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2016 Annual Report for the UNH Office of Environmental Health and Safety

2016 Annual Report

for the Office of Environmental Health & Safety

2016 Annual Report for the UNH Office of Environmental Health and Safety 2

Table of Contents

1.0 Major Accomplishments _________________________________________________ 11

2.0 Mission Statement _____________________________________________________ 15

3.0 Vision Statement _______________________________________________________ 15

4.0 Core Values ___________________________________________________________ 16

5.0 Campus Program Elements and Objectives __________________________________ 17

6.0 Injury and Illness Prevention ______________________________________________ 17

6.1 Industrial Hygiene __________________________________________________________ 17

6.1.1 Hazardous Building Materials __________________________________________________ 19

6.2 Injury Prevention ___________________________________________________________ 20

6.3 Indoor Environmental Quality _________________________________________________ 22

6.4 Occupational Safety _________________________________________________________ 23

6.4.1 Confined Space Entry ______________________________________________________ 23

6.4.2 Fall Protection ____________________________________________________________ 24

6.4.3 The Control of Hazardous Energy (Lockout/Tagout) ______________________________ 24

6.4.4 Powered Industrial Trucks __________________________________________________ 25

6.4.5 Cranes and Hoists _________________________________________________________ 25

6.4.6 Aerial/Scissor Lifts ________________________________________________________ 25

6.4.7 Workplace Safety Inspections _______________________________________________ 26

6.4.8 Hearing Conservation ______________________________________________________ 26

6.4.9 Respiratory Protection _____________________________________________________ 26

6.4.10 Hazard Communication ____________________________________________________ 27

6.4.11 Hot Work/Welding Safety __________________________________________________ 27

6.4.12 Construction Safety _______________________________________________________ 28

6.4.13 Occupational Safety Committee _____________________________________________ 29

6.5 Safety Training and Education _________________________________________________ 29

6.6 Ergonomics Programs ________________________________________________________ 30

6.7 Occupational Health Medicine ________________________________________________ 33

6.8 Emergency Procedures _______________________________________________________ 34

6.8.1 Emergency Procedures Program _____________________________________________ 34


7.0 Diving Safety __________________________________________________________ 35

8.0 Disaster and Emergency Preparedness _____________________________________ 38

8.1 Integrated Contingency Plan __________________________________________________ 38

8.2 Emergency Planning and Community Right-to-Know _______________________________ 39

8.3 Spill Prevention Control and Countermeasure (SPCC) Planning _______________________ 40

9.0 Environmental Monitoring _______________________________________________ 41

9.1 Air Quality _________________________________________________________________ 41

9.1.1 Title V Air Permit _________________________________________________________ 41

9.1.2 Air Toxics ________________________________________________________________ 42

9.1.3 Refrigerant Management Program (RMP) _____________________________________ 43

10.0 Laboratory Safety ________________________________________________________ 44

10.1 Biological Safety ___________________________________________________________ 44

10.1.1 Biosafety Stewardship and Biological Safety and Biosecurity Manual _______________ 44

10.1.2 BSL-1 Initiatives __________________________________________________________ 44

10.1.3 Biohazardous Waste Initiatives/COLSA Collaboration ____________________________ 44

10.1.4 The Institutional Biosafety Committee Updates _________________________________ 44

10.1.5 Institutional Animal Care and Use Committee __________________________________ 47

10.1.6 Bloodborne Pathogens Program _____________________________________________ 47

10.1.7 Permits _________________________________________________________________ 48

10.1.8 Biosecurity ______________________________________________________________ 48

10.1.9 Training _________________________________________________________________ 48

10.1.10 Biosafety Equipment ______________________________________________________ 49

10.2 Chemical and Laboratory Safety _______________________________________________ 49

10.2.1 Laboratory Safety Inspections _______________________________________________ 49

10.2.2 Chemical Safety Committee _________________________________________________ 49

10.2.3 Regulatory Compliance Services _____________________________________________ 50

10.2.4 Chemical Fume Hood and Laboratory Ventilation Assessments ____________________ 50

10.2.5 Laboratory Design and Renovation ___________________________________________ 51

10.2.6 Laboratory Safety Technical Services _________________________________________ 52

10.2.7 Laboratory Safety Training _________________________________________________ 53

11.0 Hazardous Materials ____________________________________________________ 53


11.1 Chemical Transfer Station ____________________________________________________ 53

11.2 Chemical Inventory Validation Program _________________________________________ 55

11.3 UNHCEMS® Inventory _______________________________________________________ 57

11.4 Hazardous Materials Shipping _________________________________________________ 59

11.5 Hazardous Waste Management _______________________________________________ 59

11.5.1 Inventory Reductions ______________________________________________________ 60

11.5.2 Summary of Hazardous and Universal Wastes Generated _________________________ 60

11.5.3 Universal Waste __________________________________________________________ 62

11.5.4 Regulated Biological Waste _________________________________________________ 66

12.0 Radiation, Laser and Magnet Safety ________________________________________ 67

12.1 Radiation Safety ____________________________________________________________ 67

12.1.1 Program Information ______________________________________________________ 67

12.1.2 Training _________________________________________________________________ 67

12.1.3 Radiation Protection Program Maintenance ___________________________________ 68

12.1.4 Audit and Regulatory Review _______________________________________________ 68

12.1.5 Radiation Safety Monitoring Instruments ______________________________________ 69

12.1.6 Occupational and Public Doses ______________________________________________ 69

12.1.7 Surveys and Monitoring ____________________________________________________ 70

12.1.8 Leak Test Procedures ______________________________________________________ 70

12.1.9 Laboratory Decommissioning _______________________________________________ 71

12.1.10 Waste Management _______________________________________________________ 71

12.1.11 Waste Minimization _______________________________________________________ 71

12.1.12 Radon Management Program _______________________________________________ 72

12.2 Magnet Safety _____________________________________________________________ 72

12.2.1 Program Information ______________________________________________________ 72

12.2.2 Training _________________________________________________________________ 72

12.2.3 Registration and Instrumentation ____________________________________________ 72

12.2.4 Surveys and Audits ________________________________________________________ 72

12.2.5 Program Maintenance _____________________________________________________ 73

12.3 X-Ray Safety _______________________________________________________________ 73

12.3.1 Program information ______________________________________________________ 73

12.3.2 Training _________________________________________________________________ 73


12.3.3 Registration and Instrumentation ____________________________________________ 73

12.3.4 Surveys _________________________________________________________________ 74

12.3.5 Audits and Regulatory Reviews ______________________________________________ 74


12.4 Laser Safety________________________________________________________________ 74

12.4.1 Program information ______________________________________________________ 74

12.4.2 Training _________________________________________________________________ 75

12.4.3 Registration and Inventory _________________________________________________ 75

12.4.4 Standard Operating Procedures _____________________________________________ 76

12.4.5 Personal Protective Equipment ______________________________________________ 76

12.4.6 Surveys _________________________________________________________________ 77

12.4.7 Audits __________________________________________________________________ 77


13.0 UNH at Manchester _____________________________________________________ 77

13.1 Safety Committee ___________________________________________________________ 77

13.2 UNHCEMS® - Chemical Inventory and Training ____________________________________ 78

13.3 Integrated Contingency Planning ______________________________________________ 80

13.4 Radon Sampling ____________________________________________________________ 81

14.0 UNH School of Law _____________________________________________________ 81

14.1 Emergency Health and Safety Committee ________________________________________ 81

14.2 Other Accomplishments ______________________________________________________ 82

15.0 Emerging Issues ________________________________________________________ 83


16.0 Communication and Outreach ____________________________________________ 84

17.0 Mechanisms to Measure Compliance ______________________________________ 85

17.1 Industrial Hygiene __________________________________________________________ 85

17.2 General Safety _____________________________________________________________ 85

17.3 Fire Protection _____________________________________________________________ 85

17.4 Occupational Health and Medicine _____________________________________________ 85

17.5 Disaster Preparedness _______________________________________________________ 86

17.6 Diving Safety _______________________________________________________________ 86


17.7 Biological Safety ____________________________________________________________ 86

17.8 Hazardous Materials Inventory and Reporting ____________________________________ 86


17.10 Radiation Safety ____________________________________________________________ 87

17.11 Laboratory Safety ___________________________________________________________ 87


Acronyms

ABSL-1 Animal Biosafety Level 1

ABSL-2 Animal Biosafety Level 2

ACM Asbestos Containing Material

AL Action Limit

APHIS Animal and Plant Health Inspection Service

AST Aboveground Storage Tank

BSEG Black Start Emergency Generator

BSL-1 Biosafety Level 1

BSL-2 Biosafety Level 2

CDC Centers for Disease Control

CFATS Chemical Facility Anti-Terrorism Standards

CFR Code of Federal Regulations

COLSA College of Life Sciences and Agriculture

CSC Chemical Safety Committee

CTS Chemical Transfer Station

DFD Durham Fire Department

DHHS Department of Health and Human Services

DHS Department of Homeland Security

DIS Decay in Store

DNA Deoxy Ribonucleic Acid

DOT Department of Transportation

EHSC Emergency Health and Safety Committee

EH&S Environmental Health & Safety

EPCRA Emergency Planning and Community Right to Know Act


Acronyms (Continued)

EPP Emergency Procedures Program

GC Gas Chromatograph

HVAC Heating Ventilation and Air Conditioning

IAQ Indoor Air Quality

IBC Institutional Biosafety Committee

ICP Integrated Contingency Plan

IEQ Indoor Environmental Quality

LED Light Emitting Diode

LEPC Local Emergency Planning Committee/Coordinator

LSC Liquid Scintillation Counter

LSII Laboratory Safety Inspection Initiative

LSP Laser Safety Program

MEMIC Maine Employee Mutual Insurance Company

MOD-rate Experience Modification Rate

NCCI National Council on Compensation Insurance

NHDES New Hampshire Department of Environmental Services

NHVDL New Hampshire Veterinary Diagnostic Laboratory

NIH National Institutes of Health

NMR Nuclear Magnetic Resonance

NRT National Response Team

NSR New Source Review

OD Operating Distance

ODS Ozone Depleting Substances

OEHS Office of Environmental Health & Safety



OSHA Occupational Safety and Health Administration

PCB Polychlorinated Biphenyls

PEL Permissible Exposure Limit

PIs Principal Investigators

PID Photoionization Detector

PPE Personal Protective Equipment

PSD Prevention of Significant Deterioration

RCC Research Computing Center

RMP Refrigerant Management Program

RNA Ribonucleic Acid

RSO Radiation Safety Officer

RTAP Regulated Toxic Air Pollutants

SAA Satellite Accumulation Area

SARA Superfund Amendments and Reauthorization Act

SCUBA Self-contained Underwater Breathing Apparatus

SDS Safety Data Sheets

SERC State Emergency Planning Coordinator/Committee

SML Shoals Marine Laboratory

SOP Standard Operating Procedure

SPCC Spill Prevention Control and Countermeasures Plan

UIC University Instrumentation Center

UNH University of New Hampshire

UNHCEMS® University of New Hampshire Chemical Environmental Management System

UNH-M University of New Hampshire – Manchester



UNH PD University of New Hampshire Police Department

USDA United States Department of Agriculture

US EPA United States Environmental Protection Agency

USNH University System of New Hampshire

XPP X-ray Protection Program


1.0 Major Accomplishments

Biological Safety and Biosecurity Manual

Safety and security of work with biological materials is a top priority at the University of New Hampshire (UNH). The Office of Environmental Health and Safety (OEHS), in conjunction with the Institutional Biosafety Committee, developed the Biological Safety and Biosecurity Manual in 2016. The Manual is used as a reference document for individuals who work with biological materials. This manual details operational procedures that provide worker protection, environmental protection, and compliance to regulations and guidelines for Biosafety Level 1 (BSL-1) and Biosafety Level 2 (BSL-2) labs. The manual additionally documents laboratory biosecurity measures to

prevent loss, theft, intentional misuse or unintentional release of biohazardous material from the laboratory.

The components of this manual provide the framework for compliance to regulation and guidance as published by agencies such as the Occupational Safety and Health Administration (OSHA), National Institutes of Health (NIH), Centers for Disease Control (CDC), United States Department of Agriculture (USDA), Department of Transportation (DOT), New Hampshire Department of Environmental Services (NHDES) and New Hampshire Department of Health and Human Services (DHHS).

The Biological Safety and Biosecurity Manual is a key resource for a successful biosafety program. The manual re-iterates the need for cooperation and commitment of all laboratory personnel and the collaboration between subject matter experts and the OEHS. The manual was rolled out to all departments working with biological materials in January 2016.

National Biosafety Stewardship

October was once again designated as National Biosafety Stewardship Month, so UNH took this time to evaluate the three areas of focus chosen for 2016 by the National Institutes of Health (NIH): Evaluate, Collaborate and Commitment. As a part of these efforts, OEHS collaborated with Institutional Biosafety Committee members representing key stakeholders in biological research on the content of the Biological Safety and Biosecurity manual. In addition, OEHS collaborated with members of the College of Life Sciences and Agriculture (COLSA) faculty and staff to evaluate the biosafety program and prepare a list of materials needed for standardizing areas such as biohazard labeling and the biowaste collection system. Both COLSA and OEHS committed funds to this project and in a collaborative effort will roll out a system in 2017.


Crane & Hoist Safety Program

In 2016, OEHS developed and implemented a Crane & Hoist Safety Program. The program ensures the safe use and operation of cranes and hoists at UNH, formalize the required inspections, outline specific training requirements for those required to use and manage cranes & hoists, and establish specific responsibilities for those operating groups responsible for cranes and/or hoists. UNH currently has an inventory of eighteen (18) operating cranes and hoists that service a variety of programs and departments. They include the largest crane, a (10) ton bridge crane located in Kingsbury Hall, to smaller cranes and hoists used by Facilities, the Dairy Farm, Chase Ocean Engineering, Jackson Estuarine Laboratory, and the Coastal Marine Center in New Castle. Regardless of the type or size, the OSHA has standards that regulate their use. The program was developed in late fall and a draft circulated to those impacted operating groups. After review and comment, the program was finalized and implemented. This included training key department responsible personnel and formalizing the inspection process. OSHA requires all cranes & hoists are inspected on a frequent and periodic basis. Frequent inspections are defined as daily to monthly while periodic inspections are defined as monthly to annually. Based on the actual frequency of use, it is up to the employer to make the determination on when frequent and periodic inspections occur. The new program formalizes how and when the frequent inspections occur and generates the required documentation. OEHS continues to coordinate the periodic inspections by outsourcing them on an annual basis and maintaining the documentation.

Figure 1: 10-Ton Bridge Crane in Kingsbury Hall


Figure 2: 2-Ton Jib Crane outside the New Hampshire Veterinary Diagnostic Laboratory (NHVDL)

Indoor Air Quality Management Plan

In late fall 2015 OEHS was approached by the Sustainability Institute to discuss indoor air quality (IAQ) as it relates to the Sustainability Tracking, Assessment and Rating System (STARS) and how the development of a formal program could benefit the Durham campus. IAQ concerns at UNH were investigated by OEHS on a regular basis however there were no formal investigative mechanisms nor was there any proactive elements to target potential IAQ issues prior to them becoming a problem. Through our discussions, the decision was made to develop a formal IAQ Management Plan. The first step involved creating a working group of key personnel that included representatives from Facilities, Sustainability, and OEHS. A draft plan was developed based on the Environmental Protection Agencies “Tools for Schools” IAQ kit. This United States Environmental Protection Agency (US EPA) program utilizes a proactive approach through education and outreach to inform building occupants of potential IAQ sources and controls that can be taken prior to a problem taking place. It also has specific investigative and reporting components to ensure accurate information is disseminated throughout the investigative process.

The UNH plan incorporates both elements of the Tools for Schools kit. The plan has two primary components, the proactive and a response component. Under the proactive element campus buildings can elect to participate by developing an IAQ team, receiving training and education on indoor air quality, conducting a building profile to establish baseline for comparison with any future investigative efforts, address any potential issues, and clearly outlining an IAQ chain of command for sharing of information. The second element involves investigating reported complaints. Under the new plan, investigations include formalized documentation including an occupant questionnaire, review of any previous investigative efforts, consistent investigation forms, and including all key building representative on all correspondence from the initial complaint to final reporting. This has not only simplified addressing IAQ complaints but also assisted in expediting any corrective measures.

OEHS has provided training for Residential Life to educate Resident Hall Directors and Apartment Managers on key elements of the program to assist in minimizing IAQ concerns through proactive


measures and to define IAQ reporting systems for residential buildings. OEHS is anticipating during 2017 to continue to educate campus operating groups on indoor air quality and further implement proactive component of the plan.

Chemical Transfer Station Deliveries

OEHS staff received and delivered 2,073 chemicals in 2016; this represents a 34% increase in the number received in 2015. OEHS operates the Chemical Transfer Station (CTS), one of only two locations where research chemicals are received on campus, the other being the Chemistry Stockroom. At the CTS, chemical containers are barcoded and then delivered to research laboratories the same day they are received. OEHS staff also input the chemical container data into the campus chemical inventory system, UNH Chemical Environmental Management System (UNHCEMS®). The CTS plays a key role in maintaining the UNH chemical inventory, which provides important benefits to researchers and helps UNH achieve its health and safety and compliance commitments.

Draft UNH Laboratory Ventilation Management Program

In 2016, OEHS staff drafted updates to the UNH Fume Hood Program to improve consistency of information related to management and use of laboratory fume hoods. The scope of the document was updated to address the laboratory ventilation system, rather than single components. The new draft document clarifies department and individual roles and responsibilities. The draft document provides a clear method for managing maintenance shutdowns of ventilation systems. The UNH Laboratory Ventilation Management Program is a key institutional policy aimed at enhancing safety of maintenance workers and laboratory researchers and students. OEHS will continue to work with campus stakeholders to finalize the draft program in 2017.

Radiation Safety Program

The State of New Hampshire conducts a thorough inspection of the Radiation Safety Program at OEHS every three years. In 2016, three inspectors spent a day reviewing records and visiting laboratories. Some of the records that they reviewed are Geiger counter calibrations records, laboratory survey records, leak test records and inventory of sealed sources, Radiation Safety Committee meeting minutes, and radioactive waste disposal records. Inspectors visited laboratories in Kendall Hall, Rudman Hall and the OEHS Central Hazardous Waste Accumulation Area. They checked for proper signage, wipe test records, and performed a few Geiger counter surveys and wipe tests of their own. OEHS passed the inspection with no items of non-compliance. The State of New Hampshire, Radiological Health Section also came to visit OEHS to see how the radioactive waste program was run. They were impressed with the OEHS web site and wanted to model their own program after the UNH program. Two Health Physicists spent several hours reviewing a presentation of the Internal Operating Procedures of the OEHS program and touring the radioactive waste facility.


Morse Hall Perchloric Acid Hood Decontamination

OEHS partnered with Facilities Project Management to desensitize and decontaminate a potentially hazardous perchloric acid fume hood located in Morse Hall. OEHS and Faciltiies completed this task, with the help of a remediation contractor, over a weekend. Due to the extremely hazardous nature of the mobilization effort OEHS wanted to ensure the building was not occupied during the decontamination effort. Waste water generated during the procedure was sampled for laboratory analysis to confirm complete removal of contaminants. This hood is now available for use.

Inventory Reductions

OEHS continues to work with outgoing faculty and staff to reduce the amount of regulatory and surplus chemicals. Much of the inventory reduction efforts are associated with faculty and staff within COLSA. 1,700 hazardous material containers were removed and disposed of throughout 2016. This represents reductions of up to 22% depending upon the science building.

2.0 Mission Statement

The UNH OEHS works to assure safe and healthful environments for all segments of the campus population, through programs of information and education, review and monitoring, technical consultation, and provision of direct services. OEHS is also responsible for developing programs to ensure compliance with applicable state and federal health, safety and environmental regulations, and campus policies on environmental health and safety. Areas of responsibility include hazardous materials, environmental management as well as injury and illness prevention as highlighted in the University System of New Hampshire (USNH) Policy on Environmental Health and Safety. The protection of human health and compliance with applicable regulations are essential conditions for the successful operation of research, conduct of instruction, and provision of public service by the University. OEHS supports the University of New Hampshire’s mission by providing leadership, resources, and services to assure a safe and healthful working environment for all members of the University and its surrounding community.

The OEHS Mission Statement was re-affirmed in 2014 after review and approval of the new five-year OEHS Strategic Plan. The Statement is distributed through the UNH Research Office web site at http://www.unh.edu/research/support-units/environmental-health-safety.

3.0 Vision Statement

OEHS will be a valued partner in the creation and maintenance of a safe and healthy University environment and will achieve excellence through its provision of leadership, oversight, stewardship and services.

http://www.unh.edu/research/support-units/environmental-health-safety


4.0 Core Values

OEHS has adopted a Code of Professional Conduct. These core values describe the standards to which we aspire. They guide our actions and help to assure accountability, responsibility and trust as we interact with one another and our campus clients.

Excellence: We dedicate ourselves to the highest standards of quality in our professional work, outreach, public service, mentoring, and advising.

Integrity: We commit ourselves to an open, honest, and trustworthy approach to all endeavors we are working on. We value fairness, straightforward conduct, adherence to the facts, sincerity and transparency. We will make a reasonable effort to provide appropriate professional referrals when unable to provide competent professional assistance.

Responsiveness: We respond to and address the needs and expectations of our students, faculty, staff, partners, and external constituents.

Respect: We foster an environment of mutual respect. We listen to each other, encourage each other and care about each other.

Diversity: We commit to an inclusive community for diverse students, faculty and staff. We reject bigotry, oppression, degradation and harassment, and we challenge injustice toward any member of our community.

Accountability: We are personally and organizationally accountable for all that we do and commit to providing timely and comprehensive evaluation of our programs and efforts.

Figure 3: UNH Wildcat Statue located in front of Whittemore Arena

Innovation: We want to be at the forefront of change and believe that the best way to lead is to learn from our successes and mistakes and continue to grow. We are forward-looking and break new ground in addressing important community and societal needs.


Openness: We encourage the open exchange of information and ideas from all quarters of the university community. We believe that through collaboration and participation, each of us has an important role in determining the direction and well-being of our community.

5.0 Campus Program Elements and Objectives

UNH has adopted an Environmental Health and Safety Mission Statement that works to assure safe and healthful environments for all segments of the campus population, through programs of information and education, review and monitoring, technical consultation, and provision of direct services. OEHS has developed and implemented programs to ensure compliance with applicable state and federal health, safety and environmental regulations, and USNH policies on environmental health and safety.

6.0 Injury and Illness Prevention

6.1 Industrial Hygiene

Industrial hygiene is the art and science of the recognition, evaluation, and control of those environmental factors or stresses, arising in or from the work place, which may cause sickness, impaired health and well-being, or significant discomfort and inefficiency among workers or citizens of the community. OEHS performs worksite assessments to determine potential health hazards throughout the many locations associated with UNH. Technical assistance is provided on issues involving chemical hazards that can contribute to exposure risks (including laboratory exposures), exposures as the result of chemical release incidents, noise, heat, and hazardous building materials. Advice is then provided on protective measures that include the development and implementation of corrective controls or the use of personal protective equipment.

OEHS calibrates and maintains an inventory of nineteen (19) direct reading/sampling instruments that include:

• Simpson 884 Sound Level Meter;

• Jerome 431X Mercury Vapor Analyzer;

• Five (5) Gillian Personal Sampling Pumps;

• Rae Systems MiniRae 2000 photo-ionization detector (PID); and

• Two (2) Gast Systems High Volume Sampling Pumps.

These instruments provide information relative to airborne constituents such as lead, asbestos, mold, particulates, and specific airborne chemicals.


In 2016, OSHA finalized and published its revised standard on exposure to silica. The major revision to the standard was the significant reduction in the permissible exposure limit (PEL) and the establishment of an action level (AL). Should either of these established values be exceeded, specific requirements must be implemented which include the development of a written control plan, training, and medical surveillance. The revised standard requires employers closely evaluate those tasks where dusts containing silica may be generated. At UNH this now includes the Ceramics Shop, Grounds and Events, and the Material Sciences Laboratories. In 2016, OEHS reached out to the Art Department and reviewed their processes that involve the use of clay. As part of the review, OEHS conducted exposure monitoring to document potential exposures and ensure that established protective controls were appropriate. All sampling efforts resulted in airborne concentrations well below the revised OSHA PEL and AL. Potential areas where dusts containing silica can also be encountered include spring cleanup efforts conducted by Grounds and Events and activities in Kingsbury Hall involving sand and concrete as part of Materials Sciences. OEHS has reached out to each group and is anticipating conducting exposure monitoring in 2017. During 2016, OEHS responded to fifty-one (51) requests from the campus community for industrial hygiene technical services. Inquiries were related to hazardous building materials, potential exposures to hazardous chemicals, heat, and noise.

During the summer months, OEHS monitors the weather to support the UNH Excessive Heat Advisory program (see UNH On-Line Policy Manual, UNH VD 3.5). A Quest wet-bulb globe thermometer (Figure 4) is placed outside to measure the outdoor heat. When the outdoor temperature exceeds the established consensus threshold for heat as established by the American Conference of Governmental Industrial Hygienists, OEHS will issue a heat advisory for the campus. The Heat Advisory contains a prescription of work and rest for those employees, athletes, visitors, and/or guests who may be working outside, and, as necessary, for those working inside. In 2016, OEHS issued a total of six (6) heat advisories.

2016 also saw a change in the notification process. Prior advisories were issued via directed communication to managers and supervisors. This was changed to utilize the UNH Police Departments (UNH PD) Emergency Notification System. The use of the UNH PD Emergency Notification System allows for heat advisories to be communicated in a timelier manner. In addition any employee can sign up for emergency notifications which allows for heat advisories to be broadcast to a larger audience.


Figure 4: Example of the Quest wet-bulb globe thermometer.

6.1.1 Hazardous Building Materials

Hazardous building materials can be present in several forms throughout UNH campus buildings. Fortunately, the presence of these materials does not constitute a risk for occupants as long as the materials are maintained in good condition and their condition monitored on a regular basis. To assist in maintaining these materials OEHS developed a Hazardous Building Materials Operations & Maintenance Manual that incorporates programs to manage the three more commonly associated materials, asbestos, lead, and polychlorinated biphenyl’s (PCB).

In 2011, OEHS initiated a project to formally assess all campus buildings for the presence of asbestos containing materials (ACM) and lead based paint. The assessment project was not only designed to identify suspected materials, but to document their locations, quantities, and condition. All known materials identified during the surveys are entered into UNH FAMIS and printed on work orders to alert Facilities personnel of the materials presence. In addition to the work orders all employees whose jobs could put them in contact with ACM are required to participate in annual Asbestos Awareness training. This includes Housekeeping, Facilities Operations, Telecom, Facilities Construction Team, and Housing. To date, 48 campus buildings have been formally surveyed for the presence of asbestos and lead and the respective data entered into FAMIS.

The Asbestos Operations & Maintenance Plan establishes responsibilities for specific operating groups that could encounter ACM as part of routine operations. The plan also outlines inspection procedures and frequencies, emergency procedures to follow in the event of a fiber release, and training requirements. Employees whose daily work routine requires possible contact with ACM, or have related responsibilities are required to attend 2-hour Asbestos Awareness Training. During 2016, 108 employees participated in the 2-hour Asbestos Awareness training. To ensure identified materials maintain good condition OEHS conducts visual inspections of all areas where known ACM are present. The conditions are documented annually and each inspection record is maintained at OEHS. Copies of all inspections along with any recommendation are forwarded to the respective operating group responsible for the inspected building/area.


More recently, the presence of polychlorinated biphenyls (PCB) in caulking has created unique challenges for building renovation and/or demolition activities. Part of the Hazardous Building Materials Operations and Maintenance Manual includes the Caulking Management Plan. This plan was developed to outline specific procedures to be followed prior to and during construction-related projects where caulking materials may be impacted. In addition, the plan outlines the procedures to be followed should caulking need to be impacted in an emergency, such as might be required to repair a broken window.

OEHS works closely with Facilities Project Management during projects that require the abatement of lead, asbestos, or PCB. Work involving abatement requires specific training and experience. To ensure only those qualified firms conduct hazardous building materials, OEHS, along with UNH Procurement Services, have approved term contractors for abatement, engineering, and project oversite.

6.2 Injury Prevention

The effectiveness of a safety program can be assessed in many ways. However it is typically reviewed from a financial perspective. UNH losses are reviewed by OEHS to evaluate the frequency (number of incidents) and the severity (cost associated with an injury). OEHS, in conjunction with UNH Human Resources and our Workers Compensation Insurance Carrier, Maine Employee Mutual Insurance Company (MEMIC), monitors monthly trends and costs and works to focus efforts on addressing those areas where a higher frequency and/or severity of accidents are occurring. During 2016, UNH experienced 302 incidents that resulted in approximately $647,000 in financial losses. While this number of incidents is slightly down (approximately 3%) from the 311 incidents in 2015 the financial losses were higher than the $437,000 recorded for 2015. The following Figure 5 summarizes UNH claims and monetary losses for the previous eleven years. During 2016, three accidents resulted in approximately $275,000 in financial losses and contributed to the 33% increase as compared to 2015.


Figure 5: Total workers compensation claims versus losses paid over last 11 years at UNH.

It must be noted that financial losses are reported as incurred costs that include both the actual costs paid to date and any potential future costs and reserves. Actual losses can fluctuate both up and down based on the claim and settlement. The sum of total paid losses for 2016 are approximately $291,000 with an approximate $489,000 being held in reserves.

A second means to evaluate the effectiveness of an existing safety program is reviewing the experience modification rate (MOD-rate). The MOD-rate is a multiplier provided by the National Council on Compensation Insurance (NCCI) that is applied to an employer’s workers compensation insurance premium. An employer with a strong safety record will have a MOD-rate of under 1 reducing the actual cost of insurance while those with weak safety records will have a MOD-rate in excess of 1. UNH’s MOD-rate in 2016 was reported by MEMIC as .68.

OEHS conducts routine accident investigations to determine the root cause of an accident, develop corrective actions as necessary, all in an effort to prevent a reoccurrence. Many involve a simple telephone call or e-mail requesting information on recommended corrective actions while significant accidents involve a more formal site visit, interviews, and assistance from various operating groups that may include Human Resources and MEMIC. These are followed up with a more formal investigation report. In 2016 OEHS conducted 41 investigations.

In an effort to further promote a safe and healthful working environment for the UNH community, OEHS participated in the Human Resources Benefits Fair, which included promoting the recently implemented Indoor Air Quality Management Plan and providing information on ergonomics to UNH Faculty and Staff. OEHS was positioned next to the Occupational Therapy Program where

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graduate students participating in the ergonomics course were available to discuss ergonomic related concerns and sign up for a free ergonomic assessment of their workspace.

6.3 Indoor Environmental Quality

OEHS investigates indoor environmental quality (IEQ) complaints and concerns by campus community members. While most complaints involve thermal comfort, odors, or non-specific symptoms, some are associated with reports of microbiological contamination/growth, specific health-related symptoms related to indoor air, or response to water intrusion. IAQ surveys and due diligence assessments are conducted following routinely practiced industry standards for the investigation of IAQ complaints. To assist in the evaluation, OEHS maintains two direct reading instruments to monitor basic IAQ parameters, two moisture survey meters to evaluate for damp conditions that can be conducive for microbiological growth, and an ultrafine particle analyzer (Figure 6) that can be used to assess for dusts/particles and determine their source.

Figure 6: TSI P-Track Ultrafine Particulate Counter

In 2016, OEHS responded to thirty nine (39) requests for IEQ services, the same as 2015 (Figure 7). OEHS requested assistance from IAQ consultants on two occasions with three investigations requiring remediation or corrective actions by qualified personnel. Remedial efforts were funded primarily by the affected departments while the external sampling efforts were funded through the Environmental Health & Safety (EH&S) Mitigation Fund established in 2009.


Figure 7: Indoor Environmental Quality Requests Received by OEHS from 2011 through 2016

6.4 Occupational Safety

The safety programs at UNH focus efforts on injury prevention through the development and implementation of policies and procedures for the recognition and identification of hazards and the development of corrective actions. OEHS works with campus stakeholders on issues of safety to assist in assuring compliance with applicable regulations, regulatory interpretation, and by providing technical assistance. In 2016, OEHS responded to 31 requests for technical assistance on a broad range of safety topics including walking and working surfaces, respiratory protection, personal protective equipment, rigging, contractor safety, fire safety and prevention, emergency action planning, scaffolding, confined space entry, fall protection, the control of hazardous energy (lockout/tagout), welding and cutting, fuel handling, electrical safety, and lift safety.

During 2016, OEHS conducted an annual review of each of its seven written Occupational Safety Programs to ensure any regulatory changes were reflected in the programs and address any operational questions or concerns from impacted campus representatives. In addition, several other areas are monitored by OEHS for compliance that include the use of Powered Industrial Trucks, aerial and scissor lifts, and cranes and hoists. A brief summary of each of the programs follows.

6.4.1 Confined Space Entry

The UNH Confined Space Entry Program is designed to outline specific requirements and procedures to allow employees to safely enter and conduct work in spaces that have been identified as permit required confined spaces. These procedures include training, air monitoring,

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the use of specific rescue equipment to facilitate non-entry rescue, and the use of a permit entry system. OEHS receives, reviews, and maintains all permits for activities involving entry into UNH confined spaces. During 2016, OEHS received one hundred and sixty (160) confined space entry permits. Permits are reviewed and if necessary, followed up on campus to ensure personnel are entering following current UNH program requirements. In addition, permits are reviewed with each applicable operating group as part of the annual program review and assessment. OEHS and UNH continue to partner with the Durham Fire Department (DFD) to provide confined space entry rescue services. In 2016 OEHS completed the review of exterior spaces and incorporated them into the confined space database. All identified permit required confined spaces were re-labeled with the applicable signage as required by OSHA and issued a unique space identification number. This number can be used in the database to search for a specific which allows the user access the written assessment that identifies specific hazards. In addition, it allows the user to complete and submit the required pre-entry plan to OEHS and DFD electronically. OEHS has identified a total of 598 confined spaces, not including catch basins and sewers.

6.4.2 Fall Protection

OSHA requires that any employee exposed to a fall of four (4) feet or more be protected by means of protective measures. Fall hazards exist for any employee required to work on, in, or near roof systems, aerial lifts, scissor lifts, scaffolding, unprotected attic spaces, open pits, floor holes, or elevated walkways and platforms. The UNH Fall Protection Program specifies specific controls to be utilized when fall hazards exist. While the OSHA fall protection standards (29 CFR 1926, Subpart M and 20 CFR 1910.28) specify three methods to protect employees from falls; safety nets, the use of guardrails, and/or personal fall arrest systems; the UNH program recognizes only two, the use of guardrails and personal fall arrest systems. As part of the program OEHS conducts annual documented inspections of the approximate 100 full body harnesses and lanyards located on campus that are used as part of a personal fall arrest system to protect employees against falls from elevated surfaces. Employees exposed to fall hazards receive training on the recognition of fall hazards and the use of protective systems. OEHS also reviews construction plans and assists in the development of permanent engineered fall protective systems.

6.4.3 The Control of Hazardous Energy (Lockout/Tagout)

Lockout/Tagout can be defined as the complete physical isolation of all energy sources associated with a piece of equipment or machinery to ensure an employee conducting servicing or maintenance is not exposed to any hazardous energy sources through the accidental startup of said equipment or machinery or release of stored energy. To achieve this, OSHA has established its Control of Hazardous Energy (Lockout/Tagout Standard) 29 CFR 1910.147. To ensure UNH Compliance with the OSHA standard, the UNH Lockout/Tagout Program outlines the


proper shut down and isolation procedures required prior to any servicing or maintenance activities. Employees conducting servicing or maintenance must identify all hazardous energy sources and once identified, they are shut down and physically isolated by the application of a lock on the isolation device (lockout). In addition, each lock is required to have a tag applied to it (tagout) that clearly specifies not to remove as lockout/tagout taking place. Each applied lock and tag is to be applied by each person conducting servicing or maintenance on each energy source required to be isolated. The UNH Lockout/Tagout program applies to all UNH employees to some degree. The selected Facilities personnel that would be required to shut off equipment and/or machinery and conduct servicing or maintenance activities are considered authorized employees and receive specific training on the program elements. All other employees are considered affected as the work an authorized employee conducts could at any time affect anyone. Affected employees receive training during the Getting Started New Employee Orientation.

6.4.4 Powered Industrial Trucks

The use of powered industrial trucks in regulated by the OSHA Powered Industrial Truck Standard, 29 CFR 1910.178 that outlines specific operating procedures, training requirements, and inspections. Powered industrial trucks are located at several locations at UNH that include Central Receiving, Stillings Dining Hall, Chase Ocean Engineering, Kingsbury Hall, and the Coastal Marine Center, and their management is coordinated by their respective department. OEHS is available to conduct the formal instruction as required by the OSHA standard and conducts periodic reviews to ensure safe operation and the required inspections are taking place.

6.4.5 Cranes and Hoists

UNH currently has an inventory of eighteen operational cranes and hoists that service a variety of programs and departments on campus. They include the largest crane, a 10-ton bridge crane in Kingsbury Hall, to smaller cranes and hoists used by Facilities, the Dairy Farm, Jackson Estuarine Laboratory, and the Coastal Marine Laboratory in New Castle. Formal training requirements, inspection procedures, and responsibilities have been developed and are part of the recently implemented UNH Crane & Hoist Safety Program. (Refer to major accomplishments).

6.4.6 Aerial/Scissor Lifts

An aerial lift can be defined as any vehicle mounted device, telescoping or articulating, or both, that is used to position personnel. Scissor lifts are considered a mobile-railed platform that can be raised straight up and down. Regardless of the definition, UNH utilizes both types of lifts for many purposes. Lifts are used by Facilities Operations, Athletics, Memorial Union Building staff, and Campus Recreation. Each operating group is responsible for their use, the management of


training for their staff, lift inspections, and maintenance. For any work conducted on any lift, the UNH Fall Protection Program requires that all personnel be secured from falls by the use of a full body harness and the appropriate lanyard.

6.4.7 Workplace Safety Inspections

The Office of Environmental Health and Safety conducts routine inspections of campus locations to evaluate for the presence of hazardous conditions and works with campus groups to develop corrective measures. Bi-monthly inspections are also performed as part of our Workers Compensation Insurance policy. A MEMIC Loss Control Representative will visit designated campus locations with OEHS representatives and documents identified hazards. These reports are forwarded to OEHS and then on to each designated location/department for corrective actions. In 2016 OEHS initiated formalized inspections for Dining Services in an effort to routinely identify hazards and work with each facility in not only developing corrective actions but in correcting unsafe behavior. OEHS in conjunction with Human Resources and Dining Services developed an appropriate inspection checklist targeting Dining specific areas. OEHS will continue this effort through 2017.

6.4.8 Hearing Conservation

Exposure to elevated noise levels that exceed established thresholds can lead to a temporary or permanent threshold shift that can result in noise induced hearing loss. OSHA has established the Occupational Noise Standard, 29 CFR 1910.95, which requires employers to develop and implement a Hearing Conservation Program should it have employees that exceed the established action level of 85 decibels as averaged over the course of an 8-hour day. Since there are areas/jobs at UNH where noise levels can exceed not only the Action Level, but the PEL of 90 decibels OEHS manages the campus Hearing Conservation Program. For those impacted employees the program requires they receive training on the components of the program, the OSHA Standard, effects of noise exposure, and the appropriate use of hearing protection. In addition, each employee included in the Hearing Conservation Program is required to participate in baseline and annual audiometric testing. This testing is conducted through the College of Health and Human Services and is conducted at Hewitt Hall.

6.4.9 Respiratory Protection

The use of respirators at UNH which is governed by a comprehensive OSHA Standard, 29 CFR 1910.134 Respiratory Protection, that outlines the specific requirements that must be met prior to and during use of respiratorys. OEHS manages the campus Respiratory Protection Program ensuring employees are properly protected against potential airborne contaminants and UNH compliance. A respirator will act as a barrier preventing hazardous airborne contaminants from


entering the body through the respiratory system. Contaminants can be physical, chemical, or biological in nature. For a respirator to be effective, it must be used following strict guidelines and procedures to ensure proper selection, use, care, and maintenance. In addition, all wearers of respiratory protection are required to participate in the UNH Medical Surveillance program and be fit tested annually. The fit test is the procedure where the employee dons the respirator they would be required to use and is challenged with a known agent. Should the employee detect the challenge agent, the respirator is not approved for use. Only those respirators that achieve an acceptable fit will be worn by employees. OEHS conducts training for a variety of departments that are covered by the respiratory protection program. These include Facilities Operations, Facilities Construction Team, and Health Services.

6.4.10 Hazard Communication

The use of hazardous chemicals in the workplace is highly regulated to ensure those working with chemical substances do so in a safe manner. Using hazardous chemicals can place UNH employees and students at risk of exposures which can lead to physical injuries and/or illnesses. One of the programs developed and managed by OEHS is the Hazard Communication Program. This program is mandated by the OSHA Hazard Communication Standard, 29 CFR 1910.1200 and the State of New Hampshire Department of Labor Right to Know Law, Title XXIII, Chapter 277-A, Toxic and Hazardous Substances.

The Hazard Communication Program is designed to provide information to those who use or those who could be potentially exposed to chemical substances. The UNH Hazard Communication Program prescribes procedures for appropriate labeling of chemical containers, maintaining a comprehensive inventory of chemical materials at UNH and corresponding Safety Data Sheets are readily available for inventoried materials. In addition, training is provided on the provisions of the UNH Hazard Communication Program for all employees working with regulated chemicals.

UNH manages its chemical inventory and Safety Data Sheets (SDSs) in UNHCEMS®. OEHS conducts an annual chemical inventory and is continually updating its compilation of Safety Data Sheets to ensure the most up to date and accurate information is available. Training is initiated during new employee orientation and is provided live, or electronically, through UNHCEMS®.

6.4.11 Hot Work/Welding Safety

OEHS continues its advisory and administrative role for the Hot Work Permit Program. This program is designed to require those personnel who are required to perform welding, torch cutting, or any other heat and spark producing activities outside a designated hot work area to complete a Hot Work Permit (Figure 8). The program offers two options for hot work:


Option 1 - Those conducting hot work can opt to complete a single shift permit, which authorizes hot work for the single date specified on the permit. Completed by the UNH Facilities Project Manager and/or the Competent Hot Work Supervisor, the permit is forwarded to OEHS prior to the commencement of activities. The second option available is to request a blanket permit.

Option 2 - A blanket permit can be submitted to OEHS and will be reviewed on site with the appropriate UNH and/or contractor personnel. Once reviewed, the blanket permit is signed and approved. The blanket permit can be used for a time not to exceed 14 calendar days.

During 2016, OEHS received ninety-three (93) single shift hot work permits and reviewed one hundred sixty three (163) blanket permit requests that were subsequently approved.

The UNH property insurance carrier, FM Global, reviewed the Hot Work Permit Program in 2016. Based on their review and comments, OEHS revised the program to increase the post hot work fire watch from 30 to 60 minutes. This was incorporated into the written program and reflected on the Hot Work Permit (Figure 8).

Figure 8: Sample Confined Space and Hot Work Permit Request Forms

6.4.12 Construction Safety

OEHS provides technical guidance to UNH project managers on environmental health and safety concerns during construction, demolition, and renovation projects. Services include minor technical inquiries, pre-construction plan review, and pre-demolition hazardous building materials abatement planning. In 2016 staff from all disciplines in OEHS participated in projects associated with the Water Treatment Facility, Chase Ocean Engineering, Randall Hall, New Hampshire Hall, Spaulding Hall, Horton Hall, Hamilton Smith Hall, Hammel Recreation Center, Kendall Hall,


Barton Hall, Babcock Hall, Paul Creative Arts Center, UNH Manchester (UNH-M), and exterior locations including Quad Way, Cowell Stadium.

6.4.13 Occupational Safety Committee

The UNH Occupational Safety Committee assists with setting forth health and safety policies and programs that are adopted and implemented within the affected departments. The Occupational Safety Committee is a joint labor-management committee, and is a vehicle through which the campus community can discuss safety concerns, disseminate information about programs and services from OEHS, and develop initiatives for future health and safety efforts. The Occupational Safety Committee incorporates representation from Facilities, Research Integrity Services, Facilities Construction Team, Housing, Campus Recreation, Memorial Union Building, Athletics, Information Technology, Hospitality Services, Health Services, Energy and Utilities, Housekeeping, Contracts Management, University Libraries, and the UNH PD. OEHS coordinates and schedules the quarterly meetings, develops meeting agendas, and records and generates meeting minutes. During 2016 the Occupational Safety Committee played in integral role in the review and finalization of the Indoor Air Quality Management Plan.

6.5 Safety Training and Education

Safety training is routinely performed and/or coordinated for those affected faculty, staff, and students on a variety of topics that include Hazard Communication, Personal Protective Equipment, Respiratory Protection, Hearing Conservation, Control of Hazardous Energy (Lockout/Tagout), Confined Space Entry, Fall Protection, Asbestos Awareness, Material Handling, and Ergonomics. The responsibility for ensuring that affected staff receive the appropriate training falls under each individual department. OEHS offers training services that are pre-arranged with the affected departments.

Throughout 2016 OEHS continued its efforts to promote training to targeted areas where increased losses were occurring, in order to ensure compliance with regulatory training requirements. OEHS continued its partnership with UNH Housekeeping to address areas of increased losses. This included redeveloping multiple training programs to address hazards and their controls to minimize exposure risks. These areas covered training on slips, trips, and falls, ergonomics and back/lifting safety, hazard communication/right to know, asbestos awareness, and bloodborne pathogens. OEHS continued to provide training for UNH Facilities Operations and the Facilities Construction Team to target specific areas that impact their operations to promote safety. OEHS participated in Dining Services Associates Day to continue to promote the proper use of personal protective equipment (PPE); review housekeeping to address slip, trip, and fall; and discuss general awareness regarding cuts and burns.


Instructor-led training on a variety of occupation safety programs was conducted in 2016 with 231 employees attending training including: Fall Protection; Confined Space Entry; Respiratory Protection; and Asbestos Awareness. In addition, 559 employees participated in the on-line Hazardous Communication/Globally Harmonized System Training available through UNHCEMS®.

With an emphasis on utilizing the UNHCEMS® Training Management System, in 2016 Occupational Safety integrated all of its training programs into UNHCEMS®. Each session was set up to allow those UNHCEMS®users to not only see what training courses were available to meet their specific requirements, but also allowed them to either register for live training sessions or complete on line training courses.

During 2016 OEHS partnered with Facilities to integrate e-training and training management through UNHCEMS®. This started with a review of UNHCEMS® with Zone Management and then training for respective departments. OEHS worked with each group to establish their user profiles and set requirements. OEHS also assisted with training select users as Training Managers to allow Facilities to set up department specific requirements. OEHS anticipates integrating UNHCEMS® user training into a Facilities Orientation program set to be implemented in 2017.

OEHS continued its partnership with Human Resources on Accident Prevention and Safety by conducting an OEHS Orientation as part of UNH Getting Started and with the Animal Resource Office to provide an Occupational Health and Safety component as part of the mandatory Animal Handler Training conducted prior to the start of each academic semester.

During 2016 OEHS coordinated live fire extinguisher training. This training has been conducted in previous years and has been highly received. In 2016 139 faculty, staff, and students participated.

6.6 Ergonomics Programs

OEHS promotes its proactive approach to ergonomics by providing guidance to the campus community on ergonomic-related risks in an effort to reduce the number of claims involving musculoskeletal disorders associated with poor workstation design and manual material handling.


OEHS conducted 110 workstation evaluations in 2016. Each evaluation consists of the following:

• Reviewing the employee’s workstation;

• Discussing with them their work processes and any symptoms they may be experiencing;

• Making adjustments and modifications to the workstation; and

• Discussing with them proper body positioning.

The assessment is followed up by a formal report that not only summarizes our observations and modifications, but includes additional recommendations to further reduce ergonomic risk factors. Simple modifications may include modifying the employee’s chair height, repositioning the keyboard to an existing adjustable tray, or raising the monitor utilizing materials readily at hand such as books or reams of paper. More complex recommendations may include replacement of existing keyboards and mouse options, re-design of work processes to reduce repetitive motions or replacement of desks and chairs. New employees are informed of the ergonomics program during their orientation and are encouraged to take advantage of the assessment services provided by OEHS. Table 1 and Figure 9 summarizes the ergonomic losses dating back to 2007.

Table 1 Ergonomic Losses (Claims) and Incurred Costs as a result of Ergonomic-Related Injuries at UNH

2007 2008 20092 2010 2011 2012 2013 2014 2015 2016

Claims 15 17 22 15 8 10 3 1 3 2

Incurred Costs1 $33,422 $114,109 $114,097 $89,341 $35,817 $27,555 $4,892 $384 $15,603 $10,775

1. Values provided by Human Resources based on loss runs as provided by MEMIC. Claims and values may vary slightly based on cause description as documented by MEMIC. Costs will fluctuate up and down based on continuing/additional treatment, indemnity costs, and/or injuries reported in 2016 that occurred in 2015.

2. Prior to 2009 ergonomic assessments performed on a reactionary basis following the report of an occupational injury.


Figure 9: Ergonomic Claims from 2007 through 2016 compared with Accrued monetary losses for time period.

During 2016, OEHS continued to field many employee requests for information on sit-to-stand workstations (Figure 10), and for their purchase and installation at the work station. This ergonomic trend has been shown to increase employee productivity and overall wellness. OEHS continues to work with Facilities Project Management and department to discuss and review the installation of sit to stand workstations as part of renovation/construction projects. We anticipate this continuing through 2017.

Figure 10: Example of a sit-to-stand workstation

OEHS maintained its partnership with the UNH Occupational Therapy program, the Office of Human Resources, and other campus departments with ongoing student projects as part of the credit course. OEHS participated in the course by presenting material on ergonomics as it relates to the UNH campus. During 2016 students conducted evaluations for selected employees on campus. OEHS received and reviewed each assessment conducted to ensure they were


conducted in line with the current assessment process. OEHS also followed up with each participant to offer a review or discussion of the student assessment and address any questions or concerns they may have had. In addition the student projects continue to be utilized in support of the OEHS ergonomics program.

6.7 Occupational Health Medicine

OEHS provides guidance to affected departments on medical surveillance requirements for faculty, staff, and students as required by state or federal requirements or as indicated by best management practices. Medical surveillance programs are established for respiratory protection, hearing conservation, lead, asbestos, bloodborne pathogens and animal handlers. OEHS continues to receive and maintain records for those participating in the Animal Handlers Medical Surveillance Program. However, the day-to-day management and participant follow up is now under the responsibility of Research Integrity Services.

There are currently 452 faculty, staff, students and visitors participating in medical surveillance programs at UNH. As displayed in Figure 11, below, the number of staff enrolled in medical surveillance programs is the same when compared to 2015. However, 2016 saw a 27% decrease in individuals enrolled in the respiratory protection medical surveillance program and a 9% increase in the Animal Handler medical surveillance program. As in 2015 the reduction of those participating in the respiratory protection medical surveillance program can be attributed to two continuing factors. OEHS, in cooperation with Facilities Operations, continues to assess tasks and determine that not all employees required the need for respiratory protection and the actual number of UNH personnel performing the tasks requiring respiratory protection are being replaced with an outsourced vendor.


Figure 11: Number enrolled in Medical Surveillance programs from 2015 through 2016.

6.8 Emergency Procedures

6.8.1 Emergency Procedures Program

It is the policy of UNH to maintain a safe environment for its students, academic appointees, staff, and visitors in an atmosphere that encourages those individuals to communicate on occupational and environmental health and safety matters without fear of reprisal. The UNH Emergency Procedures Program (EPP) is a written document required by OSHA. The purpose of the EPP is to facilitate and organize employer and employee actions during workplace emergencies. A well-developed emergency plan and proper employee training (such that employees understand their roles and responsibilities within the plan) should result in fewer and less severe employee injuries and less structural damage to campus facilities during emergencies. The EPP outlines procedures to be followed by the campus community for responding to, and recovering from, a variety of emergency and disaster situations. These events may include fires, hazardous spills, earthquakes, bomb threats, or major accidents.

During 2016 the responsibility for Emergency Management, which includes the EPP, was transferred to the UNH Police Department.

361

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Hearing Conservation Bloodborne Pathogen Asbestos0

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7.0 Diving Safety

Scientific diving is defined by OSHA regulations as diving performed solely as a necessary part of a scientific, research, or educational activity by employees whose sole purpose for diving is to perform scientific research tasks. UNH is exempt from the regulations that govern commercial diving activities provided its program is defined as scientific diving and which is under the direction and control of a diving safety program containing at least the following elements:

A diving safety manual that includes at a minimum: Procedures covering all diving operations specific to the program; procedures for emergency care, re-compression and evacuation; the criteria for diver training and certification; and a diving safety officer.

Diving Control Safety Board, with the majority of its members being active scientific divers, which shall at a minimum have the authority to: approve and monitor diving projects, review and revise the diving safety manual, assure compliance with the manual, certify the depths to which a diver has been trained, take disciplinary action for unsafe practices, and assure adherence to the buddy system (a diver is accompanied by and is in continuous contact with another diver in the water) for Self Contained Underwater Breathing Apparatus (SCUBA) diving. UNH has implemented both of these elements and is in compliance with this exemption.

The following are statistics with regard to the Diving Program at UNH:

• Total Number of Divers logging dives during 2016: 37

• Total Number of Dives logged during 2016: 729

• Total minutes of diving logged during 2016: 24,159

Tables 2 through Table 7 summarizes various dive statistics, including purpose for dives, modes of diving, breathing gas types used, and equipment.

Table 2 Number of Dives distributed by Purpose in 2016

Purpose Dive Time in Minutes

Dives Logged Number of Divers Logging Dives

Scientific 16,136 456 29

Training and Proficiency

8023 273 21


Table 3 Number of Dives by Diving Mode in 2016

Diving Mode Dive Time in Minutes


Open Circuit SCUBA 22,825 703 37

Hookah 0 0 0

Surface Supplied 301 13 8

Rebreather 1,033 13 2

Table 4 Number of Dives by Breathing gas in 2016

Type of Breathing Gas

Dive Time in Minutes Dives Logged Number of Divers Logging Dives

Air 22190 687 37

Nitrox 936 29 2

Mixed Gas 1033 13 2

Table 5 Number of Dives by Decompression Profiling Method

Decompression Method Dive Time in Minutes


Dive Tables 1,912 68 8

Dive Computer 22,247 661 33

PC-based Deco Software 0 0 0


Table 6 Number of Dives by Specialized Diving Environment in 2016

Diving Environment Dive Time in Minutes


Required Decompression

1033 13 2

Overhead Environment 0 0 0

Blue Water 0 0 0

Ice/Polar 0 0 0

Saturation Diving 0 0 0

Aquarium Diving 0 0 0

Table 7 Number of Scientific or Training/Proficiency Dives by AAUS Depth Range in 2016

Dive Depth Dive Time in Minutes


0 - 30 feet 12796 429 34

31 - 60 feet 7787 222 29

61 - 100 feet 2362 64 18

101 - 130 feet 90 2 2

131 - 150 feet 112 2 2

151 - 190 feet 128 2 1

190 - > feet 884 8 2

There were no diving incidents reported in 2016 cycle.


In addition to the scientific diving listed above, UNH runs several Academic open water scuba classes each semester. The diving statistics for that is as follows:

• Basic Open Water SCUBA Classes for Sprint 2016/Fall 2016: 46 Basic Students with approximately 20 hours of training in the pool for each student, leading to 5 open ocean dives each with 230 student dives in the ocean.

8.0 Disaster and Emergency Preparedness

OEHS is constantly reviewing and updating Disaster and Emergency Response plans required by the US EPA for the Campus. OEHS is responsible for maintaining the Integrated Contingency Plan (ICP), Spill Prevention Control and Countermeasures Plans (SPCC) (40CFR Part 112) and reporting to US EPA for Emergency Planning and Community Right to Know Act (EPCRA) (SARA Title III)

8.1 Integrated Contingency Plan

The US EPA National Response Team (NRT) passed guidance in 1996 allowing facilities to prepare an emergency response plan (the ‘one plan’) that consolidates the multitude of response plans required by several federal agencies including: US EPA, Occupational Safety and Health Administration, the Department of Transportation, The Mineral Management Service, the United States Coast Guard and the Research and Special Programs Administration.

UNH originally drafted the ICP in 2009 and continues necessary revisions to the campus ICP as needed or, at a minimum, on an annual basis.

The intent of the UNH ICP is to establish the necessary procedures and equipment required to prevent and to minimize hazards to public health, safety or welfare, or to the environment, from fires, explosions, spills or any other unplanned sudden or non-sudden release of hazardous materials to air, soil, surface water, or groundwater. The plan is also designed to prevent spills or releases of hazardous substances that violate applicable water quality standards, cause a sheen upon or discoloration of the surface waters, or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines.

This Plan contains three main sections: General Information, Spill/Release Response Procedures, and Spill/Release Prevention.

• Section I - Introduction describes UNH’s facilities and the administration of this Plan, including procedures for the distribution, periodic review, and amendment of the Plan.

• Section II - Fire, Explosion, or Spill/Release Emergency Response Procedures identifies and establishes the response and notification procedures to be used in the event of a spill/release, including: steps to be taken when a spill/release is discovered; how to report


a spill/release; guidance on mitigation and cleanup of a spill/release and disposal of related waste; and a description of spill/release response equipment maintained by UNH.

• Section III - Fire, Explosion, or Spill/Release Prevention identifies and establishes policies and procedures to be implemented with the goal of reducing the potential of a spill/release, including: a detailed description of areas of the facility where oil, petroleum products and hazardous materials and wastes are used, stored and generated; the associated containment systems; a description of the potential environmental receptors that may be affected; procedures for inspecting storage areas or equipment containing oil or hazardous waste; delivery/storage procedures; and a discussion and assessment of the potential spill/release scenarios.

The areas of the University of New Hampshire property that are covered by the ICP include:

• Durham campus;

• UNH Central Hazardous Waste Accumulation Area;

• Satellite Accumulation Areas (SAAs) in laboratories and research facilities throughout campus;

• UNH Facilities including the Heating Plant and shops;

• Transportation Garage;

• All other perimeter farms in Durham associated with the UNH Durham campus;

• Residential housing for college students and employees (single-family residences are exempt when oil is used exclusively for on premise heating); commercial properties owned or partially owned by the University of New Hampshire, and situated contiguous to the main campus in Durham; and

• Other miscellaneous properties owned by the University of New Hampshire, with property boundaries contiguous to the Durham campus.

8.2 Emergency Planning and Community Right-to-Know

EPCRA, also known as the Superfund Amendments and Reauthorization Act (SARA) Title III, is a statute designed to improve community access to information about chemical hazards and to facilitate the development of chemical emergency response plans by State of New Hampshire and local government (the Town of Durham). EPCRA requires the establishment of State Emergency Response Committees (SERCs) responsible for coordinating certain emergency response activities and for appointing Local Emergency Planning Committees (LEPCs). The emergency planning requirements of EPCRA are designed to develop state and local government emergency response and preparedness capabilities through better coordination and planning,


especially within the local community. For reporting year 2015 (submitted in 2016), OEHS notified the SERC and the LEPC that UNH stores 21 chemicals that fall above the threshold planning quantity that are required reporting to local and state government. Table 8 below summarizes the Tier II Reporting for the campus from 2012 through 2016.

Table 8 EPCRA Chemicals reported in 2016 by UNH Durham Campus for RY2015

Chemical RY 2012 (lbs) RY 2013 (lbs) RY 2014 (lbs) RY 2015 (lbs) Ammonia 1,000 1,000 1,197 1,019 Chloroform NR 1,064 1,106 783 Diesel 32,170 32,170 32,170 25,915 Formaldehyde 534 545 559 NR FR3 (transformer fluid) 43,098 43,098 43,098 43,098 Fuel Oil #2 592,339 592,339 592,339 522,672 Fuel Oil #6 554,610 554,610 554,610 554,610 Hydraulic Oil (elevators) 77,782 77,782 77,782 83,916

Hydrofluoric Acid NR NR 111 NR Mineral Oil (transformers) 145,406 145,406 145,406 145,406

Motor Oil NR NR NR 23,856 PCH-180 (Inorganic Aluminum Salt) NR 60,048 60,048 60,048

Propane 185,363 185,363 185,363 102,245 R-TEMP (transformer fluid) 13,636 13,636 13,636 13,636

Sand NR 150,000 150,000 100,000 Salt 1,000,000 857,350 857,350 607,350

Sodium Hydroxide 64,779 42,827 140,854 62,026 Sodium Hypochlorite 33,642 26,093 36,060 23,533 Sulfuric Acid 2,448 2,476 2,769 2,029 Sulfuric Acid (Batteries) 261 17,860 1 17,8601 3,838

Lead (batteries) NR NR NR 14,498 NR Not Reported, did not meet threshold planning criteria

1. Total Battery weight as a mixture

8.3 Spill Prevention Control and Countermeasure (SPCC) Planning

The priority of the US EPA Emergency Management Program is to prevent, prepare for, and respond to oil spills that occur in and around inland waters of the United States. US EPA is the lead federal response agency for oil spills occurring in inland waters, and the United States Coast Guard is the lead response agency for spills in coastal waters and deep-water ports. The SPCC rule provides requirements for oil spill prevention, preparedness, and response to prevent oil


discharges to navigable waters and adjoining shorelines. The rule (40 CFR Part 112) requires facilities that meet specific petroleum storage quantities to prepare, amend, and implement SPCC Plans.

UNH maintains certified SPCC Plans for portions of the Durham campus: the Combined Heat and Power Plant; and the UNH Landfill Gas Processing Facility in Rochester. The Plans were revised and updated for 2015. In place of an SPCC for the Durham Campus, an Integrated Contingency Plan has been developed and maintained for UNH as discussed in section 8.1 above. The completion of the certified ICP meets the US EPA requirement for a spill prevention plan (40 CFR Part 112)

UNH Facilities staff conducts regular inspections of the 55 aboveground storage tanks (ASTs) on campus. For 2016, staff conducted 338 tank inspections.

Per US EPA SPCC Regulations (as detailed in the ICP), OEHS conducted in-person training for 25 UNH staff and contractors identified as oil handling personnel, for the operation and maintenance of equipment to prevent oil discharges; discharge procedure protocols; applicable pollution control laws, rules and regulations; general facility operations; and the contents of the various facility ICP and SPCC Plans.

Staff at the Shoals Marine Laboratory decreased total oil storage on the Island in 2015 to reduce the overall burden and environmental risks. This decrease in oil storage and use on the Island means an SPCC plan is no longer required for the Shoals Marine Laboratory as it does not meet the de-minimis threshold planning quantity of 1,320-gallons of above ground petroleum storage, in aggregate containers of greater than 55-gallons each. Current petroleum storage on the Island is now 1,256-gallons. To maintain best practices, OEHS will maintain an Oil Spill Mitigation Plan for Shoals Marine Laboratory and provide annual training to the Shoals Marine Laboratory staff for oil spill prevention and response.

9.0 Environmental Monitoring

9.1 Air Quality

9.1.1 Title V Air Permit

The NHDES issued UNH a Title V Air Permit (TV-OP-010) for the campus Central Heating Plant and Co-generation Facility on April 11, 2007. A significant permit modification was issued by NHDES in November 2009 removing the permit condition requiring a fuel flow meter on the black start emergency generator (BSEG) at UNH’s Co-generation facility. In addition, UNH was issued a Temporary Permit and Prevention of Significant Deterioration (PSD) and Non-Attainment New Source Review (NSR) permit (TP-B-0531) in July 2007 for the construction and operation of combustion devices associated with a Landfill Gas to Energy facility at Rochester and on the


Durham campus. UNH was also issued a Temporary Permit (TP-0161) in July 2015 for the replacement of one of the Central Heating Plant boilers, to allow the firing of processed landfill gas in the new boiler and one of the existing boilers, as well as to remove burdensome continuous emissions monitoring requirements from UNH’s previous Temporary Permit.

UNHs’ current Title V and Temporary permits contain specific conditions that the campus must adhere to including an annual compliance certification report. UNH filed a renewal application for its Title V permit that was determined to be timely and complete by NHDES in December 2011. UNH’s Title V renewal application included all devices currently covered by the existing Title V and Temporary Permits. It is anticipated that a draft Title V permit will be issued by NHDES in 2017.

9.1.2 Air Toxics

In 2016, OEHS updated the University of New Hampshire’s air toxics compliance demonstration required under New Hampshire Air Regulation, Chapter Env-A 1400 that was initially prepared in December 2000 and subsequently updated in September 2003, March 2007, February 2009, October 2010, March 2011, April 2013, July 2013 and January 2015. UNH’s compliance demonstration is for the Durham campus, Manchester campus, Law School (Concord) and the Landfill Gas to Energy Facility located in Rochester. As part of this updated compliance demonstration, the following activities were carried out:

• Reviewed current version of Env-A 1400 for any rule changes (i.e. changes to ambient air

limits, methodologies, etc.) since the most recent compliance demonstration for potential

impacts to UNH’s compliance demonstration;

• Collected information on types and amounts of water treatment chemicals added to the

cooling towers as algaecides, fungicides, biocides, and anti-foaming agents. Documented

compliance demonstration for cooling tower regulated toxic air pollutant (RTAP)

emissions;

• Updated UNH Printing Services’ products and actual usage rates for calendar year 2015,

and reviewed Safety Data Sheets to identify any new RTAPs not covered by the previous

update, and to assess changes in usage rates;

• Reviewed and updated emissions from the combustion of Processed Landfill Gas (PLFG)

at the Landfill Gas to Energy Facility located in Rochester;

• Reviewed SDSs and determined compliance for degreasing materials used at the

Combined Heating Plant and vehicle maintenance shop;


• Reviewed activities at the Paul Creative Arts Center and Morse 145 paint booths; and

• Reviewed existing activities identified in UNH’s most recent compliance demonstration to

identify any significant changes to methods and/or equipment.

9.1.3 Refrigerant Management Program (RMP)

The purpose of the University of New Hampshire’s (UNH) Refrigerant Management Program (RMP) is to:

• Maximize the recycling of ozone depleting substances (ODS) and to minimize the release of ODS to the ambient air from the servicing, repairing, maintaining, and disposing of refrigeration appliances on its Durham, Manchester, and Concord campuses;

• Utilize certified technicians for the servicing, repairing, maintaining, and disposing of refrigeration appliances on its Durham, Manchester, and Concord campuses;

• Maintain proper records of refrigerant consumption, technician training, and recycling and recovery equipment certification;

• Ensure proper repairs are made for units with significant leak rates; and

• To ensure UNH is in full compliance with Section 608 of the Clean Air Act Amendments and the requirements of 40 CFR Part 82, Subpart F.

To achieve the stated objectives above, UNH requires all employees and contractors whose job duties require the handling, ordering, repairing, servicing, maintaining, or disposing of refrigerant or refrigeration appliances to review and comply with this written program.

In June 2015, the UNH RMP was revised to update the refrigerant-containing appliance inventory for UNH Durham and to include the UNH School of Law and the new home of UNH-M. Additional certified service providers for appliance repairs were also included in the RMP.

In October 2016, OEHS approved a work proposal by a USNH term agreement environmental engineering contractor to complete a review and audit of the UNH RMP to determine UNH’s compliance status with the requirements of 40 CFR Part 82 (Protection of Stratospheric Ozone), assess the accuracy of information contained in the existing RMP and determine if any changes are warranted based on current UNH practices and/or new US EPA guidance relative to 40 CFR Part 82. An audit of UNH’s current execution of the RMP will also be conducted, ensuring that the procedures and best management practices outlined in the RMP are being followed. This work should be completed by March 2017.


10.0 Laboratory Safety

10.1 Biological Safety

10.1.1 Biosafety Stewardship and Biological Safety and Biosecurity Manual

National Biosafety Stewardship Month and the introduction of a Biological Safety and Biosecurity Manual were much of the focus of the biosafety program in 2016. The Biological Safety Officer worked with multiple departments to determine areas of the program that could be stronger and then initiated a plan to get more robust procedures in place. UNHCEMS® was utilized to create a more user friendly biological inventory system, to initiate new training modules, and to track administrative program items more easily.

10.1.2 BSL-1 Initiatives

BSL-1 laboratories were a focus in 2016 since these labs do not fall under the Institutional Biosafety Committee purview unless research with recombinant or synthetic Deoxyribonucleic Acid (DNA) is performed. Laboratories working with environmental microbes, DNA/ Ribonucleic Acid (RNA), or microbes that do not cause human disease were contacted and visited by the Biological Safety Officer in an effort to identify these labs in a database to track the type of work they are doing. The laboratory managers collaborated with OEHS to make sure training was completed for staff and students working in the labs, biowaste procedures were sufficient for the work being done, and that the agents were being handled appropriately with BSL-1 practices.

10.1.3 Biohazardous Waste Initiatives/COLSA Collaboration

There are three accepted methods of handling biohazardous waste at UNH: chemical disinfection, thermal disinfection via a validated autoclave, or incineration by an authorized waste handler such as Veolia Environmental, via the “red bag waste” system. An effort has been initiated by OEHS to standardize the types of containers that laboratories use in order to reduce confusion about how biohazardous waste is collected and treated. As an example, red step on containers with clear autoclave bags will be standardized in all laboratories in buildings with validated autoclave systems in order to comply with solid waste rules in New Hampshire. Closed top biohazard boxes will be standardized in all laboratories that do not have access to validated autoclaves. As more departments become cross-disciplinary, a robust biowaste handling program with standardized containers will alleviate confusion in the laboratories about biowaste disposal.

10.1.4 The Institutional Biosafety Committee Updates

The Institutional Biosafety Committee (IBC) met on a quarterly basis to review recombinant and synthetic nucleic acid protocols and Biosafety Level 2 protocols in accordance with the


Institutional Biosafety Committee Charter and Procedures. The Durham and Manchester campuses both have protocols registered with the Committee. Committee membership had some turn-over in 2016 as two community representatives from the healthcare sector stepped down when their appointments came up for renewal and the Committee welcomed a new community representative from the private industry sector. Alexa Kaubris from Lonza Biologics, Inc. in Portsmouth joined the Committee in June for a three year appointment.

The IBC reviewed and approved 14 new protocols in 2016. There are 72 active protocols in five colleges being overseen by the Committee. The protocols represent research, teaching and commercial projects in BSL-1 and BSL-2 containment (Figure 12 and 13).


Figure 12: Active BSL-1 and BSL-2 IBC Protocols at UNH 2016

Figure 13: Breakout of IBC Registrations compared by college for 2016


As illustrated in Figure 14, below there are a total of sixty seven BSL-2 containment labs and thirty nine BSL-1 containment labs on the campuses. The Animal Resource Office operates two Animal Biosafety Level 2 (ABSL-2) labs and thirteen Animal Biosafety Level 1 (ABSL-1) labs (Figure 14).

Figure 14: Breakout of 121 biosafety containment laboratories by containment type

The IBC annual report was submitted to National Institutes of Health in December and was accepted without incident.

10.1.5 Institutional Animal Care and Use Committee

Two representatives from OEHS work with the Institutional Animal Care and Use Committee for biological safety and occupational safety issues as they arise. This year, the Biological Safety Officer and the Director of the Animal Resource Office collaborated on a bio exclusion operating procedure for a facility housing a population of immunocompromised mice.

10.1.6 Bloodborne Pathogens Program

The annual review of the campus Exposure Control Plan was completed in December 2016 as is required by the OSHA Bloodborne Pathogens Standard, 29 CFR 12910.1030. The Plan updates were sent to the Occupational Safety Committee for review. There were no sharps injuries reported or logged under the Bloodborne Pathogens Program in 2016. A new Sharps Safety training module was created and deployed for users handling needles, syringes and other laboratory type sharps, such as scalpels. Nineteen people completed the Safety Engineered Sharps Survey located on UNHCEMS® as part of the Bloodborne Pathogens program.


Additionally, two new participants were included in the Bloodborne Pathogens medical surveillance program.

10.1.7 Permits

There were multiple requests for technical help in acquiring United States Department of Agriculture (USDA) permits in 2016. When needed, OEHS worked as liaison between the Principal Investigator and USDA-APHIS (Animal Plant Health Inspection Service) to obtain approval for international shipments.

10.1.8 Biosecurity

In 2016, OEHS and COLSA approved 49 requests for access to the restricted areas in Rudman Hall. The requests included those from new faculty and staff members, graduate and undergraduate students, and facilities personnel. There are 749 infectious agents in biological inventory consisting of Risk Group 1 and 2 agents.

10.1.9 Training

Campus stakeholders continue to appreciate the ease of use that UNHCEMS® brings to EHS training delivery. Feedback from the campus community has been positive, and overall, compliance with training requirements continues to be on target as students, faculty and staff come on board each semester (Figure 15).

Figure 15: Comparison of individuals trained by Biosafety training program throughout 2016


10.1.10 Biosafety Equipment

There are ten autoclaves validated for treatment of biohazardous waste on the UNH campuses. Each autoclave follows a biological indicator test schedule appropriate for its use, or quarterly at a minimum, to comply with New Hampshire solid waste regulation. OEHS oversees the autoclave-testing program and ensures compliance by the end users.

There are forty-eight Class II biological safety cabinets in use and certified annually by the colleges that own them. OEHS documents the cabinet testing results in UNHCEMS®.

10.2 Chemical and Laboratory Safety

10.2.1 Laboratory Safety Inspections

The Laboratory Safety Inspection Initiative (LSII) continued in 2016 under the direction of the Laboratory Safety Officer. The LSII includes the inspection of rooms where hazardous chemicals are used or stored. In 2016, OEHS performed safety inspections in rooms possessing or using hazardous materials in the following buildings:

• Demeritt Hall • Morse Hall

• Gregg Hall • Parsons Hall

• James Hall • Rudman Hall

• Kendall Hall • Spaulding Hall

• Kingsbury Hall • Keener Dairy Nutrition Center

OEHS evaluates laboratory engineering controls during safety inspections and identifies issues requiring repair. OEHS also collaborates with Facilities Operations and Maintenance and the Energy Office on repair and maintenance projects as a technical advisor.

10.2.2 Chemical Safety Committee

OEHS continues to administer and support the UNH Chemical Safety Committee (CSC). Representatives from OEHS organize and attend quarterly meetings, compile minutes, draft appointment letters, and fulfill other administrative requirements for the committee. This year, a new member was appointed to the CSC representing the College of Engineering and Physical Sciences. Also, several members of the CSC agreed to work on the draft Laboratory Ventilation


Management Program. These CSC members have provided critical input in the development in the program and have helped ensure its success as work on it proceeds.

10.2.3 Regulatory Compliance Services

OEHS continued to monitor and ensure institutional compliance with the US Department of Homeland Security (DHS) Chemical Facility Anti-Terrorism Standards (CFATS). This regulation requires facilities that possess or transfer certain “Chemicals of Interest,” to file an in-depth screening report with DHS and comply with certain security requirements. The list of Chemicals of Interest includes over 300 chemicals that could potentially be used for sabotage or the creation of a weapon of mass effect. OEHS uses UNHCEMS® to evaluate the campus inventory for Chemicals of Interest, and works with owners to ensure the inventories are accurate.

OEHS administration of the UNHCEMS® Parsons Hall Flammable Liquid Report in 2016 resulted in successful maintenance of compliance obligations. UNHCEMS® automatically sends an alert to OEHS, Principal Investigators, and the Durham Fire Department when volumes of flammable liquids in laboratories in Parsons Hall exceed fire code storage limits. Also, UNHCEMS® sends a warning to OEHS and Principal Investigators (PIs) when inventories approach the storage limit, allowing us to evaluate inventories internally before reporting to the fire department is required. OEHS continues to work with PIs to facilitate accurate reporting of flammable liquid inventories and accurate reporting to our emergency responders.

10.2.4 Chemical Fume Hood and Laboratory Ventilation Assessments

OEHS continued to perform detailed evaluations of laboratory chemical fume hood operation and performance in 2016. OEHS assesses operation of each UNH’s 448 fume hoods annually and whenever hoods are reported to have operational deficiencies. This year, OEHS conducted 494 fume hood assessments. As a result of this work, OEHS submitted 58 service requests for fume hoods. The chemical fume hood is the primary engineering control protecting workers in research laboratories from hazardous chemical exposures; as a result, OEHS dedicates significant resources to evaluate fume hoods for safe operation.

In 2016, OEHS identified a significant number of chemical fume hood performance deficiencies in Parsons Hall teaching laboratories. Fume hood failures in teaching laboratories can have a significant impact on student safety and course schedule. OEHS increased assessments in teaching labs to minimize impact on students and classes. OEHS worked with the Facilities Maintenance staff to expedite repairs and help ensure classes were not affected.

In addition to evaluation of chemical fume hoods, OEHS also assesses operation of other laboratory ventilation components that may impact worker health and safety. These components include gas cabinets, snorkel exhausts, canopy exhausts, other point source ventilation, valve


and actuator operations, dampers, and alarms and control devices including face velocity monitors and flow controllers. This year, OEHS assessed effectiveness of canopy exhausts in Keener Dairy Nutrition Research Center and made recommendations for improved effectiveness of the equipment. Also, OEHS assessed performance of a canopy exhaust in James Hall due to concerns about cross contamination in research labs. Additionally, OEHS assessed performance of new gas cabinets installed in Morse 345 including exhaust velocity and airflow alarm function.

10.2.5 Laboratory Design and Renovation

OEHS provides technical input and support for laboratory design and renovation projects including during planning phase, construction, and commissioning. OEHS tested fume hood performance as well as other laboratory exhausts, evaluated face velocity monitor function, reviewed eyewash and deluge showers, flammable cabinets, chemical storage cabinets, safety equipment availability, egress, laboratory heating, ventilation and air conditioning (HVAC) function, and chemical storage. This year, OEHS provided input and support for the following projects:

• Morse Hall room 345 major renovation and commissioning of laboratory infrastructure to house a new Mass Spectrometer;

• Construction and commissioning of chemical engineering research laboratory in Parsons Hall Room S138;

• Provided input on proposed laboratory design for Spaulding Hall renovation;

• Provided plan review and on-site inspection of Conant Hall second floor research laboratory renovations;

• Reviewed plans for new machine shop in Chase Hall including recommendations for improvements to proposed ventilation and improved access to emergency eyewashes and showers;

• Rudman Hall laboratory heating ventilation and air conditioning (HVAC) multi-year project to correct system deficiencies including providing input about project goals and scheduling;

• Provided comments on draft plans for new water treatment plant including recommendations for fume hood system and improved access to emergency eyewashes and showers;

• Reviewed plans for new Olsen Center for Advanced Manufacturing including review of drawing for two proposed site locations; and


• Reviewed proposed plans for laboratory moves from Spaulding to Kendall Hall including in-depth review of laboratory protocols and determination of laboratory infrastructure needs.

10.2.6 Laboratory Safety Technical Services

OEHS staff provides technical safety services to teaching and research laboratories at UNH and UNH-M. These services include providing chemical safety information, incident investigation, odor investigations, laboratory exhaust evaluation, chemical storage and segregation, assessment of personal protective equipment, reproductive health assessments, and regulatory compliance services. Selected projects this year include:

• Resolved safety issues related to use improper use of a speedvac that caused release of flammable and toxic vapors into a laboratory. Identified appropriate alternative equipment use, purchased it for the researcher, and identified personnel to set up the equipment.

• Successfully negotiated change of occupancy type for a COLSA room. Occupants agreed to relocate chemical operations to a room that is better designed to protect them from potential hazards.

• Identified failure of the tepid water system in Parsons SE Wing. Discussed with Chemistry Department and shared information about the issue with Facilities maintenance.

• Developed draft standard operation procedures (SOPs) for acutely hazardous materials for researchers including for tri-n-butylphosphine, methacryloyl chloride, methyl chloroformate.

• Assisted researcher with compliance issues related to use of a highly regulated substance at a collaborating research site, enabling graduate research to proceed.

• Assisted a researcher with a cylinder change-out of a toxic for laser gas.

• Consulted with a faculty member regarding use and storage of flammable and toxic compressed gas in Kingsbury Hall, including assistance with troubleshooting installation of a gas monitor.

• Provided guidance to researchers in Morse Hall related to safe use of chloroform solutions, fume hood use, and emergency equipment.


• Consulted with researchers regarding use of an experimental 3D printer with polychlorotrifluoroethylene in order to mitigate risks or exposure to toxic and corrosive vapors and surface contamination.

• Provided guidance on project adding glassware racks and vacuum pump hose access in a fume hood.

• Consulted with a research group that was hoods improperly. Provided onsite guidance, summarized the issues, and shared them with the PI.

10.2.7 Laboratory Safety Training

OEHS provides laboratory safety training for the campus community. Below is a list of trainings provided and number of individuals who completed the training.

Table 9 Laboratory Safety Training Provided in 2016

Training Title and Description 2016

attendees

Laboratory and Chemical Safety Training: fundamentals of chemical safety, hazard communication, controlling hazards, emergency response procedures.

404

Review of Laboratory and Chemical Safety: live review session for those who have already completed Laboratory and Chemical Safety Training

16

Cryogenic Liquid Safety Training: required for those using liquid cryogens 37

Laboratory Safety Awareness for Contractors: awareness training for contractors working in occupied research or teaching laboratories

10

Laboratory Safety Awareness for Housekeepers: awareness training for housekeepers entering occupied research or teaching laboratories.

63

11.0 Hazardous Materials

11.1 Chemical Transfer Station

OEHS continued to operate the CTS in 2016. Chemical orders for all research chemicals, except those for the Chemistry Department, are received at the CTS.

OEHS staff receive chemical deliveries at the CTS, barcode the chemical containers, and collect information required for the chemical inventory. Packages are then re-sealed and delivered


directly to research labs on the same day the package is received. Monthly trends in chemical deliveries roughly follow academic and fiscal years schedules where there is usually an increase in chemical deliveries in early fall, a decline during winter break. 2016 trends followed this trend, as seen in Figures 16 and 17, below. Notably there was a significant increase in total number of chemicals delivered, 2,073, which represents a 34% increase over 2015. This increase ends a five-year trend of slight decreases in chemical deliveries. The increase is likely due to several new hires within COLSA setting up their research labs.

Figure 16: Chemicals received by OEHS for delivery from 2010 through 2016


Figure 17: Monthly breakdown of chemicals received by OEHS throughout 2016

11.2 Chemical Inventory Validation Program

OEHS conducts periodic campus-wide chemical inventory verification with the goal of verifying the accuracy of the UNHCEMS® chemical inventory. Maintaining an accurate chemical inventory is important for many reasons:

• Emergency responders rely on accurate reporting of hazards in campus buildings and

rooms;

• OEHS relies on accurate inventories for regulatory reporting requirements such as

EPCRA and DHS CFATS;

• Agreements with the State Fire Marshal’s office require UNH to actively monitor chemical

inventories in Parsons Hall and a select laboratory in Morse Hall; and

• UNH researchers rely on information in UNHCEMS® to help conduct their research; they

regularly use UNHCEMS® to search the campus inventory for chemicals they can use in

their research.

Historically, conducted every one to three years, with differing combinations of OEHS staff, student interns, and contractors, OEHS began collaborating with UNH Chemistry Department to conduct comprehensive laboratory chemical inventory verifications and inspections since 2015. OEHS offers four highly qualified Chemistry graduate students summer research stipends in exchange for work on the chemical inventory verification. In 2016, the project lasted from June 6


through August 19, during which time the team visited 550 laboratory and chemical use spaces maintained by approximately 179 UNH Faculty and Staff across 38 Departments and 19 Campus Buildings (including UNH-M). The team was successful in verifying 36,746 chemical containers and adding 313 chemical containers to the chemical inventory.

Approximately 8% of the chemical containers in UNHCEMS® were not found to be present in the laboratories visited, resulting in marking of 3,121 containers as In-Transition. OEHS works with chemical owners to resolve the location/disposition of the chemical containers not verified during the field program.

The inventory team completed an inventory of refrigerators and freezers in use across campus to store specimens and chemicals. The information collected contained the rating of the devices (such as explosive or flammable and/or subzero etc.) which was then added to the laboratory’s chemical inventory in UNHCEMS®. The data collected allows users to search for specific equipment in the laboratory used to store chemicals.

In addition to the chemical inventory verification process, the scanning team recorded laboratory safety observations relative to safe practices, storage and handling of chemicals, and biosafety concerns where applicable. Observations were submitted to the OEHS Laboratory Safety Officer and Biosafety Officer for follow up with individual laboratory owners.

Figure 18, shows the distribution of chemical inventory verified across the science buildings on campus, with Parsons Hall, which houses UNH Chemistry Department, having the highest number of total containers verified in 2016. Parsons Hall stores and uses approximately 38% of all the chemicals in the UNHCEMS® inventory.


Figure 18: Chemical Containers Verified during the Summer 2016 Inventory Program by Science Building

11.3 UNHCEMS® Inventory

Data collection and compliance reporting for OEHS relies heavily on the UNH Chemical Environmental Management System (UNHCEMS®). Indeed, the entire University Community uses UNHCEMS®. Approximately 8,660 active users accounting for faculty, staff, students, visiting researchers, and contractors, among others, have access to the UNHCEMS® software program online.

OEHS worked with the Research Computing Center (RCC) who develops and maintains the UNHCEMS® software in designing and testing a major software upgrade in 2016. OEHS reached out to faculty and staff to prepare the University community with any impacts the upgrade may have on inventory and other program management. The successful roll-out to UNH and licensees occurred between October and December 2016.

As mentioned in other sections of this Annual Report, UNHCEMS® is widely used by the University to track many other programs such as training, radiological materials, laboratory equipment, and environmental programs. OEHS assists the UNH community with gaining access to resources provided by UNHCEMS®, including training and technical support and acting as a liaison between the software development team in RCC and campus stakeholders.

OEHS initiated the barcoding and inventory for two new non-science storage areas in 2016. These areas include the Transportation Garage stock room and the Central Stores stock room. The stock rooms maintain chemicals for housekeeping maintenance and the automotive


transportation maintenance groups on campus. As part of this inventory, OEHS reviewed all chemicals used and stored in the stock rooms and identified the products that meet the Hazard Communication program requirements as a result of their listed hazards. Once the products were identified, the items were barcoded and container/chemicals details along with applicable SDSs were loaded into UNHCEMS®. This resulted in the addition of 408 containers to the campus inventory.

From January 1, 2016 through December 31, 2016 UNHCEMS® tracked the activity of 48,788 containers across the entire campus, including non-Science buildings. Of the 48,788, approximately 8,628 containers were marked empty throughout the year, leaving approximately 40,160 containers as ‘active’ across campus.

Additional UNHCEMS® statistics for the calendar year, relative to the campus chemical inventory and hazard communications include:

Table 10 Statistics for containers and Chemicals maintained in UNHCEMS® from January 2016 through December 2016

Container Disposition Total

Containers Acquired in 2016 and added to Inventory 4,928

Unique Chemicals in the UNHCEMS® Inventory 14,549

New/Unique Chemical Products added in 2016 1,710

Unique Safety Data Sheets as of December 2016 17,499

Safety Data Sheets updated 3,540

Chemical Containers marked empty 8,638

Active Door Signs (Created and tracked in UNHCEMS®) 582

Biosafety Level – 2 58

Signs Posted at UNH-M 9

Biosafety Level 2 signs at UNH-M 2

OEHS continues to work with Researchers and Staff to reduce the amount of legacy chemicals across campus. UNHCEMS® is instrumental in identifying legacy chemicals and keeping track


of laboratory moves. Data from UNHCEMS® is exported to the Laboratory Safety Manager for review once a researcher or faculty has retired or has been assigned new laboratory space to not only review the inventory for disposal but also to identify chemicals that may be valuable to other researchers and have them redistributed. All Chemical Waste disposal is also tracked in UNHCEMS® providing readily exportable datasets for the Hazardous Waste Manager in OEHS.

11.4 Hazardous Materials Shipping

OEHS continued efforts to maintain compliance with hazardous material shipping regulations by offering guidance, training, on-site review, and reference material to the UNH community. OEHS provided professional guidance and training for 20 UNH research projects in 2016. This included providing guidance for domestic and international research material shipments including those to Puerto Rico and Canada.

OEHS continued a partnership with the Thompson School Veterinary Technician Program to offer shipping certification training to students. As students enter their profession, they will very likely have responsibilities to ship infectious and potentially infectious samples. Providing the necessary training to perform these tasks will help students market themselves to prospective employers. Twenty-two (22) students in the Veterinary Technician program attended this training which was offered as part of their coursework.

Resources created by UNH OEHS for hazardous material shipping are used extensively nation-wide. Several UNH hazardous material shipping documents are widely recognized as standard reference material and are used by many other institutions. OEHS continued to create and update hazardous material shipping reference documents for the UNH research community in 2016, including updating guidance documents for shipment of laboratory synthesized chemicals, shipment of methanol solutions, and the UNH Guide for Shipping with Dry Ice.

11.5 Hazardous Waste Management

OEHS provides hazardous waste management support to faculty, staff, and students at the Durham campus as well as the Manchester campus, UNH School of Law, Jackson Estuarine Laboratory, Coastal Marine laboratory, Shoals Marine Laboratory and the UNH Transportation Garage. We manage US EPA, State of New Hampshire and State of Maine regulated hazardous waste materials generated throughout the year as a byproduct of research, teaching and facilities operations. In addition, the staff have been involved in a number of projects and initiatives to limit the university’s environmental liability by assuring proper transportation and disposal of hazardous materials and wastes and by reducing the quantity and toxicity of hazardous waste streams generated.

This year OEHS hazardous staff were involved in the following special projects:


• Member of the Zero Waste Task Force commissioned by President Huddleston and charged with diverting solid waste from landfill disposal;

• Partnered with Facilities Project Management to desensitize and decontaminate a potentially hazardous perchloric acid fume hood located in Morse Hall;

• Supported Facilities Project Management with the disposal of regulated waste materials generated during the demolition of the old outdoor pool, affiliated structures and systems.

• Supported the College of Life Science and Agriculture project to remove, remediate and replace the automotive fueling station located at the Burley-Demeritt in Lee, NH.

11.5.1 Inventory Reductions

In 2016, OEHS performed hazardous material inventory reductions throughout the University to increase safety and reduce liability, including but not limited to:

• Disposal of legacy and surplus chemical reagents from Kendall, Rudman, Spaulding and Kingsbury Halls. 1,700 hazardous material containers were removed and disposed of. This represents chemical inventory reductions by building of 22%, 5%, 18% and 9% respectively.

• Identification and disposal of reactive lithium compounds from Parsons Hall and cyanide reagents from Spaulding Hall.

• Disposal of nine cubic yards of unwanted paints, coatings, adhesives and other related commercial chemical products from Facilities Services and Housing.

11.5.2 Summary of Hazardous and Universal Wastes Generated

As a result of various campus activities, the following statistics represent chemical and biological waste generation and disposal for the University in 2016.

Total Chemical and Biohazardous Waste generated:

• Chemical Waste: 19,012 kilograms

• Biohazardous Waste: 724 cubic feet

Kilograms of Hazardous Chemical Waste generation by building is summarized in Figure 19, below. In 2016, Parsons Hall continues as the largest waste generating building on campus. Approximately ninety percent of the waste is being generated through research activity, with teaching contributing the remaining ten percent.


Figure 19: Kilograms of Hazardous Chemical Waste disposed in 2016, by Building

Kilograms of hazardous waste generated across campus buildings and departments are displayed in Figures 19 and 20, respectively. In 2016, the Chemistry department (Parsons Hall) continues to be UNH’s largest generator of hazardous waste. Chemistry will continue to lead hazardous waste generation indefinitely due to the nature of the science. The hazardous waste produced by the departments of Cooperative Extension (Spaulding Hall), Natural Resources (James Hall) and Earth Science (James Hall) is generated primarily by the environmental analysis research of three very active laboratories. Art and Art History has dropped off the 2016 list of top ten hazardous waste generating departments through their continuing recycling and waste minimization efforts.

4683.95

1405.516 1403.751110

470.85 389.3 312.5 297.5 294.5 286.15 2380

500100015002000250030003500400045005000

Building

Kilo

gram

s of

Was

teKilograms of Hazardous Chemcial Waste by Building


Figure 20: Kilograms of Hazardous Chemical Waste Disposed in 2016, by Department

11.5.3 Universal Waste

In 2016, the policy of limiting access to the Central Universal Waste Accumulation Area to a limited number of Facility Operations and Maintenance “key- holders” has continued to increase communication between OEHS and Facilities O&M staff and has helped assure regulatory compliance at the facility.

In general, Universal Waste generation in 2016 was significantly down from 2015. This is primarily because we did not begin work on any large building capital renovation projects in 2016. An indicator of this are the total quantities of fluorescent lamps and associated lamp ballasts generated in 2016 vs 2015. Fluorescent lamps and lamp ballasts are among the first regulated waste materials removed from a building undergoing demolition or a gut renovation. Figures 21 through 26 summarize light bulbs and ballasts removed for the last 10 years.

4657.25

1110 1077 1035678.516 512.5 498.55 342 328 325.95

0500

100015002000250030003500400045005000

Department

Kilo

gram

s of

Was

te

Kilograms of Hazardous Chemical Waste by Department


Figure 21: Ballasts Removed from Campus from 2006 through 2016

Figure 22: Fluorescent Lamps Disposed by OEHS from 2006 through 2016

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 20160

1000

2000

3000

4000

5000

6000

7000

8000

9000Po

unds

Ballasts Removed

52485

30070

70927

43665

54706

3999348156

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38840

22105

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 20160

10000

20000

30000

40000

50000

60000

70000

80000

Calendar Year

Feet

Fluorescent Lamps Removed


Figure 23: Compact Fluorescent Lamps Disposed by OEHS from 2006 through 2016

Figure 24: Circular Lamps Disposed of by OEHS from 2006 through 2016

2235 2317

38333078

6494

2400

4329 4143

6496

3878

2120

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 20160

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246

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553

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839

2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 20160

100200300400500600700800900

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ber o

f Lam

ps R

emov

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Circular Lamps Removed


Figure 25: U-Tube lighting Disposed of by OEHS from 2006 through 2016

Figure 26: Number of HID Lamps Disposed by OEHS from 2006 through 2016

Figure 27, summarizes the pounds of lead-acid batteries disposed of between 2006 and 2016. Since 2012 the quantity of lead-acid batteries has been reasonably consistent at 3,000 to 3,500 pounds per year.

992

552

2145

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Figure 27: Lead Acid Batteries Disposed by OEHS from 2006 through 2016

Routine maintenance of emergency lighting is the primary source of lead-acid batteries being recycled by the Office of Environmental Health and Safety.

As existing emergency lighting fixtures are replaced with modern, efficient light emitting diode (LED) type designs we may see a reduction in lead-acid battery generation and an increase in other regulated battery types such as nickel-cadmium or lithium.

11.5.4 Regulated Biological Waste

The amount of regulated biological waste being disposed of through contracted waste vendors steadily decreased from 474 standard 4.5 cubic foot boxes in 2006 to 172 boxes in 2013 (Figure 28, below). The annual generation rate has been static since 2013 at 172 to 161 boxes per year. The decrease was directly attributable to the implementation of autoclave treatment and subsequent disposal as solid waste rather than off-campus shipment as regulated medical waste for disposal by incineration.

6494

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Figure 28: Boxes of Infectious Waste Disposed of by OEHS from 2006 through 2016

The implementation of autoclave treatment of biological waste as outlined in the Biohazardous Waste Disposal Plan has reduced our direct disposal cost but indirect costs such as labor, compliance testing and autoclave purchase, operation and maintenance are less well documented at this time.

12.0 Radiation, Laser and Magnet Safety

12.1 Radiation Safety

12.1.1 Program Information

UNH possesses a Type-A Broad Scope License from the New Hampshire DHHS, Radiological Health Section, to use and store radioactive material. OEHS manages the Radiation Protection Program and ensures compliance with license conditions, applicable governmental and state rules and regulations. OEHS reviews and updates the Radiation Protection Program and the Radiation Safety Users Guide. OEHS distributes and reviews new and renewal applications for the use of radioactive material and issues permits granted by the UNH Radiation Safety Committee to Authorized Users on campus.

12.1.2 Training

State regulations require Radiation Worker training for incoming employees as well as refresher training once per year. Radiation Worker training is a 3-hour training that is half on-line and half live training and prepares workers to use radioactivity. Twenty-one students, staff, and faculty

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successfully completed Radiation Worker training, and 65 students, staff and faculty took Radiation Worker Refresher on-line. Live presentations and on-line trainings are revised every year. Radiation Worker Refresher is updated to reflect compliance with state regulations.

For those students, staff, or contractors that need to access radioactive laboratories, but do not use radioactivity, Radiation Awareness training is conducted. Most of this is live training to contractors. There were 123 students, staff, or contractors trained in Radiation Awareness in 2016.

12.1.3 Radiation Protection Program Maintenance

OEHS maintains a manual, the Radiation Protection Program and a guidance document, the Radiation Safety Users Guide. These documents are revised every two years. Both documents were updated with new organization charts and a new Delegation of Authority letter from President Huddleston to allow the Radiation Safety Officer (RSO) to stop work in unsafe conditions. All forms, such as the Addition of Personnel Form were also updated in 2016 and are now fillable.

12.1.4 Audit and Regulatory Review

Third Party Audit

State regulations require an annual review of the radiation safety program. UNH contracts with Clym Environmental Services LLC each year to review the radiation safety program at UNH. The 2016 audit indicates there were no negative observations and only one recommendation for a program change. Clym recommended UNH decrease surveys from four times per year to two times per year in inactive laboratories (laboratories not actually using radioactive material). Figure 329, below, displays the number of observations made during the annual audit since 2011.


Figure 29: Clym Environmental Radiation Survey Results 2011 through 2016

State of New Hampshire Regulatory Inspection

The State of New Hampshire, Radiological Health Section conducts a thorough inspection of the UNH Radiation Safety Program every three years. A state inspection was conducted in the summer of 2016. A thorough investigation of our records was conducted as well as an inspection of our laboratories with active permits. No items of non-compliance were observed. They offered one recommendation to reduce our inventory of sealed sources by disposing of decayed sources.

12.1.5 Radiation Safety Monitoring Instruments

OEHS tracks the annual calibration of survey instruments, such as Geiger counters, and Sodium Iodide detectors. Gas Chromatographs (GC) and Liquid Scintillation Counters (LSC) are inventoried twice per year for the sealed sources internal to the machine. OEHS has sight survey meters and one LSC. Permitted laboratories have eight survey meters, seven GCs, and four LSCs.

12.1.6 Occupational and Public Doses

Dosimetry Program

OEHS manages a dosimetry program to track the dose of external radiation in faculty, staff and students. State regulations determine how much dose one can be exposed to in a year. OEHS tracks these doses every two months to assure compliance with these state regulations. We have


TLD or thermo-luminescent dosimeters for tracking beta and gamma doses to the whole body or finger and state of the art CR39 devices for tracking neutron doses.

OEHS interprets results of dose reports for Authorized Users and Radiation Workers, for Health Services, and Veterinary Technology. We also track area monitors in Space Science, Veterinary Medicine and the OEHS radioactive waste room. Area monitors are dosimeters place in hallways to track the dose to the general public. OEHS issues 121 annual occupational dose history reports, which state dose histories for the previous year. OEHS processed 27 termination dose history reports for those who have ceased using radioactive materials or X-Rays at UNH.

For Veterinary Technology there have been 50 dosimeters exchanged every two months. Health Services had 6 dosimeters exchanged every two months and Authorized User Radioactive Permits had 69 dosimeters exchanged every two months.

12.1.7 Surveys and Monitoring

Surveys were conducted quarterly in 2016. The RSO performed surveys in laboratories three times and Clym Environmental performed surveys once per year as a third party audit. One item of non-compliance found by the RSO in 2016 has since been resolved. Surveys include monitoring with a Geiger counter and conducting wipe tests with a filter paper to look for contamination, as well as a records review. The Radiation Safety committee recently voted to reduce laboratory surveys to twice per year for inactive labs. Last year 144 surveys were conducted.

12.1.8 Leak Test Procedures

Leak tests are performed on sealed sources. These are solid forms or radioactivity that do not normally pose a threat of contamination. In rare instances, these sources may leak radioactive contamination. There are 132 sealed sources on campus. All sealed sources are inventoried twice per year. OEHS completed 68 leak test evaluations in Calendar Year 2016. There was no leakage detected above regulatory limits.

3-month Leak Tests are conducted on alpha sources, which may leak due to a thin window on the sealed source. These leak tests are performed by the RSO. Twenty 3-month leak tests were performed in 2016.

6-month Leak Tests are performed on alpha, beta, and gamma sources, which are listed as sources that may leak by the State of New Hampshire, Radiological Health Section. The RSO conducts leak tests once per year and Clym Environmental conducts another set of tests for the second period of the year.


12.1.9 Laboratory Decommissioning

Laboratory decommissioning for radioactive materials is conducted prior to closing out a laboratory. The State of New Hampshire, Radiological Health Section has given OEHS the authority to perform decommissioning surveys ourselves rather than hiring a consultant company. The State of New Hampshire then confirms the survey and takes the laboratory off the UNH Broad Scope Radioactive Materials License. This saves the University money in decommissioning funds. The RSO and the OEHS safety technician performed seven laboratory decommissioning surveys in 2016.

12.1.10 Waste Management

OEHS manages the pick-up, storage, and disposal of radioactive waste. Dry Active Waste (DAW) is stored for 3 years and then shipped out for permanent burial due to its long half-life. OEHS managed 55 gallons of DAW in 2016. Sealed sources are also disposed as DAW. Three sealed sources were disposed in 2016.

Decay–in-store (DIS) waste is stored for 10 half-lives and then disposed of as regular waste. Any radioisotope with a half-life of under 90 days can be decayed. OEHS managed 150 gallons of DIS waste in 2016. OEHS manages liquid scintillation vials as well. These vials are deregulated and are stored until a 55 gallon drum is full and then they are shipped out for chemical incineration.

OEHS managed 10.85 gallons of liquid scintillation fluid in 2016.

Uranyl Acetate and Uranyl Nitrate are another waste stream managed by OEHS. These are deregulated materials when purchased, but they need to be disposed of as radioactive waste. OEHS picks up these materials. These materials will be shipped out for permanent burial with the next DAW shipment.

The State of New Hampshire, Radiological Health Section came to visit OEHS to collaborate on radioactive waste management. They were impressed with the OEHS web site and wanted more information. The State plans to model its radioactive waste program after the UNH program.

12.1.11 Waste Minimization

OEHS maintains a waste minimization program by instructing researchers to limit long- lived isotopes that need to be shipped for burial. DIS waste such as I-125 can be decayed, and therefore save the environment, and saves UNH about $850 per drum for the disposal in a low-level waste facility. Waste minimization techniques are also taught, such as excising small pieces of contaminated bench pads rather than throwing out the whole pad after each experiment.


12.1.12 Radon Management Program

Radon is a radioactive gas emitted from rock or soil, which may be hazardous to breathe into the body. OEHS maintains a program to monitor for radon in any new building, rental property, or any large-scale construction project to a building. Charcoal vials placed in the building for the weekend are then sealed and sent to an outside laboratory for analysis. Six buildings were monitored for radon in 2016 in Durham. The results showed no significant levels of radon.

12.2 Magnet Safety

12.2.1 Program Information

Research involving the use of instruments that generate large, static magnetic fields such as Nuclear Magnetic Resonance (NMR) spectrometers or Superconducting Magnet systems is becoming more prevalent at the University of New Hampshire. In response to the hazards posed by such instruments, UNH has implemented a Magnet Safety Program. The program contains a manual for reference, a training program, standard operating procedures, and audits. The magnet safety program falls under the purview of the Radiation Safety Committee.

12.2.2 Training

An NMR training program was developed between OEHS and the University Instrumentation Center (UIC). Students, staff, and faculty take an on-line course for part 1 of their training. The UIC then trains the individual on the standard operating procedure and issues a key to the NMR room. Refresher training is tracked by the RSO each September. Ninety-five students, staff, and faculty were trained in magnet safety in 2016. More students received training for Magnet Safety than Radiation Protection or Laser Safety programs.

12.2.3 Registration and Instrumentation

A module was created in UNHCEMS® to register magnets with OEHS. There are three active superconducting magnets on campus.

12.2.4 Surveys and Audits

Surveys are conducted twice per year in the two superconducting magnet laboratories. One survey is performed by the RSO and one is performed by Clym Environmental as a third party audit. The state of New Hampshire does not inspect superconducting magnets used for research. Survey questions include: are all postings displayed; is the 5 Gauss line designated by a chain or tape on the floor, etc. Magnetic fields are measured in units of magnetic induction, such as Gauss.


The 5 Gauss line designates how close someone with a pace maker can get to the magnet without any harm.

12.2.5 Program Maintenance

The Magnet Safety Plan is updated every two years by the RSO and reviewed by the Radiation Safety Committee. The on-line training program is updated once per year in preparation for refresher training. Standard Operating Procedures are updated by the magnet laboratories annually every year.

12.3 X-Ray Safety

12.3.1 Program information

UNH is committed to an X-Ray Protection Program (XPP) of the highest quality. Likewise, UNH commits to full and complete compliance with all relevant requirements in the State of New Hampshire Rules For The Control Of Radiation. The XPP is designed to control operations conducted at UNH Research and Educational Facilities which may result in the potential exposure of UNH personnel, members of the general public, and/or the environment to X-Ray Radiation.

The University of New Hampshire’s commitment to the XPP is based on the fundamental principle that levels of radiation to be used, and exposures to all sources of ionizing radiation, are to be maintained As Low As Reasonably Achievable.

The XPP is administered by the UNH Radiation Safety Officer and supported by OEHS and the UNH Radiation Safety Committee. UNH has X-Ray diffraction machines and electron microscopes, as well as diagnostic machines for the Veterinary Technology program.

12.3.2 Training

All students, staff and faculty who would like to use X-Ray producing machines take X-Ray Safety training on-line. In addition there is a refresher training offered once per year based on state regulatory requirements. Forty-four people completed X-Ray Safety Refresher training in 2016.

12.3.3 Registration and Instrumentation

State registration and payment is required to operate an X-Ray producing machine on campus. All X-Ray producing machines are registered each summer and the certificate of registration is posted in the laboratories. An instrumentation inventory is maintained by the RSO.


12.3.4 Surveys

Nine X-Ray laboratories were surveys twice in 2016. The RSO surveys the X-Ray laboratories in the spring. For cabinet machines, surveys include testing the interlocks. Tests are completed for leakage of radiation for all X-Ray producing machines. Postings are also checked.

Postings

Signage is posted per State of New Hampshire Regulations in X-Ray laboratories including the Notice to Employees sign, which empowers workers to notify the state of unsafe conditions, the Certificate of Registration of the machine, and the Standard Operation Procedure to properly use the machine.

12.3.5 Audits and Regulatory Reviews

Clym Environmental surveys the X-Ray labs as part of the annual third party audit of the program. Clym Environmental did not note any items of non-compliance in the X-Ray program in 2016. The State of New Hampshire, Radiological Health Section inspects the UNH X-Ray protection program once every three years. They test the machines for leakage, test interlocks, and check for postings, and records of training and dosimetry. UNH was not inspected by the State in 2016.


The X-Ray Protection Program is revised every two years. The Radiation Safety Committee approved an updated version of the XPP in December 2016. Dosimetry records are also analyzed every two months for Veterinary Technology faculty and students. Additional surveys are also conducted if machines are repaired.

12.4 Laser Safety

12.4.1 Program information

The Laser Safety Program (LSP) presents guidelines to protect UNH employees and students from the hazards associated with lasers and laser system operations. The intent of this program is to ensure the safe use of lasers through engineering and administrative controls. This objective shall be accomplished by identifying potential hazards, providing recommendations for hazard control, and training laser operators and incidental personnel. The LSP manual outlines the laser safety recommendations for UNH and is based on the American National Standard for the Safe Use of Lasers, or ANSI standard guidelines. There are currently no state regulations that pertain to laser safety, although the Radiological Health Section would like to start regulating lasers in the future.


12.4.2 Training

On-line training is offered for laser operators. Training includes hazard identification, proper signage, use of protective eyewear, laser registration requirements and standard operating procedure requirements. All laser trainings are updated annually. In 2016, OEHS offered Laser Operator training to 69 students, staff, and faculty. Live and on-line Laser Awareness training is offered for those that need to enter laser labs, but do not use lasers. Ninety students and staff passed Laser Awareness on-line and an additional 63 contractors passed Laser Awareness training live in 2016.

12.4.3 Registration and Inventory

All active and inactive lasers are to be registered with OEHS. OEHS has an inventory of 28 class 3B and class 4 lasers of which 12 are in active use. Figure 30 represents the number of lasers in each building on campus. These numbers have slightly increased from last year.

Figure 30: Total Lasers on Campus by Building (includes Active Lasers and Lasers in storage)

The number of trained laser operators increased and then slightly deceased due to a change in the number of active lasers over the past six years. The total number of class 3B and class 4 lasers in UNH inventory has been roughly the same since 2011 (Figure 31).


Figure 31: Comparison of lasers in use versus the number of people trained in Laser Safety from 2011 through 2016

12.4.4 Standard Operating Procedures

SOPs are written for the regular use of class 3B and class 4 lasers. OEHS also requires an SOP for alignment procedures, as this is the most hazardous type of laser use. SOPs are updated by the Authorized User, approved by the Laser Safety Officer and signed by the students and faculty that will be using the laser. The SOP should be referenced each time the laser is used. Some examples of the safety precautions in an SOP are: prior to operation of the laser: be sure all laser operators have been trained; remove all reflective jewelry; watches, and belt buckles; be sure that the laser-in-use light is turned on; close all laser safety curtains or barriers; and don laser eye wear appropriate for the laser.

12.4.5 Personal Protective Equipment

Laser safety eyewear and laboratory coats are examples of personal protective equipment. Laser safety eyewear has an optical density (OD) and wavelength specific to the laser. The calculated wavelength and OD is described in the SOP for Authorized Users. Laboratory coats are recommended with UV lasers to protect the skin. Flame retardant laboratory coats are recommended for Class 4 lasers.


12.4.6 Surveys

Laser Safety surveys are conducted twice per year, once by the LSO and once by a third party.

There was one item of non-compliance found by the RSO and resolved. Survey questions include: have all lasers been registered; has everyone in the laboratory been trained; is appropriate eyewear found in the laboratory; are SOPs posted near the laser; are curtains or barriers adequate; and have there been any accidents involving lasers. Items of non-compliance may be given and the Authorized User has 30 days in which to respond. Significant findings are reviewed by the Radiation Safety Committee.

12.4.7 Audits

Third part audits are performed every autumn by Clym Environmental. Similar questions to the survey questions are asked of the Authorized User. Clym found four items of non-compliance in the laser program and they were resolved quickly.


The Laser Safety Program is reviewed and approved by the Radiation Safety Committee every 2 years. Updated in 2016, the Laser Safety Program includes a new organization chart, updated forms for SOPs and laser registration, and authorization for the Laser Safety Officer to stop work under unsafe conditions.

13.0 UNH at Manchester

13.1 Safety Committee

The charge of the EHSC is to assure a safe work environment for faculty, staff and students and visitors through the creation and maintenance of effective health and safety programs. It is the responsibility of the Committee to establish appropriate health and safety policies, programs and procedures in accordance with federal regulations and guidelines that cover workplace safety and emergency preparedness. The UNH Manchester Emergency Health and Safety Committee met on a regular basis in 2016 to address pertinent health, safety, and emergency matters for the UNH Manchester campus. A few of the accomplishments of the group are listed below:

• Closed circuit security cameras are functional throughout the facility. Monitored by UNH

Police dispatch as well as security services on campus

• At the beginning of each semester, UNH-M holds safety information sessions for students

and staff.


• Two Active Shooter Training sessions were held for students, faculty and staff.

In 2015, the move from 400 Commercial Street to 88 Commercial Street was completed. This necessitated many changes in 2016, including but not limited to:

• Relocation of Automated External Defibrillators;

• Relocation of chemical inventory;

• Purchase and installation of approved chemical storage units;

• New fume hood testing and certification;

• Relocation of Hazmat document cabinet;

• Identifying new storage space for universal waste;

• Working with the University Office of Emergency Management to update building evacuation plans;

• Defining new role as tenant in regards to life safety; and

• Updating the fire extinguisher inspection schedule and contract.

13.2 UNHCEMS® - Chemical Inventory and Training

Chemicals maintained at the University of New Hampshire Manchester’s campus are recorded and tracked using the UNH Barcode system, which links chemical containers to the UNHCEMS® online inventory program.


Data maintained in UNHCEMS® regarding the chemical inventory at UNH at Manchester from 2000 through 2016 is summarized in Table 10, below. Figure 32 shows the number of active chemical containers from 2000 through 2016 at UNH-M.

Table 10 Chemical Inventory Statistics for University of New Hampshire Manchester

Year Removed Containers Added Containers Active Containers

2000 0 41 559

2001 0 48 607

2002 0 15 622

2003 32 29 619

2004 18 19 620

2005 139 113 594

2006 14 23 603

2007 24 22 601

2008 18 11 594

2009 11 26 609

2010 68 36 577

2011 12 11 576

2012 44 38 570

2013 29 48 589

2014 62 32 559

2015 58 59 560

2016 31 60 589


Figure 32: Comparison of Total Chemical containers maintained by UNH-M from 2000 through 2015

The move from 400 Commercial Street to 88 Commercial Street saw an increase in square footage of laboratory space. The number of labs more than doubled; increasing from three teaching laboratories in the old space to seven teaching laboratories in the new space. The number of students accommodated in the new laboratory space also increased. The new laboratories can accommodate up to 24 students each; excluding the new microbiology and organic laboratories, which accommodate 16 students each. This is a 50% increase in overall classroom capacity. Of the seven new laboratories, five of them are biological laboratories supporting the additional class offerings in the life sciences area. UNH-M was able to acquire two new biological safety cabinets for the expanded molecular and microbial work at the campus.

13.3 Integrated Contingency Planning

A contingency plan, was prepared for the University of New Hampshire Manchester campus in 2016. The plan was created to establish preparedness, planning, spill response and spill notification procedures for hazardous materials at this campus. The University of New Hampshire at Manchester campus does not meet the minimum threshold quantities requiring a formal Integrated Contingency Plan (ICP) as prescribed by the US EPA Oil Pollution Prevention Regulations (40 CFR Part 112) and Hazardous Waste Regulations (40 CFR 260-265), the New Hampshire Hazardous Waste Rules (Env-Hw 100-1100) or the OSHA Emergency Response requirements for facilities engaging in hazardous waste operations (29 CFR 1910.120). However,


this plan was prepared as a best management practice for responding to spills for the limited quantity of hazardous materials stored at this campus.

Included within the ICP is a list of emergency contacts for the UNH Manchester facility and city and state agencies, a spill release response reporting quick reference summary, Initial Spill/Release Response Flow Chart and Spill Response Reporting Flow Chart, and a copy of the Emergency Assistance Agreement Response Form signed by the City of Manchester Fire Chief.

13.4 Radon Sampling

Radon is a radioactive gas emitted from rock or soil, which may be hazardous to breathe into the body. OEHS maintains a program to monitor for radon in any new building, rental property, or any large-scale construction project to a building. Readings are reported to the Radiation Safety Committee. Charcoal vials are placed in the building for the weekend. They are then sealed and sent to AccuStar for analysis. The Pandora building was monitored for radon in 2016 in Manchester. The results showed no significant levels of radon on the first floor. There were some slightly elevated readings (above 4 pCi/L) in the basement. Radon mitigation would be recommended only if the basement were occupied.

14.0 UNH School of Law

14.1 Emergency Health and Safety Committee

The UNH School of Law established a formal Environmental Health and Safety Committee (EHSC) in 2015. The charge of the Committee is to assure a safe work environment for faculty, staff, students and visitors through the creation and maintenance of effective health and safety programs. The EHSC reports to the UNH Law School Dean and the Office of the Provost and Vice President for Academic Affairs on matters related to emergency preparedness, industrial hygiene, and workplace safety compliance. Specific tasks include:

• Develop, review, and update written programs and procedures to ensure compliance with OSHA, New Hampshire Department of Labor and other applicable regulations, and recognized consensus safety standards;

• Serve as an advisory body to the UNH Environmental Health and Safety Committee on policies and procedures to ensure the health and safety of all faculty, staff, students, and visitors at UNH-M; and

• Obtain and analyze available data on past injuries and illnesses, identify trends, and suggest appropriate corrective actions.


The EHSC is a deliberative body that is representative of the School of Law community, and includes members from academic and administrative divisions on campus. It is the committee's responsibility to advise the Dean, and to administratively coordinate the various safety-related efforts of the university community. Full voting membership of the EHSC includes the Facilities Manager, the Security Supervisor, the Reference and Public Services Librarian, the SR Human Resource Assistant, the Information Technology Administrator, the UNH Director of Environmental Health and Safety and the UNH Assistant Director of Emergency Management. Chair and Vice-Chair are elected for 3-year terms with a majority vote. The EHSC Chair is a member of the UNH Environmental Health and Safety Committee.

14.2 Other Accomplishments

Other accomplishments completed by the UNH School of Law EHSC in 2016 include, but are not limited to:

• Established a UNH School of Law Safety Committee webpage, which can be found here http://www.unh.edu/research/unh-school-law-safety-committee) and is shown in Figure 33, below;

Figure 33: UNH School of Law Safety Committee Homepage

• Coordinated with an outside vendor to provide fire extinguisher training for interested faculty, students, and staff.

• Coordinated with Durham to provide ergonomic assessments of staff and faculty work stations.


• Provided Rape Aggression Defense training for eight students drawn from the faculty, staff, and students.

15.0 Emerging Issues


The US EPA has promulgated the Hazardous Waste Generator Improvements Rule to update the hazardous waste generator regulations. According to the US EPA, this rule would make the regulations easier to understand and comply with, and provide needed clarification on gaps in the current regulations.

The rule would allow greater flexibility for episodic generation of hazardous waste. Currently, facilities are allowed a one-time exemption for exceeding their generator status thresholds. Sporadic increased waste generation can occur due to events such as laboratory clean outs, which can happen more than once. Other areas that are considered in the proposed rule are emergency planning and preparedness, determination of hazardous waste, labeling, reporting, closure, and other clarifications.

There is great concern among institutions of higher education, however, that some provisions will have a significant negative effect and will not lead to improved safety and compliance. For example, the proposed requirement for a hazardous waste determination to be made at the point of waste generation before any dilution, mixing, or other alteration would create undue hardship on higher education sector institutions, particularly in research and teaching laboratories. Laboratories, art studios, and other research and teaching operations generate constantly changing waste streams at infrequent or erratic intervals. The population of students, faculty, and staff is constantly changing.

We know from experience that we can achieve greater safety and compliance when an institution issues guidance to laboratory workers and other generators so they are informed about aspects of chemical waste such as the characteristics, the regulatory listing, safe collection and storage, what can be mixed together safely, and labeling. This is followed up with procedures for final waste determination, performed by highly trained personnel such as environmental health and safety staff either at the time the waste is removed from the laboratory or in a central accumulation area.

Our experience is that generators are much more likely to take a cautious approach and collect and offer chemical waste that is not regulated by hazardous waste rules than to dispose of the waste in a manner that poses a risk to human health or the environment (e.g., via the sanitary sewer or municipal solid waste). Thus, the changes that clearly state that waste determination must be conducted at the point of generation may make it more likely rather than less likely that


a laboratory worker would dispose of a chemical waste improperly, due to the complexity and added burden this change would place on the generator.

16.0 Communication and Outreach

The OEHS uses many ways to communicate our mission to the campus. The department also provides invaluable information to the general public. This is accomplished in the form of a departmental website (Figure 34) and blog, face-to-face and group meetings, electronic communications, telephone consultations, on-site investigations, group trainings, and other effective communication methods.

Figure 34: OEHS Home Page

The minutes of the Chemical, Occupational, Radiation Safety, UNH-M, UNH Law School, and University Environmental Health and Safety Committee meetings are posted on the website for full public disclosure of our activities. OEHS staff members serve as representatives on these regulatory committee meetings, and attend other meetings of interest to the campus, such as building construction and renovation meetings, the Energy Task Force, the Ecosystems Task Force, the University Emergency Group, as well as ad-hoc meetings when new issues arise.

OEHS produces and distributes many pamphlets and educational materials that cover a wide variety of health and safety topics. As a general practice, the technical experts in OEHS share their programs as much as possible.


17.0 Mechanisms to Measure Compliance

UNH utilizes a number of mechanisms to assure the campus is meeting the elements and objectives of the campus EH&S programs discussed in this report. These include outside audits, regulatory inspections, technical committee oversight, OEHS program review and USNH EH&S Council review. Examples are highlighted below.

17.1 Industrial Hygiene

Indoor air quality and toxic material exposure assessments are conducted by OEHS, outside consultants or by the campus Worker’s Compensation Insurer depending on the complexity of the issue. The New Hampshire Department of Labor reviews the asbestos abatement program and the overall safety and health management program on a periodic basis.

17.2 General Safety

OEHS and the campus Worker’s Compensation Insurer conduct bi-monthly independent safety audits of targeted areas. In 2015, these included the Jackson Estuarine Laboratory, the Organic Dairy Farm, the UNH Sawmill, and Shoals Marine Laboratory. OEHS utilizes injury and illness trending data compiled by UNH’s Workers Compensation insurer to focus safety initiatives. OEHS works with colleges and departments to maintain an electronic environmental health and safety training database for affected faculty, staff, and students. This centralized record keeping process enables OEHS and/or managers to generate queries of individual staff or area departments that are due for safety training. These reports aid in the scheduling of safety training and ensure that all necessary training is completed. Procedures for particularly hazardous work such as hot work, confined space entry, and asbestos and/or lead abatement require a reporting procedure that involves regular communication and oversight from OEHS with additional assistance from the Durham Fire Department and State agencies, as necessary.

17.3 Fire Protection

Both the Durham Fire Department and the State Fire Marshal’s Office conduct fire and life safety inspections of campus buildings. Fire suppression and fire alarm systems are tested and certified by outside consultants.

17.4 Occupational Health and Medicine

Medical screening and surveillance programs are implemented by departments utilizing the services of either UNH Health Services or outside occupational health services organizations. Faculty, staff, and student compliance with the animal handler medical surveillance program is reviewed jointly by OEHS and the Office of Research Integrity Services on a monthly basis.


17.5 Disaster Preparedness

UNH has implemented an Emergency Action and Procedures Plan that outlines procedures to be followed by the campus community for responding to and recovering from fires, hazardous materials spills, and major accidents. Specific procedures to follow for fire evacuation are listed in the plan. Nobis Engineering, Inc. was hired to conduct a thorough review of the UNH Integrated Contingency Plan to ensure compliance with federal and state regulations.

OEHS liaises with UNH Police for annual reviews of Emergency Procedures an Action Plans.

17.6 Diving Safety

All aspects of the UNH research diving program are reviewed annually by the UNH Diving Safety Control Board.

17.7 Biological Safety

The UNH Institutional Biosafety Committee reviews and approves all biohazardous material protocols, including use of recombinant DNA molecules, for compliance with the National Institutes of Health Guidelines. OEHS conducts laboratory audits to assure proper biosafety procedures are being followed in the laboratory. Labs using human source materials are kept in compliance with the OSHA Bloodborne Pathogens Standard through training and strict use of Universal Precautions.

17.8 Hazardous Materials Inventory and Reporting

The U.S. Department of Transportation and the Federal Aviation Administration perform unannounced inspections and audits of the shipping program as part of a regional initiative to enforce hazardous materials shipping regulations at colleges and universities.


OEHS provides regular oversight and review of laboratories and shops that generate and store hazardous waste. The New Hampshire Department of Environmental Services and the U.S. Environmental Protection Agency conduct unannounced inspections of the hazardous waste management program at colleges and universities. OEHS staff conducted a review of the Central Hazardous Waste Accumulation Area Preparedness, Prevention and Contingency Plan, the Hazardous Waste Transporter Contingency Plan, and the Central Accumulation Area Security Plan.


17.10 Radiation Safety

OEHS inspects all laboratories that contain radioactive material quarterly, performing contamination surveys, radiation surveys and compliance audits, ensuring all laboratories continue to meet all license conditions. The Radiation Safety Program is audited annually by an outside consultant. Results of the audit are shared with the Radiation Safety Committee and the Committee approves any changes to the Radiation Protection Program recommended by the audit consultant.

17.11 Laboratory Safety

OEHS staff inspects laboratories that use or store hazardous chemicals. OEHS also contracts laboratory inspection services with a third party environmental compliance company. Additionally, OEHS provides regular oversight of laboratories during on-site laboratory safety training, visits for chemical deliveries, and fume hood testing.

Program Elements 2015 2016

3.3.3.1.1 Injury and Illness Prevention3.3.3.1.2.1 Industrial Hygiene

* Asbestos Abatement

* Lead Abatement

* Hearing Conservation

* Indoor Air Quality

* Personnel Exposure Monitoring for Toxic Materials

* Respiratory Protection

* Hazard Communication (GHS)

* Heat Stress

* Illumination

3.3.3.1.2.2 General Safety* Confined Space

* Fall Protection

* Ergonomic Evaluation

* Lock-Out/Tag -Out

* Accident Investigation

* Powered Industrial Trucks

* Cranes & Hoists

* Aerial/Scissor Lifts

* Dig Safe Program

* Bloodborne Pathogens

* Workplace Safety Inspections

3.3.3.1.2.3 Radiation Safety & Laser Safety* Radioactive Material License

* Radiation Safety Committee

* Radioactive Material Inventory

* Radiation Safety Manual

* User/Awareness Training

* Radiation Safety Laboratory Inspections

* Dosimetry

* Magnet Safety

* X-Ray Safety

* Radioactive Waste Management

* Laser Safety

LEGENDProgram in place

Program undergoing review, improvement, or under development

Program not in place

Not Applicable

USNH Council on Environmental Health and Safety Annual Report - December 2016

UNH Compliance Status December 2015 and December 2016

Program Elements 2015 20163.3.3.1.2.4 Occupational Health and Medicine

* Respirator Medical Questionnaire

* Hepatitis B Vaccination

* Animal Handlers Occupational Health

3.3.3.1.2.5 Integrated Contingency Planning* Aboveground Storage Tank Program

* Underground Storage Tank Program

* Integrated Contingency/Spill Prevention Control and Countermeasures Plan

3.3.3.1.2.6 Biological Safety* Institutional Biosafety Committee

* Biosafety Manual

* Recombinant DNA Registration

* Biosafety Laboratory Surveys

* Inventory of Infectious Material

* FDA Food Biosecurity Application

3.3.3.1.2.7 Diving Safety* Diving Safety Control Board

* Diving Safety Officer

* Diving Safety Manual

3.3.3.2 Hazardous Materials & Environmental Management3.3.3.2.2.1 Hazardous Waste Management

* Hazardous Waste Management Program

* EPA Identification Number

* Faculty/Staff/Student Training

* Contingency Plans for Central Accumulation Area

* Satellite Accumulation Area Inspections

* Universal Waste Management

* Biohazardous Waste Management

3.3.3.2.2.2 Hazardous Materials Inventory and Reporting* Chemical Environmental Mgmt System/Inventory System

* DEA Controlled Substances Inventory

* DHS Chemicals of Interest Inventory

* Community Right To Know/SARA Title III

* Safety Data Sheets

* Chemical Safety/Hygiene Plan

* Chemical Laboratory Inspections

* Chemical Safety Committee

* Title 5 Air Permit

* Stormwater Management Plan

* Refrigerant Management Plan

* Water Quality Permits

* Hazardous Materials Shipping

Annual Report - December 2016UNH Compliance Status December 2015 and December 2016

USNH Council on Environmental Health and Safety

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