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UNIVERSITY POLICY

The purpose of this policy is to minimize and, where possible, eliminate health and safety hazards and/or exposures to all University of Medicine and Dentistry of New Jersey (UMDNJ) personnel, students, and visitors from incidents involving spills, leaks, or discharges of hazardous chemicals that may occur at UMDNJ facilities and grounds. This policy does not address fires, or biological, chemodrug, and radiological spills.

Under this policy, procedures are described for UMDNJ staff and faculty to employ for the prevention of such incidents involving hazardous chemicals in the work place. Students, being under the control of the faculty, shall adhere to this policy. The procedures also describe the necessary actions to be taken during a spill, leak, discharge, or chemical exposure incident prior to the arrival of the University's Internal Response Team, local Emergency Responders (ER), and/or ER vendors under contract.

II.       ACCOUNTABILITY

Under the direction of the President, the Executive Vice President for Academic and Clinical Affairs, Senior Vice President for Administration, the Deans, Vice Presidents, Presidents/CEOs of the Healthcare Units and Department Chairpersons shall ensure compliance with this policy through the individual Department Directors and Administrators. The Director of Environmental and Occupational Health and Safety Services (EOHSS), under the Office of Emergency Management and Occupational Health and Safety (EMOHS) shall provide guidance and technical assistance to all UMDNJ Departments in complying with the Hazardous Materials Annex of the campus-specific Emergency Operations Plans (EOP).

III.      APPLICABILITY

The Chemical Spill Prevention and Mitigation Procedures encompass release incidents of typical hazardous chemicals (as well as particularly hazardous chemicals, defined herein), and may include situations where a fire condition exists simultaneously.

IV.     REFERENCES

A.       Regulated Medical Waste                                      00-01-45-15:00

B.       NJ Worker and Community Right to Know Act     00-01-45-25:00

C.       Hazardous Waste Managements                            00-01-45-35:00

D.       Laboratory Safety                                                 00-01-45-55:00

E.       Contact the Office of Radiation Safety Services or Campus Radiation Safety Officer for specific departmental policies/procedures on managing radioactive materials/waste.

V.      DEFINITIONS

A.      Typical Hazardous Chemical - Common solvents, weak acids and caustics.

B.      Particularly Hazardous Chemical - Chemicals by virtue of their physical properties require special handling procedures, including but not limited to acutely toxic chemicals, potentially explosive chemicals, select carcinogens, reproductive toxins (i.e., mutagens, teratogens), and those chemicals whose toxic properties are unknown. (A list of chemicals is available through EOHSS).

C.      Minor Spill - Less than or equal to 1 liter of a typical hazardous chemical and NO volume of a particularly hazardous chemical.

D.      Small Spill - Greater than 1 liter of any typical hazardous chemical, and any volume of a particularly hazardous chemical.

E.      Large Spill - Volume of a chemical or like material that exhibits highly hazardous physical properties, which, per EOHSS, is determined to require the assistance of an ER team from outside the University.

VI.     POLICY

A.       Requirements:

1.        Preventive Measures/Safe Work Practices:

Standard Operating Procedures (SOP; non-laboratory setting) or a Laboratory Safety Plan (LSP; laboratory setting) shall be maintained and employed by each department or School/Unit (respectively) to ensure employee awareness and empowerment regarding the use, storage, and handling of hazardous chemicals in the work place.

2.       Reporting Incidents: (refer to campus specific Emergency Response Guide for phone numbers)

a.       All spills, leaks, and discharges shall be reported to the Public Safety Dispatch office on a 24/7 basis. Upon being notified, Public Safety Dispatch will contact EOHSS with the initial details of the incident.

b.       The administrator, manager, or supervisor of the department where the incident occurred and all occupants in the immediate area shall be notified of the situation by the person reporting the incident.

c.       All chemical spill and exposure related accidents, injuries, or illnesses should be reported in writing to the Office of Risk and Claims Management by the injured employee’s supervisor.

d.      Staff or faculty who become ill or injured should notify their supervisor and contact Occupational Medicine Services; ill or injured students should contact the appropriate Student Health Services.

3.       Handling Hazardous Chemical Releases:

a.      University faculty and staff are responsible for cleaning up MINOR spills that occur in their area of work. University faculty and staff shall be prepared to act upon receiving Laboratory Safety Training. A description of the actions to be taken by University faculty and staff before, during, and after a MINOR spill are outlined in the campus specific Emergency Response Guide. Any employee responding to a MINOR spill must assess whether they are able to handle the situation based on years of experience, level of training, and availability of cleanup response equipment. Upon completion of the cleanup, the individual conducting the cleanup shall:

i.        Notify the Public Safety Dispatch Office and EOHSS.

ii.       Contact Environmental Services to have a final wet mop of the area performed. NOTE: Housekeeping personnel are not expected to cleanup a hazardous material spill and should never be asked to do so.

EOHSS documents such incidents in a logbook.

b.       No University faculty or staff member, with the exception of EOHSS staff, shall attempt to cleanup a SMALL or LARGE spill (as defined herein). Actions to be taken by University faculty and staff in the event of such spills are outlined in the campus specific Emergency Response Guide and include Notification, Isolation, Containment, and Evacuation, as necessary. The Guide is provided by EOHSS and is posted in all areas where hazardous materials are present. EOHSS reviews the Guide annually and updates it as necessary.

4.        Emergency First Aid for Chemical Exposures:

At a minimum, all employees shall be familiar with the following actions that should be performed in the event that one or more persons become contaminated during a release incident or spill cleanup. All medical emergencies must be reported to the Department of Public Safety.

a.       Eye Injury: Proceed to the nearest eyewash station. Wash eyes immediately with copious amounts of water for at least 15 to 20 minutes. Seek medical attention immediately thereafter.

b.       Skin Contact: Remove contaminated clothing immediately. Proceed to nearest deluge shower. Activate shower and stand under shower for at least 15 to 20 minutes. Seek medical attention immediately thereafter.

c.       Inhalation: Move immediately to an area where fresh air is available. Seek medical attention immediately.

d.       Ingestion: Seek emergency medical assistance immediately.

5.       Waste Disposal Procedures:

a.       Hazardous chemical waste must be disposed of in an environmentally sound manner. Regulated hazardous chemical wastes shall be collected and stored following the procedures outlined in the University Hazardous Waste Management Program (refer to Policy 00-01-45-35:00).

b.       All UMDNJ employees, students and vendors must adhere to the following procedures:

i.        Do Not dispose of hazardous chemical waste in a trash can. This would cause the waste to be landfilled or incinerated, both of which may contribute to air, land, or groundwater pollution.

ii.        Do Not dispose of hazardous chemical waste down the sink as the University’s sewer discharge permit with the local sewerage authority, which monitors UMDNJ’s discharges, does not allow this activity.

iii.       Do Not dispose of hazardous chemical waste in a storm sewer. This action may pollute a wetland or other body of water, and is prohibited by local, state, and federal storm water management regulations.

c.       Consult with EOHSS to arrange for disposal of all hazardous chemical waste.

6.       Training:

The Education and Training program is designed to meet the requirements under the Right-to-Know law, the Lab Safety Standard, and where applicable, the Bloodborne Pathogens Standard. Supervisors are required to ensure that appropriate staff participate in the training. A copy of the documentation of participation should be kept with individual’s personnel record. EOHSS provides instruction on spill cleanup procedures and reporting requirements for all necessary personnel as follows:

a.       Proper spill response procedures, equipment, and location of nearest first aid station;

b.       Safe handling of hazardous materials and hazardous wastes;

c.       Waste minimization and pollution prevention; and

d.       Safe laboratory procedures for handling blood products and/or other potentially infectious materials.

B.       Responsibilities:

1.       The Chemical Spill Prevention and Mitigation Procedures specify areas of responsibility for the University staff and faculty, department managers and supervisors, Public Safety Department, EOHSS, University Library personnel, and Office of Risk and Claims Management. Responsibilities include adherence to this policy, properly reporting all incidents, and cleaning up certain categories of spills. Any UMDNJ employee that uses, stores, or handles a hazardous chemical shall comply with the provisions of their campus-specific Hazardous Materials Annex.

2.       Each manager or supervisor (laboratory and non-laboratory settings) shall implement the policy and incorporate the procedures into their Standard Operating Procedures (SOP) or Laboratory Safety Plan (LSP).

          Department heads shall be responsible for providing all the necessary and appropriate spill cleanup response equipment for their area(s) of responsibility. EOHSS provides assistance identifying this equipment if necessary.

C.       Enforcement:

1.       Compliance with the provisions and the guidelines set forth in this policy by all faculty and staff is mandatory.

2.       Policy violations will result in appropriate disciplinary actions, up to and including termination, and unfavorable performance appraisals.

By Direction of the President:

_________________________________________
Senior Vice President for Administration

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