Environmental Health & Safety : Injury & Illness Prevention Plan

Injury & Illness Prevention Plan

Purpose/Scope
Responsibilities
ISEM
Identifying Hazards
Communicating Hazards
Correcting Hazards
Investigating Injuries and Illnesses
Health and Safety Training
Ensuring Compliance
Recordkeeping
Additional Resources

Purpose/Scope

Per the California Code of Regulations, Title 8, Section 3203, UC Riverside has adopted an Injury and Illness Prevention Program, which describes specific requirements for program responsibility, compliance, communications, hazard assessment, accident/exposure investigations, hazard correction, training, and recordkeeping. The University of California Riverside (UCR) complies with Title 8 of the California Code of Regulations, Section 3203 by striving to maintain a safe and healthful working environment, and has implemented this Injury and Illness Prevention Plan (IIPP) for this purpose.

The University of California Riverside:

Provides procedures for identifying and evaluating hazards and unsafe conditions;
Develops procedures for correcting hazards and unsafe conditions;
Communicates with employees regarding health and safety matters and how to report hazards;
Provides employee training programs;
Develops compliance strategies;
Maintains documentation for health and safety programs; and
Identifies a person or persons with authority and responsibility for implementing the program.

Responsibilities

Chancellor

The ultimate responsibility for providing resources towards the goal of effective policies regarding environmental health and safety issues rests with the Chancellor. General policies, which govern the activities and responsibilities of the Environmental Health and Safety program, are established under the authority of the Chancellor. As designated by the chancellor, the individual with responsibility for implementing the IIPP is the Director of Environmental Health & Safety (EH&S), hereafter referred to as the Program Administrator.

In accordance with the University Policy on Management of Health, Safety, and the Environment, UCR has adopted and implemented the guiding principles of the Integrated Safety and Environmental Management (ISEM) System.

Program Administrator

The Program Administrator has the authority to implement all provisions of this program. All university employees are responsible for supporting the program and for working safely and maintaining a safe and healthful work environment.

Name: Ross Grayson
Title: Director, Environmental Health and Safety
Address: 900 University Ave, Riverside, CA 92521
Phone: 951-827-5528

Environmental Health & Safety (EH&S)

Provides consultation to all levels of UC Riverside staff and faculty regarding program compliance.
Develops templates to assist Schools, Departments, and Work Units in implementing effective Injury and Illness Prevention Plans.
Consults on issues of hazard identification and evaluation; procedures for correcting unsafe conditions, systems for communicating with employees, regularly scheduled safety meetings, employee training programs, compliance strategies, and recordkeeping.
Provides centralized monitoring of campus-wide activities in the areas of environmental compliance, biological safety, chemical hygiene, emergency preparedness, fire safety, hazard communication, hazard identification, hazardous materials management, industrial hygiene, occupational safety, sanitation, and safety education and training.
Maintains centralized environmental and employee exposure monitoring records, allowing employee access to records as directed by law.
Assist Schools, Departments, and Work Units in developing and implementing ISEM
Assist departments in implementing Be Smart About Safety (BSAS) programs and efforts to reduce number of employee injuries.

Colleges, Schools, Division, and Business Units

Vice Chancellors, Deans, Directors, Department Chairs, Associate Vice Chancellors, and other managers are responsible for ensuring that:

Individuals under their management have the authority to implement appropriate health and safety procedures, practices and programs.
Areas under their management have adequate funding for health and safety programs, practices, and equipment.
Areas under their management are in compliance with UC Riverside health and safety practices, policies, and programs.
Areas under their management subscribe to and follow the five steps of the UC Riverside ISEM program:
A responsible person (see Departmental Safety Coordinator (DSC) or Lab Safety Officer (LSO), within each work unit under their management is designated to partner with EH&S to implement the work unit specific component of the IIPP.
Responsible hazard communication in the laboratory, as defined by the laboratory safety standard, either through direct contact or delegation.
Maintain, update, and distribute Chemical Hygiene Plan (CHP) according to campus policy 425-12
Document Standard Operating Procedures (SOP’s) including laboratory procedures

Work unit

Work group of individuals that includes at least one of the following:

Business Officer
Director
Manager
Unit/Department head
Areas under their management subscribe to and follow the five steps of the UC Riverside ISEM program:
Holds periodic meetings where safety is discussed or other means of communication at least quarterly
Includes people who work closely and perform similar work activities on a regular basis
Has unique training needs in order to successfully implement unit specific procedures

Supervisors / Principal Investigators (PI's)

In partnership with EH&S, Supervisors/Principal Investigators (PI's) are responsible for implementing the UC Riverside Injury and Illness Prevention Plan. Supervisors and PI's implement the IIPP through the following actions:

Identify a Departmental Safety Coordinator (DSC) / Lab Safety Officer (LSO). This person may also be the PI or Supervisor.
Ensure that work unit health and safety practices are communicated and understood through training and other programs.
Ensure that health and safety practices are consistent throughout the work unit and that work unit specific training is provided.
Include compliance with health and safety procedures as part of the annual performance evaluation.
Encourage employees to report safety concerns without fear of reprisal.
Report injuries promptly to Workers' Compensation.
Areas under their management subscribe to and follow the five steps of the UC Riverside ISEM program
Proper disposal of hazardous waste (Biological, Chemical, Radiological).
Create Standard Operating Procedures (SOP’s) including laboratory SOP’s for the Chemical Hygiene Plan.
Where appropriate, facilitate the implementation of:
Workplace Inspections
Work unit specific staff training beyond the required EH&S safety courses offered.

Employee Responsibilities

ISEM has been developed by UC Riverside to ensure that employees implement and follow the Injury and Illness Prevention Plan (IIPP). Employees are responsible for following the requirements of the IIPP through the following actions:

Complete all EH&S required training identified by the Learning Management System (LMS), including General Safety, Laboratory Safety Orientation, or Annual Training.
Know who is the designated Departmental Safety Coordinator (DSC) or Lab Safety Office (LSO) for your work unit.
Participate in all work unit specific training recommended and/or coordinated by your designated DSC or LSO.
Ask your DSC or LSO, supervisor or faculty when concerned about an unknown or hazardous situation or substance.
Report all unsafe conditions, practices, or equipment to your supervisor, DSC or LSO, or to campus EH&S.

Follow the five steps of the UC Riverside ISEM program:

Understand the Scope of Activities
Understand the Hazards
Implement Hazard Controls
Perform Work Activities within Hazard Controls
Provide Feedback and Make Improvements

Departmental Safety Coordinator (DSC) or Lab Safety Officer (LSO)

DSC and LSO representatives are responsible for following the requirements of the Injury and Illness Prevention Plan through the following actions:

Complete all EH&S required training identified by EH&S or in the Learning Management System (LMS).
Complete the work unit specific inspections and ensure that identified hazards are corrected and addressed.
Ensure work unit employees take all EH&S required training.
Maintain written records for work unit specific training.
Conduct work unit inspections. (Recommended)
Ensuring that the Safety Committee is aware of all accidents which have occurred, and all hazards which have been observed since the last meeting.
Working with the Building Coordinator to address facility-related safety concerns.
Serving as liaison with EH&S and other campus safety resources on issues the department cannot resolve.
Maintaining copies of Safety Committee minutes and other safety-related records.

The Safety Coordinator may seek assistance from other members of the department as necessary to meet these responsibilities.

Qualifications of a DSC or LSO representative:

Competency in administrative work activities or areas of research.
Ability to communicate safety procedures.
For LSOs, a background in chemical, biological, and/or radiological safety issues where applicable.
Advise and guide employees within their Work Unit to follow the five steps of the UC Riverside ISEM program

Students

Students are responsible for following the requirements of the Injury and Illness Prevention Plan through the following actions:

Ask your supervisor or faculty questions when concerned about an unknown or hazardous situation or substance.
Report all unsafe conditions, practices, or equipment either to your supervisor or to EH&S.
Keep informed about conditions that may impact your health and safety.
Participate in EH&S training programs, as required.
Follow the five steps of the UC Riverside ISEM program:
Understand the Scope of Activities
Understand the Hazards
Implement Hazard Controls
Perform Work Activities within Hazard Controls
Provide Feedback and Make Improvements

Department Safety Committee

The Safety Committee has the ongoing responsibility to maintain and update this IIPP, to assess departmental compliance with applicable regulations and campus policies, to evaluate reports of unsafe conditions, and to coordinate any necessary corrective actions. The Safety Committee meets at least quarterly and includes representatives from various sections or subunits of the department. Each employee has a designated representative on the committee. The Safety Committee membership may rotate periodically.

Unsafe conditions that cannot be immediately corrected by an employee or his/her supervisor should be reported to the Department Safety Coordinator or any Safety Committee member by filling out a "Report Hazard to Department" form.

Timely correction of workplace hazards will be tracked by the Safety Committee which will receive and review reports of unsafe conditions, workplace inspection reports, and injury reports. Specifically, the Safety Committee will:

Review the results of periodic, scheduled workplace inspections to identify any needed safety procedures or programs and to track specific corrective actions.
Review supervisors’ investigations of accidents and injuries to ensure that all causes have been identified and corrected.
Where appropriate, submit suggestions to department management for the prevention of future incidents.
Review alleged hazardous conditions brought to the attention of any committee member, determine necessary corrective actions, and assign responsible parties and correction deadlines.
When determined necessary by the Committee, the Committee may conduct its own investigation of accidents and/or alleged hazards to assist in establishing corrective actions.
Submit recommendations to assist department management in the evaluation of employee safety suggestions.

The Safety Committee must prepare and make available to all department personnel written minutes of issues discussed at the meetings. The Committee meeting minutes must be documented on IIPP Form V, “Safety Committee Meeting Documentation,” or a similar form. These minutes must be posted or made available in a convenient location and must be maintained on file for at least one year.

The Safety Committee can seek assistance in the remediation of a hazard from other departments, including Environmental, Health & Safety (EH&S) for campus health, safety, radiation, laser, and ergonomic issues, University Health Services (UHS) for workers’ compensation issues, or the University of California Police Department (UCPD) for personal security concerns.

ISEM

The goal of implementation of the University of California Policy on Health, Safety and the Environment is to systematically integrate health, safety, environmental considerations, and sustainable use of natural resources into all activities.

Five core safety and environmental management functions provide the necessary framework for any activity that could potentially affect faculty, staff, students, visitors, the public, or the environment. The functions are applied as a continuous cycle with the degree of rigor appropriate to address the type of activity and the hazard or environmental aspect involved.

Defining the Scope of Activities: Goals and programs are translated into activities, expectations are set, tasks are identified and prioritized, and resources are allocated.
Analyzing the Hazards: Hazards and environmental aspects associated with the activities are identified, analyzed, and categorized.
Developing and Implementing Hazard and Operational Controls: Applicable standards and requirements are identified and agreed upon, controls to prevent/mitigate hazards and aspects are identified, the safety and environmental parameters are established and controls are implemented.
Performing Activities within Established Controls: Readiness is confirmed and activities are performed safely and in compliance with applicable regulations and policies.
Providing Feedback and Assuring Continuous Improvement: The appropriate parties obtain feedback on the adequacy of controls, identify opportunities for improving the definition and planning of activities, conduct departmental and independent oversight and, if necessary, participate in regulatory enforcement actions. As a complement to departmental management, the campus EH&S offices may be contacted to provide safety and environmental assistance, consultation, and independent oversight functions.

Identifying Hazards

Regular, annual workplace safety inspections of all departmental administrative, shop and laboratories must be conducted. By law, the first of these inspections must take place when the department first adopts the IIPP. The inspections should be noted on the corresponding Checklists provided in Appendix B or other documentation, and the department should maintain copies of this documentation. Corrective Actions should be documented on the Hazard Correction Report (IIPP Form IV). These regular inspections will be supplemented with additional inspections whenever new substances, processes, procedures, or equipment introduced into the workplace represent a new occupational safety and health hazard or whenever supervisors are made aware of a new or previously unrecognized hazard.

Generally, supervisors are responsible for identification and correction of hazards that their staff and/or students face and should ensure that work areas they exercise control over are inspected at least annually. Supervisors should check for safe work practices with each visit to the workplace and should provide immediate verbal feedback where hazards are observed.

The "Report of Unsafe Condition of Hazard” (IIPP Form I) should be filled out when a referral is made to the Safety Committee as a result of a condition discovered during an inspection for which the responsible supervisor could not determine an immediate remedy. The "Report of Unsafe Condition or Hazard” form can also be obtained by any employee, filled out and turned in anonymously.

Communicating Hazards

Supervisors are responsible for communicating with all workers about safety and health issues in a form readily understandable by all workers. All department personnel are encouraged to communicate safety concerns to their supervisor without fear of reprisal.

The Safety Committee is another resource for communication regarding health and safety issues for department employees. Each employee has a representative on the committee that will inform him or her of hazard corrections and committee activities. Additionally, Safety Committee minutes and other safety-related items are posted or made available at a convenient location. Employees will also be informed about safety matters by e-mail, voice mail, distribution of written memoranda, or by articles in the internal Departmental newsletter (if applicable). Occasionally, the Safety Committee may also sponsor seminars or speakers or coordinate other means to communicate with employees regarding health and safety matters.

Supervisors are responsible for ensuring that employees are given access to hazard information pertinent to their work assignments. Information concerning the health and safety hazards of tasks performed by department staff is available from a number of sources. These sources include, but are not limited to, Material Safety Data Sheets (MSDSs, see below), equipment operating manuals, the Department Safety Coordinator, EH&S, campus libraries, container labels and work area postings.

Material Safety Data Sheets

Material Safety Data Sheets (MSDSs) provide information on the potential hazards of products or chemicals. Hard copies of MSDSs for the chemicals used in the department are available to all employees in a convenient location. If an MSDS is found to be missing, a new one can be obtained by faxing a written request to the manufacturer. A copy of this request should be kept until the MSDS arrives.

MSDSs are also available over the Internet from a variety of sources. They can be obtained by accessing the EH&S web page http://www.ehs.ucr.edu and clicking on “MSDS.” For further information, contact EH&S for a fact sheet explaining how to use MSDSs. Videos and training on how to read and understand the information presented on an MSDS are also available from EH&S.

Equipment Operating Manuals

All equipment is to be operated in accordance with the manufacturer’s instructions, as specified in the equipment’s operating manual. Copies of operating manuals should be kept with each piece of equipment in the department. Persons who are unfamiliar with the operation of a piece of equipment and its potential hazards must at least read the operating manual before using the equipment. Training should also be sought from an experienced operator or supervisor.

Correcting Hazards

Hazards discovered either as a result of a scheduled periodic inspection or during normal operations must be corrected by the supervisor in control of the work area, or by cooperation between the department in control of the work area and the supervisor of the employees working in that area. Supervisors of affected employees are expected to correct unsafe conditions as quickly as possible after discovery of a hazard.

Specific procedures that can be used to correct hazards include, but are not limited to, the following:

Tagging unsafe equipment with “Temporarily Out of Service” signs and providing a list of alternative tools or procedures for employees to use until the item is repaired.
Stopping unsafe work practices and providing retraining on proper procedures before work resumes.
Reinforcing and explaining the need for proper personal protective equipment and ensuring its availability.
Barricading areas that have chemical spills or other hazards and reporting the hazardous conditions to a supervisor or Building Coordinator.

Supervisors should use the Hazard Correction Report (IIPP Form IV) to document corrective actions, including projected and actual completion dates. If necessary, supervisors can seek assistance in developing appropriate corrective actions by submitting the Hazard Correction Report to the Safety Committee. If the Safety Committee requires assistance from other campus resources such as EH&S, or UCPD, these resources should be contacted immediately.

If an imminent hazard exists, work in the area should stop, and the appropriate supervisor must be contacted immediately. If the hazard cannot be immediately corrected without endangering employees or property, all personnel need to be removed from the area except those qualified and necessary to correct the condition. These qualified individuals will be equipped with necessary safeguards before addressing the situation.

Investigating Injuries & Illnesses

Injury Reporting

Employees who are injured at work must report the injury immediately to their supervisor. Students who are not employees who are injured or involved in an accident should report the incident to their instructor. In either case, if immediate medical treatment beyond first aid is needed, call 9-1-1. The injured party will be taken to the appropriate hospital or medical center.

The supervisor of the injured employee must work with designated department personnel to ensure that the "UCR Accident Investigation Form" and a "University of California Incident Report" are completed properly and submitted online at www.ehs.ucr.edu.

If the injured employee saw a physician, the supervisor should obtain a medical release form before allowing the employee to return to work. The health care provider may stipulate work tasks that must be avoided or work conditions that must be altered before the employee resumes his or her full duties.

Injury Investigation

The employee’s supervisor or student’s instructor is responsible for performing an investigation to determine and correct the cause(s) of the incident. Specific procedures that can be used to investigate workplace accidents and hazardous substance exposures include:

Interviewing injured personnel and witnesses.
Examining the injured employee’s workstation for contributing factors.
Reviewing established procedures to ensuring they are adequate and were followed.
Reviewing training records of affected employees.
Determining all contributing causes to the accident.
Taking corrective actions to prevent the accident/exposure from reoccurring.
Recording all findings and actions taken.

The supervisor’s findings and corrective actions should be documented and presented to the Safety Committee using the UCR Accident Investigation Report. If the supervisor is unable to determine the cause(s) and appropriate corrective actions, other resources should be sought. Available resources include the department’s Safety Committee, EH&S, and other campus safety organizations.

The Safety Committee will review each accident or injury report to ensure that the investigation was thorough and that all corrective actions are completed. Investigations and/or corrective actions that are found to be incomplete will be routed back to the supervisor for further follow-up, with specific recommendations noted by the committee. The Department Safety Coordinator will bring corrective actions that are not implemented in a reasonable period of time to the attention of the Department head.

Health & Safety Training

Employee safety training is provided at no cost to the employee and is conducted during the employee’s normal working hours on University time. Safety training may be presented by a knowledgeable supervisor, other department personnel, or by representatives from other relevant campus departments.

UCR will utilize Learning Management System (LMS) software to plan, deliver, and manage all EH&S learning events/activities. This system will focus management of learning on learners vs. training providers.

Regardless of the instructor, all safety training should be documented using the “Safety Training Attendance Record” (IIPP Form II) or an equivalent record that includes all the information required on this form.

Initial IIPP Training

When the IIPP is first implemented, all department personnel will be trained on the structure of the IIPP (IIPP Form III), including individual responsibilities under the program, and the availability of the written program. Training will also be provided on how to report unsafe conditions, how to access the Safety Committee, and where to obtain information on workplace safety and health issues.

Personnel hired after the initial training session will be oriented on this material as soon as possible by the Safety Coordinator or appropriate supervisor. These individual training sessions should also be documented on IIPP Form III.

Training on Specific Hazards

Supervisors are required to be trained on the hazards to which the employees under their immediate control may be exposed. This training aids a supervisor in understanding and enforcing proper protective measures.

All supervisors must ensure that the personnel they supervise receive appropriate training on the specific hazards of work they perform, and the proper precautions for protection against those hazards. Training is particularly important for new employees and whenever a new hazard is introduced into the workplace. Such hazards may include new equipment, hazardous materials, or procedures. Health and Safety training is also required when employees are given new job assignments on which they have not previously been trained and whenever a supervisor is made aware of a new or previously unrecognized hazard.

Specific topics which may be appropriate to department personnel include, but are not limited to, the following:

Fire prevention techniques and fire extinguisher use.
Obtaining emergency medical assistance and first aid.
Disaster preparedness and response, including building evacuation procedures.
Health and safety for computer users.
Back care, body mechanics, and proper lifting techniques.
Hazard communication, including training on MSDSs, chemical hazards and container labeling.
Proper housekeeping.
Chemical spill reporting procedures.

Ensuring Compliance

All department personnel have the responsibility for complying with safe and healthful work practices, including applicable regulations, campus policy, and departmental safety procedures. Overall performance in maintenance of a safe and healthy work environment should be recognized by the supervisor and noted in performance evaluations. Employees will not be discriminated against for work-related injuries, and injuries will not be included in performance evaluations, unless the injuries were a result of an unsafe act on the part of the employee.

Standard progressive disciplinary measures in accordance with the applicable personnel policy or labor contract will result when employees fail to comply with applicable regulations, campus policy, and/or departmental safety procedures. Faculty members will be disciplined for unsafe practices in accordance with the Faculty Code of Conduct. Students not employed by the University will be disciplined for unsafe practices in accordance with the Student Code of Conduct. All personnel will be given instruction and an opportunity to correct unsafe behavior. Repeated failure to comply or willful and intentional noncompliance may result in disciplinary measures up to and including termination.

Recordkeeping

Documents related to the IIPP are maintained in a safe and convenient location for record keeping. Documents that should be kept on file include:

Records of scheduled and periodic workplace inspections, including the persons conducting the inspection, any identified unsafe conditions or work practices, and corrective actions.
Employee safety training records, including the names of all attendees and instructors, the training date, and material covered.
Reports of Unsafe Conditions or Hazards.
Safety Committee Meeting Documentation.
Hazard Correction Reports.
Accident, Injury or Illness Investigation Reports www.ehs.ucr.edu

Additional Resources

A number of University programs and service organizations have been established to address injury and illness prevention and to maintain and promote a safe and healthful work environment for the campus community. A list is provided below; please use the Campus Telephone Directory for up-to-date telephone numbers.

State Agencies

California Division of Occupational Safety and Health (Cal/OSHA)
Governors Office of Emergency Services
California Environmental Protection Agency
California Air Resources Board
California Integrated Waste Management Board
California Office of Environmental Health Hazard Assessment

Federal Agencies:

Environmental Protection Agency
Code of Federal Regulations
Occupational Safety and Health Administration
Centers for Disease Control and Prevention
National Institute for Occupational Health and Safety

For additional information, comments, or questions, contact EH&S (951) 827-5528, or visit: http://www.ehs.ucr.edu.

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