Compliance Certification Report
| 3.10.6 | The institution takes reasonable steps to provide a healthy, safe, and secure environment for all members of the campus community. | ||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
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[Compliance] |
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The University of Alabama in Huntsville (UAH) is in compliance with Principle 3.10.6 because it provides a safe and healthy working and learning environment for its students, faculty members, staff, and visitors. These efforts are maintained by a large number of policies, services, and programs, which are supported by a variety of administrative offices, academic departments, and University committees. The following sections identify three separate organizational units, each with primary responsibility for a specific aspect of the health and safety effort:
Office of Environmental Health and Safety The mission of the Office of Environmental Health and Safety (OEHS) is to develop, implement, and manage the University's environmental health and safety programs. Evidence of fulfillment of that mission is that the institution maintains compliance with applicable federal, state, and local environmental and safety regulations. The OEHS is headed by a Director who has responsibility for developing, implementing, and managing the University's environmental health and safety programs. The Director is supported by a Campus Safety Specialist, a Hazardous Materials Specialist, and a co-operative education student. The Director has a BS in Environmental Science with a minor in chemistry. She has several years of experience working in Environmental Protection Agency (EPA) contract laboratories and American Industrial Hygiene Association (AIHA) accredited commercial laboratories. Her environmental experience ranges from water quality, to air pollution and hazardous materials and waste management, to underground storage tank removals, upgrades and management, and asbestos management. Her safety experience covers the development and implementation of safety programs for laser, radiation, biological and chemical laboratories, and safety programs for industrial companies. A brief discussion of the ways in which various committees, audits, programs, and policies and procedures support the goals of health and safety follows. University Environmental Health and Safety Committee The President of the University appoints the Environmental Health and Safety Committee membership. This committee meets biannually and ensures campus-wide compliance with the applicable federal and state environmental health and safety requirements affecting UAH faculty, staff, and students. The Committee provides recommendations to address deficiencies and reports the results to the President. The Committee implements and/or monitors recommendations as directed by the President, and is responsible for any other tasks relating to environmental health and safety as may be assigned to it by the President. Laboratory Safety Committee The role of the Laboratory Safety Committee is to assess and review potential hazards related to the handling, use, and management of hazardous chemicals, materials, and operations on UAH properties. The committee accomplishes this through quarterly meetings in which safety audit results are discussed. The committee ensures that any safety deficiencies are addressed in a timely manner. Laboratory injury reports are reviewed at the quarterly meetings and recommendations for the prevention of similar accidents are considered. Committee recommendations are submitted to the OEHS and to the University Environmental Health and Safety Committee. The Provost appoints the members of the Laboratory Safety Committee. The members are faculty and staff from areas of teaching and research that most often utilize hazardous materials, chemicals, and/or conduct hazardous operations. Membership is reassigned every third year. Additional information, including the charge of the committee and meeting minutes, is included in Sources for this section. Radiation Safety Committee The Radiation Safety Committee is responsible for ensuring University compliance with all state and federal regulations pertaining to the use of ionizing radiation sources. The Radiation Safety Committee meets quarterly. Additional information, including the charge of the committee and meeting minutes, is included in Sources for this section. Facilities and Operations Safety Council The Facilities and Operations Safety Council is concerned with all forms of physical and chemical safety hazards that may be encountered by the employees of the Facilities and Operations Department in their daily work routines. The council provides guidance and assistance for the implementation and maintenance of an organized system for recognizing, reporting, and correcting hazards. The council is responsible for the timely reporting of hazards and an annual review of the Facilities and Operations Safety Manual. Hazards are identified in the Occupational Safety and Health Act regulations and recommendations as found in the Code of Federal Regulations, Chapter 29 and also in the National Fire Protection Association codes and guidelines. The Safety Council meets quarterly. Additional information, including the charge of the council and meeting minutes, is included in Sources for this section. Use of Human Subjects Committee UAH has designated and established an Institutional Review Board, the Use of Human Subjects Committee (UHSC), for the protection of human subjects in research in accordance with the requirements of the Code of Federal Regulations, Title 45, Part 46 for federally sponsored research and all other human subject research regardless of sponsorship. UAH subscribes to the ethical principles involving the use of human subjects delineated in the "Belmont Ethical Report: Principles and Guidelines for Protection of Human Subjects of Research." Members of the UHSC are appointed by the Vice President for Research in accordance with the requirements of the Code of Federal Regulations, Title 45, Part 46, Section107 and applicable UAH policy. The UHSC requires that the investigator for research involving human subjects submit to the UHSC a human subject application for approval. Additional information, including the charge of the committee and meeting minutes, is included in Sources for this section. Documentation of UHSC activities and a complete file of each research proposal reviewed are maintained in the UHSC office. Animal Care and Use Committee The University also has a standing committee entitled the Animal Care and Use Committee that assures compliance with Public Health Service Policy on humane care and use of laboratory animals. Additional information, including the charge of the committee and meeting minutes, is included in Sources for this section. Compliance and Audits UAH complies with regulations promulgated by the EPA as written in the Code of Federal Regulations. The EPA regulations are broad in scope, covering several aspects of environmental protection. The institution undergoes periodically a number of compliance audits concerned with conformity to various environmental regulations. Some of these audits are conducted by outside agencies while others are performed internally. In a number of cases, written documentation is generated only in a non-compliance situation. The Alabama Department of Environmental Management (ADEM) conducts an annual audit and a bi-annual audit. The former is concerned with underground storage tanks, while the latter focuses on hazardous waste. The results of these audits are reported to the EPA. The institution has not received any notices of non-compliance. The Department of Natural Resources and Environmental Management of the City of Huntsville conducts an annual audit concerned with air and water pollution. These audits are necessary in order to receive a permit or letter of permission to conduct operations with minimal discharges. The documentation is on file and displayed. The Alabama Department of Public Health conducts an audit every five years, with potential for additional unannounced visits. The primary issue is radiation safety and any problem areas will result in a letter of non-compliance. To date, no such letters have been received. The Fire Marshal's Office of the City of Huntsville conducts an inspection regarding fire safety whenever a new building is constructed or an older building is renovated. Other inspections are conducted on a frequent, but irregular basis. When a new building is constructed on campus, UAH obtains evidence of non-pollution through an assessment performed by an outside contractor. To date, there have been no negative results. Also, controls are placed in buildings to prevent release of pollutants to the environment. As mentioned in an earlier section, some audits are conducted internally, with the focus on environmental and safety issues. One of these is an annual audit of laboratory facilities conducted by a Hazardous Materials Specialist. Procedures for conducting the audit, as well as the Laboratory Audit Form are in the Laboratory Safety Manual, accessible on the OEHS website. A second audit conducted internally is the radiation audit that occurs semi-annually. The results of these examinations are communicated in Radiation Audit Reports, which are on file in hardcopy format. Finally, plans are underway to begin conducting a Building Fire Safety Audit. Training Programs The OEHS conducts a series of training workshops on a continuing basis. In most instances, attendance sheets reflecting the extent of participation are kept on file. Training course statistics are contained in the OEHS unit profile. Examples of training programs are briefly described below:
Hazard Analysis The procedure to detect hazards is outlined in applicable safety manuals. Potential hazards are identified by the OEHS prior to the onset of new research activities in the form of project and recombinant DNA registrations. Hazards are also identified through annual inspections of laboratory facilities. Laboratory Safety There are approximately 327,000 square feet of research and teaching laboratory and laboratory service area on the UAH campus. The UAH laboratories are designed for research and teaching endeavors encompassing engineering, physical science, computational science, biological science, materials science, creative arts, and behavioral science. The Laboratory Safety Program is comprised of several manuals that outline standard guidelines and practices for maintaining the health and well being of building occupants and the environment. The manuals provide guidance for maintaining University regulatory compliance. Although UAH is not regulated under the Occupational Safety and Health Act (OSHA), the University accepts OSHA as minimal guidelines for occupational safety. A brief description of each manual is presented below. The Laboratory Safety Manual outlines UAH programs for maintaining compliance with the Hazard Communications Standard, Occupational Exposure to Chemicals in Labs, and OSHA regulations as they apply to the safe operation of equipment and maintaining fire safety. The Laboratory Safety Manual also outlines the requirements for safety equipment inspections and laboratory audits. The audits are intended to provide guidance to faculty and staff concerning the regulatory status of the laboratory and the projects conducted in the laboratory. Notices of compliance and deficiencies are sent regarding the audits. The OEHS and the Laboratory Safety Committee have developed a Biological Safety Manual for use at UAH with the following goals in mind:
The UAH Biological Safety Manual provides safety guidelines, policies, and procedures for the use and manipulation of biologically hazardous materials. The use of radioactive materials and radiation producing devices is addressed in the Radiation Safety Manual and the Laser Safety Manual (discussed below). The University currently maintains a radioactive materials license through the State of Alabama Department of Public Health. The Radiation Safety Program at UAH requires all users of radiation to register and request authorized user status through the Radiation Safety Officer. Any person entering the radiation area must be informed as to the hazards and how to protect him or herself. The Program is based on as low as reasonably achievable guidelines as required by the State Radiation Control Board. All authorized users are required to have radiation safety training. All radiation users are monitored in a manner appropriate to the radiation hazard. The Radiation Safety Committee meets quarterly as required by law and whenever new applications for uses of radioactive materials or radiation producing items are filed. The committee reviews the use of the radiation and ensures compliance with state regulations as per the UAH License. The UAH Laser Safety Manual provides guidelines for University departments, research centers and/or laboratories utilizing any non-ionizing radiation devices, including lasers and microwaves. The Laser Safety Manual requires those persons responsible for lasers and other non-ionizing radiation sources to be familiar and comply with all procedures found within the UAH Laser Safety Manual. Each unit using such devices must establish appropriate procedures addressing all usage, control, and safety exposures involved and must submit a Laser Safety Plan to the Laboratory Safety Committee for approval. It is the responsibility of the OEHS to monitor the compliance with procedures established within the UAH Laser Safety Manual and the device/site specific Laser Safety Plan. The University maintains compliance with Environmental Protection Agency regulations such as the Resource Conservation and Recovery Act, Emergency Planning and Community Right-To-Know Act, and Toxic Substances and Control Act through guidelines established in the UAH Hazardous Waste Management Plan (HWMP), which is an appendix of the Laser Safety Manual. The goals of the HWMP are to protect the environment and thus the health and safety of employees, students and the surrounding community. Strict adherence to environmental regulations is managed through the HWMP and training of faculty and staff. The HWMP outlines the United States Environmental Protection Agency rules and regulations pertaining to the handling and disposal of hazardous wastes. The OEHS has overall responsibility for policies and procedures for the management of hazardous waste and hazardous materials on campus, and the Director of Environmental Health and Safety is the University compliance officer with responsibility for oversight of the management program. Basic safety guidelines for the Facilities and Operations Department are provided in the Facilities Safety Manual The main objectives of this manual are to protect the health and safety of Facilities and Operations employees during their daily work routines and maintain compliance with applicable OSHA regulations. All of the employees in the Facilities and Operations Department have a responsibility to obey rules and apply safe work practices. Implementation of rules applying to safe work practices improves safety consciousness and attitudes among employees. Department of Public Safety The primary mission of the a href="http://police.uah.edu/">UAH Department of Public Safety is to enhance the quality of learning by protecting life and property and to provide a safe environment through professional services to the UAH community. The Department staff includes twelve police officers, seven support personnel, and student employees who provide law enforcement and emergency services 24 hours a day/seven days a week. UAH police officers are certified by the Alabama Peace Officers Standards and Training Commission (APOSTC) in Montgomery, Alabama. Officers are certified after attendance of a 480 hour law enforcement academy. The APOSTC also requires police officers to receive at least 12 hours of continuing education annually. Officers receive mandated annual in-service training in areas such as firearms, legal issues, and tactical skills from the Huntsville Police Academy and other locations. Officers also receive certification in first aid, CPR, and external defibrillator from Huntsville Emergency Medical Service, Inc. (HEMSI). UAH officers enforce federal, state, and local statutes as well as UAH regulations. These officers have broad law enforcement powers including the authority to make arrests. UAH police provide protection to the University campus 24 hours a day/seven days a week (including holidays) through patrol and communications services. UAH Police offer 911 services to bring immediate assistance to crime victims, emergencies, and other situations. Police communication operators are in constant contact with UAH police officers, Huntsville Police, and other emergency service providers. The department is easily accessible to visitors through a public lobby that is always available. Officers protect the campus area by motor vehicle, bicycle, and foot patrol. Other services include crime prevention programming, building checks, traffic enforcement, and special event security. UAH officers are empowered under the Code of Alabama, Section 16-47-10 and Section 16-47-11, which give them broad jurisdiction across the State of Alabama. Since the UAH campus is located geographically within the City of Huntsville, Huntsville police have concurrent jurisdiction with UAH officers over criminal matters occurring on campus. It has been agreed that UAH officers have initial and primary jurisdiction over campus-based crimes, with city officers providing assistance as requested. However, the Huntsville Police Department is the primary investigative agency for several types of serious crimes. The Department of Public Safety maintains an excellent working relationship with other state and local agencies and participates in both state and national campus law enforcement associations. The Department of Public Safety prepares and submits reports regarding serious offenses to the nationwide information center to which all authorized law enforcement agencies have access. Additionally, information is shared with other police agencies on arrests and serious crime. Serial numbers of reported stolen vehicles and goods are also shared through the National Crime Information Center to other police agencies. The Department of Public Safety also complies with the provisions of The Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act. The Department publishes an annual report disclosing University security policies and selected crime statistics for a three-year period. Other activities (not all inclusive) of the Department of Public Safety to provide a safe environment are:
The Department of Public Safety is under contract with The Commission for Accreditation of Law Enforcement Agencies (CALEA) to receive law enforcement accreditation. The Department voluntarily follows professionally recognized criteria for excellence in management and service delivery. Currently, the department is in the self-assessment phase and hopes to receive an accredited status in approximately two years. Vehicle Safety Management Program The Vehicle Safety Management Program is comprised of a set of policies and procedures that apply to any person using a University vehicle on University business. A manual detailing those policies and procedures is posted on the UAH website. The program is conducted through the Office of University Counsel. The mission of the Program is to promote and enhance employee and public safety. The Program includes measures relating to the qualification, training and supervision of employees and others who drive University vehicles; the establishment of safe practices and rules; planned inspections and maintenance of vehicles; and the reporting, investigation, and review of accidents. Several organizational units have responsibilities for carrying out specific tasks under the Program. These units include Human Resources, Career Services, Office of Counsel/Risk Management, Department of Public Safety, Business Services, and the Office of Environmental Health and Safety. As an example, Human Resources includes a review of the Program in the orientation provided to each new employee. Also, as mentioned above, the OEHS conducts defensive driving classes. The Program has only been in operation since October of 2004. Therefore, the data for assessing the effectiveness of the Program is limited. However, the insurance carrier evaluates the competence of each driver prior to that driver being insured. Wellness Center The UAH Wellness Center provides students, for a nominal fee, access to health care administered by a nurse practitioner working in a collaborative and consultative relationship with a supporting medical doctor. The Wellness Center takes a holistic approach to health care, recognizing that students cannot perform at their best in their studies if body, mind, and spirit are not in sync. In addition to the nurse practitioner who reports to the Vice President for Student Affairs, the Center's staffing consists of two registered nurses and a staff assistant. The Center operates only during the daytime hours; there is no provision for emergency after-hours care. Most students make appointments, but walk-ins are also welcome. The Center handled 3,445 office visits from students in FY04. The Center provides information to students related to medical care after operating hours or for healthcare issues beyond the scope provided by the Center. The Center is a member of the American College Health Association, a voluntary professional organization which provides information and Continuing Professional Education (CPE) courses for its members. The Center's accomplishments are outlined in a report submitted annually to the Vice President for Student Affairs. The most recent edition (2003-2004) reported the results of a student survey expressing 100% satisfaction with the Center's services. The report is on file in hardcopy. Office of Student Affairs In addition to the Wellness Center, the Vice President for Student Affairs has a role in health and safety in three areas. First, the UAH Counseling Center Director, along with other licensed counselors, works with the mental health issues of students. Second, Student Affairs receives, on a daily basis, campus police reports. The Judicial Affairs officer follows up on these reports as needed. Finally, the Office of Vice President of Student Affairs informs students each semester on the FERPA Drug/Substance use and crime statistics. UAH Cafeteria The UAH Cafeteria provides meals that are both appealing and nutritious. The cafeteria serves three meals per day, seven days per week, under a management contract with the Sodexho Corporation. Training takes place as a part of the new employee orientation process. This initial training program is a 2-3 day exercise built around a training packet provided by Sodexho. All aspects of receiving, cooking, serving, and storage are covered. Current employees are also expected to periodically attend a continuing education course entitled Serv-Safe. The focus of this training is on safety and updating employee skills. Each employee receives a certificate upon completion of the training. In terms of quality control, Sodexho conducts a comprehensive audit on a surprise basis about every 1-2 years, resulting in a written report. In addition, The Madison County Health Department conducts its inspection quarterly. Scores have generally been in the middle to upper 80s. The only issues that have come out of those inspections relate to equipment maintenance and management has responded by correcting deficiencies. The supervisor of the cafeteria operation also conducts a monthly internal audit. Sodexho provides a packet which contains guidelines for the conduct of that audit. |
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