Are You Compliant? An Overview of Facility Management Regulations

Keith McLeanRich Township School District 227

& Rob Rottersman, MS, CIH

ENVIRON

• Life Safety Code

Life Safety Code

• Things we will try to cover today:• History • Where these rules come from and who is

responsible for enforcing the code?• Who’s job is on the line if something unsafe

happens.• Ways to stay ahead of the inspectors.

Where does the authority come from for Regional Superintendents to inspect schools?

• Since 1915, Regional Superintendents have been charged with the duty to “…inspect the building plans and specifications of public school rooms and buildings…” (ILSC 5/3-14.20)

• “…Inspect and survey all public schools under his or her supervision…” (ILCS 5/3-14.20)

Added Responsibilities

1965- Duty to review and approve Safety Survey Reports (ILCS 5/2-3.12 as amended)

• Included duty to review and approve amounts of funds to be raised through tax levies or sale of bonds for fire prevention, safety, energy conservation, handicapped accessibility, school security and specific repair purposes (ILCS 5/2-3.12 and 5/17-2.11)

History and development of codes

• The Health/Life Safety codes that we follow every day in our buildings come from a History of tragedies that led to the creation of codes. Some of the first recordable codes were defined in the early 1800’s.

History-Free School Act

• 1825…The introduction of the “Free School Act” which charged local voters of districts to create regulations for building and repairing school houses as they saw necessary.

History – Public Building Egress Act

• In 1874, in response to the Famed “Chicago Fire” the Legislature passed the “Public Building Egress Act.”

• In 1915 the Safety and Sanitation Law required the Superintendent of Public Instruction to create specifications for minimum requirements for Heating and Ventilation and Safety against FIRE.

History and HLS Creation

• In December of 1958 there was a horrific and tragic fire at Our Lady of Angels school. Many children and teachers died. This event led to the establishment of the code drafting committee.

History 1963 to now

• 1963- State Superintendent issued Circular series A-157 (Part 185) entitled “Building Specifications for Health and Safety in Public Schools” and (Part 175) which was titled “Efficient and Adequate Standards for the Construction of Schools.”

• Currently, (Part 180)entitled “Health/Life Safety Code for Public Schools” is in effect for new schools.

Life Safety Code

• What is the main purpose of the annual building inspection?

Summary of reasons for HLS Code

• To ensure that schools are safe, sanitary, and fit for occupancy.

Which Code???

• Building Officials and Code Administrators (BOCA)

• •Published the BOCA National Building Code and other National Codes

• •In 2003 BOCA, International Conference of Building Officials (ICBO) and Southern Building Code Congress International (SBCCI) consolidated to become the International Code Council

What is IBC?

• International Building Code • The International Code Council, made up of

representatives from the three model code groups, BOCA National Building Code, ICBO Uniform Building Code and SBCCI Standard Building Code, was formed in 1994 to develop a single model code.

• In 2003 this became the International Building Code

For some confusion• When are Parts 180, 185, and 175 of the Illinois

Administrative Code used in the inspection of a building? • Timeline for code maintenance requirements: • Part 185 Before 07/01/1965 • Part 175 07/01/1965 to 03/23/1995 • Part 180 (BOCA 93) 03/24/1995 to 07/05/1998 • Part 180 (BOCA 96) 07/06/1998 to 10/02/2005 • Part 180 (IBC 2003) 10/03/2005 to 09/24/2007 • Part 180 (IBC 2006) 09/25/2007 to 12/31/2009 • Part 180 (IBC 2009) 01/01/2010 to present

How are Parts 180, 185 and 175 applied?

• Every new facility and or structure must conform to Part 180 requirements.

• Existing facilities may be maintained in compliance with the code that applied to the facility when built. (BOCA 93 Fire Prevention Code and Property Maintenance Code are retroactive.)

• All equipment, systems, devices and safeguards must be maintained in good working order.

How Often • Required by law once a year.

• BUT!!!

• Facilities may be inspected more frequently at the discretion of the Regional Superintendent.

• Includes facilities rented or leased by the district and used for school purposes.

Simple Advice

• Think about safety all year…Not just before an inspection.

• Don’t look the other way when you see a violation..Door stops, clutter, Blocked egress etc…

• Add Health and Life Safety items to your PM Schedule and document things you inspect. – Emergency lights…Exit signs etc…

Simple Advice

• Share the inspection checklist with Principals, B&G Personnel so that people can correct problems as they arise.

• Treat your ten year inspection as a planning guide for projects. Unless safety is an immediate and evident issue, You will likely be overridden when it comes to other projects taking less priority than Life Safety projects.

Current Checklist

Other Codes• Illinois School Code• Accessibility Blueprint of Standard Dimensions• Accessible Parking• International Code Council (Formerly BOCA)• Day Care Center Rules• Illinois Accessibility code• Lead Based and Asbestos Abatement• Sprinkler Code 105 ICLS 5/22-23• Maybe Illinois Department of Historic Preservation

Links

• ISBE Website• www.isbe.state.il.us/construction/health_safety/default.htm

• Great deal of history• Webinars• All inspections and forms• Permits and application processes• Items of interest…may become code

Integrated Pest Management

What Is IPM in Illinois

Schools and Childcares• IPM is a Proven, Preventative Approach• IPM is the safest and smartest way to work on

troublesome pest issues. • The goal of IPM is to prevent pests in the first

place. Rather than treat and "re-treat" over and over again.

• Even when treating for pests, non-chemical methods are desirable as first line of defense

Steps in IPM• Inspect all areas in and around your School • Identify potential pest problems and conditions that

are conducive to infestation.– Food in classrooms– Clutter– Gaps and holes in walls etc..

• Select appropriate preventative methods, based on each potential pest issue

• Apply materials only as necessary - correctly and carefully - so your employees and stakeholders are not exposed. Powders and Baits are most common.

Common Pests in School Settings

• Flies and cockroaches may spread disease.• Cockroaches can cause allergies and asthma

attacks.• Yellow jacket stings are painful and can be life-

threatening to those with allergies. • Spiders may inflict painful bites and some may

pose a health risk.

Common Pests in School Settings

• Mice may contaminate food, trigger asthma attacks and cause structural damage.

• Termites cause structural damage.• Low risk Aesthetic problems include weeds invading

playgrounds; ants swarming and fruit flies in the kitchen

• Another common problem for schools is weeds. Unsightly, Allergens, Sports Field Nightmares. Including larve of Japanese beetles

IPM Right to Know

• Illinois law requires schools and Childcare facilities to use IPM.

• Even in the course of IPM there will be need to control pests using non-natural methods.

• If you find yourself in a situation that pesticides, including herbicides, have to be applied…Notifications have to be made.

•

Notifications and Process

• Parents and Staff• Notifications may appear in newsletters,

calendars, Bulletins and other correspondence currently published by the school

• Notification may also be by letters to individuals

• Two Business days before application…No more that 30 days prior to application.– No annual application calendar!

Notification process

• Include the Date(s) of application and contact information of the person responsible. Generally the Facility Manager.

Exempt Materials

• Applications of the following pesticides are not subject to the notification requirement.– Anti-Microbial Agents• Disinfectants• Sanitizers• Deoderizers• Insecticide Baits – • Rodenticide Baits

Emergency Applications

• Prior written notice IS NOT required if there is an imminent threat to health or property. Notification must be made as soon as possible with an explaination of the circumstances that lead to the emergency application.

• REMEMBER…Regularly scheduled applications are NOT a part of an IPM program. Constant monitoring and deterrents are more desireable.

More information

• SPCA = Safer Pest Control ProjectFor IPM Training, Resources, Manuals and a list of

area IPM professionals– www.spcpweb.org

• Illinois Dept. of Public Health• For information on new legislation and

manuals to help start an IPM program– www.idph.state.il.us

OSHA/IDOL

Topics for Today• GHS• Hazard Communication• Personal Protective Equipment• Lockout/Tagout• Lifts & fall protectionA brief overview of a few select OSHA programs. Presentation should not be construed as a comprehensive session covering all OSHA regulations.

IDOL or OSHA?

Non-Public Buildings/Employees• OSHA has jurisdiction

Public Buildings (including municipal and schools)• Illinois Department of Labor (IDOL) has jurisdiction• IDOL has adopted OSHA standards

Hazard Communication

OSHA 29CFR 1910.1200

• Who has a hazard communication program?• Is it compliant with the standard?

Key Elements

• Written Program• Material Safety Data Sheets (MSDS)– Safety Data Sheets (SDS)

• Chemical Inventory• Training• Labeling

Written Program

How the School will Meet Requirements:1. Labeling/warning information2. MSDS (SDS in future)3. Employee Information and Training4. List of Hazardous Chemicals 5. Hazards of “non-routine” tasks6. Outside contractor/visitor communication*Program must be available upon request

HazCom vs. GHS

GHS• Transition to Safety Data Sheets (SDS)– Follow a 16 section format – Organizes and simplifies the present information

• Worker training – Required to learn the new elements and SDS

format– Existing HazCom training protocols still apply

Effective Completion

DateRequirement(s) Who

December 1, 2013 Train employees Employers

June 1, 2015*

December 1, 2015

Comply with all modified provisions of the final rule, except:

Distributors may ship products labeled by manufacturers under the old system until December 1, 2015.

Chemical manufacturers, importers, distributors and

employers

June 1, 2016

Update alternative workplace labeling and hazard communication program as necessary, and provide

additional employee training for newly identified physical or health

hazards.

Employers

Transition PeriodComply with either 29 CFR

1910.1200 (this final standard), or the current standard, or both.

All chemical manufacturers, importers, distributors and

employers

* This date coincides with the European Union implementation date for classification of mixtures.

GHS Timeline

GHS Pictograms and Hazard Classes

• Oxidizers • Flammables• Self Reactives• Pyrophorics• Self-Heating• Emits Flammable Gas• Organic Peroxides

• Explosives• Self Reactives• Organic Peroxides

• Acute Toxicity (severe) • Corrosives • Gases Under Pressure

• Carcinogen• Respiratory Sensitizer• Reproductive Toxicity• Target Organ Toxicity• Mutagenicity• Aspiration Toxicity

• Environmental Toxicity • Irritant• Dermal Sensitizer• Acute toxicity (harmful)• Narcotic Effects• Respiratory Tract• Irritation

Labeling

Container Labels Must Contain:• Identity of hazardous chemicals• Appropriate hazard warnings• Name & address of manufacturer• Don’t forget secondary containers• Comply with GHS by 2015Manufacturers label should be sufficient

TrainingAll employees who use or could come in contactwith “hazardous” chemicals must be trained– At the time of hiring– Before beginning a new assignment/job change– Whenever there is a new hazard that was not included in previous training– Whenever new hazards are discovered for an existing product

GHS training by December 2013

School Hazard Communication Hot Spots

• Science Classes– OSHA’s Chemical Hygiene Plan (CHP) for laboratories

applies– 29 CFR 1910.450

• “Shop” classes - other OSHA regs apply– Chemicals; cleaners, degreasers, paints, etc– Welding & weld fume exposure

• Outside contractors/vendors– Custodial cleaning crews, contractors, lawn care, pesticide

applicators, etc.

Respiratory Protection

OSHA CFR1910.134, .139

Respirators as a “last resort” for reducing chemical exposures to safe levels.

Better Options:- Eliminate hazard (product substitution)- Engineering controls (ventilation)

Safety Shoes

29CFR1910.136

• Required when danger of injury from falling or rolling objects, objects may pierce the sole or feet are exposed to electrical hazard

Eye Protection

29CFR1910.133

Eye & face protection shall be worn when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustics, chemical gases or vapors or injurious light radiation

LockOut/TagOut(Control of Hazardous Energy)

OSHA 29CFR1910.147

“Covers the servicing and maintenance of machines and equipment in which the unexpected start up or release of stored energy could cause injury to employees”

LO/TO RequirementsWritten Program/Policy

Define “Authorized” employees• Understand the machines & energy• Trained in LO/TO• Authorized to install & remove locks/tags

Define Effected Employees• Employees who may operate locked or tagged out equipment

Fall ProtectionMultiple references in the standardOSHA CFR1910.21-1910.27 Appendix D

• Guards and rails– Floor openings, uneven floor surfaces, etc.

• Ladders & Stairs– Wood vs. metal & fixed vs. permanent

Scaffolding

OSHA 29CFR1910.27 Subpart D

“Walking – Working Surfaces”

Defined – “Any temporary elevated platform and its supporting structure used for supporting workmen or materials or both”

Regulations depend on scaffold type

Powered Platforms & ManliftsOSHA CFR1910.66Specific for Building Maintenance

• Regulations specific for type of lift• Includes standards for harnesses, use, inspection & training• Protection from falling objects

Safety Quiz: Who’s Liable?

Bob dropped a banana peel, slipped and fractured his skull, who’s at fault?

1) Bob2) Bob’s school district3) Floor wax manufacturer4) Banana importer5) Grocery store6) Newspaper that advertised banana sale7) The Banana farmer8) All of the above

Presenter Contact Information

Robert Rottersman, MS, CIHSenior Manager

ENVIRON International CorporationOffice: (312)288-3857

e-mail: rrottersman@environcorp.com