INDUSTRIAL HYGIENE SURVEY
of the
THE ART DEPARTMENT of . STOUT UNIVERSITY ~ MENOMONIE, WISCONSIN
Monona Rossel, M.S., M.F.A., industrial hygienist
Arts, Crafts and Theater Safety, Inc. 181 Thompson St., #23, New York NY 10012-2586 212/777-0062
June 12, 2006
TABLE OF CONTENTS
PART I. INTRODUCTION .
OSHA REGULATIONS
GENERAL INDUSTRY v. CONSTRUCTION STANDARDS.............................. 2
STANDARDS
AVOIDING LIABILITY
ADMINISTRATORS SPECIAL ROLE
PART II. GENERAL REGULATORY RECOMMENDATIONS........................................ 4
A HAZARD COMMUNICATION
B. RESPIRATORY PROTECTION. . 5
C. PERSONAL PROTECTIVE EQUIIPMENT
EYEWEAR
FACE PROTECTION
GLOVES
FOOTWEAR
PROTECTIVE CLOTHINGIDRESS CODE
D. FIRST AID, MEDICAL SERVICES & BLOODBORNE PATHOGENS............ 6
EYEWASHES/DELUGE SHOWERS
E. FIRE PROTECTION: EMERGENCY RESPONSE, EXTINGUISHERS............ 7
F. FOOD & DRINK/SANITATION
G. ELECTRICAL EQUIPMENT
ELECTRICAL PANELS
GUARDING OF LIVE PARTS
GROUND FAULTING
TEMPORARY WIRING
USE OF TWO PRONG PLUG ADAPTORS
H. HOUSEKEEPING................................................................................................. 8
I. BUILDING ACCESS
J. GRADUATE STUDIOS
K. SMOKING & DRINKING POLICIES
PART III. EPA REGULATIONS............................................................................................
A.GENERATORSTATUS
B. REGULATED CHEMICALS USED IN ART...................................................... 10
C. SINK DRAIN TRAPS
D. SOLID WASTE
E. MODEL WASTE PROGRAM................................................. 11
F. WASTE TREATMENT SYSTMS
NEUTRALIZATION TANKS
BIOLOGICAL DEGRADATION
RISD: A TREATMENT SYSTEM THAT WORKS
G. CONTAINMENT& SPILL CONTROL............................................................... 12
RECOMENDATIONS
PART IV. VENTILATION................................................................................................. 13
A. ASHRAE STANDARDS
B. ASHRAE SYSTEM IN THE SCHOOL
C. ASHRAE & CHEMICAL USE.............................................................................. 14
D. ACGIH STANDARDS.
I. DILUTION VENTILATION·
2. LOCAL EXHAUST VENTILATION
TABLE 1 -VENTILATION ,...................................... 15
PROCESSES REQUIRING DILUTION/DISPLACEMENT
PROCESSESIEQUIPMENT REQUIRING LOCAL EXHAUST
E. WORKPLACE AIR QUALITY STANDARDS
F. OUTDOOR AIR QUALITY & LOCATION OF EXHAUSTS
G. VENTILATION AND LIABILITY :............................ 16
H. GENERAL VENTILATION RECOMMENDATIONS
PART V: SPECIFIC RECOMMENDATIONS· THEATER............................................... 17
A. THEATER
B. SCENE SHOP...................................................................................................... 20
C. DRESSING ROOMS.......................................................................................... 21
D. GREEN ROOM
E. WARDROBE ROOM
PART VI: SPECIFIC RECOMMENDATIONS· ART BUILDING................................. 22
A. PROCESS LAB
B. ROOM 234
C. WOODSHOP -ROOM 119 D.METALSHOPROOMI19A...................................................................... 23
E. SCULPTURE ROOM 120................................................................................ 24
F. CLAY MIXING ROOM 107.............................................................................. 25
G. CERAMICS ROOM 103................................................................................... 26
H. PRINTMAKING................................................................................................ 31
I. PAINTING & DRAWING ROOMS 1 &2......................................................... 36
J. INDUSTRIAL DESIGN ROOM 216A & 220................................................... 43
K. ARTMETALS ROOMS 101 & 101A........................................................... 44
PART VI1: PRIORITY RECOMMENDATIONS ......................................................... 47
APPENDIXES ..................................................................................................... 48
i
INDUSTRIAL HYGIENE SURVEY: THEATER AND ART DEPARTMENTS OF STOUT-UNIVERSITY OF WISCONSIN
Monona Rossol, M.S., M.F.A., industrial hygienist
Arts, Crafts and Theater Safety, Inc.
181 Thompson St., # 23, New York NY 10012-2586
212/777-0062
June 12, 2006
PART 1. INTRODUCTION
This report and its recommendations are based on information obtained by Monona Rossol, of Arts, Crafts and Theater Safety (ACTS) during a survey done on April 27 and 28, 2006. The information on conditions and practices consists of 1) descriptions by the personnel, 2) a previous report on this facility I wrote in 1993, and 3) observations during a walk through survey of the department. With only these sources available, this report must not be considered as exhaustive or inclusive of all potential hazards that may exist. ACTS and its employees and agents are not responsible for any accident, injury or other loss that may occur as a result of any hazard.
The evaluations and recommendations contained in this report are based on current reference sources and accepted industrial hygiene principles and practices. The recommendations made are advisory. ACTS is not responsible for the carrying out the recommended changes in operations and equipment. Monona Rossol will answer any questions about the material in this report and provide follow-up technical advice and counsel on request.
OSHA REGULATIONS. The Occupational Safety and Health Administration (OSHA) regulates safety of workers in the US. However, Stout, like all of the University of Wisconsin schools, is regulated under the rules of the Department of industry, Labor and Industrial Relations (DILHR). These rules must be equal to or more protective than the federal OSHA regulations. And DILHR has adopted the OSHA regulations. Rather than look up the citations in DILHR codes, I will refer to the federal OSHA regulations. I leave it to the Health & Safety Office to check for differences between the OSHA regulations and DILHR's laws, if any.
Whether they are federal or state laws, the OSHA regulations are considered minimum health and safety precautions for the protection of adult paid employees. DILHR used to include the students directly under these laws, but no longer do. However, since DILHR's occupational regulations are considered minimum health and safety precautions for the protection of paid adult employees, failure to provide equal or better protections for the unpaid, inexperienced students can be used as evidence of negligence in personal injury lawsuits. Students actually need more training and protection than is required for the faculty.
For this reason, the training and precautions required for the protection of faculty should be extended to the students. In fact, OSHAIDILHR training should be part of the curriculum. This will also provide students with information that will equip graduates for teaching or creating art in the real world.
GENERALINDUSTRY v. CONSTRUCTION STANDARDS. Whether the applicable regulations are state or federal, the laws are further divided into two sets: rules for general industry and rules for construction work.
Workers in a permanent venue, such as the various art studios and classrooms on campus, come under the Virginia state equivalent of the General Industry Standards (29 CFR 1900-1910). But workers on a temporary location rather than in a permanent shop come under the Construction Industry Standard (29 CFR 1926). OSHA's definition of construction work is broad and includes any "alterations or repair, including painting and decorating." This means that installation or building of a large sculpture in studios or in galleries may come under the construction standards.
Both sets of regulations will be mentioned in this text when appropriate and they will be cited in the standard format. For example, the Hazard Communication Standard is found in the 29th part of the Code of Federal Regulations (CFR) at: 29 CFR 1910.1200.
STANDARDS. In addition to regulations there are professional standards applicable to ventilation (ASHRAE & ACGIH), electrical installations (NEC), fire protection (NFPA), protective equipment (NIOSH & ANSI), and so on. These acronyms and their standards will be identified in this report when applicable.
For example, the National Fire Protection Association (NFPA) codes are often incorporated into local building and fire codes. And both the NFPA standards and the OSHA regulations would prohibit building obstructions (sculptures) in egress areas. NFPA would prohibit installing fabric or plastic sculptures that are no iIre rated in public buildings.
Occasionally, OSHA cites employers under the General Duty Clause when there is no applicable regulation. To do this, OSHA will often cite a standard that is not actually a law. For schools, however, it is the liability for failing to follow professional standards that is greater issue. School risk managers and attorneys should consider the professional standards as important as regulations when assessing liability.
AVOIDING LIABILITY. Schools and teachers can be found liable for accidents or illnesses if they fail to meet any of five major duties: to inform, to train, to enforce, to exemplify, or to provide a safe work environment.
1. TO INFORM. Administrators are responsible for providing teachers (employees) with information about job site hazards. Likewise, teachers must pass safety information on to students. The information must be complete and specific. For example, if a student is injured or made ill because a teacher neglected to inform the class of potential hazards, the courts may interpret this as willful and/or knowing negligence on the part of the teacher and/or school.
2. TO TRAIN. Teachers must ensure that each student knows how to work safely with hazardous materials or equipment. Teachers must develop mechanisms to verify that students are trained to avoid making incorrect assumptions about their comprehension. This is most often done by observing them and their work and by giving safety quizzes. Teachers should keep records of their observations and copies of these quizzes to document that their students understood the safety presentations.
3. TO EXEMPLIFY. Teachers and administrators must model safe behavior. If teachers or administrators are observed violating safety rules, they may be liable for damages caused when students also break the rules. In addition, teachers and administrators must demonstrate a proper attitude toward safety. They must make it clear that safety is more important than finishing the work, cleaning up in time, or any other objective. Administrators who show contempt for the regulations, who glorify risk-taking, or who belittle students or other teachers who try to follow the rules are demonstrating failure to exemplify.
4. TO ENFORCE. Administrators cannot allow teachers to violate the rules. Regulators make it clear that without an enforcement policy, there is no safety program. Likewise, teachers must be in. control of their students and must enforce the safety rules and administrators must support the teachers' attempts to enforce the rules. In fact, teachers and administrators may be liable even when students willfully break the safety rules if it can be shown that the rules' were not enforced. And courts have held that enforcement policies must include meaningful penalties for those that break the rules--not a slap on the wrist. The penalties for infractions of safety regulations should be in writing as a part of every school's written safety program.
5. TO PROVIDE A SAFE STUDIO/SHOP/CLASSROOM. No amount of enforcement, training or information will make up for teaching in an unsafe environment. If a lesson cannot be done with all proper precautions. safety equipment. and ventilation. the project must be eliminated from the curriculum. There is never a good enough reason for students or teachers to violate safety laws in schools.
ADMINISTRATOR'S SPECIAL ROLE
Administrators are ultimately responsible for the efficacy of school health and safety programs. Some administrators do not fulfill these duties under the guise of allowing teachers and students "artistic freedoms." A common example is allowing students the freedom to work alone at night in buildings without supervision, without security, and even without ventilation if it is turned off after hours. Under these conditions, administrators have no good legal defense for accidents involving chemicals or machinery, for illnesses for which emergency services were not speedily procured, or for assaults in unsecured premises.
So-called freedoms involving risks like these must be rescinded immediately and replaced with sound health and safety discipline. For example, students should have a sequence of deadlines to meet during the semester so that they do not have work night and day to the point of exhaustion to produce an entire art show or theatrical production in the last few weeks of class.
In other words, administrator~ must administer, teachers must supervise, and students must take direction. Everyone must do his or her job or the safety of all and the liability of the school and its teachers are at risk.
PART II. GENERAL REGULATORY RECOMMENDATIONS
A. HAZARD COMMUNICATION (1910.1200). The faculty is much more aware of this law than when I was here in 1993. And in the training I did for faculty and students, we reviewed the provisions of the law which include:
· a written program which includes a survey (inventory) of all potentially toxic materials held in the schoo1;
· a labeling program which insures that each container of potentially toxic materials has a label which meets OSHA regulations;
· a file of material safety data sheets (MSDSs) on all the potentially toxic materials;
· regular training of all potentially exposed workers.
Labels must have the name/address of the manufacturer, the name of the product exactly as it is on the MSDS, and any required hazard warnings. As soon as a product is separated from this vital information is it in violation of both EPA and OSHA regulations. For example, some clay and glaze chemicals in the pottery have been put in bins and containers only labeled with the name of the substance. This entire inventory is in violation of the labeling regulations.
The survey and the MSDS file must be all inclusive of potentially toxic products. For this reason, students cannot purchase and bring in their own materials unless they are of the exact brands as those products on the survey and for which MSDSs are already on file. Most universities solve this problem by providing a list of the materials that are permitted to be used the class (see also the permissible list information in the Environmental regulations below).
If a student wants to use a different product, the teacher can direct the student to contact the manufacturer and obtain an MSDS. Then the safety office can evaluate the MSDS. Lf the product is suitable for use under classroom conditions, it can be added to the survey and MSDS file.
MSDSs. In most departments I saw MSDSs in binders, but some were not current or complete.
B. RESPIRATORY PROTECTION (29 CFR 1910.134). There are situations in which the students and/or faculty may need respiratory protection. If this is the case, the school must:
· develop a written respiratory protection program;
· provide medical certification (by a health professional or doctor) to ensure that wearers do not have health problems that may be exacerbated by breathing stress or wearing a mask or respirator such as asthma, heart problems, etc.;
· provide someone trained in one of the five OSHA-approved methods to fit test wearers; and
· provide training in the use, limitations, and maintenance of the masks or respirators.
Providing less than a full program will leave students with misconceptions about respirator use that will cause them put themselves at risk throughout their careers. An alternative strategy is to substitute safer materials for toxic ones and to provide good ventilation. This makes respiratory protection unnecessary. Over time, the ventilation is cheaper than respiratory protection.
C. PERSONAL PROTECTIVE EQUIPMENT (1926.28,1910.132-133). OSHA requires written risk assessments, written programs, and formal training about the proper use, limitations, and maintenance of safety equipment. OSHA usually relies on the American National Standards Institute (ANSI) for standards of care for selection and proper use of protective equipment. The school is required to provide these OSHA and ANSI program elements for the faculty, but students should be included in the training and programs as well.