SCHOOL SAFETY PROCEDURES FOR ART AND INDUSTRIAL ART PROGRAMS 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 school or school district 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 Education or other governing body of the school. 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 Superintendent of (school district name), with the full endorsement of the Board of Education, states that it is the policy of (school district 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 (school district name). It is the policy of (school district 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, Superintendent, (school district 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 School Superintendent. Since the health and safety program affects all levels of operation of a school system, 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. Some school districts 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 schools. 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. This could be an district-wide or school Health and Safety Committee. For a small school district, a general Health and Safety Committee would be sufficient. However, for larger school districts with many schools, it would be advantageous to also form a separate Health and Safety Committee for arts and industrial arts to deal specifically with the many hazards found in these departments. Of course, there should also be a district-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 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 materials, etc. Composition A Health and Safety Committee should be representative of all those working in the school or school district - including teachers, technicians, maintenance, administration, and students - as well as people with health and safety responsibilities in the school district. 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 school district 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 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 schools 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. (See Figure 2-2 for a sample accident 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 a health and safety program. Anyone using chemicals or machinery, whether a teacher or studnet, should receive education about the hazards of the chemicals and processes they are using, and training in how to work safely. A discussion of studnet training is covered later in this chapter. Education and training of teachers 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 Americans with Disabilities Act 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. Figure 2-2. Sample Accident/Illness Reporting Form Name of individual:________________________________________________________________ Check one: Student, Instructor, Other If student: Grade ____ Location of instructor when accident/illness occurred: ___________________________________________________________________________ ___________________________________________________________________________ Date of accident/illness: ___________________________________________________________________________ Description of injury/illness: ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ Description of how accident/illness happened: ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ Indicate equipment, machinery, tools, chemicals or other materials involved: ________________________________________________________________ ___________________________________________________________________________ __________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ Describe unsafe practices or processes, if any, contributing to accident/illness: _________________________________________________________ ______________________________________________________________________________________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ Suggestions for prevention of a similar accident/illness: ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ ___________________________________________________________________________ Witness to accident/illness: 1. ________________________________________________________________________ 2. ______________________________________________________________________ Injured individual's signature: _________________________________________________________________________ Instructor's signature (if applicable): _______________________________________________________________ NOTE: Original copy to be filed with the School Nurse. File copies with Department Chairperson, District Safety Officer and Reporting Teacher (if applicable). --------------------------------------------------------------------------- ART AND INDUSTRIAL ART PROCEDURES Art and industrial art programs use a wide variety of materials and processes, many of which can be hazardous. This 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 illness related to the use of these materials or processes. In order to exert some control over these potentially hazardous situations, 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 classroom. 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. Purchasing 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. Students should never be allowed to bring their own art materials into the classroom. 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. Since elementary school art materials must be non-toxic (see the discussion of labeling and the Labeling of Hazardous Art Materials Act of 1988 in Chapter 5), procedures should be adopted to ensure that elementary school teachers can not order toxic art supplies for elementary school classes. One recommended way to accomplish this is to have separate supply lists for elementary and secondary schools. Ordering of art supplies by low bid only is very hazardous since many toxic or improperly labeled art supplies can be cheaper than safer materials. Bid requirements for elementary schools should require certification that the products are non-toxic. Imported art supplies have turned out to be a particular problem, due to the difficulty of obtaining information on the contents and toxicity of the ingredients in these imported products. Student Training and Supervision Schools and teachers have a major responsibility for ensuring the safety of the students. This is not limited to having a safe classroom for students. There is also the responsibility for ensuring that students receive adequate safety instruction and that they are properly supervised. In fact many state laws hold that teachers are in loco parentis to their students. This means that teachers must exercise greater care in preventing student injuries than would be expected of an ordinary reasonable and prudent person. Failure to do so is negligence, and if this negligence resulted in an injury to a student, then the school and teacher could be held liable both financially and professionally. The following are some rules to ensure that students are protected. 1) Instruct Students in Safety Information on the hazards of art materials and techniques should be incorporated into all classes and students should be tested on this material as they are in other areas. Preferably this instruction should include some written information (e.g. data sheets, written safety rules, books). However other forms of instruction such as audio-visual aids are also useful. Documentation of this safety instruction should be made and filed (including copies of the tests and instructional materials). 2) Supervise Students Carefully For both safety and liability reasons, there should always be adequate supervision of students in classrooms. Safety rules such as wearing personal protective equipment, banning of smoking and no horseplay should be rigidly enforced. Students should never be allowed to work in the classroom without direct supervision. If no teacher is present, and an accident happens, a court would find a clear lack of supervision. In addition students should never be allowed to bring in their own art materials since they could contain unknown hazards. 3) Be Aware of Special Needs of Disabled or Other High Risk Students Some students - such as emotionally disturbed students, physically disabled students, or pregnant students - might need special supervision and attention. In some instances they might not be able to use the same materials and processes as other students. In particular pregnant students should not be exposed to hazardous airborne chemicals (this also, of course, applies to pregnant teachers). Careful evaluation is needed in each case to determine what special precautions might be necessary, or whether the student should be in the classroom at all. 4) Set An Example For Students Teachers must obey the safety regulations themselves in order to impress on the students the seriousness of these rules (and protect themselves). It is the responsbility of the school administration to ensure that teachers are following proper safety procedures. SCHOOL HEALTH AND SAFETY MANUAL The school 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 school 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. 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.