I. Purpose:
Hazardous materials, which are typically recognized as presenting some form of physical or health hazard, are a common resource in a university environment. Product substitution is a consideration, but hazardous materials may be necessary for continued operation. This management plan has been developed and implemented to safely control those hazardous materials and waste used, handled, and/or disposed of by the university to protect students, visitors, faculty, staff, and the environment.

II. Goal:
The mission of this plan is consistent with the university's commitment to environmental health and safety, which is communicated throughout the organization. The success of this plan is achieved through the development and implementation of specific hazardous materials and waste policies, procedures & guidelines. The overall goal is to maintain a process whereby human health and environmental protection are not compromised during the continued use of those hazardous materials. The HM&W Goal(s) for 2005/2006 include:

1. Obtain the appropriate material safety data sheet (MSDS) for each hazardous chemical identified in the University's chemical inventory.
2. Provide education and training to all maintenance and environmental services staff on the presence and safety precautions when working in facilities with asbestos containing building materials.

III. Objective:
The objective of this plan is to establish the foundation for a comprehensive hazardous materials and waste process (HM&W). This plan and subsequent policies, procedure & guidelines have been established to safely control those hazards associated with potentially hazardous materials. In addition, the plan identifies organizational structure and responsibilities to ensure the achievement of goals. The above noted goal(s) will be achieved by:

1. The MSDS goal will be achieved by establishing a written Hazard Communication Policy, which includes responsibilities for departments to maintain an up-to-date chemical inventory, obtain corresponding MSDS's and provide copies to Safety Services.
2. The goal related to asbestos awareness will be achieved by completing an asbestos assessment for all RMU facilities, identifying the location of asbestos on facility drawings and providing employees asbestos awareness education.

IV. Scope:
This plan applies to all Robert Morris University personnel including, but not limited to, those located at the Moon Campus, Island Sports Center, Pittsburgh facilities and other locations operated by the University. In addition, students, volunteers, visitors, and other service providers are also included within the general scope of the plan.

V. Codes, Standards & Regulatory Requirements:
The HM&W plan has been designed to ensure compliance with all federal, state and local hazardous materials and waste requirements. The regulatory and accrediting agencies include, but are not limited to:

1. United States Environmental Protection Agency (EPA)
2. Occupational Safety & Health Administration (OSHA)
3. PA Department of Environmental Protection (DEP)
4. PA Department of Labor & Industry
5. Allegheny County Health Department
6. Local City Ordinances
7. Nuclear Regulatory Commission (NRC)

VI. Roles & Responsibilities:

1. Safety Services/Hazardous Materials and Waste Subcommittee:
   1. To ensure that the goals of this plan are met, the Safety Officer will provide technical assistance and serve as a resource regarding environmental, safety and industrial hygiene issues. The Safety Officer will work with the HM&W subcommittee to develop the majority of implementation policies identified in the plan. The Safety Officer assists with environmental and worker exposure monitoring to evaluate airborne concentrations of various dusts, vapors and gases.
   2. The HM&W Subcommittee will review and deal with specific hazardous material issues such as, reviewing reported HM&W incidents, maintaining written documentation and providing recommendations for corrective action. The composition of this team will ensure communication with various disciplines within the university, including on-campus and off-site facilities, but also establishes a mechanism whereby all aspects of selection, handling, storage, uses and disposal of HM&W are addressed.
2. Safety Management Subcommittee & Health Services:
   1. Will administer Infection Control/Bloodborne Pathogen activities. This includes policy development, training, and investigation of incidents involving potential exposure to infectious materials. The Bloodborne Pathogen policy will be found in the Safety Management section of the safety policy manual.

      Note: The "Infectious/Biohazard Waste Disposal Policy" will be located within the HM&W section of this policy manual.

   2. Will establish Incident Investigation and Recordkeeping procedures to include HM&W incidents.
3. Employees:
   Employees are responsible for complying with all of the requirements of the Robert Morris University HM&W Plan

VII. Implementation Policies, Procedures and Permits:
The policies, procedure and permits which provide the basis for the Hazardous Materials and Waste Plan will be developed and implemented to comply with applicable federal, sate, and local requirements. The independent policies or components thereof provide the written documentation as required by regulations and also establish written procedures necessary to address the potential concerns associated with the selection, inventory, handling, storage, use, and disposal of hazardous materials and waste. The HM&W Plan establishes processes for:

1. Selecting, handling, storing, transporting, using and disposing of hazardous materials and waste from receipt or generation through use or final disposal;

   Those chemicals specified by the EPA as hazardous must be stored in a secure area to restrict access to authorized personnel. All hazardous chemicals must be stored in appropriate containers and clearly labeled with their contents and appropriate warning. For example, flammable liquids will be labeled "Flammable". All container labels must be legible. Employees will receive departmental training on the proper handling of hazardous material in their area. Detailed procedures will be outlined in the Hazard Communication Policy HM 2.1. Safe use of chemicals in the Lab environment will be detailed in the Chemical Hygiene Policy found in section 4.0 of this manual.

   All waste identified as hazardous or regulated will be disposed of in an environmentally safe manner as specified in the applicable waste disposal policy (see attached Appendix). Safety Services should be consulted before disposal of any hazardous material to ensure compliance with University policy requirements.

2. Establish criteria to identify, evaluate and inventory hazardous materials and waste generated;

   A chemical inventory and corresponding material safety data sheets (MSDS's) will be maintained by each department for the hazardous materials used by that department. Department Management will update their department's inventory and MSDS file when new materials are introduced into the workplace and forward a copy to Safety Services. Safety Services will maintain a master inventory and MSDS file for the University (see Hazard Communication Policy HM 2.1).

   When hazardous materials are ordered, it is the responsibility of Shipping & Receiving to ensure all shipping papers (MSDS's) are forwarded to the user department and a copy is sent to Safety Services.

3. Managing hazardous chemical waste, biohazard waste, universal waste, and other regulated waste;

   Hazardous and other regulated waste must be managed to prevent release into the environment. Management of these wastes requires proper identification, segregation, containment and ultimate disposal. RMU has identified several waste streams that must be managed accordingly. The specific waste policies identified in the appendix to this plan will be established and detail the procedures for proper handling and disposal of these waste streams which will include, Hazardous Waste, Infectious/Biohazard Waste, and Universal/Regulated Waste.

4. Information and procedures related to asbestos containing building materials:

   Some buildings facilities owned or operated by the university may contain asbestos containing building materials (ACBM). To ensure these materials are identified, suspect facilities will be assessed. Procedures will be established in an Asbestos Management Policy (HM2.5) and personnel who may come in contact with ACBM will be provided information/training.

5. Use of Personal Protective Equipment:

   Exposure to some hazards may not be controlled by using engineering or administrative controls and may require the use of personal protective equipment (PPE). Policies and procedure for general PPE and Hearing Conservation will be found in the Safety Management section of this manual. Where it has been determined or believed that respiratory protection is needed, it will be utilized in accordance with the Respiratory Protection Policy (HM 2.4).

6. Providing adequate and appropriate space and equipment for safe handling and storage of hazardous materials and waste;

   Designated areas, rooms or cabinets shall be maintained for the storage of hazardous materials and wastes. Rooms/cabinets shall be designated/labeled and secured to prevent unauthorized access. A variety of equipment and personal protective equipment (PPE) is provided to facilitate safe use, transport and handling. The Hazard Communication Policy and Compressed Gas Cylinder Policy (HM 2.7) identify safety procedures. A SPCC Plan will be established for chemicals in bulk storage containers or vessels.

7. Reporting and investigating all hazardous materials or waste spills, exposures and other incidents;

   All hazardous material spill and similar incidents must be reported, investigation and appropriate corrective action taken. Procedures related to Incident Investigation and Recordkeeping will be found in Section 1 - Safety Management of this manual.

8. Hazardous gases, vapors indoor air quality and mold;

   A variety of methods including general ventilation, filtration, dilution and designated ventilation systems (using fume hoods and scavenger systems) to the exterior of the building are utilized to exhaust airborne contaminates. Air monitoring may be necessary to confirm proper air quality. Departments should coordinate with the Safety Officer to investigate and monitor air quality concerns. Monitoring is conducted in accordance with OSHA and other regulatory guidelines.

9. Procedures that describe precaution and protective measures used during hazardous material spill;

   In addition to the safety procedures and information provided through Hazard Communication and Personal Protective Equipment, a Chemical Spill Cleanup policy will be established and found within the HM&W Plan.

10. Annual Evaluation;

    This Plan will be evaluated annually by the HM&W Sub-Committee. The annual evaluation will assess the program goal(s), objective(s), scope, performance and effectiveness. A summary report will be submitted to the University Safety Committee annually.

11. Ongoing Monitoring of Performance
    Performance measures are selected to monitor actual and/or potential risks related to one or more of the following issues:
    • Staff knowledge and skills
    • Level of staff participation
    • Monitoring and inspection activities
    • Emergency and incident reporting
    • Inspection, preventative maintenance and testing of equipment

      The HM&W performance measures established for 2005 include:

    • Number of hazardous material spills/incidents reported.
    • Proper record or waste manifest received for each Hazardous or Universal Waste shipment.

VIII. Orientation and Education Program:
University personnel will receive education on aspects of the HM&W Management Plan. Training and education may be provided during new employee orientation, with new tasks and/or annually. Training may be provided through presentation, computer based, self-study/learning packets, hands on and similar training tools.

Employees receive department specific HM&W training from their department manager/supervisor. This includes job specific hazards.

IX. Information, Collection, and Evaluation System:
Status reports will be prepared and submitted to the University Safety Committee on a quarterly basis. The reports should include, but are not be limited to, a summary of the plan effectiveness as measured by the performance measure(s) identified in this management plan. It may also include risks not anticipated in the original management plan design; the need for additional resources to accomplish the goals and objectives; and identified problems, needs, opportunities and proposed solutions for correction of identified deficiencies.

X. HM&W Management Documentation:
Every operational department will receive a copy of this plan and the associated implementation policies and procedures. These documents will be contained in Section 3.0 of the Robert Morris University - Safety Policy Manual. The manuals are assembled and distributed by the Safety Department.

APPENDIX
Implementation Policies, Procedures & Permits

Associated Policies:
Bloodborne Pathogens - See Section 1.0 Safety Management
Chemical Hygiene - See Section 4.0 Lab Safety Management

Asbestos Management
Hazard Communication