POLICY

It is the policy of Western Oregon University to comply with ORS 465.003-037 to 
reduce and manage all toxic substances and hazardous waste on the university 
campus from the point of purchase to legal disposal.  Hazardous chemical 
management shall consist of purchasing, handling, storage, disposal, reduction 
and recycling.

    PURPOSE

The purpose of the policy is to ensure that all departments and campus 
purchasing agents comply and/or are proactively moving towards compliance of 
campus hazardous waste materials.  In addition, the policy is necessary to 
maintain low generation of waste so the university preserves the status of a 
"Conditionally Exempt Generator" and reduce danger, financial impact and 
hazardous waste disposal from campus.

WESTERN IS RESPONSIBLE FOR ALL HAZARDOUS CHEMICALS AND WASTE ON CAMPUS FROM DATE 
OF PURCHASE UNTIL THE CHEMICAL NO LONGER EXISTS.

Hazardous Chemical Management Priorities:

1. Reduce the quantity of hazardous waste generated by Western at time of 
   purchase and during the period of usage.
2. Manage generated hazardous waste in a manner which protects the safety and 
   health of students, faculty, staff and the public.
3. Manage hazardous waste in an environmentally sound and responsible method.
4. Maintain compliance to all Federal and State regulations for hazardous   
   waste management.

Toxic Chemical Generators:
The following departments are known to purchase, store and generate toxic 
chemicals or waste:

* Physical Plant
* Student Health Center		
* Theatre Department
* Auxiliaries 
* Educational Media Center		
* Natural Science
* Safety Services
* Art Department			
* Physical Education
* Athletic Department

    PROCEDURES

1. Permit - "Permit required" spaces will not be entered until all 
   hazards are eliminated.  A permit (attached) is required to be 
   completed for all "Permit Required Confined Space Entry Work."  
   Issued permits are to include all work to be done in the space 
   during a shift and encompass all participants, including the 
   following:

    ? General Information;
    ? Permit Space Hazards;
    ? Entry Preparation;
    ? Emergency Service;
    ? Equipment required for entry and work;
    ? Communication procedures;
    ? Authorized person that may enter the confined space;
    ? Authorized attendants;
    ? Testing record;
    ? Authorization by entry supervisors.

2. Monitoring - Is to occur in all portions, top to bottom, corners, 
   spaces, pipes and duct work of the space before and during entry.  
   Results are to be recorded on the permit for each entry.

    ? Elements Monitored - The confined space is to be monitored at all
      times for oxygen, lower explosive limit (LEL), and carbon monoxide.
    ? Monitor Calibration - The monitor is to be calibrated prior to each
      day's use to the manufacturers standard of operation for carbon
      monoxide, hydrogen sulfide and oxygen.
    ? Alarms - Monitor alarms are to be set at 20.4% (lower limit) 
      and 21.4% (high limit) for oxygen, 10% of LEL for methane, 
      13 PPM (one-half of the ACGIH time-weighted average 
      exposure limit) for carbon monoxide.
    ? Maintenance on the monitor is to occur based on manufacturer's 
      recommendation.

3. Training - The Physical Plant Facilities Maintenance Supervisor 
   will provide confined space training to all employees assigned to 
   work as entry or standby personnel.  Annual training by the 
   Physical Plant Facilities Supervisor will consist of the following:

    ? Hazard Communication;
    ? Confined Space Entry Equipment - Including lifeline, monitoring 
      instruments and methods, hoisting equipment, non-sparking tools, 
      ventilation equipment and communication methods;
    ? Emergency Rescue - Polk County Fire District Number One is designated
      as the rescue agency for confined space rescue.  Polk One is to be 
      notified prior to any confined space entry;
    ? Protective Equipment - Consists of eye, skin, and respiratory equipment 
      and their maintenance;
    ? Confined Space Entry - Review of entry to include ventilation,
      isolation, communication, posting, barricading procedures and 
      protection from external hazards;
    ? Permits - Procedural and permit elements;
    ? Hazardous Atmosphere - Instructions including development, prevention, 
      control and working in hazardous atmospheres;
    ? Hazard Recognition - Identification of the types of hazards which can be 
      encountered, signs/symptoms of exposure, first aid procedures;
    ? Fall protection;
    ? Lock Out/Tag Out - Energy control procedures.

4. Confined Space Work Procedures

    ? Confined Space Entry Permit - The Physical Plant Facilities Supervisor
      or his designee is the person responsible to authorize entries and have 
      oversight of the monitoring section of the permit.
    ? Unauthorized Entry - Work will not be performed in unauthorized confined 
      spaces by Western employees or contractors.
    ? Hazardous Free Spaces - Spaces are to be cleaned and purged prior to 
      entry to include being free of hazardous atmospheres.  Oxygen content
      of 20.4-21.4%, toxic content less than 1/2 of the exposure limits and 
      flammability levels at less than 10% of LEL for specific gas/vapor for
      the entire entry period.
    ? Lock Out/Tag Out - Energy control procedures for all energy sources are 
      to be followed.
    ? Monitored Spaces - Spaces are to be monitored before entry and 
      continuously through the work process.  Entry persons are to be 
      evacuated whenever a monitor alarm sounds, and reassessment of the 
      space performed.
    ? Ventilation will occur throughout the work if initial monitor results 
      indicate the atmosphere is not acceptable. 
    ? Non-Sparking Tools - Only non-sparking tools may be used whenever 
      flammable or combustible atmospheres are capable of being created.
    ? Work Review is to occur prior to entry to determine of the work itself 
      will contribute to an unacceptable atmosphere, including welding and
      gluing.
    ? Hot Work Permit - If equipment that generates a hazardous atmosphere by 
      consuming oxygen or creating a harmful vapor or gas is used in a 
      confined space, additional precautions are to take place to eliminate 
      the hazard and protect the entrant person.  A second permit is required 
      detailing additional precautions required.
    ? Standby Person will be at the point of entry in constant communication 
      with the entry person(s).  The standby person can order an evacuation 
      when a hazard or ill effect of an entrant is noted.  The standby person 
      must summon Polk One for rescue.
    ? Rescue - Polk One will respond and rescue the entrant.  If the person 
      has a lifeline the standby person is to call Public Safety for initial 
      response until Polk One arrives.  If the person can be retrieved 
      through a pre-existing lifeline the standby person and Public Safety 
      may attempt to retrieve the person if it can be determined that no 
      urther serious harm will occur.
    ? Heat Stress and Disorders - Heat stress may cause a person to process 
      information poorly, disregard danger warnings, make poor choices, have 
      slower reaction time, have impaired coordination, or misjudge istances. 
      Persons who begin to experience heat cramps, heat exhaustion or heat 
      stroke are to remove themselves from the space.

5. Permit Entry Procedures - Persons who determine a need to enter a "permit
   required" confined space are to comply with the following procedures:

    ? Inform supervisor. 
    ? Determine Hazards - Determine the potential hazards in the confined 
      space (e.g., oxygen deficiency, internal configurations, or depths 
      impairing the ability to escape unaided should an injury or acute 
      illness occur).
    ? Test Atmosphere - Test upper and lower levels using the gas monitor 
      which may include using plastic tubing on the lower levels.  
      Ventilation is to occur if a hazard is identified or possible.
    ? Personal Protective Equipment - Wear protective equipment based on 
      potential hazardous atmosphere which may include, but not be limited 
      to, gloves, respirator, boots, etc.  (This will include a lifeline, 
      shoulder harness, and retrieval system.)
    ? Complete Permit - Complete the entire permit and have it signed by the 
      Physical Plant Facilities Maintenance Supervisor.
    ? Standby Person - Is to be located at the entry point in constant 
      communication.
    ? Rescue Notification - Polk One is to be notified prior to entering a 
      confined space.

6. Contractors - When contracted work is to occur in a "permit required"
   confined space the Physical Plant Facilities Supervisor is to be notified.  
   He will provide the contractor with Western's Confined Space Program, MSDS 
   and hazard information.  It will be the responsibility of the contractor to 
   evaluate, monitor, and enter the space at their own assumption of risk.

7. Shared Work - In the event a contractor and Western work together in a 
   confined space, Western's confined space procedures will be followed.

    AUTHORITY

Oregon Revised Statutes 465.003-037; OAR 340; OR-OSHA and DEQ laws.

    APPROVAL

1. Responsibility

   a. Faculty, Supervisors, and Departments are responsible for management of 
      all hazardous chemicals and waste in their work site area, to include:
        : Documented training for employees on chemical use, hazards and 
          applications, labeling and securing (Hazard Communication "Right to 
          Know" law);
        : Written procedures are in place for the handling and disposal of 
          chemicals in their department/work area;
        : Written procedures are in place on how to store and dispose of 
          hazardous chemicals and hazardous waste in their areas;
        : Identifying alternatives to hazardous chemicals (particularly prior
          to purchase);
        : Make immediate availability of Material Safety Data Sheets (MSDS) to 
          all employees exposed to chemicals in their area;
        : Date all purchasing and receiving, and date of disposal of all
          hazardous chemicals in their unit;
        : Reviewing toxic use and waste reduction advantages;
        : Assign person(s) responsible for hazardous chemicals in their 
          department/area.

   b. Purchasing Department:  Responsible for the inventory of all hazardous 
      chemicals and purchasing, to include:
        : Identifying and purchasing alternative chemicals vs. hazardous 
          chemicals;
        : Obtaining MSDS on hazardous chemicals if one is not enclosed in 
          shipments;
        : Providing a written inventory of all hazardous chemicals purchased or
          in stock at all times.

   c. Safety Services Division:  Responsible for the management of OR-OSHA and 
      DEQ laws relating to hazardous chemicals on WOU's campus, including:
        : Develop written campus plan to comply with ORS 465 and OAR 340;
        : Quarterly and annual reports to DEQ;
        : Coordinate off campus disposal with vendors;
        : Hazardous waste and chemical cleanup coordination & reporting to DEQ;
        : Department consultation for reducing, recycling and storage 
          techniques.
        : The university master plan required by statute;
        : Consultation, monitoring and regular inspections of those departments 
          handling chemicals & hazardous waste to ensure university compliance;
        : Maintenance of records for compliance to OR-OSHA and OAR requirements.

   d. Employees Responsibilities include:
        : Participate in annual department training related to hazardous waste;
        : Follow written safety procedures on chemical use and storage;
        : Perform work around potential hazardous chemicals in a safe manner.

2. Purchasing Responsibility:  Centralized purchasing of all chemicals with the 
   campus goal to eliminate hazardous waste prior to entering WOU's inventory.  

   To reduce and eliminate hazardous chemical exposure, the following guidelines 
   are in place for departments and the centralized purchasing department:

   a. Over purchasing - Avoid over purchasing of hazardous chemicals.
   b. Review MSDS - Review MSDS for hazardous components prior to purchase.
   c. New Equipment - Consider toxic use and waste reduction advantages when 
      purchasing new equipment.
   d. Material Safety Data Sheets (MSDS) - All hazardous chemicals are to have 
      MSDS on file when purchased and inventoried at the site where the chemical 
      is used.
   e. Replacing Chemicals - Chemicals that are hazardous should be reviewed by 
      the purchasing agent for alternative or less hazardous chemicals.
   f. Expired Chemicals - Chemicals out of date or have an expired shelf life 
      should not be allowed to be put into inventory.
   g. Only As Needed - Reduce or eliminate hazardous chemicals by purchasing 
      supplies only when and as needed. Projected savings from purchasing 
      chemicals in larger quantities is often offset by costs for disposal of 
      unused portions, especially those with a limited shelf life.