Issue Date: April 5, 2012
Overall supervision of adherence to all hazardous materials policies and procedures within the district will be the responsibility of Director of Facilities who will serve as the hazardous materials program supervisor, referred to throughout these procedures as the "supervisor."
At each location, a district employee will be designated as the local hazardous materials coordinator, referred to throughout these procedures as the "coordinator." At each location, there also will be an alternate district employee designated as a backup to the coordinator.
The coordinator will be responsible for all aspects of dealing with hazardous materials at the location and will comply with all district policies and procedures and local, state and federal laws and regulations dealing with hazardous materials. The coordinator also will be responsible for reporting any violations of the district's hazardous materials policy or procedures simultaneously to the supervisor and the building/location administrator.
Initial Inventory and Material Identification
The supervisor will cause an initial inventory of all hazardous materials to be completed throughout the district to identify potentially hazardous substances. The supervisor will
[Choose either Option 1:] contract for a qualified hazardous materials person/firm to conduct the inventory of hazardous materials at each location with the assistance of the supervisor and the location/building administrator or a designee. This person/firm also will coordinate the identification of any unknown materials. The supervisor shall follow District procurement procedures in this contracting process.
[Or choose Option 2:] designate a qualified district employee to conduct the inventory of hazardous materials at each location with the assistance of the supervisor and the location/building administrator or a designee. This person also will coordinate the identification of hazardous materials.
The party conducting the inventory will work with at least one designated district employee at each location (either the coordinator or an individual directly in charge of any of the hazardous materials storage/use areas). The party conducting the inventory shall also provide training in the proper process of identifying hazardous materials to the designated District employee at each location.
At the direction of the coordinator, these trained employees will conduct all future inventories.
The coordinator will arrange for the identification of any unknown suspected hazardous substance through the supervisor.
Tracking, Inventory, and Material Safety Data Sheets
Each coordinator will be responsible for logging in the receipt of all hazardous materials received at that location. The coordinator will track and keep complete written records of the storage, use and ultimate disposition of the hazardous materials. On or before [insert month and day] of each year, the coordinator will provide a copy of the current inventory log and record of disposition of all hazardous materials to the supervisor.
The supervisor will maintain a copy of each location's inventory and documentation of all hazardous materials. This information may be released to appropriate police, fire and emergency service authorities.
The supervisor will be responsible for establishing and maintaining the material safety data sheets (MSDS) system for the district.
Each operation and location will maintain a set of MSDS in its area for all hazardous materials present in or which are to be brought into the operation and location. These MSDS will be available for review and use by every district employee. The MSDS also will be available for inspection by appropriate police, fire, health and emergency service authorities.
The purchasing department and the warehouse each will maintain a set of MSDS for all hazardous materials, which have been purchased, or which are or have been stored.
Purchase of Hazardous Materials
In addition to following the district's regular purchasing procedures, an employee may purchase hazardous materials only with the approval of the coordinator for use at a specific location. The purchasing department will not process any purchase order, which does not include the appropriate approval.
The supervisor, the purchasing department and the warehouse will maintain a list of hazardous materials (for which approval is required for purchase), which will be updated at least once a year.
Hazardous materials will not be purchased through any mechanism other than a purchase order through the purchasing department unless the following conditions are fulfilled:
- The requester secures the prior written approval of the supervisor.
- The requester provides written notice of the purchase along with copies of all supporting documents including MSDS and the reason for the purchase to the supervisor, the location/building administrator and the supervisor of purchasing.
- All purchase orders for hazardous materials will include a requirement that the shipment of any such materials includes MSDS with any order or portion of the order. Purchase orders also will note that failure to provide MSDS with the shipment may result in either the district's refusing to accept the shipment or the district’s conditionally accepting the shipment and refusing to pay for it until the MSDS are provided.
Any unapproved purchase of hazardous materials is forbidden. Such a purchase may be grounds for termination.
The above procedures also will apply to the acceptance of donated hazardous materials.
Storage, Recycling or Transfer of Hazardous Materials
The supervisor will designate an area or areas for storage of:
- Materials that might become or are hazardous materials.
- Hazardous materials that have been declared waste and are being held for disposal.
The supervisor may designate storage areas at each location if appropriate as well as a central district storage site.
When a coordinator has a material, which qualifies as hazardous material at that location and which may require disposal, the coordinator will contact the supervisor to arrange for storage, transfer or disposal as appropriate. Materials no longer needed at one location may be available for transfer within the district to other programs or locations.
When materials are not needed by a district location, operation or program, the materials may be declared as waste. Only the supervisor is authorized to declare a hazardous material as waste.
Storage of hazardous materials will comply with federal, state and local law. All hazardous materials will be separated according to physical properties and stored safely in storage areas appropriate to the risk posed by the materials. For example, volatile substances such as petroleum distillates will be stored in approved safety cabinets. Where appropriate, storage cabinets may be locked and access to students or non-authorized staff limited.
All containers for hazardous materials will be labeled to show date of receipt by the district, shelf life and expiration date. Where space permits, materials will be stored so that the oldest materials are used first (first in-first out).
Transfer of hazardous materials within the district will be accomplished in compliance with “Transportation of Hazardous Materials,” below.
Disposal of Hazardous Materials
A coordinator or a location/building administrator should contact the supervisor if he or she believes that there may be hazardous materials at the location for which there is no immediate need or which may need to be disposed of. Only the supervisor is authorized to declare materials to be waste, excess or surplus and to order their disposal.
When materials are determined to be ready for disposal, the supervisor will arrange for disposal in a manner that complies with all local, state and federal laws and regulations.
Federal and state laws and regulations provide exemptions from certain regulatory requirements for small quantity generators, i.e., those entities or locations that generate waste in amounts below statutory or regulatory threshold amounts. Disposal determinations should preserve small quantity generator status for each location and for any central storage area.
The supervisor will maintain written documentation of the disposal of hazardous materials from all locations in the district. This documentation will be retained in permanent form at one additional location.
Transportation of Hazardous Materials
Transportation of hazardous materials will meet all local, state and federal requirements and will be coordinated by the supervisor.
Federal regulation of the transportation of hazardous materials is extensive, complex, requires significant insurance protection, and involves specialized training of staff and special equipment. Because the district cannot meet these requirements economically with current staff, equipment and training, the district will arrange for qualified third parties to transport any hazardous waste or hazardous materials outside the state.
Once a hazardous material is under district control, each location controlling the material will be responsible for the material until it is properly transported to another district location. The supervisor will verify that the transportation used meets all district, local, state and federal transportation, financial responsibility and insurance requirements.
Unless the supervisor provides specific written approval, no district employee or volunteer will transport hazardous materials owned by or attributed to the district in a personal automobile.
Unless the supervisor provides specific written approval, no district employee or volunteer shall permit a student to transport hazardous materials owned by or attributed to the district in any vehicle, including district vehicles.
Any unauthorized transportation of hazardous materials is beyond the course and scope of the district employee's or volunteer's authority and is forbidden.
Emergency Response Plan
The supervisor will develop an emergency response plan that will enable any district employee aware of any incident involving hazardous material to take appropriate action to protect students, staff, the general public and district property.
This plan will comply with all applicable laws and regulations and will be coordinated with the district and the location evacuation plans.
In addition, a plan to handle spills and leaks will be developed for each location for all hazardous materials at the location. The plan will address immediate emergency procedures, required notification and clean-up procedure and will comply with all applicable laws and regulations.
All information regarding a hazardous materials incident will be released to the media or the public only by the district's communication officer, the superintendent or their designee. No other district employee is authorized to release information regarding any such incident.
The supervisor will coordinate with the district's legal counsel and the superintendent's office any notification or reports to local, state and federal authorities as well as the district's appropriate insurance/risk management representative.
An evacuation plan will be developed and implemented for each location. In developing the evacuation plan, consideration will be given to the location and the types of hazardous materials present at the location.
An evacuation drill will be held at least once each calendar year at each location. Where possible, this plan will be coordinated with existing fire drills, bomb threat evacuation plans or other drills and may be conducted in conjunction with any of these other drills. Written records of the drill will be maintained by each location.
As appropriate for the location, copies of the evacuation plan will be posted within the buildings. Copies of the evacuation plan will be maintained by the coordinator, the location/building administrator, the supervisor and any other designated person approved by any of the above-named persons.
Where practical, the evacuation plan will be coordinated with the fire department, police department and the district's transportation department.
Training of Staff and Students
The coordinators, administrators, staff members handling hazardous materials and school nurses/health paraprofessionals will receive training in responding to hazardous materials emergency incidents.
When hazardous materials are used in the classroom, both staff and students will be trained in the handling, storage and use techniques appropriate to the materials used as part of the curriculum. The staff also will be instructed in emergency procedures, including evacuation, appropriate to the materials.