EBBD-R

File:   EBBD-R (pdf)
Adopted: April 13, 1989    

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HAZARDOUS MATERIALS PROCEDURES

1. Hazardous Materials Program Supervision Responsibility

Overall supervision of the operation of all hazardous materials policies and procedures within the District will be the responsibility of the Director of Operational Services who will serve as the hazardous materials program supervisor, referred to throughout these procedures as the "supervisor."

At each building or location (hereafter location), a District employee will be designated, subject to the approval of the supervisor, as the local hazardous materials coordinator, referred to throughout these procedures as the "location coordinator." At each location, there also will be an alternate District employee designated as a backup to the coordinator.

The location 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 location coordinator also will be responsible for reporting any violations in the District's hazardous materials policy or procedures simultaneously to the supervisor and the building/location administrator.

Each District employee and volunteer, individually, is responsible to comply with the requirements of this policy and procedures.

2. Purchasing (or Accepting Donated) Hazardous Materials

In addition to following the District's regular purchasing (or donation acceptance) procedures, an employee may purchase hazardous materials (or accept the donation of hazardous materials) for use at any location only with the approval of the location 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 prohibited hazardous materials which will be updated at least once a year. Any purchases from this list of prohibited materials shall require prior written consent of the supervisor. Hazardous materials will not be purchased through any mechanism other than a purchase order through the Purchasing  Department unless the following conditions are fulfilled:

a. The requestor secures the prior written approval of the supervisor; or

b. The supervisor or location coordinator designates a bona fide emergency which requires the purchase or use of hazardous materials; and

c. Within 48 hours the requestor provides written notice of the purchase along with copies of all supporting documents including MSDS and the reason for the emergency purchase to the supervisor, the location/building administrator, and the supervisor of Purchasing.

All purchase orders for (or the acceptance of donated items of) hazardous materials shall include a requirement that the shipment of any such materials includes MSDSs with any order (or donation) or portion thereof. Vendors shall be informed that failure to provide MSDSs 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 MSDSs are provided.

Any unapproved purchase (or acceptance of donated) hazardous materials is beyond the course and scope of the District employee's or volunteer's authority or employment. Such a purchase (or acceptance of a donated item) may be grounds for disciplinary action up to and including termination of employment.

3. Storage of Hazardous Materials

Storage of hazardous materials will be in compliance 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. Where appropriate, storage cabinets may be locked and access to students or non-authorized staff limited. The supervisor shall designate an area or areas for storage of:

Materials which might become or are hazardous materials and Hazardous materials which have been declared waste and are being held for disposal.

The supervisor shall designate storage areas at each location, if appropriate, as well as a central District storage site.

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).

4. Receipt and Tracking of Hazardous Materials and Material Safety Data Sheets (MSDSs)

Each location coordinator will be responsible for logging in the receipt of all hazardous materials received at the location. The location coordinator will track and keep complete written records of the storage, use, and ultimate disposition of the hazardous materials on forms provided by the supervisor. Once per year or more often as designated by the supervisor, the location 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 sheet (MSDS) system for the District.

Each operation and location will maintain a set of MSDSs in its area for all hazardous materials with which it has contact. These MSDSs will be available for review and use by every District employee. The MSDSs also will be available for inspection by appropriate police, fire, health, and emergency service authorities.

The warehouse will maintain a set of MSDSs for all hazardous materials with which they have had contact.

5. Inventory of Hazardous Materials and Material Identification

The supervisor will cause an inventory of all hazardous materials to be completed throughout the District to identify potentially hazardous substances. The supervisor will designate qualified District employee(s) to update the inventory of hazardous materials at each location with the assistance of the supervisor and the location/building administrator or his designee. This person also will coordinate the identification of hazardous materials.

The supervisor shall provide training in the proper process of identifying hazardous materials to at least one designated District employee at each location (either the location coordinator or an individual directly in charge of any of the hazardous materials storage/use areas).

At the direction of the location coordinator, these trained employees will conduct all future inventories.

The location coordinator will arrange for the identification of any unknown suspected hazardous substance through the supervisor.

6. Materials Identification and Status Determination

When any District employees, students, or volunteers have reason to believe that a substance or mixture of substances is hazardous, they will contact either the teacher in charge of the classroom, their supervisor, or the location coordinator, and they will detail their concerns. Pending a decision by the supervisor, the location coordinator has the authority to determine that the material in question may be treated as a hazardous material subject to this Policy and Procedures EBBD. Subject to the other provisions of this regulation, only the supervisor shall have the authority to finally determine if a
material is to be treated as hazardous.

The location coordinator shall be responsible to arrange for the identification of any unknown suspected hazardous substance through the supervisor.

When a coordinator or a location administrator has a material which they believe to qualify as a hazardous material and which they do not immediately need for their program or operation requirements or which may be waste and which may require disposal, they will contact the supervisor for action.

Only the supervisor shall be authorized to declare a hazardous material to be either excess, surplus, or waste. Further, only the supervisor shall be authorized to order the disposal of hazardous materials or waste.

7. Disposal of Hazardous Materials

If and 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. The disposal shall be supervised by the supervisor who shall comply with the documentation requirements.

At the option of the supervisor, the disposal effort may be conducted from each separate location generating the waste. In either arrangement, preference shall be given to the method that results in the most economical disposal method and meets all of the requirements of the EPA and other local, State of Colorado, and federal requirements. Normally, the preferred method will involve the process in which the location generator qualifies for "small quantity generator - exempt" status.

8. Transportation of Hazardous Materials

The supervisor shall oversee the transportation of hazardous materials in District control both within the District and outside the District. Prior to any transportation of hazardous materials or waste inside or outside the District, the supervisor shall verify in writing that the transportation alternative used meets all District, local, state, and federal transportation and insurance requirements.

Once a hazardous material is under District control, each location controlling the material will be responsible for the material until it is passed to the control of another District location.

Federal regulation of the transportation of hazardous material is extensive, complex, requires significant insurance protection, and involves specialized training of staff and special equipment. Because the District cannot meet these requirements for the transportation of any hazardous waste or hazardous materials outside the state economically with current staff, equipment, and training, the District will arrange for qualified third parties for transport.

Unless specific written approval is received by a District employee from the supervisor, no District employee or volunteer will transport hazardous materials owned by or attributed to the District in their own or any other personal vehicle.

Subject to the same requirement, no student will be permitted by any District employee or volunteer 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. Violation of these transportation requirements may result in disciplinary action up to and including termination or a volunteer's revocation of authority.

9. 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.

10. Evacuation Plan

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, and tornado 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.

11. Training of Staff and Students

The coordinators, administrators, staff members handling hazardous materials, and school nurses/health paraprofessionals shall 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.

12. Hazardous Materials Reduction and Substitution Program

Each location and operation shall begin a program of identifying the quantity of hazardous materials which it uses over the course of the year. Once those quantity requirements have been established, each program or operation will strive to eliminate any excess of those requirements. Where possible, less dangerous substitutions will be identified and used in place of hazardous materials. District staff are encouraged to reduce the size of demonstrations to reduce the risk of exposure.

Where possible, purchase of new hazardous materials will be coordinated among the various locations, operations, and programs within the District. When materials are identified as not being needed for one program or operation, the materials shall be made available for use by other programs or operations.

End of File:  EBBD-R