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Revised November 2006
Reference:
California Code of Regulations Regarding the Injury
and Illness Prevention Program, Title 8, section 3203 - Cal/OSHA's
Regulation
"Stanford University makes all reasonable efforts to:
- protect the health and safety of Stanford University faculty, staff,
and students;
- provide safe workplaces - academic, research, and administrative -
for faculty, staff and students;
- provide information to faculty, staff, and students about health and
safety hazards;
- identify and correct health and safety hazards and encourage faculty,
staff and students to report hazards;
- provide information and safeguards for those on campus and in the
surrounding community regarding environmental hazards arising from operations
at Stanford University." (see ** below)
Per California Code of Regulations, Title 8, Section 3203,
Stanford has adopted an Injury and Illness Prevention Program (IIPP) which
describes specific requirements for program responsibility, compliance,
communication, hazard assessment, accident/exposure investigations, hazard
correction, training, and record keeping.
Requirements outlined in this manual are mandated by regulation
where the word "shall" is used and are advisory in nature
where the word "should" is used.
** Health and Safety at Stanford University - Principles,
Responsibilities, and Practices (Adopted by Stanford University Cabinet,
April 1991). Note that other policies described in this program are found
in Administrative Guide Memos 25.1 - 25.8, 23.9.
The ultimate responsibility for Stanford's IIPP rests with
the President of Stanford University, John Hennessy. The program administrator
is:
Name: Lawrence M.Gibbs,
CIH
Title: Associate Vice Provost -
Environmental Health and Safety
Address: Stanford University, ESF - 480 Oak
Road, Stanford CA 94305-8007
Telephone: (650) 723-0448
Responsibilities include:
- Advising senior management on safety and health issues.
- Working with senior management to develop safety and health guidelines
and policies.
- Preparing and distributing the University's guidelines, policies and
procedures on safety and health issues.
- Maintaining current information on local, state and federal safety
and health regulations.
- Serving as liaison with governmental agencies.
- Planning, organizing and coordinating safety trainings.
- Developing a code of safe practices and inspection guidelines.
- Arranging for safety and health inspections and follow up to insure
necessary corrective action is completed.
- Establishing, conducting and maintaining an injury/illness/accident
report and investigation procedure.
- Coordinating with the University's Department of Risk Management on
maintaining injury and illness records (OSHA log 300).
- Reviewing injury and illness trends.
- Establishing a system for maintaining the records of inspection, hazard
abatement and training.
Managers are responsible for ensuring that:
- Individuals under their management have the authority to implement
appropriate health and safety policies, 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 Stanford University
health and safety practices, policies, and programs.
Supervisors are responsible for implementing Stanford University
IIPP. This includes:
- Ensuring that workplaces and equipment are safe, well-maintained,
and in compliance with external agency regulations and Stanford policies,
programs, and practices.
- Ensuring that workplace safety and health practices and procedures
are clearly communicated and understood by employees through training
programs.
- Enforcing health and safety rules fairly and uniformly related to
job performance.
- Evaluating employees on compliance with safe work practices.
- Acknowledging employees who make a significant contribution to maintenance
of a safe workplace and disciplining employees who fail to follow safe
work practices.
- Encouraging employees to report workplace hazards without fear of
reprisals.
- Ensuring that periodic, scheduled workplace inspections are conducted
and that identified health and safety deficiencies are corrected in
a timely fashion.
- Ensuring that accidents and injuries are reported and investigated
promptly. See section 7.1 regarding reporting procedures for serious
and non-serious incidents.
- Ensuring that inspections/investigations and employee health and safety
records are kept for the designated period(s) of time.
Employees are responsible for following the requirements
of the IIPP. This involves:
- Keeping themselves informed of conditions affecting their health and
safety.
- Participating in training programs, as required.
- Adhering to healthy and safe practices in their workplace.
- Promptly reporting to their supervisors of potential hazards in the
workplace, injuries and/or accidents.
EH&S is responsible for the development and administration
of the IIPP. This involves:
- Assisting supervisors in conducting workplace hazard assessments to
identify, evaluate, and correct hazards.
- Providing training and technical assistance to managers and supervisors
on implementation of the IIPP.
- Reviewing, updating and evaluating the overall effectiveness of the
IIPP.
- Evaluating the adequacy and consistency of training designed by schools,
departments, etc. (i.e., Tier 2 Training - See Section
9.2).
Stanford University shall ensure
that employees comply with safe and healthy work practices. Managers and
supervisors are responsible for establishing and maintaining good health
and safety practices. To ensure compliance:
- Employees are recognized for following safe and healthful work practices
(e.g., oral acknowledgments at receptions, small gifts such as plaques,
etc.),
- Employees are trained and retrained, as necessary or as required;
- Health and safety practices are integrated into new employee job descriptions
and performance appraisals,
- Disciplinary actions with employees for failure to follow safe and
healthful work practices are taken, when appropriate,
- An anti-reprisal policy for employees reporting safety and health
concerns is enforced.
Stanford University shall communicate
with employees in a form readily understandable by all affected employees
on matters related to occupational safety and health, including provisions
designed to encourage employees to inform the employers of hazards at
the worksite without fear of reprisal.
Stanford uses various communication systems to relay information
to all employees on matters relating to occupational safety and health,
which include:
- The tri-tier training program,
- Health and safety publications,
- Health and safety meetings,
- University
Safety Partners,
- Research compliance panels,
- Anonymous and confidential hazard reporting,
- And an anti-reprisal policy.
These systems are described below:
A tri-tier training program is an integral component of
the communication system. The training program is described in Section
9.
Health and Safety Publications are available from the Department
at Environmental Health and Safety. Call the Training and Communications
Officer at (650) 723-0448 or e-mail to Bob Edgar to request printed copies.
- Health and Safety meetings at the school, department or unit level
are conducted.
- Represent the deans of each school and several administrative areas
(Residential Dining Enterprises, Facilities Operations).
- Communicate with respective departments about health and safety matters
or to ensure the implementation of applicable EH&S programs.
- Meet regularly to discuss campus-wide safety issues and to share safety
concerns with EH&S.
- Five administrative panels on research compliance.
- Assure the institution's compliance with federal regulations regarding
research activities by reviewing those research activities which involve
the use of human subjects, laboratory animals, biohazardous agents,
recombinant DNA or radiological hazards.
- To report a hazard or share a health and safety concern, employees
may call (650) 723-0448 or submit a concern via EH&S's web address
- http://www.stanford.edu/dept/EHS
- Hazard reporting may be done anonymously or confidentially.
- Employees and students shall not be discharged
or discriminated against in any manner for bona fide reporting of health
and safety hazards to Stanford or to appropriate governmental agencies.
Supervisors shall inform employees and students
of this policy and encourage reporting of workplace hazards to the management.
Stanford University has developed a policy which provides
guidelines for responding to violence or threats of violence in the workplace
- see Administrative Policy 23.9 entitled, "Violence in the Workplace",
which is available at - http://adminguide.stanford.edu
The general roles and responsibilities of employees, supervisors,
Staff Affair Officers, Employee Relations, Help Center, and Police/Security
are dictated by the type of situation. There are specific procedures for
responding to:
- Threats of violence.
- Acts of violence not involving injuries or weapons.
- Acts of violence involving injuries or weapons.
Stanford University shall have
procedures for identifying and evaluating work place hazards, including
scheduled periodic inspections to identify unsafe conditions and work
practices. Supervisors are responsible for seeing that periodic inspections
are conducted. To assist supervisors, EH&S has developed self-inspection
standardized forms and checklists
and guides for inspection and record keeping. EH&S also conducts
periodic surveys to assist the supervisors in identifying and correcting
potential hazards.
Work area Inspections shall be
conducted according the following schedule:
- Upon initial establishment of IIPP.
Recommended frequency: office areas: at least annually
labs and shops: at least quarterly
- When new substances, processes, procedures or equipment which present
potential new hazards are introduced.
- When new, previously unrecognized hazards are identified.
- When occupational injuries or illnesses occur.
To assist supervisors in identifying and correcting potential
hazards, EH&S conducts surveys (e.g., baseline occupational health
and safety surveys of operating units, inspections of hazardous materials
storage/disposal, fire safety).
Stanford's Internal Audit Department includes a review of
the unit's compliance with health and safety issues related to the implementation
of this IIPP.
Several outside agencies conduct regular, periodic inspections
at Stanford, which assist the University in achieving some of its inspectional
responsibilities. These include:
- County of Santa Clara Fire Marshal's Office
- City of Palo Alto Fire Department
- County of Santa Clara Environmental Health Department
Records of scheduled and periodic inspections to identify
unsafe conditions and work practices shall be
maintained for a minimum of one year (unless otherwise specified). The records shall
include:
- The person(s) conducting the inspection,
- Any description of the unsafe conditions and work practices,
- The actions taken to correct the identified unsafe conditions and
work practices.
The supervisor is responsible for maintaining these records.
Stanford University shall investigate
occupational injury or illness. The following standardized procedures
for reporting and investigating occupational injuries, illnesses, and
accidents are reviewed below.
- Employee reports accident/exposure to supervisor as soon as possible.
- Supervisor immediately contacts EH&S at (650) 725-9999 to report deaths, or serious
injury or illness.
Cal/OSHA defines an injury or illness as "serious"
if it:
* Requires inpatient hospitalization for a period in excess of 24
hours for other than medical observation; or
* An employee suffers a loss of any member of the body; or
* An employee suffers any serious degree of permanent disfigurement.
- EH&S immediately reports any serious injury or illness to Cal-OSHA.
Other incidents may be reported on a case-by-case basis (i.e., chemical
carcinogen exposure).
- For more details, see document entitled, "Serious
Accdient/Illness Reporting Procedures" at website:
http://www.stanford.edu/dept/EHS/
- For all other injuries, contact supervisor.
- Supervisors are to provide Employee's Claim for Workers' Compensation
Benefits (Form DWC-1) for all accidents, to employees immediately. Supervisors
and employees are to complete within 24 hours.
- The SU-17 ( all injury/illness/exposures) has two sections: one for
the supervisor and one for the employee to complete. To be completed
within 24 hours. Available at:
http://www.stanford.edu/dept/Risk-Management/docs/forms/su-17.html
- Cal-OSHA 5020 to be completed (typed) within 24 hours by the supervisor
(for cases when one or more workdays is lost by an employee or when
treatment of the employee is required by a physician in a medical facility).
Available at:
http://www.stanford.edu/dept/Risk-Management/docs/forms/5020.html
- SU-16 completed by the supervisor when an employee has one or more
workdays is lost.
Available at:
http://www.stanford.edu/dept/Risk-Management/docs/forms/su-16.fft
- All forms are to be submitted to Risk Management or in hard copy at
651 Serra Street, Room 250, Mailcode 6207.
- EH&S has an investigation team consisting of an occupational health and safety specialist,
chemical waste specialist, environmental
specialist, biosafety officer, radiological safety specialist, and fire
marshal.
- Serious accidents (described in Section 7.1)
and overexposures (see ** below) to chemical and physical stressors
are investigated immediately by a cognizant specialist.
** As established by California Occupational Health and
Safety Administration (Cal-OSHA) regulations.
- EH&S interviews injured workers and witnesses;
- EH&S examines workplace for factors associated with the accident/exposure;
- EH&S determines the possible causes of the accident/exposure.
- Supervisor takes corrective action to prevent the accident/exposure
from recurring;
- Supervisor records the findings and corrective actions taken.
Stanford University is commited to correct unsafe or unhealthy
work conditions in a timely manner, based on the severity of the hazards.
Hazards shall be corrected according
the following procedures:
- When observed or discovered;
- When an imminent hazard exists which cannot be immediately
abated without endangering employee(s) and/or property, all exposed
personnel will be removed from the area, except those necessary to correct
the existing condition.
Employees necessary to correct the hazardous condition shall
be provided with necessary safeguards.
Unsafe conditions that cannot be corrected with resources
available to the supervisor or manager must be reported to the next higher
level of management. Resources to correct hazards include the following:
- Facilities Operations - If the correction
required is part of Facilities Operations maintenance responsibilities,
Facilities Operations will address the repair without charge to the
department.
- Departmental Funds - If the repair
does not fall into the category of maintenance, departmental funds may
be required.
- School/University Funds - If departmental
funds are not available, departments must seek other resources from
the school or University.
Stanford University policy requires that "faculty,
staff and students shall be trained to
protect themselves from hazards in their working environment. Supervisors
shall train employees and students in:
- General health and safety practices;
- Job-specific health and safety practices and hazards;
- Recognition and assessment of health and safety risks;
- Minimization of risks through sound safety practices and use of
protective equipment;
- Regulations and statutes applicable to their work; and,
- Stanford University health and safety policies."
Stanford has organized its training system into a tri-tier
program, which is described below:
Tier 1 Training
- General University orientation provided by Human Resources to all
new employees.
- Includes information on Stanford's health and safety policies and
practices, employee health and safety rights and responsibilities, health
and safety services at Stanford, what the employee should expect in
terms of further training.
Tier 2 Training
- Provided by the school, department or building safety representatives
in conjunction with EH&S to employees and students in labs, shops,
or other workplaces where special hazards may be encountered.
- Training topics include hazard communication (i.e., hazard identification,
hazardous materials safety, hazard reporting), emergency response and
evacuation procedures, fire and earthquake safety, rights and responsibilities,
personal protection, and record keeping - provided as applicable.
- EH&S reviews Tier 2 Trainings for adequacy and consistency.
Tier 3 Training
- Provided by the supervisor for laboratory researchers and assistants,
lab class students, and shop and food service workers.
- Training consists of information specific to the hazards and equipment
used by these individuals. Training is communicated by one or more of
the following methods: safety meetings (formal or informal), material
safety data sheets, videos, pamphlets, booklets, and postings.
Training shall be provided to
all employees:
- When the IIPP is first established;
- When new employees are hired;
- When employees are given new job assignments for which training has
not previously been received;
- Whenever new substances, processes, procedures or equipment are introduced
to the workplace and represent a new hazard;
- Whenever the employer is made aware of a new or previously unrecognized
hazard;
- When employees become supervisors (so that they can familiarize themselves
with the safety and health hazards to which employees under their immediate
direction and control may be exposed).
- EH&S assists schools and departments in providing health and safety
training to employees on a variety of topics. These include IIPP training,
laboratory safety training, respirator training, radiological safety,
and many others.
- EH&S has developed standardized forms for training record keeping.
These are available from EH&S.
- EH&S has a safety video library, a collection of safety publications,
and technical staff to assist supervisors and departments in implementing
training programs.
- Documentation of health and safety training for each employee shall
include: (1) employee name or other identifier, (2) training dates,
(3) type(s) of training, and (4) training providers. This documentation
shall be maintained for one year.
- The supervisor is responsible for maintaining these records.
- Stanford Training and Registration System (STARS) via the Stanford Axess portal is a computerized training database
for registration and maintenance of training documentation. Call EH&S's
Training and Communications Office at (650) 723-0448 if you have questions
regarding this area.
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