OSHA, EPA, and Independent Schools – Part 4

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

Fire Prevention, Emergency Action, Medical Services and First Aid

Fire Prevention
OSHA regulations state an employer’s fire prevention plan include “a list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard; procedures to control accumulations of flammable and combustible waste materials; procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials; the name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires; and the name or job title of employees responsible for the control of fuel source hazards.”

Compliance with this OSHA regulation should be relatively easy for schools. Local and state regulations, plus years of common practices, have led schools to carefully monitor fire hazards, place smoke alarms and fire extinguishers around schools, and conduct regular fire drills. Deadly school fires are now a rare event.

That said, schools must have written fire prevention plans. It is possible that your school’s plan is more about fire response. If so, the information from OSHA and the model fire prevention plan below may prove helpful.

Emergency Action
Fire represents one peril to schools, but not the only one. Natural disasters, chemical spills, intruders, hostage taking, acts of violence, and bomb threats require that all schools have an Emergency Action Plan, details of which are found in OSHA1910.38.

To comply with this OSHA standard, you must have an emergency action plan. Your school may call refer to this as an Emergency Preparedness Plan, Emergency Operations Plan, or simply your Emergency Plan. OSHA provides an online tool (e-tool) for helping you to create a plan (http://www.osha.gov/SLTC/etools/evacuation/expertsystem/default.htm).This tool is very bare-boned, and you are likely to have already covered the information in your school’s plan. Nevertheless, it can help clarify questions, such as who is authorized (if anyone) to fight fires.

Writing and maintaining a comprehensive emergency plan is a large task, which pales only in comparison to the effort required to train staff to perform the many and myriad tasks in the plan.

Medical Services and First Aid
OSHA is concerned about medical services and first aid for employees being readily available in case of an accident or health emergency.

To comply with OSHA 1910.151 that schools must:

  1. Ensure the ready availability of medical personnel for advice and consultation on matters of plant health.
  2. In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.
  3. Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.
OSHA requires that first aid kids be available, but stops short of mandating what needs to be in them. It does refer to ANSI Z308.1-2003 Minimum Requirements for Workplace First Aid Kits. OSHA does does not require that schools have Automated External Defibrillators (AED), though the American Heart Association does recommend them and local or state agencies may require them.


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




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3 thoughts on “OSHA, EPA, and Independent Schools – Part 4

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