A HEALTH AND SAFETY PROGRAM FOR ARTS ORGANIZATIONS WHY HAVE A HEALTH AND SAFETY PROGRAM? Accidents, spills of toxic chemicals, fire, etc. can involve teachers, students, volunteers, other staff members, and in some instances, even members of the public. These various groups have a variety of legal options in case of injury. 1. Law Suits: If a member of the public, a volunteer or a student is harmed while working or visiting at a museum or school, whether through the negligence of the institution or its staff or not, they may sue. Such suits in recent years have resulted in awards exceeding a million dollars for cases involving severe injuries or death. Even if the institution is not found guilty, extensive legal expenses may be incurred. Employees are not permitted in most instances to sue their employer because they are covered under the workers' compensation laws. 2. Workers' Compensation: Employees who are injured on the job or develop an occupational disease are entitled to workers compensation benefits. In some cases volunteers may also be eligible (check with your state agency). The size of an institution's insurance premiums will depend on the number of claims it has filed. 3. OSHA: Employers are required by the Occupational Safety and Health Act to provide " safe and healthful working conditions for working men and women". The Occupational Safety and Health Administration (OSHA) has the responsibility for administering the law, issuing regulations on health and safety, and carrying out inspections to enforce the regulations and law. OSHA can fine employers who do not comply. The establishment of a formal, working health and safety program is a proven way to prevent injuries and illnesses due to fires, accidents or overexposure to chemicals. An effective health and safety program can also result in lowered workers' compensation claims, reduce the likelihood of negligence suits, lower workers' compensation and liability insurance premiums and provide a mechanism to ensure compliance with OSHA regulations. 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 : l) to recognize hazards in the laboratory, 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. ASPECTS OF A HEALTH AND SAFETY PROGRAM A formal health and safety program must have certain characteristics. 1. 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. 2. There must be specific individuals designated as responsible for the functioning of the health and safety program and who are accountable for its operation. 3. There must be defined approved activities which are aimed at carrying out the objectives of the health and safety program. This section will discuss the personnel requirements and responsibilities. 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 govering 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. Responsibility for the Health and Safety Program A successful health and safety program should have two officers designated to perform distinctly different duties: l) 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. 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 progam. Many institutions have a safety officer on staff who may be fulfilling many of these functions. The health and safety program director needs 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 a institution-wide Health and Safety Committee. For small organizations with only a few staff members, this would be sufficient. However, for larger institutions with several departments and a large staff, it might be advantageous to also form separate departmental Health and Safety Committees to specifically deal with the many hazards found in the various departments. 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 hazards, accidents, 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 chemicals, etc. Composition: A Health and Safety Committee should be representative of all those working in the museum or other institution - including teachers, conservators, technicians, maintenance, administration, students and volunteers - as well as people with health and safety responsibilities in the institution. Each committee member should have specific expertises 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 so that there is continuity. 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: 1) inspections, 2) accident/illness reporting and investigation, 3) hazard evaluation and control, 4) emergency planning, 5) education and training, 6) medical surveillance and 7) 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. Checklists should be developed to aid in conducting inspections. 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 expertises 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: 1) The Center for Safety in the Arts - CSA has conducted such survey walk-throughs at many institutions and is available to determine hazards due to materials and processes. 2) 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. 3) 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. 4) 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. 5) 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 some of the other services mentioned.) 6) Private industrial hygiene firms - These can be good but expensive. The American Industrial Hygiene Association in Akron, Ohio has a list of consultants. 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 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. Hazard Evaluation and Control 1. Evaluation. Once hazards are reported and investigated, 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. Another important resource is a file of Material Safety Data Sheets on all products used. These are obtained from the manufacturer or distributor. Before any new chemical is introduced, a Material Safety Data Sheet should be obtained on the chemical. Then an evaluation should be made by the Health and Safety Committee to determine whether the chemical can be used safely in the particular area or what steps need to be taken to insure its safe use. 2. Priorities. 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" basis, efforts and resources could be directed towards problems of lower consequence while those with greater potential for destruction will be overlooked. The following is a list of such priorities: Critical hazard. The hazard is capable of causing death, possible multiple deaths, widespread occupational illnesses and loss of shop facililties. Serious hazard. The hazard can result in death, injuury, serioous illness and property and equipment damage if not corrected as soon as possible. Moderate hazard. The hazard can cause illness, injury and equipment damage but the injury, illness or damage would not be serious. Minor hazard. The hazard will not result in a serious injury or illness. The potential for the hazard causing damage beyond a minor first aid case is remote. Once the hazards uncovered in the shop or lab have been ranked according to their potential destructive consequences, the next step is to estimate the probability of the hazard resulting in an accident situation. Probability estimates can be made on the following qualitative scale: A. Imminent, B. Probable, C. Reasonably Probable, D. Remote. For example, a spill of a gallon of toluene would be rated 1.A because of the imminent fire and health risks, whereas a spill of a few cubic centimeters of toluene would only have a rating of 4.D since the hazards are minimal. Obviously each situation is unique and will require separate evaluation. When the hazards have been ranked according to both scales, it is easy to determine where action is mandatory. A hazard rated 1.A, for example, demands corrective action before a hazard with a rating of 3.B. In determining priorities for correction of hazards, it is important to remember that the correction of many hazards can take a long time, for example the revamping of a ventilation system. It is also important to show that the health and safety program can move quickly. Fixing of less serious hazards that are highly visible but can be corrected in a short period of time can demonstrate the working of the health and safety program and give people confidence in it. Emergency Planning A major component of any effective health and safety program is a detailed emergency plan. Such emergency plans should cover fire, chemical spills, emergency abort procedures and other contingencies. Emergency plans are also required by OSHA regulations ( CFR 1910.38 ). See CSA data sheet on emergency planning. Education and Training Education and training is one of the most crucial elements of a health and safety program. Anyone using chemicals should receive education about the hazards of the chemicals and processes they are using, and training in how to work safely. New employees should receive an orientation lecture as soon as they start. All employees should receive annual refresher courses. In many states, this type of training is required by Right-To-Know laws. Health and Safety Committee members should receive more advanced training, for example, participating in a course on art hazards. Specialized training could be required on respirator choice and fitting. A written respirator program is required by OSHA (CFR 1910.134). The institution should develop a health and safety manual for use by all employees. This manual can be developed in-house or by a consultant. It should include at least the following topics: 1) the administration's policy statement on health and safety, 2) the role and responsibilities of the health and safety committee, 3) a formalized inspection program, 4) safe working procedures for the various activities, 5) the institution's emergency plan, 6) a list of mandatory safety rules, 7) the accident/illness reporting procedure, and 8) procedures for obtaining safety information and equipment. Every employee should be issued a copy of this health and safety manual. A crucial part of education on hazards in art are sources of information. As mentioned earlier, a basic health and safety library should be accessible to all employees. The references at the end of this data sheet list many of the books which could be in this library. Assistance in conducting education and training programs can be obtained from the Center for Safety in the Arts as well as private consultants. These programs can include simple awareness lectures, full day programs, or more comprehensive courses (e.g. CSA's courses on art hazards). In addition CSA has a 2-hour videotape on art hazards that is available. Medical Surveillance A medical surveillance program should be established for all 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 for signs of illness. 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. REFERENCES A. M. Best Company. Best's Safety Directory. 2 volumes. Oldwick, NJ (1986). Updated regularly. American Conference of Governmental Industrial Hygienists. Documentation of the Threshold Limit Values 5th ed., Cincinnati (1986). Updated regularly. Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment. Cincinnati (1988). Updated yearly. American Mutual Assurance Alliance. Handboook of Organic Industrial Solvents. 6th edition, Chicago (1986). Clark, Nancy, Thomas Cutter, and Jean-Ann McGrane. Ventilation Nick Lyons books, New York (1984) * Committee on Industrial Ventilation. Industrial Ventilation: A Manual of Practice. 20th ed., American Conference of Governmental Industrial Hygienists, East Lansing, MI (1988). Updated regularly. * Firenze, Robert. The Process of Hazard Control. Kendall/Hunt, Dubuque (1978). Gosselin, Robert, Roger Smith and Harold Hodge Clinical Toxicology of Commercial Products 5th ed., Williams and Wilkins, Baltimore (1984). Hawley, Gessner (Ed.) The Condensed Chemical Dictionary. 10th ed., Van Nostrand-Reinhold, New York (1981). International Labor Office. Encyclopedia of Occupational Safety and Health. 2 volumes. 3rd ed. Geneva,Switzerland (1983). McCann, Michael. Artist Beware , 2nd ed. Lyons and Burford, Publishers, New York (1992) * National Fire Protection Association. NFPA #45. Fire Protection for Laboratories Using Chemicals 1982. Boston (1982) National Institute for Occupational Safety and Health. The Industrial Environment: Its Evaluation and Control. Government Printing Office, Washington, DC (1973). A Guide to Industrial Respiratory Protection DHEW(NIOSH) #76-189, Government Printing Office, Washington DC (1976) NIOSH Certified Equipment List As of September 1, 1983. DHEW(NIOSH) #83-122. Government Printing Office, Washington, DC (1983). Updated regularly. Occupational Diseases: A Guide to Their Recognition, revised ed.,Government Printing Office, Washington, DC (1977) 1980 Registry of Toxic Effects of Chemical Substances, two volumes. DHEW (NIOSH)# 81-116. Government Printing Office, Washington, DC (1981). National Research Council Committee on Hazardous Substances in the Laboratory. Prudent Pactices for Handling Hazardous Chemicals in Laboratories. National Academy Press, Washington, DC (1981). National Safety Council. Accident Prevention Manual for Industrial Operations. 8th ed., Chicago (1981) Patty, Frank (Ed.) Industrial Hygiene and Toxicology. Vol. II 3 parts. 3rd ed., Interscience Publishers, New York (1982) Rossol, Monona. Stage Fright: Health and Safety in the Theater. Arts, Crafts and Theater Hazards, New York (1986). * Sax, N. Irving.Dangerous Properties of Industrial Materials. 6th ed., Van Nostrand-Reinhold, New York (1984) Updated regularly U.S. Department of Labor. General Industry Occupational Safety and Health Standards 29CFR 1910 Federal Register. Updated regularly. c Copyright Center for Safety in the Arts 1986, 1992.