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When I was studying to be a teacher a professor told my class that “cheating will occur when the incentive to cheat is high, and the risk of detection is low.” I have found this to be a wise observation.

Several months ago, an article in Inside Higher Education caught my eye. In it, the author of a study on cheating suggested that “the more distant students are, the more disconnected they feel, and the more likely it is that they’ll rationalize cheating.”

Many schools have had honor codes for decades, signed by hundreds of students who have passed through their institutions. The schools stand firm in their conviction that the code helps to assure that students “do the right thing” by fixing their moral compasses on higher ideals and a shared sense of purpose. Should students lose their way, the honor code and its accompanying judicial procedures help the students back to the desired path.

Do honor codes founded in brick-and-mortar ¹institutions still have application to education that takes place in virtual classrooms?

Of course they do. Yet the means of achieving student buy-in to an honor code in courses where their is not a shared sense of place or student camaraderie offers new challenges to educators. If my professors proposal regarding cheating as more likely in circumstances where there is “high incentive and low risk of detection” still holds true, then one must acknowledge that observing offending behaviors in virtual classrooms is more difficult than in physical classrooms. Sure, one can insist that students take exams in proctored environments, but that kind of defeats the purpose of online education and it is disrespectful to young people.

So why not work on the other side of the equation, namely reducing the incentive to cheat?

I have previously suggested that teachers don’t trust students and that our current practices of assessing students are a major contraint on educational innovation. I also believe that you can’t bolt technology onto old educational practices and expect it to work. Yet, changing teacher habits can be very hard. There’s will always be a certain faction of the faculty that resists everything. (see Whatever It Is, We’re Against It)

What contributes to the incentive to cheat? I posit that there are several reasons:

• pressure on students to get high grades.
• mistrust that examinations are a fair measure of student knowledge, but more a guessing game about what a teacher holds to be important or version of Trivial Pursuit.
• teachers who lack them time or incentive that would enable them to author and review more creative means of assessment.
• reductionist thinking among some parents and educators who believe that something as complex as learning can be easily measured with multiple choice and other “objective” test questions.
• students who are disengaged from the course or learning in general, going through the motions, and looking for the path of least resistance.

This is the last of a series of six posts regarding important OSHA or EPA rules that apply to independent schools.

Whistleblowers

OSHA regulations protect workers who file complaints against employers for unsafe or unhealthy working conditions from harassment or termination. Such workers are informally referred to as “whistleblowers.” OSHA believes that the protection to workers willing to “blow the whistle” on illegal employer practices to be so important that they have established a special office to enforce regulations.

To comply with this regulation, schools must not retaliate against an employee who reports you to OSHA or the EPA for an alleged violation of workplace safety rules. It does not matter if you told the employee not to report it, or if you told them the condition was going to be fixed later, or if it was minor and to “forget about it.” Firing, demoting, or otherwise disciplining or any negative treatment of the employee could be construed as harassment and is illegal.

Record Keeping and Training
Throughout this series of posts I have referred to various regulations and guidelines. Simply said, if it is regulated, it must be documented and training must be provided. This is why so many sections contain model policies and/or guidelines for creating policies.There are companies who specialize in providing OSHA training. Much of this training is aimed at hazardous industries such as construction, oil wells, mining, and agriculture. Education is a relatively safe industry in comparison to these. Yet hazards are nonetheless present and schools must be willing to provide training where indicated. Experience suggests that many schools could be doing a better job with offering in-service workshops in this area, but time is precious and I fear that in the list of important professional education topics OSHA, EPA, and similar safety and health issues do not get the attention they deserve.

Helpful Documents

CalOSHA Safety and Health Training and Instruction Requirements, CalOSHA

EPA Record Keeping, EPA

Training Requirements in OSHA Standards and Training Guidelines, OSHA

Office of the Whistleblower Proection Program, OSHA

Example Policy
Model Employee Protection (Whistleblower) Policy, Nonprofit Risk Management Center

Summary
Among the best singe resources I have found is a document written by the EPA, Long Island University, and Columbia University entitled Environmental Compliance and Best Management Practices Guidance Manual for K-12 Schools. This is a wonderful resource for all schools.There are so many forms, records, and notices required under OSHA and EPA that it can be hard to keep them all straight. Here’s a table I have developed that you may also find to be helpful.

This is the fifth of a series of six posts regarding important OSHA or EPA rules that apply to independent schools.

Personal Protective Equipment
“OSHA requires the use of personal protective equipment (PPE) to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing these exposures to acceptable levels. Employers are required to determine if PPE should be used to protect their workers.”  (http://www.osha.gov/SLTC/personalprotectiveequipment/)

To comply with this regulation schools must provide PPE at no cost to employees. In schools, this would routinely include safety glasses, gloves for outdoor work or rubber gloves for handling bloodborne pathogens or other hazardous and infectious materials, and respiratory masks when dealing with airborne chemicals.

• OSHA 1910.39
• OSHA 1910.38
• OSHA 1910.151

 

Helpful Documents
Fundamentals of a Workplace First Aid Program, OSHAIntroduction to Fire Prevention Plans, OSHASASH – School Action for Health and Safety, Labor Occupational Health Program, University of California Berkeley

Example Policies
Fire Prevention Plan Sample, U.S. Department of Commerce, NOAAInjury and Illness Model Prevention Program for Non-High Hazard Employers, State of California

Next up: Part 5: Job Hazard Analysis, Injury and Illness Protection, and Personal Protective Equipment

Previous Posts
Part 1, Bloodborne Pathogens and Infectious Disease
Part 2, Chemicals Used in Labs, Classrooms, and Custodial Supplies
Part 3, Mercury, Lead, Asbestos, Indoor Air Quality (IAQ), Material Safety Data Sheets, Notices and Public Notices/Right to Know

Coming Up Next:
Part 5: Job Hazard Analysis, Injury and Illness Protection, and Personal Protective Equipment
Part 6: Whistletblowers, Record Keeping, and Training

 

 

 

This is the third of a series of six posts regarding important OSHA or EPA rules that apply to independent schools.

Mercury, Lead, Asbestos, Indoor Air Quality (IAQ), Material Safety Data Sheets, Notices and Public Notices/Right to Know

• Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
• Universal Waste Regulations [40 CFR 273]
• Asbestos Hazard Emergency Response Act (AHERA)
• Toxic Substances Control Act (TSCA)
• Clean Air Act (CAA)
• Resource Conservation and Recovery Act (RCRA)
• Safe Drinking Water Act (SDWA)
• OSHA 1910.1200

Mercury
Mercury is a powerful toxin. A few drops can poison an entire lake. Found in older thermometers, barometers, thermostats, and school chemistry labs, the EPA has set its sites on safely eliminating mercury in all U.S. schools. Many states also have programs designed to rid schools of mercury. Pertinent mercury regulations are contained in the Clean Air Act, the Safe Drinking Water Act, the Resource Conservation and Recovery Act, and the Clean Water Act.

I recently had the opportunity to look into regulations from the Occupational Health and Safety Administration (OSHA) and the Environmental Protection Agency (EPA) to determine their applicability to independent schools. It felt like jumping into an ocean, at night, with nary a ship nor landmark in sight. I found that while there is an abundance of regulation, there is relatively little guidance for schools, and what guidance is available often focuses on schools that received federal funds.

Between them, OSHA and the EPA has hundreds of regulations that do (or could) apply to independent schools. Looking at these regulations broadly, I found that they cluster into six areas:

1. Bloodborne Pathogens and Infectious Disease
2. Chemicals Used in Labs, Classrooms, and Custodial Supplies
3. Mercury, Lead, Asbestos, Indoor Air Quality (IAQ), Material Safety Data Sheets, Notices and Public Notices/Right to Know
4. Fire Prevention, Emergency Action, Medical Services and First Aid
5. Job Hazard Analysis, Injury and Illness Protection, and Personal Protective Equipment
6. Whistletblowers, Record Keeping, and Training

This is the first of a series of six posts regarding the aforementioned OSHA or EPA rules. For each of these, I will offer a brief description of the purpose of the rule, what schools need to do to be in compliance, where you can find more information, and model policies.

Bloodborne Pathogens and Infectious Disease

(OSHA 1910.1030)

Bloodborne Pathogens
Bloodborne pathogens are contained in blood or other bodily fluids that can cause serious disease, such as HIV and Hepatitis B. Students, teachers, staff, custodians, coaches–anyone who works in a school may deal with an occasional scraped knee, bloody nose, or vomiting student. By regulation these “bodily fluids” must be treated as contaminated substances.

To comply with OSHA rules on bloodborne pathogens, schools must develop a policy for dealing with bloodborne pathogens and follow it. The policy should describe who it applies to, what it applies to, and give examples of those job classifications at greatest risk for exposure to bloodborne pathogens. It should describe how the school plans to safely handle bloodborne pathogens, including cleanup and disposal. You are required to document when exposure occurs, provide training in proper treatment methods (and maintain training records), offer free Personal Protective Equipment (PPE) to employees who deal with bloodborne pathogens, and free immunizations against hepatitis-B to at-risk employees who request them.

Infectious Disease
OSHA is exploring issuing regulations in the area of airborne infectious disease in the workplace. For years, OSHA has had a directive in place for employees who are exposed to tuberculosis while on the job.

Presently there are no OSHA rules in place for airborne infectious disease in the workplace, but this may change. Meanwhile, many state and local health agencies have mandated that schools report incidents of flu strains other communicable diseases. Check with your local health department to determine your school’s reporting requirements.

Helpful Documents
A Best Practices Approach for Reducing Bloodborne Pathogens Exposure and Exposure Control Plan for Bloodborne Pathogens – California Department of Industrial Relations. This policy is typical of the types of diseases that all schools should report to their local health authorities

Bloodborne Pathogens in Schools, multiple sources

Hepatitis B Vaccination Protection Fact Sheet, OSHA

Mandatory Disease Reporting, Santa Clara (CA) County

OSHA Fact Sheet on Hepatitis B Vaccination Protection - OSHA

Self Assessment Manual for Proper Management of Medical Waste – California Department of Health Service

Example Policy
Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards – OSHA

Coming up next:
Part 2: Chemicals Used in Labs, Classrooms, and Custodial Supplies
Part 3: Mercury, Lead, Asbestos, Indoor Air Quality (IAQ), Material Safety Data Sheets, Notices and Public Notices/Right to Know
Part 4: OSHA, EPA, and Independent Schools
Part 5: Job Hazard Analysis, Injury and Illness Protection, and Personal Protective Equipment
Part 6: Whistletblowers, Record Keeping, and Training

We all reach a moment in our lives when we think to ourselves: “My God! I’m turning into my [insert parent or other old person here].”

I recently discovered that I am turning into my mother. At 4’11″ and 95 lbs. for most of her life, this sweet person was soft-spoken and largely kept her opinions to her self in the presence of strangers. She “voted with her feet” by simply avoiding places or people that peeved her.

As she aged (she recently passed away at age 96), my mom became increasingly sensitive to smells. Like many women, my mom wore perfumes and colognes (Lilly of the Valley was a favorite), but as she aged her opinion of perfume changed as did her vocabulary describing them: fragrance, aroma, smell, stink, putrid. This was particularly sad to watch as it eventually led her to reject her formerly beloved flowers. She even stopped attending weekly Mass as she could not tolerate the smell of perfumes and incense.

My mother would be aghast at commercials like the one above. The use of artificial smells contained in a spray can to elicit positive associations would be beyond her. In the commercial, a woman in the kitchen lights a candle, inhales from it, while animations of psychotropic drugs enter her nostrils. She then hallucinates cookie reindeer and a Santa ornament coming to life. A child in the living room joins in the hallucination as Santa and reindeer fly through the window as a man and animated snowman peer through it.

Okay, maybe my interpretation of this scene is not what S.C. Johnson was hoping for, but if you take a look at the MSDS (material safety data sheet) for some of their household sprays ¹ you learn that misuse of the product could kill you, and first aid is to remove the victim to fresh air. Hmm.

So it is that I am becoming a Scrooge of scents. Sweet floral aromas in particular seem to make my head throb. We use something called “Bahama Breeze” in the restrooms at my workplace. If this stuff really smells like Bahama, I’ll take the third-world latrine tour instead.

Fortunately, I still love the smell of coffee brewing in the morning, redwood trees, and petrichor (look it up; I bet you like it too.)

I’m in a minority position in my house. My wife lives scented candles, bath oils, and spays lavender on her pillow. Our dog, Riley, seems to find all smells to be fascinating, but since that includes rotting carcases and other dog’s poop, we both tend to discount his opinion.

I draw the line, however, and making my house smell “like Christmas” or anything else through the use of aerosols and secretly sneak scented candled into the trash when they’re about 50% gone. So far I have not gone so far as to avoid people, but I do avoid certain stores and close my office door when certain heavily perfumed visitors are in the building. Fortunately, I have a window I can open where one a good day I can breathe the fresh California air – and on a fab one car fumes from the nearby street. Either is preferable to many Eau de Colognes.²

Glade MSDS.

Related post: Cleaniless is Scents-less

Repetitive stress injuries associated with the use of computers and other electronic devices leads to temporary and sometimes long-term injuries to faculty and staff which can cost school’s hundreds and thousands of dollars in lost productivity, wages for substitute teachers, and worker’s compensation claims. The Occupational and Safety Health Administration (OSHA) has not (much to the relief of employers and manufacturers of electronic devices who fear millions of dollars in litigation) mandated computer ergonomics rules, but many states have. As educators, we wring our hands (both in anxiety and to relieve our own aching joints) and wonder what we’re doing to generations of children and  teens who sit in computer labs using equipment sized for adults and lounge around on floors or slump in couches using i-Pads, Kindles, and netbooks. While there are plenty of state mandates regarding math and reading performance of children, I have yet to run across one that requires demonstrated proficiency in ergonomics.

A lack of national regulation law does not exonerate us of our moral obligation to provide and ergonomically safe environment for adults and students. (In the state of California, all employers are required to comply with CalOSHA’s regulations for safe computer use: Subchapter 7; General Industry Safety Orders: Group 15, Article 106 Ergonomics.) As adults become more aware of safe computer use practices, workstation accommodations, injury prevention, and the consequences of long-term ergonomic neglect, they will be better prepared to address the needs of their students in their care.

And so it is that I offer a simple set of guidelines that a school in the hope that it may lead to better conditions for all of the users within a school. I have deliberately eschewed legalese and long-winded medical explanations. This policy is aimed at adults, the group that is most likely to be covered by ergonomic employment law and, at least currently, the group most at risk for injury due to their longer use of electronic devices.

A Model Ergonomic Policy

The School will:

• Provide and maintain computer equipment and furnishings that conform to the standards and specifications in this policy at no cost to employees
• Evaluate workstations for proper equipment and furnishings
• Properly set-up up computer workstations for employees
• Provide proper training to employees
• Maintain records of employee repetitive stress injuries

Employees will:

• Notify their supervisor when ergonomic issues arise
• Follow guidelines for proper position and methods
• Promptly report any issues with computer equipment maintenance or repair
• Attend ergonomic training offered by the school
• Comply with recommendations made by supervisors and ergonomic consultants
• Provide proper eyeglasses, contact lenses, or other eye ware as recommended by their eye-care professional

A Physician’s Guide to the California Ergonomics Standard

California Department of Industrial Relations, Easy Ergonomics for Desktop Users

California Department of Personnel Administration, The Computer User’s Guide to an Ergonomic Workstation

OSHA Computer Workstation Checklist & OSHA Workstation Purchasing Guidelines

Apple Ergonomic Information

Time-Out Ergonomics Software (free, donations accepted) Macintosh Only

UCLA’s Guide to Office Ergonomics

Free or Inexpensive Ergonomics Software - Most ergonomists suggest regular breaks from computer work and certain stretches and eye exercises to mitigate the effects of repetitive motions. There are a host of software applications that will interrupt your computer work at specified intervals to encourage such breaks, and to provide you with instruction on certain kinds of exercises to do during the break. Here are a few of the leading ones.

MacBreakZ
StretchBreak
StretchWare
TimeOut
WorkRave 

Readers looking for a broad introduction to the many facets of planning, financing, and building a K-12 school will be well served by Building Type Basics for Elementary and Secondary Schools by Bradford Perkins with Raymond Bordwell [Amazon citation]. Part of the series “Building Type Basics” from John Wiley & Sons (other titles are in areas such as healthcare, museums, housing, colleges and universities), the book reads like one designed for a graduate course for faculty, administrators, and board members who may be charged with building new facilities. This is not a criticism, as the text covers a lot of ground, with discrete chapters that may serve as a wonderful reference when one needs a quick refresher on points to consider for such details as wayfinding, building codes, or lighting.

The text is laid out in discrete chapters that will be useful should the reader need to revisit something, or to provide to a specialist on your design team. Interested in HVAC and plumbing? Chapter 8, Mechanical Systems is for you. Thinking about refurbishing a building? Check out Chapter 16, Renovation. From the pre-planning phase through financing, you will find something of value. Project Managers, CFOs, CIOs, Business Managers, Board Chairs and other who need a broad view will find the scope useful, and others with more focused interests may be directed to appropriate sections. A list of chapters demonstrates the utility of this book:

1. Predesign
2. Circulation
3. Design Concerns and Process
4. Site Planning
5. Codes
6. Sustainable Design Issues
7. Structural Systems
8. Mechanical Systems
9. Electrical/Communications Systems
10. Technology and Special Equipment
11. Materials
12. Acoustic Control
13. Lighting Design
14. Interior Issues
15. Wayfinding
16. Renovation
17. International Design Issues and Opportunities
18. Operations and Maintenance
19. Cost Issues
20. Financing

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