Safety Committee is from 6-10 people. (In a smaller institution where there are not at least six people available, all the various functions can be performed by a fewer number of persons if need be.) Obviously the amount of time spent on Committee activities will vary from person to person, depending on their job. Health and Safety Committee members should serve staggered terms of membership so that there is continuity of activity. Members should also undergo special training. Meetings Health and Safety Committee meetings should be held at least once monthly during regular working hours. Attendance should be mandatory. Formal procedures should be adopted for the meetings and careful minutes kept and posted in a conspicuous spot or sent out prior to the next meeting. Agendas should be drawn up, made public, and followed. It is crucial that all Health and Safety Committee activities be carefully documented. For example, recommendations for correction of health and safety problems should include what is to be done, by whom and when, how, and why the recommendations are needed. All of this should be in the minutes. This can be important in case of possible legal action, and also to document the effectiveness of the health and safety program. FUNCTIONS OF A HEALTH AND SAFETY PROGRAM There are a number of crucial activities that must be carried out in order to have an effective health and safety program. These are: * inspections; * hazard evaluation and control; * accident/illness reporting and investigation; * emergency planning; * education and training; * medical surveillance; and * monitoring and evaluation. Inspections One of the best ways to identify potential hazards is through regular inspections. Supervisors and staff usually carry out daily, informal inspections noting such problems as spills, failure of a ventilation system, hot plates left on, uncapped containers, etc. Problems that are found should be reported in writing to the Health and Safety Committee. In this way, deficiencies and hazards can be identified and corrected. However, more formal, periodic (ie. monthly) inspections are also needed. They can be carried out by trained Health and Safety Committee members or health and safety professionals if they exist. Checklists and formalized reports of findings are crucial for these inspections. Finally, outside professionals should be called in every few years to make an independent survey. This should especially be done if the institutions do not have a professional health and safety staff or if they do not have expertise in a given area, for example industrial hygiene. In some instances this might require specialized techniques such as air sampling. Some outside organizations that can assist in such surveys are: * State Consultation Plans: OSHA funds free consultative services in each state. In many cases these are operated by the state; in others, by universities. They will do an OSHA-like inspection, but they are not an enforcement agency. The only time they would report findings to OSHA would be in the case of imminent danger situations. You must agree, however, to implement their recommendations. * NIOSH Health Hazard Evaluation Program: This program is particularly useful where medical problems are occurring and their source is uncertain. NIOSH (National Institute for Occupational Safety and Health) can also provide medical evaluations during such a survey. * Environmental health departments of large universities: They are often looking for places where their industrial hygiene students can get experience, and can provide free assistance. * Insurance company loss control programs: Many insurance companies will conduct a survey at your institution if you request it. They will usually only pick up on major hazards and it is important that they be told everything you work with since they are often not overly familiar with art materials and processes. (This is also true of many of the other services mentioned.) * Private industrial hygiene firms or consultants: These can be good but expensive. The American Industrial Hygiene Association in Akron, Ohio has a list of consultants. I recommend only using firms that have a certified industrial hygienist on staff. Hazard Evaluation and Control Once hazardous conditions have been reported, they must be evaluated. Evaluation requires research into the particular hazards. To accomplish this, the institution will need a basic library of health and safety materials related to the chemicals and techniques used in their facilities. The references at the end of this chapter can help in establishing such a library. Another important resource is a complete and up-to-date file of Material Safety Data Sheets (MSDSs) on all products used. These are obtained from the manufacturer or distributor. (See MSDS section of Chapter 3.) Once the hazard evaluation step has been carried out, then it is necessary to decide what to do about the hazard. Since there are often a variety of hazards which need control or correction, and limited funds and time available to correct them, it becomes necessary to prioritize the hazards and to develop a timetable for appropriate action. By organizing the hazards according to their potential destructive consequences, it is possible to determine which conditions warrant immediate action, which can take secondary priority, and which can be addressed in the future. Without such a system, there can be no consistent guide for corrective action. Even worse, if time is not taken to rank hazards on a "worst first" priority basis, efforts and resources could be directed towards problems of lower consequence while those with greater potential for destruction will be overlooked. Accident/Illness Reporting and Investigation Most places have some sort of reporting mechanism for serious accidents and illnesses. Investigations of the causes of these accidents or illnesses can result in recommendations that can prevent a reoccurrence. However, cut fingers, spills, headaches, eye irritation, dermatitis, and other minor problems are often ignored until more serious manifestations such as a missing finger, fire, liver damage or chemical pneumonia result. If these earlier, minor problems were reported, investigated and their causes corrected, then the more serious problems might have been prevented. A formal reporting mechanism for all proven and suspect occupational illnesses, accidents and spills, including near misses, should be developed. A report form to be filled out by the supervisor should be provided for this purpose. In some instances the health staff may be the ones to discover problems. In such a case they also should fill out a reporting form. These reports should go to the Program Director or Health and Safety Committee, which should designate someone to investigate the cause of the problem and to recommend corrective action. The resulting investigative report should be discussed by the entire Committee and its recommendations recorded in the minutes. Emergency Planning A major component of any effective health and safety program is a detailed emergency plan. Such emergency plans are required by OSHA and the Environmental Protection Agency, and should cover fire, chemical spills, emergency abort procedures and other contingencies. Chapter 4 of this manual covers emergency procedures. Education and Training Education and training is one of the most crucial elements of any health and safety program. Anyone using chemicals or machinery should receive education about the hazards of the chemicals and processes they are using, and training in how to work safely. Education and training is covered in Chapter 3. Medical Surveillance A medical surveillance program should be established for staff. This program can involve two aspects: detecting pre-existing medical conditions which could put particular individuals at greater risk, and monitoring those exposed to toxic chemicals or harmful physical agents for signs of illness. Under the Americans with Disabilities Act of 1990 (see Chapter 5), it is illegal to discriminate against qualified job applicants (those meeting the "essential functions" of the job description). Pre-employment physical examinations and questions about disabilities are not permissible, although preplacement medical examinations can be performed after an employment offer has been made to determine pre-existing medical conditions or as baselines to monitor on-going changes, if such exams are given to all applicants. Some OSHA regulations require such medical examinations. If a pre-existing condition is found, then the ADA would require "reasonable accommodation" to ensure that the person would not be placed at risk of further damage. For example, a hearing impaired individual might require special measures such as engineering controls or hearing protectors to protect their hearing in a noisy environment that might not be dangerous to non-hearing impaired people. All individuals hired for a job with high noise exposure, for example, should have a baseline audiogram. Then regular audiometric examinations in this example would help monitor any changes in their hearing status. In fact, this is required by OSHA for exposures over 85 decibels. Similar types of medical surveillance could be applicable to exposure to lead, cadmium, silica and other chemicals which can cause occupational illnesses, and in some cases are also required by OSHA regulations. Monitoring and Evaluation of the Health and Safety Program Monitoring and evaluation of the effectiveness of a health and safety program is essential to ensure that the program is actually carrying out its functions of preventing injuries and illnesses, and to provide objective criteria to prove this to the administration. Monitoring of a health and safety program is the day-to-day review of its progress. This ensures that inspections are being carried out, that accidents and illnesses are properly reported and investigated, that recommendations are actually being carried out on schedule, and that health and safety training is adequate. The evaluation of a health and safety program is an overall review of the program itself to see that it is functioning properly. Often this is best done by an outside evaluator. ART DEPARTMENT PROCEDURES Traditional experimental attitudes on the part of art students and some teachers often create situations with the potential for serious health and safety problems, and the possibility of liability on the part of the school in case of an accident or occupational illness. In order to exert some control over these potentially hazardous situations, but still not stifle student initiative, standard procedures are needed. Approval Mechanism The health and safety program director or designee (e.g., health and safety committee) should formally evaluate and approve all proposed changes in art processes and materials to determine if they can be used safely in a particular studio. This includes not only regular course materials, but also individual projects being carried out by students. Material Safety Data Sheets (MSDSs) should be obtained on all proposed art materials in order to assist in this evaluation. When necessary, outside technical assistance should be obtained to evaluate the safety of a material or process. Purchase of Art Materials Whenever possible, art materials should be centrally ordered in order to have control over the ordering process. If individual departments order their own materials, then there should be a central approval mechanism for all new materials, as discussed above. Material Safety Data Sheets should be obtained from suppliers as a condition of purchase. For new materials, MSDSs should be obtained in advance in order to evaluate the material for approval. In order to ensure that MSDSs are obtained when needed, the purchase order should contain a box indicating yes or no for MSDS required. Filling out this box by the person requesting the purchase should be mandatory. Students should only be allowed to purchase art materials on an approved inventory list, unless special documented permission is obtained. MSDSs should be obtained. (See Chapter 3 for more information on MSDSs.) STUDENT SUPERVISION Traditionally, art schools have taken a very laissez-faire attitude towards students working after hours on class assignments, and have even encouraged it. In many schools, students have keys and can get into art buildings at any time of the day or night. Unfortunately, this has had serious consequences, including injuries and death. In addition to the health risks from the art materials, allowing students unlimited access to studios can create other problems. For example, if security personnel are not aware that students are in a building, then these students might not be informed of possible emergencies such as a fire. Unrestricted access has also resulted in vandalism and violent crime. One of the most important ways to minimize these hazards is for colleges to expand the hours in which studios are supervised (or to close the studios). This would be particularly important for studios such as sculpture and woodworking where extensive safety hazards exist. An alternative, which is used by many universities, is to lock all dangerous equipment after hours. There are two aspects to the problem of students working unsupervised. First, at what stage of his or her education should an art student be allowed to work unsupervised? Second, what restrictions should apply to protect the student and the university? Written procedures are needed for evaluating when students are allowed to work unsupervised in regular studios or in individual studio spaces. These procedures should include the experience of the students and the amount of training in safety and emergency procedures necessary for students to work unsupervised. In general, I do not think first or second year students have the experience with art processes to work unsupervised. More advanced students should have at least a 3-hour lecture on art hazards and precautions, along with training in the college's emergency procedures, before being allowed to work unsupervised. There are two major restrictions that should apply to working unsupervised. First, no one should be allowed to work alone, in case of emergencies. Second, there should be restricted access. Students should not have keys. Instead, there should be a sign-in and sign-out procedure with regular checks by security. Methods of indicating who is approved to work unsupervised could include a pass system or list of approved students available to the guards. Such a check-in system is also important to allow emergency personnel to know who is inside a building in case of emergency. Safety Procedures for Individual Studios Many art schools have individual studios or group studios for senior students or graduate students. Written safety procedures, including penalties for noncompliance, should be developed for such studios. These rules should include what materials can be used (which can depend on the ventilation), no smoking, drink or food in studios, etc. Students should have to sign a contract agreeing to these rules in order to be assigned a studio. Enforcement procedures should be developed, including possible loss of studio privileges. Similar procedures should be developed for students working unsupervised in regular classroom studios. ART DEPARTMENT HEALTH AND SAFETY MANUAL The art department should develop its own health and safety manual and distribute it to all employees and students. The health and safety manual should include at least the following topics: * the administration's health and safety policy statement; * roles and responsibilities of health and safety personnel and the health and safety committee; * procedures for ordering materials; * a formalized inspection program; * safe working procedures for standard activities; * proper waste management procedures * emergency procedures; * a list of mandatory safety rules and penalties for noncompliance; * accident/illness reporting procedures; and * procedures for obtaining safety information and equipment. Many of the sections in this manual could become part of the art department health and safety manual. REFERENCES 1. A. M. Best Company. (1990). Best's Safety Directory. two volumes. Oldwick, NJ. Updated regularly. 2.American Conference of Governmental Industrial Hygienists. (1992). Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment. ACGIH, Cincinnati, OH. 3. American Mutual Assurance Alliance. (1986). Handbook of Organic Industrial Solvents. 6th edition, Chicago, IL. 4. Clark, N., Cutter, T., and McGrane, J. (1984). Ventilation. Lyons and Burford, Publishers, New York, NY. * 5. Hawley, G. (Ed.) (1981). The Condensed Chemical Dictionary. 10th ed., Van Nostrand-Reinhold, New York, NY. 6. Lewis, R.J. (1992). Sax's Dangerous Properties of Industrial Materials, 3 volumes. 8th ed. Van Nostrand Reinhold, New York, NY. 7. McCann, M. (1992). Artist Beware. 2nd ed., Lyons and Burford Publishers, New York, NY. * 8. National Institute for Occupational Safety and Health. (1990). NIOSH Pocket Guide to Chemical Hazards. DHHS (NIOSH) Publication No. 90-117. Government Printing Office, Washington, DC. Updated regularly. 9. National Institute for Occupational Safety and Health. (1979). Occupational Safety and Health in Vocational Education. DHEW (NIOSH) Publication 79-138. DHEW (NIOSH), Cincinnati, OH. 10. Occupational Safety and Health Administration. (1989). General Industry Occupational Safety and Health Standards. 29 CFR 1910. U.S. Department of Labor, Washington, DC. 11. Patty, F. (Ed.) (1982). Industrial Hygiene and Toxicology. Vol. II, 3 parts. 3rd ed., Interscience Publishers, New York, NY. * These are available from the New York Committee for Occupational Safety and Health. CHAPTER 3. HAZARD COMMUNICATION The OSHA Hazard Communication Standard (29 CFR 1910.1200) applies to all employees in the United States who are exposed or potentially exposed to hazardous substances at their workplace. The purpose of the Hazard Communication Standard is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees by means of comprehensive hazard communication programs. Such hazard communication programs must include container labeling and other forms of warning, material safety data sheets and employee training. WHO IS COVERED Because OSHA's provisions do not apply to state and local governments in their role as employers, public employees such as state college teachers are not covered by the Hazard Communication Standard unless they work in a state with an OSHA-approved state plan. For example, New York has an approved state plan that covers public employers, such as state colleges, called Public Employee Safety and Health (PESH). Private colleges are covered under federal OSHA. The 25 States with their own OSHA-approved occupational safety and health plans must adopt a comparable standard within 6 months of the publication date of a final standard. These states include: Alaska, Arizona, California, Connecticut (for State and local government employees only), Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, Virgin Islands, Washington, and Wyoming. Federal workers are covered under executive order. The Hazard Communication Standard preempts all state (in states without OSHA-approved job safety and health programs) or local laws which relate to an issue covered by the federal standard. The only state worker right-to-know laws authorized would be those established in states and jurisdictions that have OSHA-approved state programs, for example, New York. WHAT IS COVERED A chemical is considered hazardous by OSHA if it poses a physical or health hazard. Health hazards may include both acute and chronic health effects. Physical hazards include combustible liquids, compressed gases, explosives, flammables, organic peroxides, oxidizers, pyrophorics, and unstable or water-reactive chemicals. The burden of evaluating chemicals to determine whether they are hazardous remains on the chemical manufacturers and importers who produce or import such chemicals. Certain products are not covered under the Hazard Communication Standard, including hazardous waste, wood or wood products, articles (defined as manufactured items), foods, drugs, or cosmetics intended for personal consumption in the workplace, and any consumer product or hazardous substance as defined by the Consumer Product Safety Act and Federal Hazardous Substances Act that is used in the workplace in the same manner as normal consumer use. Although wood and wood products are exempted from the requirements of the standard, wood dust is not exempted, and is considered a "hazardous chemical". WORKPLACE INVENTORY The first step in developing a hazard communication program is to assemble an inventory of all hazardous substances present in the workplace. Material Safety Data Sheets should be obtained for all products with warnings of any type on the label. The inventory list should include the product name, the manufacturer, hazardous components, and location where the product is used or stored. The type of hazard (fire, health, etc.) and the amount of the product would also be useful information for the inventory. This inventory should be updated annually. LABELS Containers must be labeled with the identity of the hazardous chemicals and provide hazard information in the form of words, pictures, symbols or a combination thereof. The purpose of the label is to serve as an immediate visual warning of the chemical hazards in the workplace. Certain products or chemicals are exempt from labeling requirements if they are labeled in accordance with other Federal regulations and include pesticides and consumer products. If chemicals are dispensed from a large container into a smaller container, the new container must be labeled (unless it would be used up in one day). MATERIAL SAFETY DATA SHEETS The college must obtain Material Safety Data Sheets (MSDSs) on all hazardous products. These MSDSs are produced by the manufacturer or importer of a hazardous product. MSDSs are not required for non-hazardous products, although many manufacturers of art materials provide MSDSs for their nonhazardous products, with a statement saying the product is nonhazardous. The manufacturer must provide distributors and other customers with MSDSs, upon first purchase of a hazardous product, and if the MSDS changes. Distributors of hazardous chemicals must automatically provide MSDSs to commercial customers, including colleges. MSDSs should be stored centrally, as well as in the area where the product is used. I recommend storing the MSDSs in a three-ring binder for easy access. SARA and MSDSs Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA) also requires employers covered by the Hazard Communication Standard to maintain MSDSs and submit such information to State emergency response commissions, local emergency planning committees, and local fire departments if the chemical is present in excess of reporting thresholds (see the SARA section of Chapter 5). This provides information to fire departments and the community in case of fire and other emergencies. The reporting thresholds are 10,000 pounds for chemicals not on the Extremely Hazardous Substance List, and 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for chemicals listed as Extremely Hazardous Substances (EHS), as reported in the Federal Register, April 22, 1987 (52 FR 13378). The only chemicals on the Extremely Hazardous Chemical List likely to be found in Art Departments in excess of the reporting thresholds are sulfuric acid and nitric acid. The reporting threshold for each of these is 500 pounds (approximately one 55-gallon drum). If an EHS is present in greater quantities than its TPQ (1000 pounds for each), then the college has to cooperate with local emergency authorities in emergency planning under section 303 of SARA, as well as more detailed inventory reporting under section 312 of SARA. Note that the total amount any EHS on the campus has to be counted in determining whether the reporting threshold has been reached, not just the amount in the Art Department. Understanding MSDSs OSHA has a standard MSDS format. Manufacturers are not required to use this format as long as all the required information is present. The MSDS must be in English and must have no blank spaces. The following gives information on what should be contained in the various sections of a MSDS: Identity The identity of the product should be the same name as found on the product label. Section I The MSDS must have the name, address, and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing the MSDS who can give further information on the product hazards and emergency procedures. It must also give the date of preparation of the most recent version. Section II - Hazardous Ingredients/Identity Information: This must include the chemical and common names of hazardous ingredients. For mixtures that have been tested as a whole, only the ingredients found to be hazardous must be listed. If the mixture has not been tested, all toxic ingredients at a concentration greater than 1% must be listed, as well as all carcinogenic ingredients at concentrations over 0.1%. Materials are considered hazardous if they are listed in OSHA's Z list (29 CFR 1910, Subpart Z, Toxic and Hazardous Substances), if the American Conference of Governmental Industrial Hygienists has assigned a Threshold Limit Value (TLV) to the material, or if it has been found to be toxic, carcinogenic, irritating, sensitizing or damaging to certain body organs. The MSDS does not have to list the percentage concentration of each ingredient. This section must also have the OSHA Permissible Exposure Limit (PEL), the ACGIH Threshold Limit Value (TLV) or any other exposure limit used by the manufacturer. The one exception to listing the chemical names or common names of hazardous ingredients, according to OSHA, is if the manufacturer claims, and is able to document, that it is a trade secret. In this case, the manufacturer must state on the MSDS that the identity of the ingredients is a trade secret. Section III-Physical/Chemical Characteristics: This section should include information on boiling point, vapor pressure, vapor density, solubility in water, specific gravity, percent volatile, evaporation rate and appearance and odor. Sometimes the pH is included for aqueous solutions. Section IV - Fire and Explosion Hazard Data: This section has information on the flammability of the product, on types of fire extinguishers needed, and on other special precautions. This data is important when planning for emergencies. Section V - Reactivity Data This section tells you about the product's compatibility with other chemicals, and special conditions to avoid. The stability of the product indicates whether the product can decompose and what conditions can do this. The incompatibility section tells you what chemicals can react with the product. This section is very important in determining what materials you should not store near this product. Hazardous decomposition products tells you what hazardous chemicals can be produced when the product is heated or burned. The hazardous polymerization section tells you whether the product can polymerize, and what conditions can cause this. Section VI - Health Hazard Data This section should tell you the routes (skin contact, inhalation, ingestion) by which the product can affect you, the symptoms of overexposure, acute and chronic health effects, emergency first aid measures, and carcinogenicity. If the product, or chemicals in the product, has been found to be a carcinogen or probable carcinogen by the International Agency for Research on Cancer (IARC) or OSHA, or is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens, then the MSDS must state so. It should also list medical conditions which could be aggravated by exposure to the product. Section VII - Precautions for Safe Handling and Use This section covers such topics as spill control, waste disposal, storage and handling precautions, and other special precautions such as personal protective equipment needed for spills. Unfortunately, the section on waste disposal often just says dispose of according to local, state and federal regulations. Section VIII - Control Measures This section should give you a lot of information about respirators, ventilation and other personal protective equipment, but often doesn't. The respirator recommendations should state what type of cartridge should be used. The ventilation section should tell you whether general mechanical ventilation (dilution ventilation) is sufficient, or if local exhaust ventilation is recommended, and if so, what type. This section should also list other recommended personal protective equipment such as gloves, goggles and protective clothing. Unfortunately most MSDSs do not tell you what type of glove to use. SIGNS Signs are a useful adjunct to other hazard communication methods. Signs can be used in a given area to describe normal procedures, for example, how to use a given piece of equipment, or for restrictions, for example, that solvents should not be used in a glaze spray booth. Some OSHA standards also require warning signs on rooms restricting access, for example with certain carcinogens. Another major purpose of signs is for emergencies. Signs should be used to indicate the location of emergency equipment such as fire extinguishers, emergency showers and eyewash fountains. In addition, signs are required for emergency procedures, such as evacuation in case of fire or spills. TRAINING AND EDUCATION Under OSHA's Hazard Communication Standard, education and training must be provided to the employee at the time of the initial work assignment, whenever a new hazard is introduced into the work area, or when new information becomes available. Employees must be given information on the following topics: * discussion of employee rights and employer responsibilities under the OSHA Hazard Communication Standard; * location and employee access to the written Hazard Communication Program, including any inventory lists of hazardous chemicals; * location and employee access to MSDS collections; * instructions in the use and interpretation of product labels and MSDSs; and * operations in the work area where hazardous materials are present. The training requirements must include detailed information on hazardous materials stored or used in their workplace, including: * methods and observations employees can use to detect the presence or release of hazardous chemicals (e.g. appearance, smell, monitoring); * the physical and health hazards of hazardous materials present in the workplace; and * measures employees can take to protect themselves, including appropriate work practices, emergency procedures, and personal protective equipment. Student Training Although the Hazard Communication Standard requires only training of employees, I recommend that students also receive training in the hazards of art materials and suitable precautions. Besides protecting students, this training is also essential for liability reasons. First year students should receive a hazard awareness lecture to alert them to potential hazards and suitable precautions. A more detailed course at this level is not likely to be effective since most of the students will not have much experience with the art materials and processes. A more detailed course - approximately 15-20 hours in length - could be given at a more advanced level. Students should be tested in writing on their knowledge of health and safety, and copies of these tests kept for documentation. Training Programs The Center for Safety in the Arts had a variety of educational programs aimed at providing this training, including l) a 2-3 hour awareness lecture, 2) full day training workshops, and 3) 18-hour courses on art hazards. These are available independently by CSA staff. For further information write CSA or visit the CSA web site. In addition, CSA has available a two-hour videotape on art hazards entitled Art Safety: Hazards and Precautions, which can be used for training students and staff. CSA has a wide variety of written materials on art hazards which can be used in training, including the new second edition of Dr. McCann's book Artist Beware. Art Hazards News is a newsletter published by the Center for Safety in the Arts which provided up-to-date-information on hazards, precautions, regulations, lawsuits, etc. that are related to art hazards. There are four 8-page issues and one 24-page Resource Issue annually. CSA also has consultative and other programs for Art Departments of colleges and universities. (See Appendix 1.) WRITTEN HAZARD COMMUNICATION PROGRAM A written hazard communication program must be developed and implemented for each workplace. This written program must describe how the Hazard Communication Standard will be implemented in your workplace. This written program must be available to employees, designated representatives of the employees, and OSHA and NIOSH (National Institute for Occupational Safety and Health). Employers must establish an information and training program for employees exposed or potentially exposed to hazardous chemicals. This written hazard communication program must include the following: * description of hazard determination procedures; * description of labeling procedures; * description of MSDS collection and review procedures; * description of employee information and training programs; * description of methods to be used to exchange MSDSs and information concerning labeling and work practices with other employers at the worksite; and * listing of all hazardous chemicals known to be present in the workplace. Figure 3-2 is a sample written Hazard Communication Program which could be adapted to the needs of individual colleges. Figure 3-2. Sample Written Hazard Communication Program NOTE: The written program must include the specific methods that are used to achieve compliance with the requirements of the Hazard Communication Standard (29 CFR 1910.1200). The specific methods described in this sample written program are for illustrative purposes, and other effective methods may be substituted to satisfy local needs or practices. I. General The purpose of this instruction is to ensure that (college name) is in compliance with the OSHA Hazard Communication Standard (HCS) 29 CFR 1910.1200. (name, title) is the overall coordinator of the Hazard Communication Program, acting as the representative of the Health and Safety Program Administrator, who has overall responsibility. In general, each employee will be informed of the substance of the HCS, the hazardous properties of chemicals they work with, and measures to protect themselves from these chemicals. II. List of Hazardous Chemicals The (title) will maintain a list of all hazardous chemicals used in the facility, and update the list as necessary. The hazardous chemical list will be updated upon receipt of hazardous chemicals at the facility. The list of hazardous chemicals is maintained at (location). III. Material Safety Data Sheets (MSDSs) The (title) will maintain an MSDS library on every product containing a substance on the list of hazardous chemicals. This MSDS library will be located in the (location). The MSDS will consist of a fully completed OSHA Form 174 or equivalent. The (title) will ensure that each work area maintains an MSDS for hazardous materials used in that area. MSDSs will be readily available to all employees. The (title) is responsible for acquiring and updating MSDSs. The (title) will review each MSDS for accuracy and completeness, and will consult with the Health and Safety Program Administrator if additional research is necessary. All new products procured for the facility must be approved by the Program Administrator or his or her designee(s). Whenever possible, the least hazardous substance will be used. MSDSs that meet the requirements of the HCS must be fully completed and received at the facility either prior to, or at the time of receipt of the first shipment of any potentially hazardous chemical purchased from a vendor. It may be necessary to discontinue procurement from vendors failing to provide approved MSDSs in a timely manner. IV. Labels and other Forms of Warning The (title) is designated to ensure that all hazardous chemicals in the facility are properly labeled. Labels should list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer or other responsible party. The (title) will refer to the corresponding MSDS to verify label information. Immediate use containers, small containers into which materials are poured for use on that shift by the employee drawing the material, do not require labeling. To meet the labeling requirement of HCS for other in-house containers, refer to the label supplied by the manufacturer. All labels for in-house containers will be approved by the (title) prior to their use. The (title) will check monthly to ensure that all containers in the facility have up to date labels. V. Training Each employee who works with or is potentially exposed to hazardous chemicals will receive initial training on the HCS and the safe use of those hazardous chemicals. Additional training will be provided for employees whenever a new hazard is introduced into their work areas. Hazardous chemical training is conducted by (title). (Attach a copy of course outline, training schedules, and a description of course materials). The training will emphasize these elements: * a summary of the standard and this written program; * hazardous chemical properties including visual appearance and odor and methods that can be used to detect the presence or release of hazardous chemicals; * physical and health hazards associated with potential exposure to workplace chemicals; * procedures to protect against hazards, e.g., personal protective equipment, work practices, and emergency procedures; * hazardous chemical spill and leak procedures; and * where MSDSs are located, how to understand their content, and how employees may obtain and use appropriate hazard information. The (title) will monitor and maintain records of employee training and advise the facility manager on training needs. VI. Contractor Employers All outside contractors must notify the Health and Safety Program Administrator, or his or her designee, in advance of proposed activities. If these activities will involve the use of hazardous products, the contractor must provide MSDSs. The (title), upon notification of proposed activities, will advise contractors of any chemical hazards which they may encounter in the normal course of their work on the premises. VII. Non-Routine Tasks Any supervisor contemplating a non-routine task, e.g. boiler repair, will consult with the (title), and will ensure that employees are informed of chemical hazards associated with the performance of these tasks and appropriate protective measures. This will be accomplished by a meeting of supervisors and the Health and Safety Program Administrator, or his or her designee, with affected employees before such work is begun. VIII. Additional Information Further information on this written program, the hazard communication standard, and applicable MSDSs is available at (location & telephone no.). REFERENCES 1. Accrocco, J.O. (1988). The MSDS Pocket Dictionary. rev. Genium Publishing Company, Schenectady. 2. Occupational Safety and Health Administration. (1985). Hazard Communication. 29 CFR 1910.1200. U.S. Department of Labor, Washington, DC. CHAPTER 4. EMERGENCY PROCEDURES Emergency procedures are a major, neglected area in many colleges. However, they are essential. If written emergency procedures are not developed beforehand, then someone is going to have to develop them on the spot in an emergency, a situation not to be recommended. Most colleges have emergency plans in case of fire because of the grave threat to both occupants and property. However there are many other types of emergencies which can require evacuation or other emergency procedures. These include natural disasters such as floods and hurricanes, electrical failure, sprinkler leakage, bomb threats, chemical contamination, medical emergencies, etc. In addition, art departments can have emergencies such as toxic chemical spills, fires and explosions, and personal injuries from accidents involving machinery. Whether the emergency emanates from an art studio or in an unrelated section of the college, the art department staff must be able to safely shut-down any process at any point and prepare to evacuate the building. Failure to have pre-planned emergency abort procedures for such processes as a foundry pour, for example, could result in a more serious emergency than the original one. GENERAL EMERGENCY PROCEDURES OSHA requires that all employers have written emergency action plans. According to 29 CFR 1910.38(a)(2), the emergency action plan must, at a minimum, contain the following elements: * emergency escape procedures and escape route assignments; * procedures to be followed by employees who remain to perform (or shut down) critical processes before they evacuate; * procedures to account for all employees after emergency evacuation has been completed; * rescue and medical duties for those employees who are to perform them; * preferred means for reporting fires and other emergencies; and * names or regular job titles of persons or departments to be contacted for further information or explanation of duties under the plan. The plan developed must cover the college as a whole, as required by OSHA regulations. The art department, however, because of the special hazards found there, needs to develop its own emergency procedures which should be incorporated into the overall college emergency plan. There are three main steps involved in the preparation and implementation of an emergency plan: 1) planning and documentation of such, 2) training, and 3) periodic drills. All three of these are crucial if the emergency plan is going to work as intended. Planning The effectiveness of the emergency plan will depend primarily on the amount of planning. The first step of the planning stage involves identifying all the potential emergencies that could develop. Next, procedures must be developed which will be followed in case of an emergency. In particular, this involves establishing a chain of command, and assigning particular roles to employees, and developing the following procedures: * an adequate emergency communications system of alarms and notifications; * a detailed evacuation procedure; * shutdown procedures; and * procedures for meeting other types of emergencies. It is important to involve all employees in this planning process in order to ensure maximum effectiveness of the final emergency plan. Role of Staff The emergency plan, when formulated, will rely on various staff members to form Emergency Teams and carry out the various emergency procedures developed. An Emergency Coordinator should be appointed to coordinate the work of the Emergency Teams. The duties of this coordinator include: * assessing possible emergencies to determine the response needed; * directing the emergency response effort; * calling in outside emergency services such as the fire department and medical aid as needed; * directing shutdown of the college when necessary; and * directing/determining safe re-entry or other post-emergency procedures. Since the role of the Emergency Coordinator is so crucial, it is essential that a back-up coordinator be appointed. In addition there must be adequate trained personnel for the Emergency Teams themselves so that trained teams are always available. Depending on the size of the college there may be more than one team trained for various types of emergencies. Possible areas in which teams have to be trained include: * use of various types of fire extinguishers; * first aid, including cardiopulmonary resuscitation (CPR); * shutdown procedures; * evacuation procedures; * chemical spill control procedures; * use of self-contained breathing apparatus (SCBA); and * search and emergency rescue procedures. Obviously many of the emergency functions would be college-wide rather than specific to the Art Department. First aid and evacuation procedures, for example, are often assigned to security staff since they are well-acquainted with the buildings and all their exits. In addition they are usually readily available in case of emergency. In some instances, security guards might also be trained in emergency search and rescue procedures, although this is often left to police or fire-fighters. This might be particularly important when students or staff with disabilities need to be evacuated (e.g., people in wheelchairs or with disabling diseases such as severe emphysema). Of course, if security guards are going to have expanded roles beyond their original guard duties, then the increased responsibility must be accompanied by more careful recruiting, more training, and even higher pay scales. In all these situations, it is important that members of Emergency Teams be able to determine when not to intervene. They must be trained to recognize when a fire or other emergency is beyond their capability to handle. If there is a chance that team members might receive fatal or disabling injuries, they should wait for professional fire-fighters or emergency response teams. In many instances, especially in small colleges, it might not be practical to have Emergency Teams for all these emergencies, and instead they should rely on outside help, for example, Fire Department HazMat Teams. Communications There are three groups of people who need alerting in case of an emergency: employees and others in the college; Emergency Teams; and special groups of people outside the college. Alarm system: An alarm system is needed to alert people inside the building as to the emergency and the need for evacuation. OSHA regulations (29 CFR 1910.165) requires that alarm boxes be available within a travel distance of 200 feet. Recommended alarm systems include supervised telephone, manual fire alarm, or pull box stations with paging systems to transmit messages throughout the building. Special alarm systems connected to smoke detectors, sprinkler systems, ventilation systems or the like can also be part of the overall alarm system. In addition, special alarms to alert visually or hearing impaired individuals should be considered. Note that these alarm systems should have an independent power supply in case the emergency affects the electrical system. The alarm system must be distinctive so that employees will easily recognize it and respond quickly. In addition, each employee should be informed as to the proper procedures for reporting emergencies. Emergency communications system: This is needed for the Emergency Teams. Portable radio units are the best for this. The office of the Emergency Coordinator should serve as the headquarters for coordinating emergency efforts. In case of evacuations, the reporting area for evacuees might be the best location for an alternate headquarters for quickness of communications. Outside notification: There are a number of people outside the college who should be notified in case of emergencies. In some instances colleges choose to connect alarm systems to a central facility such as the guard station and whoever is on duty there has the responsibility to notify the appropriate outside people. An up-to-date, written list of key personnel to be notified in order of priority must be easily accessible. One such group consists of local authorities such as the fire department, police department, Health Department, OSHA, and other emergency services. Where appropriate, alarm systems should be directly connected to appropriate authorities. The other group that might need notifying would include top college administration officials, staff physician, and other off-duty essential personnel. Evacuation Procedures Emergency evacuations should be considered even as the building is planned and built. At this time, the proper number of exits and routes should be incorporated into the building. The Life Safety Code and OSHA regulations specify building construction, numbers, locations and sizes of exits, access to exits, marking of exits, etc. (29 CFR 1910.36 and 1910.37). (See Chapter 10.) The essence of the regulations are that repetitive and well-marked exit routes be provided for each and every building occupant. While OSHA regulations do not cover students or visitors, they must be considered an additional dimension to the evacuation problem. Evacuation routes should be clearly identified for each working location. Floor plans showing evacuation routes and any safe areas should be included in the plan and also located in visible spots throughout the building. The crucial factor in planning evacuation routes and procedures is getting everyone out of the building in the shortest time possible. The plan should include descriptions of particular duties assigned to employees including those needed to: * maintain essential services; * assist evacuation; * count staff; * check for total evacuation; and * attend to any first aid needs. Special attention has to be given to the problem of evacuating persons with disabilities. This not only includes the obvious examples of disabilities such as people in wheelchairs, and visually and hearing impaired persons, but also people with less obvious mobility impairments such as severe emphysema, heart problems, or advanced age. Such people might not be able to move fast enough on their own to leave the building in a short enough period of time. Procedures for evacuation of persons with disabilities might include training of security guards in moving people in wheelchairs, provision of safe areas to wait for evacuation assistance, etc. The emergency coordinator should have knowledge of the locations of disabled employees and students. Training Without proper training of all employees about emergency procedures, the emergency plan remains just a piece of paper. There are several levels of training required. All employees and students should receive training in how to report an emergency, how to recognize emergency communications, and how to escape. Depending upon the nature of the emergency plan, all, some or no employees will receive training in how to use fire extinguishers and how to give emergency first aid. Emergency Teams will receive specialized training depending upon the nature of their assignment. In particular, personnel responsible for responding to chemical spill and leak emergencies will require specialized training in the proper selection and use of such personal protective equipment as face and eye protection, gloves, whole body suits, and self-contained breathing apparatus (SCBA). Insufficient training in the use of personal protective equipment could result in severe injuries or even fatalities to Emergency Team personnel in actual emergencies. Training needs to be done at the following times: * when the emergency plan is first developed; * when it is updated; * when new equipment, materials or processes are introduced; * for all new employees, or if an employee gets new duties; * if drills indicate the need for further training; and * at least annually. While some of the above mentioned training can be provided by supervisory staff (e.g. drill procedures), certain areas require outside personnel to properly and effectively carry out training programs (e.g. use of SCBA gear). Drills Rather than wait for an actual emergency to test the effectiveness of an emergency plan, regular drills should be instituted. Fire drills are the classic form of emergency drill. These should be carried out semi-annually and only a few crucial individuals such as the Emergency Coordinator, the chief of Security and the college president should know about the drill in advance. The fire drill should also be held in conjunction with your local fire department. It is essential that all staff and students participate in the drill and this should be enforced by college administrators. If the college has certain activities that go on that should not be disrupted except in an actual emergency, then possibly advance warning could be given that an emergency drill will be held during a certain period (e.g. a week). During this period, no crucial activities should take place that could not be interrupted so as to ensure that all personnel participate in the drill. Note that special drills might be necessary to practice shutting down these special activities in case of an actual emergency. A fire drill is the most common type of emergency practice. However drills for other types of emergencies, such as a medical emergency, chemical spill or leak of toxic gas should also be instituted. In many cases these would not involve evacuation so that there would be minimal disruption of college activities. Evaluation Once the drill is completed, an evaluation of its effectiveness must be carried out. Critical areas for evaluation include number of people evacuated, number of people left inside the building and unaware of the drill, and people "late" in leaving the building (i.e. past the evacuation time goal). Comparisons of average and slow evacuation times are useful for re-planning evacuation routes. FIRE EMERGENCIES Fire prevention plans shall contain the following minimum elements, according to 29 CFR 1910.38(b): * a list of major workplace fire hazards and their proper handling and storage procedures, ignition sources, and control procedures; and * names of job titles of personnel responsible for maintaining fire control procedures and equipment The fire control plan shall also cover housekeeping procedures, training and maintenance. Fire safety is discussed in detail in Chapter 8. REGULATIONS FOR SPILLS AND LEAKS Spills and leaks of chemicals can create significant fire and health risks. The Occupational Safety and Health Administration (OSHA), under its Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120), requires schools, colleges and other employers to develop procedures for emergency response to spills and leaks. Employers who do not operate an EPA or state-permitted hazardous waste treatment, storage and disposal facility must comply only with paragraph (q) of this standard. Section 304 of the Superfund Amendments and Reauthorization Act (SARA) has emergency notification of various emergency authorities in cases of releases of toxic chemicals into the environment in excess of reportable quantities. In addition, RCRA requires large and small quantity generators to appoint an emergency coordinator who is present or on call, and the development of an emergency/contingency plan in case of spills or leaks of hazardous waste that could expose the public or contaminate the environment (40 CFR 262.34). The emergency plans developed in this section could fulfill this requirement. OSHA Definition of Emergency Response According to paragraph (a)(3) of the OSHA standard (29 CFR 1910.120), an "Emergency Response" means "a response effort by employees from outside the immediate release area or by other designated responders (e.g., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard. Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses." Procedures for non-emergency spills and leaks, as defined above, are discussed in a later section. Emergency Response Plan Paragraph (q) of this standard requires employers to develop a written emergency response plan. This plan shall address the following points, unless already covered in the Emergency Action Plan (29 CFR 1910.38): * pre-emergency planning and coordination with outside parties; * personnel roles, lines of authority, training, and communication; * emergency recognition and prevention; * safe distances and places of refuge; * site security and control; * evacuation routes and procedures; * decontamination; * emergency medical treatment and first aid; * emergency alerting and response procedures; * critique of response and follow-up; and * personal protective equipment and emergency equipment. If the employer has a policy of immediate evacuation of their employees from the danger area when an emergency occurs, and does not permit any of their employees to assist in handling the emergency, then they are exempt from the requirements of paragraph (q), provided they have an emergency action plan in accordance with CFR 1910.38(a). This emergency action plan should include procedures for small spills that can be cleaned up quickly, how to recognize and report spill emergencies, and immediate evacuation of all employees for larger, dangerous spills. Employees who might discover or witness a spill or leak should have first responder awareness training (see below). Emergency Notification Under SARA If a spill or leak into the environment has the potential to expose the public, and if the size of the spill is in excess of SARA reportable quantities for the chemical, then section 304 of SARA requires emergency notification of appropriate authorities. If there is a toxic release of a chemical on the CERCLA list in excess of the reportable quantity for that chemical, then the National Response Center must be notified (Telephone 800/424-8802). The National Response Center must also be notified if the spill involves hazardous waste. If the chemical is listed by SARA as an Extremely Hazardous Substance (EHS), then local emergency authorities (the local emergency planning committee and the state emergency planning committee) must also be notified. Table 4-1 lists chemicals that might be found in Art Departments in excess of reportable quantities, and could be involved in a spill or leak into the environment. Note that some states or municipalities might have more stringent reporting requirements. In cases of such a reportable release of a toxic substance into the environment, the emergency notification must include: * the name of the chemical; * an indication of its hazardous quality; * an estimate of the amount released into the environment; * the time and duration of the release; * an estimate of the quantity released; * the medium into which the release occurred; * health hazard information on the chemical; * evacuation procedures; * name and telephone number of a contact person; and * a written follow-up notice including response action, anticipated health hazard data, and medical advice for exposed individuals. ------------------------------------------------------------------------- Table 4-1. Reportable Quantities (RQ) for Certain Chemicals Under Section 304 of SARA. Chemical RQ (lbs.) EHS Ammonia 100 yes Asbestos 1 Cadmium oxide 1 yes Cellosolve 1 Cyanides (soluble salts) 10 Diglycidyl ether (some epoxy resins) 1 yes Hydrogen fluoride 100 yes Hydrogen peroxide ( > 52%) 1 yes Hydroquinone 1 yes Lead 10 Lead-containing leachable wastes 10 Mercuric chloride 1 yes Mercury 1 Methyl ethyl ketone peroxide 10 Potassium cyanide 10 yes Potassium silver cyanide 1 yes Silver cyanide 1 yes Sodium cyanide 10 yes Silver nitrate 1 Emergency Response Procedures The senior emergency response official responding to the emergency shall become the individual in charge of the site-specific Incident Command System (ICS). As more senior officials arrive, this command position is passed up the line of authority. All emergency responders and their communications shall be coordinated and controlled through this individual in charge of the ICS, assisted by the senior official present for the employer. The individual in charge of the ICS shall do the following: * Identify the hazards. * Implement appropriate emergency operations. * Ensure that appropriate personal equipment is worn. For actual or potential inhalation hazards, positive-pressure self-contained breathing apparatus (SCBA) shall be worn, as long as an inhalation hazard exists. * Limit the number of emergency personnel at the emergency site to those actively performing emergency operations. A buddy system shall be used in hazardous areas. * Provide for back-up personnel standing by for assistance or rescue, including advanced first aid personnel. * Designate a safety official with knowledge of the situation to identify and evaluate hazards and provide direction for the safety of operations. This safety official shall have the authority to alter or suspend activities in case of immediately dangerous to life or health (IDLH) or imminent danger situations. * Implement decontamination procedures after emergency operations have terminated. The standard also has procedures for medical surveillance and consultation [CFR 1910.120(q)(9)], chemical protective clothing [CFR 1910.120(q)(10)], removal of hazardous substances and contaminated materials [CFR 1910.120(q)(11)], and personal protective equipment test methods (Appendix A). Training Many colleges have a health and safety department with personnel trained and equipped to handle hazardous spill and leak emergencies, and this department should be consulted to determine whether spill response services are available. The OSHA Hazardous Materials Operations and Emergency Response Standard defines the amount of training needed for different levels of emergency response personnel. In order of the amount of training required and competence, the types of emergency response personnel are: 1) first responder awareness level; 2) first responder operations level; 3) hazardous materials technician; and 4) hazardous materials specialist. In addition, there are training requirements for an on-scene incident commander, and skilled support personnel. Except for first responder awareness training, the employer shall certify all competencies and provide a certificate to the employee. All emergency response employees shall receive annual refresher courses of sufficient content and duration to maintain and demonstrate their competencies. 1. First responder awareness level: All employees who might discover or witness a spill or leak should receive basic training in initiating the proper emergency procedures, even if the college policy is for evacuation of all employees in an emergency. These requirements are similar to and can be incorporated into OSHA Hazard Communication training requirements (see Chapter 3). First responders at the awareness level shall have training or sufficient experience to demonstrate competence in the following areas: * understanding the types of hazardous substances, and possible risks (e.g. fire, explosion, toxic effects, etc.); * understanding the potential outcomes of an emergency when hazardous substances are present; * the ability to recognize the presence of hazardous substances in an emergency; * the ability to identify the hazardous substances, if possible; * an understanding of the role of first responder awareness individuals in the employer's emergency response plan, including site security and control and the U.S. Department of Transportation Emergency Response Guidebook; and * the ability to realize the need for help and to notify the proper officials. Basically, an individual with first responder awareness training identifies the existence and nature of an emergency, if possible, and initiates the emergency response plan by calling for help. The individual takes no further action and immediately leaves the danger area, unless he or she has had more advanced emergency response training. 2. First responder operations level: First responders at the operations level respond to releases of hazardous materials in a defensive manner without trying to stop the release. Their intent is to contain the release from a distance, keep it from spreading, and prevent exposures. They must have first responder awareness level competency, and 8 hours of training or proven experience in the following competencies: * basic hazard and risk assessment techniques; * knowledge of appropriate personal protective equipment selection and use; * understanding of hazardous materials terms; * knowledge of basic control, containment and/or confinement operations; * basic decontamination procedures; and * an understanding of relevant operations and shutdown procedures. 3. Hazardous materials technician: A HazMat technician responds aggressively to stop the release of hazardous substances. He or she shall have at least 24 hours of First Responder Operations Level training, the competencies of a first level operations responder, and proven experience in the following additional competencies: * implementation of the emergency response plan; * use of field survey equipment to identify materials; * knowing how to function in the Incident Command System; * knowledge of advanced control procedures; and * knowledge of basic chemical and toxicological terminology and behavior. 4. Hazardous materials specialist: A HazMat specialist responds with and in support of HazMat technicians, but has more specific knowledge of various hazardous substances. He or she shall have 24 hours of HazMat technician training, proven experience in the competencies of a HazMat technician, as well as the following additional competencies: * knowledge of the state emergency response plan; * in-depth knowledge of hazard and risk assessment techniques; * knowledge of specialized control procedures; * an understanding of chemical, radiological and toxicological terminology and behavior; and * the ability to develop a site safety and control plan. 5. On-scene incident commander: The incident commander assumes control of the incident scene beyond the first responder awareness level. The incident commander shall have 24 hours of first responder operations level training and proven competencies, as well as the following additional competencies: * knowledge and ability to implement the employer's incident command system; * knowing the hazards of working in personal protective equipment; * knowing how to implement the local emergency response plan; * knowing of the state emergency response plan and Federal Regional Response Team; and * knowing and understanding the importance of decontamination procedures. 6. Skilled support personnel: Non-emergency personnel whose skills might be needed to operate specific equipment in an emergency, and who might be exposed to hazardous substances do not have to have the above training required of emergency responders. However, they shall be given an initial briefing at the site prior to participation in emergency operations. This briefing shall include: * instruction in wearing appropriate personal protective equipment; * nature of the chemical hazards; and * duties to be performed. CLEANING UP SPILLS AND LEAKS Many of the basic steps involved in cleaning up emergency and non-emergency spills and leaks are similar. The primary difference is the degree of hazard, the level of training, and the types of personal protective equipment necessary to clean up the spill safely. Even non-emergency spills and leaks take knowledge and training to know how to clean up safely. This can be done in standard Right-To-Know training given in compliance with the OSHA Hazard Communication Standard. Preparing for Spills and Leaks To prepare for hazardous spills, even non-emergency ones, certain supplies are needed. These can include: * Proper personal protective equipment, including chemical resistant overalls, gloves, goggles and face shields, boots, full protective suits, and appropriate respirators. Some of this equipment (SCBA, in particular) would only be worn by trained HAZMAT personnel, but anyone cleaning up even minor spills should know what to wear for the type of spills that could occur. * Clean-up equipment and supplies, including spill control materials, absorption materials and pillows, spark-proof tools, fire extinguishers, leak patches, etc. You should have appropriate spill control materials available for the types of spills likely to occur. Spill control kits are available from safety equipment suppliers. * First aid supplies (see the next section). Standard Spill Control Procedures The following procedures should be used in evaluating how to clean up spills and leaks. 1. Get away. The first person to notice the spill or leak, should get away from the immediate area of the spill in order to evaluate the situation but without exposing him or herself. Obviously, this might not be needed if the nature of the spill is known and is minor (e.g. 1/4 cup of a known solvent). 2. Identify the spill to the extent possible. Do so without being at risk. This includes identifying: * the type of material spilled (e.g., from the label); * the size of the spill and whether the leak has stopped; * whether two chemicals are involved in the leak and could react with each other; and * any unusual features such as foaming, odor, fire, etc. 3. Is this an emergency? Leaks that can be cleaned up by personnel on the spot or by maintenance personnel are not emergencies. If this is not clear, consider it an emergency. Table 4-2 gives examples of spills and leaks that should be considered emergencies: If there is an emergency situation, initiate the emergency procedures defined in the Emergency Response Plan. The following steps might be part of the Emergency Response Plan. If the plan involves immediate evacuation, then do not proceed any further. Rather sound the alarm and assist evacuation. Any fires involving hazardous substances (e.g. solvents, oxidizers, corrosive chemicals), or any spill or leak that causes any injury such as unconsciousness should be considered emergencies. 4. Get help for all but very minor spills. In emergency situations, the amount of training determines the degree of participation in the cleanup. 5. Identify the material spilled. Is it flammable, combustible, toxic and volatile, toxic or corrosive and nonvolatile, or an oxidizing agent? The label and Material Safety Data Sheet on the product should give information on safe cleanup procedures. 6. Plan how to clean up the spill or leak. Procedures for common types of spills and leaks are discussed below. 7. Obtain the proper spill control materials. This would include spill control materials, leak patches, etc., as discussed under Preparing For Spills and Leaks. 8. Put on appropriate personal protective equipment. This can include respirators, gloves, goggles, etc., as needed. 9. Stop the source of the spill or leak. This can include turning off the valve of a leaking gas cylinder, patching a leaky hose, or uprighting a knocked over container of liquid. ----------------------------------------------------------------------- Table 4-2. Emergency Spill Amounts Type of spill Amount Examples extremely flammable liquids > 1 pint acetone, rubber cement flammable liquids > 1 quart toluene, ethyl alcohol combustible liquids > 1 quart mineral spirits toxic, volatile liquids > 1 quart acetic acid, methylene chloride ammonia concentrated acids > 1 gallon sulfuric acid concentrated alkalis > 1 gallon lye solution poisonous, reactive any cyanides and materials sulfides oxidizing agents > 1 pound conc. nitric acid nitrates, dichromates, chlorates leaks from gas cylinders uncontrolled oxygen, acetylene 10. Stop the spill from spreading. This can include use of appropriate spill control pillows or other spill control materials for spilled liquids to build a dike, shutting down ventilation systems to keep gases and vapors from spreading, and plugging drains to prevent contamination of the water supply. Flammable liquids in the sewer system, for example, can be an extreme explosion hazard. Allowing hazardous chemicals to enter the sewer system may also be a violation of EPA, state, or local disposal regulations. 11. Clean up the spill. Use appropriate adsorbing materials and equipment. In general, paper towels or rags should not be used for liquids that evaporate quickly since they will not prevent further evaporation. For very small spills, you can use paper towels if they are immediately placed in an approved oily waste can. 12. Dispose of contaminated materials properly. Contaminated spill control materials and disposable personal protective clothing must be disposed of as hazardous waste. Contaminated tools and non-disposable personal protective equipment should be safely decontaminated. 13. File an incident report. The incident report should be filed with the health and safety program director for every spill, including non-emergency spills, detailing the nature of the spill, how it occurred, how it was cleaned up, any problems, and recommendations for preventing further spills of the type. The spill might also have to be reported to local, state or federal authorities (see section on Emergency Notification Under SARA). Specific Recommendations The following section gives the hazards and specific recommendations for cleaning up a variety of common spills and leaks that could occur in an art department. When a spill is large enough for cleanup to be considered an emergency response, then the Emergency Response Plan should be followed. The recommendations below should be incorporated into the emergency response procedures. Flammable Liquid Spills Spills of flammable liquids are among the most dangerous types of spills because they are potentially hazardous to health as well as a fire hazard at room temperature and below. A spill of a flammable liquid will spread out and evaporate very quickly to reach high vapor concentrations. The lower explosive limit (LEL), the lowest concentration of the flammable vapor in air which can burn, can be achieved very easily, and then all it takes is a spark, flame or other source of ignition to cause a fire or explosion. Spills of more than a one pint of an extremely flammable liquid or one quart of a flammable liquid should be considered emergency response situations. The following are procedures to be followed for flammable liquid spills: 1. Immediately shut off any flames. For large, emergency spills, shut off power to any electrical equipment, lights, etc. in the spill area using a control outside the spill area (e.g fuse box) to prevent sparks setting off a fire or explosion. 2. Open the windows and turn on any explosion-proof fans exhausting to the outside (they should be on separate circuits from the rest of the room). Air conditioning and ventilation systems should be turned off to prevent vapors from spreading throughout the building. 3. Evacuate the area as a precaution because of the fire risk. In emergency response situations, trained emergency personnel would determine the degree of evacuation needed, unless the college has an immediate evacuation plan. 4. Wear gloves, goggles and air-purifying respirators for small spills (although minor spills might not require a respirator). Cleaning up large spills or unknown spills requires positive-pressure self-contained breathing apparatus (SCBA) because of high vapor concentrations that could be present. The fire department might be able to do this if no one in-house is qualified and trained with SCBA. Other protective clothing and equipment that might be needed for large spills includes gloves, goggles and face shield, impermeable clothing, and boots. 5. Control the spread of large spills by diking with spill control pillows or similar materials. Make sure the flammable liquid does not enter drains. 6. Use appropriate spill control materials to clean up the spill. Dry clay or vermiculite will work if proper spill control materials are not available. Paper towels should not be used for more than tiny amounts of volatile liquids because the paper will aid evaporation. 7. Pick up contaminated spill control materials using sparkproof tools (e.g. plastic, aluminum), and place in garbage bags. This material must be treated as hazardous waste under EPA regulations. Flush the affected area with water afterwards. Combustible Liquid Spills Combustible liquids are not a fire hazard at room temperature since their flash point is above 100ø F. In general, handle combustible liquid spills (e.g. mineral spirits) as a volatile liquid spill. However, if a spilled combustible liquid contacts hot surfaces, then heating of the liquid could result in a fire hazard and the spill should be handled as a flammable liquid spill. Volatile Liquid Spills Inhalation of vapors and possible skin absorption of the liquid are the major hazards associated with volatile liquid spills such as 1,1,1-trichloroethane, methylene chloride, acetic acid and combustible liquids. Spills of solutions of gases dissolved in water such as ammonia, and bleach are also discussed here. Flammable liquids are treated separately. Spills of more than one quart should be considered emergency response situations. The following are procedures for cleaning up spills of volatile liquids: 1. Open windows and turn on any fans exhausting to the outside. Ventilation systems should be turned off to prevent vapors from spreading throughout the building. 2. Evacuate the immediate area as a precaution because of the health risk. In emergency response situations, trained emergency personnel would determine the degree of evacuation needed, unless the college has an immediate evacuation plan. 3. Wear gloves, goggles and air-purifying respirators for small spills (although minor spills might not require a respirator). Cleaning up large spills or unknown spills requires positive-pressure self-contained breathing apparatus (SCBA) because of high vapor concentrations that could be present. The fire department might be able to do this if no one in-house is qualified and trained with SCBA. Other protective clothing and equipment that might be needed for large spills includes gloves, goggles and face shield, impermeable clothing, and boots. 4. Control the spread of large spills by diking with spill control pillows or similar materials. 5. Use appropriate spill control materials to clean up the spill. Dry clay or vermiculite will also work if proper spill control materials are not available. Paper towels should not be used for more than tiny amounts of volatile liquids because the paper will aid evaporation. 6. Pick up contaminated spill control materials and place in approved waste disposal containers. This material must be treated as hazardous waste under EPA regulations. Flush affected area with water afterwards. Acid and Alkali Spills With acids and alkaline solutions, the concern is mostly skin contact due to the corrosive properties of concentrated acids and alkalis, and irritation from dilute solutions. Note that many concentrated acids react violently with water. Spills of more than a gallon of concentrated acids or alkalis should be considered an emergency response situation. All concentrated hydrofluoric acid spills should be considered an emergency and need special procedures. The following are recommended procedures: 1. Do not touch spilled material. 2. Wear protective clothing, gloves, goggles, and boots in order to avoid skin contact. For concentrated acids and alkalis, a face shield is needed in addition to goggles. For volatile concentrated acids, SCBA may be needed. The MSDS should be checked. 3. Control the spread of large spills of concentrated acids by diking with spill control pillows or similar materials for later disposal as hazardous waste. 4. Small acid spills can be neutralized with sodium bicarbonate or sodium carbonate and alkali spills with sodium bisulfate or citric acid. Commercial adsorbent spill control materials can also be used. 5. Neutralized acids and alkalis can then be mopped up, wringing out the mop in the sink or a pail with a wringer. Cyanide and Sulfide Spills Reactive materials such as cyanide and sulfide powders and solutions are potentially very hazardous because of the risk of producing extremely toxic hydrogen cyanide and hydrogen sulfide gases, especially if the spill also involves acids. Cyanide solutions may also be absorbed through the skin. All spills of cyanide, sulfide and other reactive materials should be considered emergency response situations. The following are recommended procedures: 1. Do not touch spilled material. 2. Wear protective apron, goggles, gloves, and respiratory protection (positive-pressure SCBA). For small powder spills, air-purifying respirators with a HEPA filter would suffice. 3. Scoop up powder with clean shovel or other tool, and place in a dry, container approved by the Department of Transportation. 4. Liquid spills should be adsorbed with spill control materials. Do not allow spill to enter drains or sewer system. 5. Flush spill area with water. 6. Dispose of as reactive hazardous waste. Oxidizing Agent Spills Oxidizers such as dichromates, nitrates, chlorates, concentrated hydrogen peroxide, and concentrated nitric acid are strong oxidizing agents which can ignite solvents and other combustible materials. They are also skin and respiratory irritants and may have other health hazards. See Material Safety Data Sheets on individual materials for specific instructions on cleaning up spills. Spills of more than one pound of an oxidizing agent should be considered an emergency response situation. The following are general procedures for oxidizer spills: 1. Do not touch the spilled material. Keep away from combustible materials (wood, paper towels, oil, etc.) 2. Wear appropriate protective equipment (e.g. apron, goggles, gloves, respirators, etc.) For small powder spills, air-purifying respirators with a HEPA filter would suffice; for larger spills, SCBA is required. 3. Scoop up powder with clean shovel or other noncombustible tool, and place in a dry container approved by the Department of Transportation. 4. Liquid spills should be adsorbed with spill control materials. Do not allow spill to enter drains or sewer system. 5. Concentrated hydrogen peroxide spills are not emergencies. The solution should be diluted with water, and then allowed to decompose to ordinary oxygen. The residue can be poured down the drain. 6. Flush spill area with water. 7. Dispose of the adsorbed material as flammable hazardous waste. Organic Peroxide Spills Methyl ethyl ketone peroxide and benzoyl peroxide are hardeners used with various plastics resins and can be ignited by sparks, flames and heat. They are normally dissolved in solvents to make them less reactive. Spills of organic peroxides should be handled as flammable liquid spills. Water-Based Paint Spills Latex paints and other water-based paints are not an inhalation hazard even though they may contain small amounts of organic solvents. Even large spills of water-based paints are not considered emergency response situations. The following are basic procedures for clean-up: 1. Gloves and goggles should be worn for cleanup. 2. Wet mopping is the best method of cleanup. 3. The diluted paint can be flushed down the sewer if it does not contain lead, chromates, cadmium, or other toxic metals. If toxic metals are present, dispose of as hazardous waste. Compressed Gas Cylinders Leaking compressed gas cylinders can be an emergency if the cylinder gas is oxygen (an oxidizer), a flammable gas such as acetylene or propane, or a toxic gas such as ammonia, and if the leak cannot be turned off by closing the cylinder valve. In this situation, follow prescribed emergency response procedure. The following are recommended procedures: 1. If a leak is suspected, test with nonfat (detergent) soap or other leak detection solution. Do not use a flame. 2. If the leak cannot be stopped by turning off the cylinder valve, take the leaking cylinder outside well away from sources of ignition if the gas is oxygen or is flammable. (If the gas is toxic, wear positive-pressure SCBA.) 3. Try and temporarily stop the leak through the cylinder valve by attaching a regulator which is closed. 4. Reopen the cylinder valve slightly to allow gas to escape slowly. 5. Clearly tag and secure the cylinder. Post a sign warning people not to approach within 20 feet with cigarettes or other sources of ignition. If necessary, post a security guard. 6. Contact the supplier or manufacturer, and follow their further instructions. FIRST AID First aid is not medical treatment. The purpose of first aid is to provide emergency supportive treatment until the injured person can get medical treatment from a physician. First aid can also be used to attend to minor cuts, bruises, etc. where medical treatment is not necessary. OSHA's section on medical services and first aid (29 CFR 1910.151) requires that employers ensure the ready availability of medical personnel for advice and consultation on matters of workers' health. In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, there should be personnel adequately trained to render first aid. First aid supplies approved by the consulting physician shall be readily available. Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use. First Aid Kit First aid kits should be available in all studios where injuries could occur requiring their use. Prepackaged first aid kits are available from safety equipment suppliers. They should be regularly checked to ensure they are kept stocked. First Aid Training Various courses in first aid are regularly given by the American Red Cross. These can be useful for teachers, guards, etc. However, if emergency facilities are not readily available, the college should ensure that state-certified first aid practitioners are available. There are a variety of state-certified levels for first aid practitioners. The lowest level is certified first aid responder with 40 hours of training. In increasing order of training are basic EMT (Emergency Medical Technician), EMT intermediate, EMT critical care technician, and EMT paramedic. EMT intermediate and higher levels must work under a physician's supervision. This can be by radio or telephone, and most hospital emergency departments maintain facilities for such supervision. EMT basic and certified first responders can immobilize a patient for transportation, bandage wounds, do CPR and similar classic first aid measures. They cannot administer oxygen or medications, give intravenous solutions, read electrocardiograms, use a defibrillator, or use most other resuscitation equipment. Employees who are trained in first aid and designated by their employer as first aid responders are covered by OSHA's Bloodborne Pathogens Standard (CFR 1910.1030). This standard applies to all occupational exposure to blood and other potentially infectious materials. This standard requires offering first aid responders Hepatitis B vaccination, written procedures for cleaning up blood exposures, medical follow-up for exposed workers, personal protective equipment, training and proper disposal of infected materials. OSHA policy, however, is to allow employers to delay Hepatitis B vaccination for first aid responders until after they have actually provided treatment where there was exposure to blood or other infectious material. This, however, only applies to employees for whom first aid response is only an incidental duty. Eyewash Fountains and Emergency Showers In case of splashes of irritating chemicals in the eye(s), it is crucial to begin rinsing the eyes within the first 15 seconds since damage begins immediately. Rinsing of the eyes should continue for at least 15 minutes. Eyewash Fountains: Plumbed eyewash or plumbed eye/face wash fountains should be in every studio where chemicals can be splashed in the eyes. All eyewash fountains should meet the requirements of the American National Standard for Emergency Eyewash and Shower Equipment (ANSI Z358.1-1990). Laboratory faucet adapters are generally not recommended because they share their water with the sink faucets, are difficult to reach easily, and it is difficult to adjust the temperature of the water quickly and properly. Hand-held hoses are not recommended because they require holding and a person needs both hands to hold eyes open for rinsing. Small, portable eyewash bottles are not recommended because of danger of contamination, and lack of adequate water to rinse eyes for 15-20 minutes. If plumbed water is not available, ANSI-approved self-contained eyewash fountains should be used and regularly checked for contamination. Emergency Showers: Emergency showers should be present wherever concentrated acids, alkalis or other corrosive materials are mixed and used since spills of corrosive chemicals can cause severe damage. If splashed with a corrosive chemical, stand under the shower and start the water flowing (about 30 gallons/minute); then remove contaminated clothing. Emergency showers should be ANSI-approved. Combination eyewash fountains/emergency showers are also available. Eyewash fountains and emergency showers should meet the following criteria: * They should be ANSI-approved. * They should be accessible within 10 seconds and not be more than 100 feet away. An individual should not have to go through a door or be separated by a wall. Note that some local regulations may require closer locations. * They should be conspicuously located with a visible sign. The area around the shower or eyewash fountain must be kept clear. * They should be located a safe distance from electrical equipment and outlets because of splashing. * They should have an instant on, stay-open ball valve. This allows people to hold both eyes open, for example, while rinsing, and to remove clothing. * Spray heads should be protected by dust covers when not in use. * Potable water should be supplied. For comfort and to prevent shock or other injury, water temperatures between 60ø F and 95ø F are suggested. * The flow of water from eyewash fountains should be gentle so as not to injure soft eye tissue. * All personnel should be trained in their use. * They should be tested weekly (according to the ANSI standard). * Adequate floor drains should be provided for emergency showers. REFERENCES 1. American National Standards Institute. (1990). American National Standard for Emergency Eyewash and Shower Equipment (ANSI Z358.1-1990). ANSI, New York, NY. 2. 3M Occupational Health and Environmental Safety Division. (1989). Hazardous Spill Clean-Up. 3M Company, St. Paul, MN. 3. National Fire Protection Association. (1985). NFPA 101 Life Safety Code 1985. NFPA, Quincy, MA. 4. Occupational Safety and Health Administration. (1990). Hazardous Waste and Emergency Response (OSHA 3114). U.S. Department of Labor, Washington, DC. 5. Occupational Safety and Health Administration. (1985) How To Prepare for Workplace Emergencies (OSHA 3088 Rev.), U.S. Department of Labor, Washington, DC. 6. Occupational Safety and Health Administration. Occupational Safety and Health Standards 29 CFR 1910. U.S. Department of Labor, Washington, DC. 7. Occupational Safety and Health Administration. 1910.38 Employee emergency plans and fire prevention plans 1910.120 Hazardous waste operations and emergency response 1910.151 Medical services and first aid 1910.165 Employee alarm systems 1910.1030 Bloodborne pathogens 8. Office of Hazardous Materials Transportation. (1987). 1987 Emergency Response Guidebook. U.S. Department of Transportation, Washington, DC. CHAPTER 5. LAWS AND REGULATIONS A wide variety of federal, state and local agencies administer laws and regulations on health and safety that apply to college art departments. In addition, in case of accident, teachers and colleges can be subject to lawsuits if negligence is involved. This chapter will discuss the most important of these laws and relevant government agencies. OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) Employers are required by the federal Occupational Safety and Health Act of 1970 (OSHAct) "to ensure as far as possible every working man and woman in the Nation safe and healthful working conditions". The Occupational Safety and Health Administration (OSHA), a federal agency, has the responsibility for administering OSHAct, issuing standards on health and safety, and carrying out inspections to enforce the regulations and law. OSHA can fine employers who do not comply. Coverage of OSHAct applies to all private employers and their employees in the 50 states, the District of Columbia, Puerto Rico, and all other U.S. territories. In 23 states with OSHA-approved state plans, OSHA has delegated its authority to enforce OSHAct. OSHA-approved state plans must cover state and local government employees. State plans may also cover private employers and their employees. Once federal OSHA has adopted a regulation, these states must adopt a comparable standard within 6 months of the publication date of a final standard. States with OSHA-approved state plans include: Alaska, Arizona, California, Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, Virgin Islands, Washington, and Wyoming. OSHA does not protect students. However, it does apply to students who are working for the college as studio assistants and similar jobs. Rights and Responsibilities Under OSHAct, employers are responsible for keeping a hazard-free workplace, knowing and obeying OSHA standards, informing employees about OSHA and their rights, keeping appropriate records, informing OSHA of fatalities and 5 or more injuries requiring hospitalizations, posting citations, and abating citations. Employees are responsible for following employer health and safety rules and OSHA standards, wearing required personal protective equipment, reporting hazardous conditions and accidents to their supervisor, and cooperating with OSHA compliance officers. Employees have the right to see copies of applicable OSHA standards, to request information on hazards and precautions, to request OSHA to make an inspection if it is believed there are hazardous conditions or violations of OSHA standards, to have his or her name kept confidential when filing an OSHA complaint, to have an authorized employee representative present during inspections, to have access to monitoring and medical records, and to not be discriminated against for exercising these rights. OSHA Standards The general duty clause of OSHAct states that each employer "shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees." This general duty clause can be used by compliance officers when there is no specific OSHA standard. OSHA also promulgates and enforces specific health and safety standards. OSHA standards cover such areas as emergency plans, fire safety, machine guarding, flammable and combustible liquids, spray finishing, welding, sanitation, toxic and hazardous substances, etc. These General Industry Standards are found in 29 CFR 1910. Many applicable OSHA standards were discussed in Chapter 4. OSHA standards are available from OSHA offices. Toxic and Hazardous Substance Standards Subpart Z, Toxic and Hazardous Substances, of the OSHA standards lists the Permissible Exposure Limits (PELs) for several hundred chemicals (CFR 1910.1000). These PELs were recently revised, mostly to reflect changes in the Threshold Limit Values (TLVs) of the American Conference for Governmental Industrial Hygienists (although 1992 court decisions have challenged these changes). Prior to this revision, most PELs were based on 1968 TLVs. The PELs are legal standards. TLVs are defined as "airborne concentrations of substances and represent conditions under which it is believed that nearly all workers may be repeatedly exposed day after day without adverse effect." One problem with TLVs for many chemicals is that the manufacturers of those chemicals had a major say in the TLV development. As a result there is considerable controversy over the adequacy of the resulting TLVs. In addition, they do not protect sensitive workers. In order to apply the numerical TLVs (or PELs), there must be air sampling to determine the concentration in air of that chemical. In addition to the PELs, Subpart Z has specific standards for many hazardous substances, including asbestos, lead, cadmium, formaldehyde, and many other carcinogens. Inspections OSHA has the right to inspect any workplace without advance notice. There are several types of inspections: * imminent danger; * fatality and multiple injuries; * valid employee complaints; * special emphasis programs (aimed at high risk industries); and * random inspection programs. The OSHA inspector can issue citations and penalties for violation of OSHA standards. These citations usually give an abatement date for correction of the violations. The size of the penalty depends on the type of the violation, which includes other than serious, serious, willful, and repeated violations, and failure to correct a prior violation. The citation and penalty (or lack of same) can be appealed by the employer. Employees or unions can contest abatement times for correcting violations. Hazard Communication Standard The OSHA Hazard Communication Standard (29 CFR 1910.1200) applies to all employees in the United States who are exposed or potentially exposed to hazardous substances at their workplace. The purpose of the hazard communication rule is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards is transmitted to employers and employees by means of comprehensive, written hazard communication programs. The OSHA Hazard Communications Standard was discussed in detail in Chapter 3. Employee Exposure Access and Medical Records OSHA requires that employers allow employees and their designated representatives to examine and copy employee exposure records and medical records (29 CFR 1910.20). Exposure records includes air sampling and other workplace environmental monitoring data and reports, biological monitoring results, Material Safety Data Sheets, and any other information related to an employee's exposure to toxic substances and harmful physical agents. Medical records means any records concerning the health of an employee, and includes medical examinations, questionnaires, physician's opinions, etc. To release medical records to designated representatives such as unions, the employee must sign a release form. The employer must keep medical records for the period of employment plus 30 years, and employee exposure records for 30 years. Record-keeping and Reporting OSHA requires that most employers keep records of occupational illnesses and injuries on OSHA forms 200 and 101 (29 CFR 1904). Employers with fewer than 10 employees and employers in certain low risk industries - including colleges and universities - do not have to follow these record-keeping requirements. However, if an on-the-job accident results in the death of an employee or in the hospitalization of 5 or more employees, all employers - including colleges and universities - must report the accident in detail to the nearest OSHA office within 48 hours (29 CFR 1904.8). Voluntary Compliance Program OSHA funds a voluntary compliance program, usually operated by the state departments of labor. Under this free program, a voluntary compliance officer will conduct an inspection of the workplace at the request of the employer, and make recommendations for correction of any hazards. Employers working with this program may be exempt from OSHA general schedule enforcement inspections for a period of one year. The voluntary compliance program does not report to OSHA any violations found, except in cases of imminent hazard which could involve death or serious injury. Appendix 3 lists the voluntary compliance offices in each state. STATE RIGHT-TO-KNOW LAWS State right-to-know laws were preempted by the OSHA Hazard Communication Standard except for public employees in states with OSHA-approved state pl