Injury & Illness Prevention Program | Safety, Health, & Sustainability

I. Purpose

California State University San Marcos is committed to providing an accessible, attractive, and safe environment for faculty, staff, students, volunteers, and visitors. It is the policy of the University to maintain, as it is reasonably within the control of the University to do so, a campus environment that will not adversely affect their health and safety or subject them to avoidable risks of accidental injury. There may be situations where the hazards are mitigated by the employee, supervisor, or Safety, Health, and Sustainability (SH&S). To accomplish this, the University has developed an Injury and Illness Prevention Program (IIPP) in compliance with Cal/OSHA regulations, CSU System Executive Orders and University guidelines.

The goal of the IIPP is to assist University employees, volunteers, and students in identifying hazards in the workplace, determining how to correct hazards that may occur, and taking steps to prevent them from recurring. The program also provides a framework for accountability and reporting. The following describes specific requirements for program responsibility, compliance, communication, hazard assessment, accident/exposure investigations, hazard correction, training, and recordkeeping. The IIPP is intended to achieve the following objectives:

Identify a person or persons with authority and responsibility for implementing the program;
Communicate with employees regarding health and safety matters and how to report hazards;
Develop compliance strategies;
Provide procedures for identifying and evaluating hazards and unsafe conditions;
Investigate accidents and incidents;
Develop procedures for correcting hazards and unsafe conditions;
Provide employee training programs; and
Maintain documentation for health and safety programs.

II. Authority

California Labor Code Section 6401.7, California Code of Regulations, Title 8, Sections 3203 & 1509, and the current (CSU Executive Order 1039).

III. Scope & Responsibility

This program applies to University employees (including student employees), volunteers, and matriculated students. It applies to University programs and activities whether on or off-campus. University auxiliary and affiliate organizations are responsible for applying similar practices as stringent to their respective programs and activities. Elements of this IIPP pertain to non-state employees, students, and visitor populations in that a mechanism exists to identify, report, and correct unsafe or potentially hazardous conditions at the University. Report Safety Concerns at:
/shs, email shs@csusm.edu, or call 760-750-4502.

Members of the campus community can refer to the “Responsibility” section (III) in the CSU Environmental Health and Safety Policy (CSU ). All members of the campus community are expected to perform work in a safe manner and report hazards that they become aware of to their supervisors and/or Safety, Health & Sustainability without fear of reprisals.

IV. Definitions

Cal/OSHA – The California Occupational Safety and Health Administration is the State agency that protects workers from safety hazards through regulations, safety programs, inspections, and consultative assistance.

Employee – A person who works for the California State University in return for financial or other compensation.

Supervisor – "Supervisory employee" means any individual, regardless of the job description or title, having authority, in the interest of the employer to hire, transfer, suspend, lay-off, recall, promote, discharge, assign, reward, or discipline other employees, or responsibility to direct them, or to adjust their grievances, or effectively to recommend such action, if, in connection with the foregoing, the exercise of such authority is not of a merely routine or clerical nature, but requires the use of independent judgment. (Source: HEERA)

Volunteer – An individual who performs work or provides services without compensation for a quarter, semester, academic year, calendar year, session, or any part thereof. (Source: HR Web page)

Principal Investigator or Project Director – Means the individual (whether referred to in the Contract or Grant as a Principal Investigator, Project Director or other similar term) designated by the Sponsoring Agency to be responsible for ensuring compliance with the academic, scientific, technical, and for day-to-day management of the sponsored program/project. Financial and administrative aspects of the Contract or Grant are the joint responsibility of the Recipient and the Principal Investigator. (Source: �� Corporation's Sponsored Projects Administration Handbook)

V. Implementation

The University President has assigned overall management for the IIPP to the Vice President for Finance and Administrative Services. The Director of Safety, Health and Sustainability is responsible for implementation of the IIPP. Additional responsibilities for implementation include the following:

A. Safety, Health and Sustainability (SH&S)

It is the responsibility of the Director of SH&S, under the direction of the Vice President for Finance and Administrative Services, to develop and manage the IIPP and monitor compliance. The Director is responsible for establishing, communicating, and maintaining campus safety programs that meet the requirements of applicable regulations. In the case of life safety matters or imminent danger to life or health, the Director of SH&S or his/her designee has the authority to order the cessation of the activity until the hazardous condition is abated or adequate measures are taken to minimize exposure to campus personnel. Further responsibilities are outlined below:

Develop, implement, maintain, and revise the University Environmental, Industrial Hygiene, and Occupational Safety Programs.

Provide consultation regarding IIPP compliance to Deans, Directors, Department Chairs, Supervisors, and Department Safety Coordinators. Consult on: issues of hazard identification and evaluation, procedures for correcting unsafe conditions, systems for communicating with employees, regularly scheduled safety meetings, employee training programs, compliance strategies, and recordkeeping.

Provide centralized monitoring of campus-wide activities in the areas of environmental compliance, biological safety, chemical hygiene, emergency action plans (8CCR3220), fire safety, hazard communication, hazard identification, hazardous materials management, industrial hygiene, occupational safety, public health and sanitation, safety education, and training.

Maintain responsibility for review and authorization of all radiation use on campus. All policies and procedures are written and implemented by the Radiation Safety Officer in collaboration with the Radiation Safety Committee.

Maintain responsibility for review and authorization of all Hazardous Materials use on campus. All programs are written, reviewed with, and implemented by the Director of SH&S or the Chemical Hygiene Officer in collaboration with the Chemical Hygiene Safety Committee.

Maintain centralized environmental and employee Medical Monitoring Program records, allowing employees to access their records upon request, in accordance with applicable law.

Provide or ensure general safety training is provided to all employees which includes hazard communication, emergency action plans/emergency preparedness procedures, and injury and illness reporting.

Maintain and implement a system of recordkeeping, to document all employee safety education and training activities. Additional records should include but are not limited to all employee and student injuries, incident reports, or complaints involving safety issues.

Develop procedures, as appropriate, to inform employees of outside contractors who work in areas under department jurisdiction of the hazards to which those employees may be exposed.
Provide a method for the campus community to report unsafe work practices or conditions. This form of communication may be anonymous or by formal complaint. An anonymous complaint must be handled according to collective bargaining agreements with respect to progressive discipline.
Other services and responsibilities of this office are outlined on the .

B. University Risk Management

The Risk Manager is responsible for coordinating campus risk management assessment programs, developing and implementing training and assessment methodologies to assist the campus with effectively avoiding, mitigating, transferring, and/or controlling risk.

C. Deans and Associate Vice President

It is the responsibility of the Deans and Associate Vice Presidents to ensure departments under their direction are complying with the provisions set forth in the IIPP. Refer to the “Responsibility” section in the CSU Environmental Health and Safety Policy, . Specifically, these individuals will:

Ensure adequate resources, including time, are available for the training compliance and education of themselves and their employees.

Provide support, including fiscal, for the correction of hazardous conditions under their direction.

D. Directors and Department Chairs

The primary responsibility for establishing and maintaining a safe and healthy work environment for employees, students, and visitors is at the department level. It is the responsibility of Directors and Department Chairs to develop, in collaboration with SH&S, departmental procedures to ensure effective compliance with the IIPP and other University environmental, health and safety policies as they relate to operations under their control. Refer to the “Responsibility” section in the CSU Environmental Health and Safety Policy, . SH&S is available for consultation in this area and can provide document templates. Areas of responsibility include education and training, identification and correction of unsafe conditions, and record keeping. Specifically, these individuals will:

Identify hazardous job duties and activities within their department(s). Work with SH&S to develop and maintain written departmental safety procedures which correspond to these hazards. Ensure that each supervisor and employee adhere to these procedures.

Develop and implement an education and training program designed to instruct employees and students in general safe work practices specific to their job duties. Such education and training shall take place before the employee or student is assigned to potentially hazardous employment.

Instruct employees and students in the recognition and avoidance of unsafe conditions, including hazards associated with non‑routine tasks and emergency operations. Permit only those employees or students qualified through training to operate potentially hazardous equipment.

As directed by current federal, state, and local regulations, a full inventory of all hazardous materials must be maintained by the department, if applicable. SH&S will request a copy of the inventory annually to include in reports sent to governmental agencies which regulate the use of all hazardous materials at California State University, San Marcos.

Develop a system of record keeping documenting all student safety education and training activities. Additional records should include, but are not limited to, all student injuries, incident reports, complaints, or grievances involving safety issues.

Request safety procedures from each manufacturer on potentially hazardous equipment where specialized training might be necessary.

Post safety notices in conspicuous locations.

When applicable, designate staff that will be responsible for serving as the Department Safety Coordinator (DSC), acting as a liaison with SH&S to advise the Department Chair/Director on safety related issues. In departments where there is no Director or Department Chair the Dean of the college will then appoint the DSC.

Conduct periodic safety meetings, or agenda items, where department personnel can openly discuss safety issues. These meetings can be scheduled separately or included in regular departmental meetings.

E. Principle Investigator, Project Directors, and Managers/Supervisors

It is the responsibility of first line Supervisors and Principal Investigators/Project Directors to ensure all employees under their direction have been trained in the proper procedures for each job. They are responsible for learning and implementing EH&S procedures that are applicable to their employees, areas and operations under their control. Refer to the “Responsibility” section in the CSU Environmental Health and Safety Policy, . Additional responsibilities include:

Developing procedures to ensure effective compliance with the IIPP as it relates to operations under their control. Specific areas of responsibility include employee/student education and training, identification and correction of unsafe conditions, and record keeping.
Develop and maintain written workplace procedures that are not otherwise provided by SH&S, which conform to campus and departmental guidelines.
Ensure that each employee adheres to adopted procedures.
Become familiar with the potential safety and health hazards that may affect their employees. Instruct employees/students in the recognition and avoidance of these unsafe conditions, including hazards associated with non‑routine tasks, and emergency operations. Permit only those employees or students qualified through training to operate potentially hazardous equipment or utilize hazardous materials.
Report all unsafe conditions and equipment to the Department Chair/Director or Department Safety Coordinator.
Ensure that themselves and their employees are trained whenever new substances, processes, procedures, or equipment are introduced to the workplace or when previously unrecognized hazards have been reported. The training must occur prior to the time an employee is exposed to the hazard. SH&S can coordinate/provide training when requested in various venues.

F. Department Safety Coordinators (Program in development stages due to Labor Relations, 01/08/2019)

Department Safety Coordinators (DSC) are appointed by each Director, Department Chair, or Dean and are critical to the effective implementation of the IIPP. These roles may be part of the College of Science, Technology, Engineering and Math (CSTEM) staff or the Instructional Support Technicians duties. The DSC will:

Assist the Dean, Director, or Department Chair in the development and implementation of the campus IIPP or a departmental IIPP.
Serve as liaison with SH&S for the department on matters pertaining to inspections, accident/injury investigations, personnel safety education and training, and safety reporting.
Obtain relevant safety and health information; and conduct or coordinate education and training for employees related to workplace hazards.
Conduct periodic safety inspections of department facilities, equipment, and projects to identify unsafe conditions and practices.
Make recommendations and initiate corrective actions regarding identified hazards or deficiencies.
Ensure maintenance of department records on training, accident/injury, exposure monitoring, or other pertinent data.
Other safety related duties as assigned by the Dean, their delegate or the Department Chair. These duties should not be in conflict with other bargaining unit health and safety contract requirements.

G. Faculty

Refer to the Responsibility section in the CSU Environmental Health and Safety Policy,

H. Staff

Staff are subject to University environmental, health and safety policies and procedures. Compliance is important in the prevention of work-related injuries and illness Refer to the Responsibility section in the CSU Environmental Health and Safety Policy, . If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation. Responsibilities include:

Consulting with their supervisors when concerned about an unknown or hazardous situation or substance.
Reading and complying with procedures and guidelines provided by their department, supervisors, or SH&S.
Reporting all unsafe conditions, practices, or equipment either to their supervisor or to SH&S without fear of reprisal.
Attending and completing education and training sessions, to understand, and comply with all applicable safety requirements. Training must be timely and in advance of the assignment of duties.

I. Student Employees and Volunteers

Student Employees and Official Volunteers are expected to adhere to safety practices presented by SH&S, Faculty, Principal Investigators, Project Directors, technical staff, student assistants, graduate assistants, and other authorized individuals. Please refer to the “Responsibility” section in the CSU Environmental Health and Safety Policy, . If a CSU policy or program is in conflict with a Collective Bargaining Agreement (CBA), the CBA shall take precedence unless otherwise proscribed by law or regulation. Responsibilities include:

Consulting with their supervisors when concerned about an unknown or hazardous situation or substance.
Reading and complying with procedures and guidelines provided by their supervisors or SH&S.
Reporting all unsafe conditions, practices, or equipment either to their supervisor or to SH&S without fear of reprisal.
Attending and completing education and training sessions, to understand, and comply with all applicable safety requirements. Training must be timely and in advance of the assignment of duties.

J. Students

Students shall follow all established EH&S requirements for the campus. Students are expected to adhere to safety practices presented by SH&S, Faculty, Principal Investigators, Project Directors, technical staff, student assistants, graduate assistants, and other authorized individuals. Refer to the Responsibility section in the CSU Environmental Health and Safety Policy, .
Responsibilities incldue:

Ensuring their own safety.
Reading and complying with procedures and guidelines provided by SH&S if they are applicable to hazardous processes they are exposed to.
Reporting all unsafe conditions, practices, or equipment either to their faculty, residential assistant, or campus SH&S department without fear of reprisal.
Attending and completing education and training sessions, to understand, and comply with all applicable safety requirements. Training must be timely and in advance of being assigned hazardous operations.

VI. Accountability

Employees, volunteers, and students shall adhere to safe and healthy work practices as defined by established campus and departmental safety and health guidelines. Failure to comply with established safety procedures may result in appropriate disciplinary action consistent with the provisions of Memoranda of Understanding (MOU) between CSU and applicable bargaining agreements and specific sections within the California Education Code and the California Code of Regulations, Title 5.
In addition, positive incentives for compliance are in place for all employees. These include nomination for the Governor’s Employee Safety Award (GESA), SH&S Safety Champion recognition, Caught Doing Something Safe (CDSS) initiative, acknowledgement in the SH&S Safety Sense newsletter, and letters of commendation may be written by supervisors on behalf of employees who have made noteworthy achievements in the area of environmental, occupational health and safety.
Fines due to violation citations may seriously impact a departments or divisions annual operating budget. Contingency plans should be implemented to provide for this possible expense and procedures should be established to provide priority to budget requests for compliance issues. Review the IIPP policy and procedure for more information.
Management shall demonstrate leadership and commitment with respect to environmental, health and safety, and address safety concerns brought to their attention.

VII. Program

Because of the diversity of operations within the University and the differences in organizational structure within departments, University administration recognizes that certain responsibilities and procedures in this IIPP may not be fully carried out by each department. Therefore, departments will have some latitude in formulating and implementing alternative procedures, when necessary, if the IIPP objectives and regulatory compliance are not compromised.

The program elements for the IIPP include:

- Safety Communications

Several methods of communicating with employees, volunteers, and students on matters relating to health and safety have been established.

Employee, Volunteer, and Student Safety Training - Training provides employees, volunteers, and students with the most effective method of communicating safety concerns. Refer to the section on Employee Safety Training and the IIPP Policy and Procedure.
Department Safety Meetings - High hazard departments (for ex. Facility Development & Management, Biology, Chemistry, Physics, Kinesiology, School of Arts, and other applicable departments) should schedule regular safety meetings during which safety and health issues shall be openly discussed by department employees. If not scheduled separately, safety should be a standing agenda item for departmental meetings. Management should attempt to schedule meetings when most employees can attend. Minutes must be kept to document who was in attendance and what topics were discussed if the topic is in relation to safety. Departments will ensure safety minutes are available to all department employees. Other low hazard departments are highly encouraged to incorporate safety subjects into their meetings periodically. Managers and supervisors must encourage employees to report any unsafe or unhealthful conditions they discover without fear of reprisal.
Campus Safety Newsletter - SH&S may publish a periodic newsletter for the campus community. When available, this publication is devoted to environmental, occupational safety and health topics, as well as off-the-job safety issues. When available the newsletter is distributed to employees who have asked to be included in a distribution list, posted on the SH&S website and visibility boards across campus.
Safety Notices - SH&S provides departments with a variety of safety information. These notices should be posted in high visibility areas within the department, provided by e-mail, or provided as hand-outs to employees during trainings.

- Environmental, Health and Safety Inspections

Section 3203, Title 8 of the California Code of Regulations specifies that scheduled periodic inspections shall be conducted to identify and eliminate unsafe conditions and work practices. The purpose of inspections is to identify and correct potential problems before employees become injured or property is damaged.

A. Scheduled Workplace Inspections

SH&S recommends that all areas be self-inspected on an annual basis, at minimum. Those departments engaged in hazardous operations are encouraged to conduct quarterly inspections.
It is the responsibility of each department to ensure that regular and systematic inspections are scheduled for all departmental areas. It is recommended that Department Safety Coordinators be involved in these inspections.
Departments may use the most appropriate inspection form: Three inspection forms can be provided to departments: a) office environments and general areas, b) laboratories, and c) industrial. These reports are to be completed by the Department Safety Coordinator or a departmental representative and submitted to SH&S.

1. 1. Office environment and general area form
  2. Laboratory form
  3. Industrial form

SH&S will conduct inspections of public access areas (i.e., hallways, stairways, interior and exterior public assembly areas, restrooms, classrooms, etc.) on an as needed or upon request basis.

The Chemical Hygiene Officer or Safety Specialist conducts laboratory and other high hazard area inspections. This inspection is not in lieu of the department’s other responsibilities.

B. Unscheduled Workplace Inspections

Departments will conduct evaluations when new substances, processes, procedures, or equipment are introduced, which represent a new potential occupational safety or health hazard. Notify SH&S for assistance if the department is unable to do this evaluation.
Departments will conduct an inspection whenever notification of a new or previously unrecognized hazard is received. Notify SH&S for assistance if the department is unable to resolve the issue.
SH&S will conduct random unscheduled workplace inspections to help ensure the maintenance of a safe and healthful work environment.
SH&S will conduct an environmental, health and safety inspection with the Department Safety Coordinator (DSC), Supervisor, Principal Investigator, or other department representative if an occupational injury, occupational illness, or exposure to hazardous substances occurs as defined by Cal/OSHA.
The State Fire Marshal, United States Department of Agriculture, County of San Diego’s Department of Environmental Health, San Diego Air Pollution Control District, State & County Department of Health Services, Cal/OSHA, City of San Marcos Fire Department, and other regulatory agencies make unannounced periodic inspections of university facilities. When this occurs, immediately notify SH&S at ext. 4502. SH&S will act as the liaison between the regulatory agency and University administration.
The Chemical Hygiene Officer or Safety Specialists may conduct periodic informal inspections of laboratories or hazardous areas.

C. Food Service

Food service inspections are conducted on an as needed or upon request basis by a Registered Environmental Health Specialist (REHS) or SH&S. SH&S is the Local Enforcement Agency (LEA) for ��.

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- Reporting Work-Related Injuries

When an injury or illness occurs that is serious enough to require immediate medical treatment, notify University police by dialing 911 or x4567 from a campus phone or 911 or (760)750-4567 from a cell phone or other outside line. Describe the injury or incident completely so that a determination can be made on the proper response.
If the injury is not serious or life-threatening, but medical treatment is required for an employee or a formally recognized (by HR) volunteer, contact the Workers’ Compensation Coordinator (WCC) out of the Office of Human Resources at x4416. The WCC will ensure the employee or volunteer is provided the proper forms and authorization for medical treatment. The employee or volunteer will be seen at either the contracted occupational medical provider or the local emergency service hospital. Students will be seen at the Student Health & Counseling Center or the local emergency service hospital. The medical provider will determine if the employee's illness or injury is serious enough to require time off or accommodations. This information will be disseminated to the Supervisor or Responsible Person through the WCC.

Workers Compensation
A Report of Employee Injury (completed by the supervisor and returned to the Workers Compensation Coordinator) and an Employee's Claim for Workers’ Compensation Benefits form (DWC-1 completed by the employee and returned to the WCC) must be completed for all injuries and work-related illnesses. These forms must be completed within 24 hours of the injury and submitted to the Workers' Compensation Coordinator in Human Resources. Forms submitted are available on the Workers Compensation website.
Workers Compensation will retain the Report of Employee Injury & Employee’s Claim for Workers’ Compensation Benefits forms. The report of employee or volunteer injury will be provided to SH&S for follow up or investigation, if applicable.

- Accident Investigation

Serious occupational injuries, illnesses, or exposures to hazardous substances must be reported to SH&S no later than six hours after they become known. SH&S will contact Cal/OSHA as required by law. SH&S, in conjunction with a representative from the injured employee's department, will investigate the circumstances of the incident to determine the cause and if there are future mitigation efforts.
A copy of each investigation report will be forwarded by SH&S to the Supervisor or Principal Investigator, as needed or requested.
A report may also be done by University Police or SH&S for injuries or incidents that occur which involve Students and Visitors.

- Hazard Reporting, Assessment, and Control Procedures

All employees are responsible for reporting hazards to their Supervisor, Department Chair, or SH&S.

A. Identification of Hazards

Hazardous situations can be found at any time. The more severe the hazard, the quicker the action needed for correction. Employees must use their own judgment in assessing the severity of a hazard and work with their supervisor if there are any concerns.

Department Inspections

Upon completion of any scheduled or unscheduled inspection, all findings will be prepared in writing and submitted to Department Chairs and SH&S on the appropriate Safety Inspection Checklist. Corrective action or a suitable timetable for elimination of a hazard is the responsibility of the department. SH&S will provide correction assistance, referral, and consultation.

SH&S Laboratory or Hazardous Area Inspections

Inspections conducted by SH&S will be reported in writing to the responsible Faculty Member/Principal Investigator (PI) or Supervisor of the area. Corrective actions that are not resolved or Immediately Dangerous to Life and Health (IDLH) situations are reported to the Department Chairs and the corresponding Department Safety Coordinator. Corrective action or a suitable timetable for elimination of the hazard (where appropriate) is the responsibility of the department where appropriate and necessary. SH&S will provide correction assistance, referral, and consultation.

Hazard Reporting

Hazards should be reported to Department Chairs, Managers/Supervisors or Department Safety Coordinators. Employees may report hazards by calling SH&S or anonymously submitting a safety concern on the SH&S website.

B. Hazard Classification and Remediation

Once identified, hazards are ranked according to the severity of the resulting injury or exposure and the probability of its occurrence. Imminent violations and hazards should always be given top priority and corrected immediately, or consideration given to halting operations affected by the violations or hazards.

Imminent Hazards

An imminent hazard is any condition or practice where there is reasonable certainty that a hazard exists that can be expected to cause death or serious physical harm. If a condition exists that presents an imminent hazard to health or safety, persons conducting the inspection shall immediately notify the Department Chair/Head, Manager/Supervisor, or SH&S, as appropriate.

All imminent hazards shall be repaired, removed from use, or modified to a hazard of lesser status immediately. The Manager/Department Chair/Area Supervisor shall inform all employees of any such imminent hazard(s) that cannot be immediately corrected and ensure that all necessary precautions are taken to prevent injuries or illnesses.

Serious Hazards

Serious hazards under the right circumstances will cause physical injury or illness. All serious hazards shall be corrected or modified to a potential hazard within 48 hours, unless an extended schedule has been agreed upon by SH&S and the department. Those affected by the hazard must be notified of existing conditions and procedures for avoiding an accident.

Potential Hazards

Potential hazards can cause minor injuries or illnesses under the right circumstances. These hazards will be corrected in an agreed upon schedule or modified as determined by SH&S and the department. Those affected by the hazard must be notified of existing conditions and procedures for avoiding an accident.

- Employee Safety Training

Effective dissemination of safety information is crucial to maintaining a successful IIPP. Refer to the Safety Training section in the Injury and Illness Prevention Program policy and procedure for more details. It is necessary to provide training for employees on general safe work practices and specific instructions concerning hazards unique to each employee's job assignment. The SH&S Safety Sense Newsletter, Safety Bulletins, or Microgram emails are a form of employee training where information of a general nature is disseminated campuswide. Other methods or modes of training include:

A. New Employee Safety Orientation

All new employees are offered general safety (IIPP) training through their supervisor, web-based training, or SH&S. This training is required for all University employees including student assistants and formally recognized volunteers. Full and part-time faculty may receive safety training information from the Faculty Center, their supervisor, or SH&S. During this training, employees receive an introduction to the University's safety program. Topics include but are not limited to:

Injury & Illness Prevention Program
Hazard Communication Awareness
Hazardous Material Awareness
Smoking Policy
Ergonomics Awareness
EAP/Emergency & Incident Preparedness
Reporting Campus Hazards
Fire Protection Awareness
Safety Training
Safety Communications
Safety Inspections
Employee Safety Responsibilities

B. General Safe Work Practices

SH&S has developed training programs designed to meet general safe work practice requirements. The frequency of these training programs is determined by regulations, prudent practices, or by supervisor requests. Available training courses can be reviewed at the SH&S Training web page The following training programs are elements of a larger program (the IIPP) which services broader campus needs. These programs* include, but are not limited to:

Back Injury Prevention
Biological Safety
Defensive Driver
Chemical Hygiene
Ergonomics (Office) & Lifting Safety
CPR & First Aid
Hearing Conservation
Lockout/Tag out
Radiation Safety
Supervisor Safety
Event Risk Management
Hazard Communication
Confined Space Entry
EAP/Emergency Preparedness
Fire and Life Safety
Industrial Powered Cart & High Lifts
Laboratory Safety
Heat Illness Prevention
Occupational Safety
Respiratory Protection
Risk Management
Food Safety

*Specific training programs can be developed as needed for specialized department needs.

C. Specific Safe Work Practices

Specialized training dealing with an employee's unique job assignment must be developed by each supervisor or with SH&S’ assistance. It is the responsibility of each Manager/Supervisor/Principal Investigator to identify the hazards of the job and ensure each employee is trained on the proper procedures.
Each Manager/Supervisor/Principal Investigator will ensure that all new employees receive general and specific training before their assignment to a new job or when an employer/employee is made aware of a new or previously unrecognized hazard.
Manager/Supervisors/Principal Investigators will ensure that employees are trained when new substances, processes, procedures, or equipment are introduced to the workplace.
All employee training shall be documented in writing or through the Campus’ Safety Learning Management System. Training topics, participants, signatures, and dates shall be recorded for student training and kept on file in SH&S. The same information shall be recorded and kept on file within each department and retained for the amount of time designated by the Records Retention Program or SH&S. SH&S maintains at least 3 years of recorded training documentation for Employees. For students, the departments retain a full academic year.

D. Retraining or Refresher Training

It's the responsibility of the department to have employees retrained or refreshed per department guidelines, SH&S training requirements, or regulatory requirements.

Recordkeeping

Records are kept for specified lengths of time. Refer to the CSU Records Retention Program procedure.

VIII. University Environmental, Industrial Hygiene, and Occupational Safety Programs

Programs incorporated into the overall campus IIPP are included to ensure that adequate measures are covered throughout the campus. Programs are reviewed every three years or as required by regulatory compliance. Some are available on the SH&S web site or can be requested from SH&S. Existing programs are outlined below. Specific written programs are contained in the noted appendices.

The Occupational Safety Program provides for, but is not limited to, safe working/walking surfaces, ergonomics, adequate illumination, proper maintenance of tools and other equipment, proper guarding of machinery, an Electrical Safety Program, a Lockout/Tag Out Procedure for all energized systems, safe use and storage of a compressed gas, a Confined Space Entry Procedure, equipment and procedures for the safe handling of materials, and a Defensive Driving program.

The Industrial Hygiene Program provides for personal monitoring and environmental testing to identify, monitor, and control potentially harmful substances and physical agents in the campus environment. Specific attention is given to such areas as noise, personal protective equipment and clothing, medical monitoring, ergonomics, indoor air quality, and exposure to toxic materials. The success of this program requires that the University develop the capability to:

Recognize the environmental stresses which present a potential hazard and understand their effects on employees.
Evaluate by experience and with the aid of quantitative measurements, the magnitude of those stresses.
Prescribe methods to reduce, control, or eliminate such stresses.

A. Biohazard Safety

The Biohazard Safety Program provides for the review of the University's teaching projects, research activities, and facilities involving the acquisition, use, storage, and disposal of biohazardous agents. The program ensures compliance with campus policies, National Institute of Health Guidelines, and other governmental regulations regarding the use of infectious and toxin-producing agents that have the potential for causing disease in healthy people, animals, or plants. The program is in compliance with the Cal/OSHA Bloodborne Pathogen Regulation (California Code of Regulations, Title 8, Section 5193)

The Bloodborne Pathogen Program - To minimize possible exposure of employees to bloodborne pathogens, the University has established a program designed to minimize or eliminate employee exposure. Included in the program are biomedical waste management, Hepatitis B Vaccination Program, infection control, and the implementation of the Medical Monitoring Program.
Exposure Control Plan
Biohazardous Waste Information
Biohazardous Spill Response
The Institutional Biosafety Committee – Office of Graduate Studies & Research

B. Building Plan Review & Construction Safety

The Building Plan Review Program provides that SH&S shall review and make recommendations where appropriate on all building plans for new construction, renovations, or modifications to existing buildings. This is to ensure that the buildings will comply with applicable health and safety standards and the building and its facilities will be adequate for the proposed use. All campus building committees, Energy Management & Utility Services, Facility Services, Planning, Design and Construction (PDC) and other responsible individuals will involve SH&S early in the planning stages of building construction, improvements, and acquisitions.

C. Confined Space Entry

This program requires safe operating procedures to be used when entering spaces such as sewers, pipelines, tanks, boiler compartments, ducts, vaults, pits, vats, bins, silos, areas that may lack oxygen, have dangerous air contamination, or other qualifying factors. The program is in compliance with the Cal/OSHA Confined Space Permit Required Regulation (California Code of Regulations, Title 8, Section 5157).

D. Contractor Safety

The Contractor Safety Program provides that contractors and their employees, when on University premises, work in accordance with federal, state, and local regulations and in such a manner to support the campus' efforts to prevent accidents and control losses. The University has established policies and regulations to be followed by contractors and service representatives. These rules are included in contracts and specifications set by the University. Acceptance of these rules and agreement to honor them shall be included in all awarded contracts.

SH&S has been given the authority to inspect job sites for safety violations. SH&S will work in collaboration with Planning, Design and Construction (PDC) on issues that affect campus projects. Through this IIPP and in relation to Occupational Safety and Environmental Compliance, University Police are specifically designated as representatives of SH&S in their absence. If the contractor is found to be jeopardizing the safety of the campus by their negligence, SH&S or their designee, has the authority to require the contractor to immediately remedy the situation or leave the campus. If the contractor refuses to comply, University Police will be asked to assist SH&S in escorting the contractor off campus. This will be done in collaboration with the PDC project manager when possible. If SH&S is unavailable, University Police has the authority to advise the contractors of their obligation to correct safety hazards immediately and to remove a contractor if an observed safety violation is left uncorrected.
SH&S has the authority through contract specifications to request the inspection of the contractor’s Injury and Illness Prevention Program and other applicable Environmental, Health and Safety related documents.
All safety issues and concerns regarding contractors that are working on �� property or leased spaces shall be reported to SH&S. SH&S will report the first complaint to the Project Manager who is responsible for the information dissemination to the Contractor and the resolution. The resolution may require feedback or follow up by SH&S at the discretion of the Project Manager. If a second complaint on the same issue is brought to the SH&S office, we will work in collaboration with the Project Manager to resolve the issue. SH&S has the authority to investigate or inspect the site in response to the complaint or perceived safety issue and to verify resolution.

E. Emergency Action Plan/Emergency Preparedness

The campus Emergency Action Plan & the Emergency Preparedness Program provides for a consistent and adequate means of handling a variety of emergencies. The goals of the program include the preservation of life, the protection of property, and continuity of campus operations. University employees, students, and the public are informed of and included in the preparedness and response strategy. The University has developed an Emergency Action Plan, in accordance with Title 8 Section 3220. The campus Emergency Preparedness Program includes the following items:

Emergency Operations Plan
The Emergency Operations Plan has been developed by the Emergency Preparedness Manager and outlines the actions to be taken by the University in response to emergency situations. It is a multi-hazard plan and is compatible with the State Office of Emergency Services Plan and other local agencies. The Plan is placed into operation by the President when an extraordinary emergency reaches proportions beyond the capacity of routine procedures.
Office of Emergency Management - /em/

F. Ergonomics

The Ergonomics Program is designed to educate the campus community on proper body mechanics to minimize and prevent the frequency and severity of cumulative trauma disorders and repetitive motion injuries. Workstation evaluations are conducted to correct the relation of equipment to body positions. Discussion includes stretching exercises, workstation & risk assessments, and modifications. The program is in compliance with the Cal/OSHA Ergonomics Regulation (California Code of Regulations, Title 8, Section 5110).

G. Fire and Life Safety

In accordance with the requirements of Title 8 Section 3221 and Title 19, the University Fire and Life Safety Program provides for a written Fire Prevention Plan. The plan includes established practices and procedures to control potential fire hazards and ignition sources; installation and maintenance of fire protection equipment and systems; regular portable fire extinguisher inspections and maintenance; and employee training on the use of fire extinguishers and fire protection procedures. The program is also in compliance with the Cal/OSHA Fire Extinguisher Regulation (California Code of Regulations, Title 8, Section 6151). The program includes:

Open Flame Program – Coming Soon
Portable Fire Extinguishers Program – Coming Soon
Heat Producing Electrical Appliances – Coming Soon
Flammable Liquids Storage Cabinets and Portable Safety Cans – Coming Soon
Evacuation or Fire Protection Plan – Emergency Management

H. Food Service, Public Health, and Sanitation

All employees, students, and visitors should be protected from pathogenic illnesses caused by inadequate sanitation. Guidelines are in place for food and pool inspections, training, and preventative maintenance. This program also applies to all student food sales. Per San Diego County Environmental Health & Quality program, SH&S is the Legal Enforcement Agency (LEA) for these areas of compliance. The Public Health and Sanitation program provides for regular inspections of all campus food establishments by SH&S, contracted, or appropriately credentialed personnel, to ensure that operations and facilities are in conformance with state and local public health codes. The purity of all drinking and swimming pool water is monitored by appropriate personnel to guard against the presence of harmful bacteria and other contaminants. Other activities include proper housekeeping practices, wastewater quality, proper disposal of food, and other non-hazardous solid waste.

SH&S consults, when contacted, on the sale or distribution of food items by student and campus groups to ensure proper sanitation methods are followed. Food service inspections are conducted on an as needed or upon request basis by a Registered Environmental Health Specialist (REHS) or appropriately trained and experienced SH&S representatives.

SHS will continue to Identify workplace-specific areas, activities and processes that could potentially expose employees to infectious disease (COVID-19, Influenza, RSV, TB, etc) hazards and conduct risk assessments when necessary to reduce the risk to others. SHS will continue to provide mitigation controls recommended by regulatory agencies. SHS will also continue to monitor all CDC, CDPH, and San Diego County HHSA COVID-19 guidelines.

I. Hazard Communication

The purpose of the Hazard Communication Program is to inform employees about hazardous substances in the workplace, potential harmful effects of these substances and appropriate control measures. The primary tools of this program are warning labels, SDSs, and employee training. The program is in compliance with the Cal/OSHA Hazard Communication Standard (California Code of Regulations, Title 8, Section 5194).

The written Hazard Communication Program provides for:

A listing of hazardous substances used in each workplace through the Chemical Inventory program.
A system of labeling containers. All hazardous materials & Hazardous Waste shall be labeled.
Safety data sheets for each hazardous substance used; through the Chemical Inventory Program using �� credentials.
Safety Data Sheets online program and resources.
A comprehensive training program for employees who use hazardous materials.

J. Hazardous Materials and Waste Management

The Hazardous Material and Waste Management Program provides that employees are trained in the safe procurement, transportation, handling, storage, and disposal of hazardous chemicals. Adequate safety equipment is provided in the workplace and properly maintained; employees are required to use personal protective equipment and clothing when handling chemicals; hazardous materials are properly labeled and stored; safe emergency response procedures have been established; ventilation equipment is properly used and maintained; and hazardous waste is managed in a safe and efficient manner. The program is in compliance with the Cal/OSHA Occupational Exposure to Hazardous Chemicals in Laboratories (California Code of Regulations, Title 8, Section 5191, 5192, & 5209 and Title 22 Section 66265.16).

Hazardous Waste Program resources.

K. Hearing Conservation

The University has established a Hearing Conservation Program to maintain effective control over the harmful effects of excessive noise on students and employees. Included in this program is the monitoring of locations and operations that produce excessive noise, identification of employees exposed to noise and a program for annual hearing exams, if applicable. The program is in compliance with the Cal/OSHA Hearing Conservation Program (California Code of Regulations, Title 8, Section 5097, 5098 & 5099).

L. Indoor Air Quality

Through a collaborative effort with SH&S, Facility Services, Energy Management & Utility Services, and Planning, Design, and Construction (PDC), standards for indoor air quality will be maintained through reasonable preventative and responsive measures. This could include renovation, maintenance, inspections, monitoring, consultation from outside providers, and/or analytical testing.

M. Laboratory Safety

Academic research and teaching laboratories are complex workplaces. A wide variety of potential hazards exist either resulting directly from the work conducted or the tools used to conduct that work. It is the practice of the University that all laboratory research and teaching involving chemical, physical, and biological hazards will be conducted in a safe and responsible manner. The responsible person (PI, Supervisor, Staff, or Faculty Member) for this space ensures safety practices or procedures are followed by personnel, students, visitors, and volunteers. The program is in compliance with the Cal/OSHA Occupational Exposure to Hazardous Chemicals in Laboratories (California Code of Regulations, Title 8, Section 5191).

The Director of SH&S, Radiation Safety Officer, Chemical Hygiene Officer, and the Safety Specialists are responsible for the coordination of the Laboratory Safety Program and the development of the written Chemical Hygiene Plan for the campus. Persons using Hazardous Materials within the academic laboratories will be assisted with developing safety programs in accordance with Title 8, risk assessments, and . Assistance includes providing information on safe handling methods, storage of reactive and toxic substances, and personal protection. Available toxicological information includes permissible exposure limits to certain chemicals and the effects of overexposure to various target organs.
Laboratory Safety Program
Chemical Hygiene Program
University safety personnel conduct surveys of laboratory spaces to advise the research staff about physical and chemical hazards routinely found in research laboratory settings. The focus is on problems connected with chemical storage, waste management, earthquake preparedness, electrical hazards, and personal protection.

N. Lockout/Tag out/Block out

The Lockout/Tagout/Block out Program provides procedures for employees who maintain electrical, mechanical, pneumatic, hydraulic, and other energy systems which could unexpectedly start up and cause injury. Authorized employees will isolate, lock, and tag the equipment to warn others that maintenance is occurring, and equipment cannot be operated. The program is in compliance with the Cal/OSHA Control of Hazardous Energy regulations (California Code of Regulations, Title 8, Section 3314).

Lock out/Tag Out/Block out Program information – Coming Soon

O. Medical Monitoring Program

The employee Medical Monitoring Program was developed to help administrators in identifying those employees, both faculty and staff, who because of their exposure to certain health or physical hazards on the job, are required by state regulations to receive specific and periodic medical examinations, to ensure their health and safety is not adversely affected by their work environment. The implementation of the program is the responsibility of SH&S. The Managers/Supervisors/Principal Investigators are responsible for identifying these employees for SH&S and assisting with the compliance of the program. Employees are responsible for completing medical evaluations per direction of their supervisor or Responsible Person and according to the specifications of the program. The program is in compliance with various Cal/OSHA regulations that pertain to medical monitoring or surveillance (California Code of Regulations, Title 8).

Medical Monitoring Program

P. Radiation Safety Program

The Radiation Safety Program provides for the safety of personnel, students and the public during operations involving ionizing and non-ionizing radiation sources. Working in conjunction with the Radiation Safety Committee and within the guidelines approved under the University's “Specific License” with the State; the Radiation Safety Officer administers the Radiation Safety Program to ensure that all exposures to radioactive sources are kept to a level as low as reasonably achievable. The program is in compliance with the Cal/OSHA Non-Ionizing and Ionizing regulations (California Code of Regulations, Title 8, Section 1801 and Title 17, Section 30255).

Radiation Safety Manual
Laser Safety Manual – Coming Soon

Q. Respiratory Protection Program

The University uses engineering and administrative controls to eliminate or minimize employee exposure to unsafe levels of airborne contaminants. When such controls are not feasible, use of personal respiratory protective equipment may be required to provide the appropriate level of protection. The University Respiratory Protection Program establishes a process regarding the use of respirators. Respirator users are included in the Medical Monitoring Program (See section O). The program is in compliance with various Cal/OSHA regulations that pertain to medical monitoring or surveillance (California Code of Regulations, Title 8, Section 5144).

R. Smoking Policy

Smoking has been shown to cause severe respiratory distress and illness in many people, especially those with asthmatic and allergic conditions. The University & CSU System recognized the need for establishing a policy regarding smoking on campus. The policy prohibits smoking on University property which includes University buildings, state-owned vehicles, and complies with State law. The program is also in compliance with Cal/OSHA regulations that pertain to smoking in the workplace (California Code of Regulations, Title 8, Section 5148).

S. Workplace Violence

Many institutions are at risk for workplace violence. This program is to ensure, as much as reasonably achievable, a safe working environment. Campus offices and departments should be aware of their own particular security issues and report any instances of belligerence or threatening behavior to University Police. Training is required of all employees initially, annually, whenever new or previously unrecognized workplace violence hazards have been identified, or when substantive changes are made to the current plan. The University is committed to zero tolerance to acts or threats of violence and verbal or sexual harassment.

Workplace Violence Program – VP of FAS Division webpage