Safety Checklist Program for Schools
DHHS (NIOSH) Publication Number 2004-101
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- Employee Emergency Plans and Fire Prevention Plans (29 CFR 1910.38)
- Subpart C – Preparedness and Prevention and
Subpart D – Contingency Plans and Emergency Procedures
- Hazardous Waste Operations and Emergency Response (29 CFR 1910.120)
- Sample Procedure for Handling Chemical Spills at Schools
- Special Note
Appendix D: Emergency Procedures in Schools in the Event of a Chemical Spill
Four major sources of regulations are may apply to emergencies involving a chemical spill. A brief overview of the major requirements of these regulations follows.
Employee Emergency Plans and Fire Prevention Plans (29 CFR 1910.38)
This OSHA regulation gives the requirements of plans for the effective evacuation and accounting for employees in case of an emergency, e.g., chemical spill. The written evacuation plan must address, at a minimum, the following:
- Emergency escape procedures, signals, and routes
- Procedures for employees who must remain in the facility to shut down equipment before they evacuate
- Procedures for accounting for all employees
- Rescue and medical duties
- Preferred mechanisms for employees to report emergencies
- Names and job titles of employees who can be contacted for more information regarding evacuation plans
- A list of the major workplace fire hazards and their proper handling and storage procedures, potential ignition sources and their control procedures, and the type of fire protection equipment or systems that can control a fire
All employees who assist in the evacuation must be trained on how to implement their function. Post emergency telephone numbers near telephones, on employee notice boards, and in other conspicuous locations (see OSHA 29 CFR 1910.165). All employees who are affected by the evacuation plan must be trained in its contents and implementation. Update the plan and training as procedures and or evacuation routes change.
Subpart C – Preparedness and Prevention and Subpart D – Contingency Plans and Emergency Procedures
The EPA regulations (40 CFR 265.30 to 265.56) establish procedures to ensure that emergencies are planned for and minimized in order to successfully protect the environment and surrounding community (See the Hazardous Waste checklist). To minimize hazards from releases of hazardous materials to air, soil, or surface water, the written plan must include the following:
- Description of arrangements with local authorities and contractors to assist in spill cleanup and notification activities
- Name(s) of the emergency coordinator(s) for the school
- Emergency equipment and corresponding locations of fire extinguishers, spill control equipment, etc.
- Available decontamination equipment
- Evacuation procedures, routes, and notification signals
This plan must be kept up-to-date and submitted to local police, fire, and rescue departments and to the local emergency planning committee and any emergency response teams who may respond to such an event.
Required steps for handling emergencies include the following:
- Identify the source, character, and extent of the release
- Activate internal alarms
- Notify State and local agencies for help (if necessary)
- Assess hazards to humans and the environment
- Notify authorities if spill poses hazards to the environment or the community
- Check for leaks, pressure buildup, etc.
- Following cleanup, arrange for treatment, storage, and disposal of wastes
- Decontaminate all equipment
- Forward a written report to the EPA Regional Administrator within 15 days
Hazardous Waste Operations and Emergency Response (29 CFR 1910.120)
The OSHA Hazardous Waste Operations and Emergency Response standard covers procedures for handling a chemical spill by designated responders and employees who respond from outside the immediate release area. 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 the standard. Students or teachers should not respond to significant spills because of the extensive training requirements and equipment needed. Trained State, county, or municipal hazardous materials response teams should be brought in if such a spill occurs. These teams will follow the requirements of the hazardous waste operations and emergency response standard that ensures that emergency responders work safely during spill cleanup activities. They will have a written plan that covers the following:
- Pre-emergency planning
- Personnel roles, lines of authority, training, and communications
- Emergency recognition and prevention
- Safe distances, places of refuge
- Site security and control
- Evacuation routes and procedures
- Decontamination procedures
- Emergency medical treatment and first aid
- Emergency alerting and response procedures
- Personal protective equipment and emergency equipment
- Critique of response and followup
This regulation also requires that an emergency coordinator be designated and that an incident command system be followed. Positive pressure supplied-air respirators are required until air monitoring indicates that less protection is safe for the area. Training requirements for responders vary depending on the level of activity in the emergency response. Personnel responsible for stopping leaks and cleaning spills must be trained to the hazardous materials technician level (minimum 24 hours training annually). Medical surveillance is also required for these responders.
If teachers or maintenance employees respond to minor spills, they must have had training covering the hazards of the spilled material and the correct response actions. They also must have the appropriate personal protective equipment along with training on how to use it. In addition, they must know how to dispose of the spilled material following all Federal and State regulations. The regulations listed below may apply to staff with these responsibilities:
- 29 CFR 1910.132 – General Requirements for Personal Protective Equipment
- 29 CFR 1910.133 – Eye and Face Protection
- 29 CFR 1910.134 – Respiratory Protection
- 29 CFR 1910.135 – Occupational Head Protection
- 29 CFR 1910.136 – Occupational Foot Protection
- 29 CFR 1910.1200 – Hazard Communication
Sample Procedure for Handling Chemical Spills at Schools
A sample emergency response procedure consistent with the above regulations is presented here to help schools formulate their compliance plans.
Each chemical spill incident is a unique occurrence, and procedures for handling such spill may vary among emergency response teams. In this section, NIOSH describes the usual steps taken during an emergency response incident and suggests practical ways to prepare for a chemical spill to cooperate with the emergency responders and incident commander. However, NIOSH does not imply that these written suggestions are the only ways to prepare for and assist in a chemical spill incident.
Review all classrooms to identify spill hazards. All teachers and students should be trained to recognize hazardous material spills and what procedures to follow. This instruction should include information about the effects of hazardous materials on humans and the environment. If a spill is beyond the cleanup capability of the person who created the spill or custodial staff, follow these procedures:
- 29 CFR 1910.132 – General Requirements for Personal Protective Equipment
- Notify the principal and the classroom teacher and ask them to call 911. Tell them the name of the material, location of the spill, and approximate volume of spilled material.
- Evacuate all students from the classroom using the steps in the evacuation procedure (this is a separate document).
- Evacuate adjacent classrooms if the spread of contamination is enough to affect them.
- Do not permit any persons to enter the spill area, contact the spilled material, or place themselves at risk unless they have appropriate training and personal protective equipment.
- Take immediate steps to prevent spilled materials from entering drains or spreading to other environmentally sensitive areas. These steps include placing absorbent materials (stored in classrooms with a high likelihood of a spill) around the perimeter of the spill and blocking drains.
The fire department may dispatch their hazardous materials emergency response team (HAZMAT) to handle the spill. The HAZMAT incident commander is usually the fire department chief and is the senior person responsible for directing all activities during the cleanup effort. The incident commander may take the following steps:
- Dispatch trained emergency responders to the scene, bringing appropriate personal protective clothing such as supplied-air respirators, chemical resistant gloves and suits, and boots. They may also bring communications devices, air-monitoring equipment, and first aid equipment. They may may use salvage drums, sorbents, and decontamination equipment stored in areas where there is a high probability of a spill.
- Establish external communication channels between the school and outside parties using the school dispatcher or any other appropriate means of external communication.
- Contact outside agencies including any of the fire, police, emergency medical, health, or emergency management departments if the chemical spill is large.
- Contact the Federal and State spill hotlines if he or she believes at any time during the response that the spill or release represents a hazard to the environment or community.
The incident commander will determine when it is safe to reoccupy the classroom or building by considering air monitoring results and checking all potentially affected classroom equipment for evidence of pressure buildup or leaks, etc. After the completion of the emergency response, the incident commander may convene all responders, the classroom teacher, and the appropriate school administrators to critique the handling of the response, to determine the cause of the incident, and to identify future preventive measures.
Hazardous chemical waste is regulated by EPA. See Hazardous Waste Self-Inspection Checklist the checklist on Hazardous Waste.
Compliance with all of these regulations is essential to ensure the safe and effective resolution of hazardous materials spills. The planning regulations can be met by preparing separate plans or by developing a separate evacuation plan and integrating the requirements of all regulations into a single coordinated plan. Schools should also establish communication with the nearest hazardous materials response team to facilitate prompt action if the need arises.