University of Washington Policy Directory

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*Formerly part of the University Handbook
Administrative Policy Statement
10.3.3


Occupational Safety and Health Programs: General Requirements for WISHA Compliance

(Approved by the Executive Director of Health Sciences Administration by authority of Executive Order No. 1)



3.  General Requirements for WISHA Compliance

All of the University's organizational units are required to plan and implement occupational safety and health programs to ensure that facilities, equipment and supplies, management practices, and operational procedures meet applicable safety and health standards. Note: Department or unit safety and health programs must be documented in a written safety and health plan. Assistance in developing these programs and copies of the state and other occupational safety and health standards can be provided by EH&S. At a minimum, programs should include the following:

a.   Accident Investigations

Accident investigations must be conducted following accidents that cause serious injuries and have immediate symptoms. For serious accidents, investigation must be conducted by EH&S and include the immediate supervisor of the injured employee, witnesses, an employee representative, and any other person with the special expertise required to evaluate the facts relating to the cause of the accident. The findings of the investigation shall be documented by EH&S. Less serious accidents do not require EH&S's involvement in the investigation, but all accidents must be investigated by the supervisor of the employee(s) involved and findings and corrective action reported on the appropriate University incident/accident report form (see Section 4 of this policy statement).

b.   Hazard Identification

Hazard identification is critical to establishing effective employee safety and health programs. Employing departments and supervisors must be aware of and identify the potential hazards in work areas under their control. If employees have the potential to be exposed to workplace hazards, specific programs must be in place. EH&S can assist departments in identifying hazards and implementing the appropriate health and safety programs. Following is a list of occupational safety and health concerns which are regulated by WISHA; however, the list is not necessarily conclusive. Any workplace hazard must be identified and corrected, whether a specific regulation exists or not.

 
  • Accidents
  • Air Contaminants
  • Asbestos
  • Benzene
  • Bloodborne pathogens
  • Carcinogens
  • CFC (chlorinated
       fluorocarbons)
  • Chemical hazards in
       laboratories
  • Chemical hazards,
       nonlaboratory
  • Compressed gas &
       compressed gas equipment
  • Confined spaces
  • Cranes, overhead & gantry
  • Electrical
  • Emergency evacuation
  • Emergency response to
       hazardous materials incidents
  • Ergonomics (repetitive
       motion/cumulative trauma)
  • Excavation, trenching &
       shoring
  • Falls (from heights)
  • Falls (slip and trip hazards)
  • Fire emergency & fire
       hazards
  • Fire extinguishers
  • First-aid emergencies
  • Forklift operation
  • Formaldehyde
  • Hand & portable power tools
  • Hazardous energy
       (lockout/tagout)
  • Hazardous materials
       shipping
  • Hazardous waste
       operations
  • High noise
  • Ladders
  • Lasers
  • Lead
  • Lifting 20 lbs. or more
  • Machinery & machine
       guarding
  • Materials handling &
       storage, including cranes,
       derricks, rigging
  • Means of egress
  • Personal protective
       equipment
  • Physical agents
       (illumination, ionizing &
       nonionizing radiation,
       vibration, pressure,
       temperature)
  • Powered platforms
  • Radiation
  • Respiratory hazards
  • Welding
  • Working surfaces, guarding
       floors & wall openings,
       ladders, scaffolds
  • WISHA regulations covering these hazards require a variety of protective measures such as specific safety procedures, equipment, and training; medical surveillance; engineering controls; etc. EH&S can provide information needed to comply with these regulations.

    c.   Self-Evaluation Inspections

    To determine whether work areas meet the General Safety and Health Standards and Occupational Health Standards (Chapters 296–24 and 296–62 WAC) established by L&I, departments must conduct regular, thorough inspections to evaluate work conditions and work practices. These inspections should be held at regular intervals to insure continuing compliance with standards; contact EH&S, 206–543–7388, for assistance.

      1) Conditions Not in Compliance With WISHA—Conditions identified as being out of compliance with WISHA should receive immediate corrective action. EH&S will advise departments on ways to correct specific conditions. Further consultation with L&I is available to departments needing assistance in solving specific problems. State consultants do not issue citations as state inspectors do when areas are below standards, but rather advise and recommend corrective actions. Requests for these services should be made through EH&S. The L&I representative will be received by EH&S, and the consultation will be conducted jointly with an EH&S representative.

      2) Correction of Noncomplying Conditions—If a department is unable to correct a condition which is out of compliance due to budget or personnel limitations, the department must submit a report to the appropriate vice president or dean for resolution. The report should include the recommended corrective action and an estimate of the resources needed to implement it.

    d.   Safety Orientation

    Safety orientation is required for all employees. This requirement is met in part by the University's New Employee Orientation Program and in part by the employing department.

      1) New Employee Orientation Program—The New Employee Orientation Program covers the following information:
    • A description of the University's total safety program.

    • How and when to report injuries and unsafe conditions and practices.

    • Reporting emergencies.

    • A description of the University's Hazard Communication Program.

    • A description of the University's Health and Safety Committee Plan.
      2) Employing Department—The employing department provides the following information:
    • Location of first-aid kits, Material Safety Data Sheets (MSDS), and other safety and health information.

    • Emergency evacuation routes and procedures.

    • Use and care of required personal protective equipment.

    • Identification of hazardous gases, chemicals, or materials, along with instructions on safe use and emergency actions following exposure (specific hazard communication training).

    • On-the-job review of the safety practices.

    • Required safety and health training.

    Note: Temporary and hourly employees do not attend the University's New Employee Orientation Program, so employing departments must provide comprehensive safety orientation within the department at the time of their initial assignment; call EH&S, 206–543–7201, for a New Employee Safety Orientation checklist.

    e.   Safety Education and Training

    To ensure an effective program, employees must be trained in safe work practices. Supervisors are responsible for seeing that these practices are followed. EH&S will assist departments in implementing safety training and education programs upon request.

      1) Training New Employees—New employees should be thoroughly trained in safe operation of equipment, and in safe procedures for performing all duties included in their job assignments before being permitted to perform on their own.

      2) Safety Education Meetings—Safety education meetings should be held periodically in each organizational unit to reinstruct employees in safe work practices and to inform employees of new developments relating to safe operations.

      3) Specific Training—Specific training is required for certain occupations and occupational exposures. Contact EH&S Training, 206–543–7201, for assistance in determining employee safety training requirements.

    f.   First-Aid Training

    In certain workplaces it is a requirement that personnel trained in first aid be present. For example, shops, dispersed work crews, and field trips must have first-aid certified employees present during each shift. EH&S will interpret first-aid requirements for organizational units, and can provide qualifying first-aid training upon request.

    g.   First-Aid Kits

    As specified by WISHA, first-aid kits must be readily accessible and procedures in place to assure that first-aid kit contents are maintained in a serviceable condition; contact EH&S, 206–543–7388, for first-aid kit content requirements.

    h.   Health and Safety Committees

    The University of Washington has implemented an occupational Health and Safety Committee Plan to comply with WISHA regulations and to provide a forum for employee participation in assessing and enhancing workplace health and safety at the University. University health and safety committees are structured along organizational lines and report to the head of the organizational unit. A University-wide health and safety committee, composed of members of the organizational unit committees, provides campuswide consistency and oversight and reports to the director of EH&S. See Administrative Policy Statement 10.11, for a description of the University's Health and Safety Committee Plan.

    i.   Posting Employee Job Safety and Health Notices

    Each University unit or department must have a bulletin board for posting safety notices and safety educational material. The board must be in a location accessible to all employees (hallway, lunchroom, photocopy room, etc.) and at a minimum must display the posters required by L&I and the University Hazard Communication poster; call EH&S, 206–543–7201, to obtain copies of the required posters.

    j.   Record Keeping

    State standards require designated organizational units to maintain records of all safety activities covering the previous twelve months. These records must be made available to L&I noncompliance personnel at their request. Department records should include:

    • Results of self-evaluation inspections.

    • Records of requests for assistance in correcting noted deficiencies.

    • Minutes of safety education-accident prevention meetings.

    • Records of employees requiring medical evaluations including dates of examinations and immunizations.

    • Records of employee safety training, including dates when certificates expire, where applicable.