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HAZARDOUS MATERIALS REGULATION

Policy Number: 
Superintendent File: EBAB-R

1.   Hazardous Materials Program Supervisor

Overall supervision of the operation of all hazardous materials policies and procedures within the District shall be the responsibility of the Assistant Superintendent for Support Services, who shall serve as the hazardous materials program supervisor, referred to throughout these procedures as the “supervisor.”

At each location, a district employee shall be designated as the local hazardous materials coordinator, referred to throughout these procedures as the “coordinator.” At each location, there shall be an alternate district employee designated as a backup to the coordinator.

The coordinator shall be responsible for all aspects of dealing with hazardous materials at the location and shall comply with all District policies and procedures and with all local, state, and federal laws and regulations dealing with hazardous materials.  The coordinator shall also be responsible for reporting any violations in the District’s hazardous materials policy or procedure simultaneously to the supervisor and the building/location administrator.

2.   Tracking, Inventory, and Material Safety Data Sheets

Each coordinator shall be responsible for logging-in the receipt of all hazardous materials received at this location. The coordinator shall track and keep complete written records of the storage, use, and ultimate disposition of the hazardous materials. On or before December

31st of each year, the coordinator shall provide a copy of the current inventory log and record of disposition of all hazardous materials to the supervisor.

The supervisor shall maintain a copy of each location’s inventory and documentation of all hazardous materials.  This information may be released to appropriate police, fire, and emergency service authorities.

The supervisor shall be responsible for establishing and maintaining the Material Safety Data

Sheet (MSDS) system for the District.

Each operation and location shall maintain a set of MSDSes in its area for all hazardous materials with which it has contact. Each MSDS also shall be available for review and use by every District employee and shall be available for inspection by appropriate police, fire, health, and emergency service authorities.

3.   Purchase of Hazardous Materials

The supervisor shall maintain a hazardous materials information sheet that shall be updated and distributed to schools once per year. This information sheet shall include a list of prohibited hazardous materials, as well as information on hazardous materials that require special purchase, tracking, storage, transportation, and handling procedures. The building/location administrator shall insure that the hazardous materials information sheet is distributed to all building/location employees at the beginning of the school year.

In addition to following the District’s regular purchasing procedures, any employee may purchase hazardous materials only with the approval of the coordinator for use at a specific location.  Any district employee who purchases any hazardous material must submit an MSDS to the coordinator before the hazardous material may be brought into the building or location.  If the hazardous material being purchased does not include an MSDS from the manufacturer, then the employee making the purchase shall be responsible for completing an MSDS prior to bringing the hazardous material into the building or location. The Purchasing Department shall not process any purchase order which does not include appropriate approval.

Any unapproved purchase of hazardous materials is beyond the course and scope of the employee’s authority and is forbidden. Such a purchase may be grounds for termination.

The above procedures also shall apply to the acceptance of donated hazardous materials.

4.   Storage Recycling or Transfer of Hazardous Materials

The supervisor shall designate an area or areas for storage of:

a.   Materials that might become or are hazardous materials.
b.   Hazardous materials that have been declared waste and are being held for disposal.

The supervisor may designate storage areas at each location if appropriate as well as a central District storage site.

When a coordinator has a material that qualifies as hazardous material at his/her location that may require disposal, the coordinator shall contact the supervisor to arrange for storage, transfer, or disposal as appropriate.  Materials no longer needed at one location may be available for transfer within the District to other programs or locations.

When materials are not needed by a District location, operation, or program, the materials may be declared waste.  Only the supervisor will be authorized to declare a hazardous material as waste.

Storage of hazardous materials shall be in compliance with federal, state, and local law. All hazardous materials shall be separated according to physical properties and stored safely in storage areas appropriate to the risk posed by the materials. For example, volatile substances such as petroleum distillates shall be stored in approved safety cabinets. Where appropriate, storage cabinets may be locked and access to students or non-authorized staff limited.

All containers for hazardous materials shall be labeled to show date of receipt by the District, shelf life, and expiration date.  Where space permits, materials shall be stored so that the oldest materials are used first (first in-first out).

Transfer of hazardous materials within the District shall be accomplished in compliance with Section 6 of these procedures.

5.   Disposal of Hazardous Materials

When a coordinator or a location/building administrator believes that he/she has materials that may qualify as hazardous for which there is no immediate need for program or operation requirements or that may need to be disposed of, he/she shall contact the supervisor. Only the supervisor shall be authorized to declare materials to be waste, excess, or surplus and to order their disposal.

When materials are determined to be ready for disposal, the supervisor shall arrange for disposal in a manner that complies with all local, state, and federal laws and regulations.

Federal and state laws and regulations provide exemptions from certain regulatory requirements for small quantity generators, i.e., those entities or locations that generate waste in amounts below statutory or regulatory threshold amounts. Disposal determinations should preserve small quantity generator status for each location and for any central storage area.

The supervisor shall maintain written documentation of the disposal of hazardous materials from all locations in the District. This documentation shall be retained in permanent form at one additional location.

6.   Transportation of Hazardous Materials

Transportation of hazardous materials shall meet all local, state, and federal requirements and shall be coordinated by the supervisor.

Federal regulation of the transportation of hazardous materials is extensive, complex, requires significant insurance protection, and involves specialized training of staff on special equipment. Because the District cannot meet these requirements economically with current staff, equipment, and training, the District shall arrange for qualified third parties to transport any hazardous waste or hazardous materials outside the state.

Once a hazardous material is under District control, each location controlling the material shall be responsible for the material until it is passed to the control of another District location.  The supervisor shall verify that the transportation used meets all District, local, state, and federal transportation, financial responsibility, and insurance requirements.

Unless specific written approval is received by a District employee from the supervisor, no District employee or volunteer may transport hazardous materials owned by or attributed to the District in his/her personal automobile.

Subject to the same requirement, no student may be permitted by any District employee or volunteer to transport hazardous materials owned by or attributed to the District in any vehicle, including District vehicles.

Any unauthorized transportation of hazardous materials is beyond the course and scope of the District employee’s or volunteer’s authority and is forbidden. Unauthorized transportation may be grounds for discipline, up to and including termination.

7.   Emergency Response Plan

The supervisor shall develop an emergency response plan that will enable any District employee aware of any incident involving hazardous material to take appropriate action to protect students, staff, the general public, and District property.

This plan shall comply with all applicable laws and regulations and shall be coordinated with the District and the location evacuation plans.

In addition, a plan to handle spills and leaks shall be developed for each location for all hazardous materials at the location. The plan shall address immediate emergency procedures, required notification, and clean-up procedure.

All information regarding a hazardous materials incident shall be released to the media or the public only by the District’s Director of Communications, the superintendent, or designee. No other District employee is authorized to release information regarding any such incident.

The supervisor shall coordinate with the District’s legal counsel and the superintendent’s office any notification or reports to local, state, and federal authorities as well as the District’s appropriate insurance/risk management representative.

8.   Evacuation Plan

An evacuation plan shall be developed and implemented for each location. In developing the evacuation plan, consideration shall be given to the location and the types of hazardous materials present at the location.

An evacuation drill shall be held at least once each calendar year at each location. Where possible, this plan shall be coordinated with existing fire drills, bomb threat evacuation plans, and tornado drills and may be conducted in conjunction with any of these other drills. Written records of the drill shall be maintained by each location.

As appropriate for the location, copies of the evacuation plan shall be posted within the buildings.  Copies of the evacuation plan shall be maintained by the coordinator, the location/building administrator, the supervisor, and any other designated person approved by any of the above-named persons.

Where practical, the evacuation plan shall be coordinated with the fire department, police department, and the District’s transportation department.

9.   Training of Staff and Students

All coordinators, administrators, and staff members handling hazardous materials shall receive information and/or training required to appropriately respond to hazardous materials emergency incidents.

When hazardous materials are used in the classroom, both staff and students shall be trained in the handling, storage, and use techniques appropriate to the materials used as part of the curriculum. The staff also shall be instructed in emergency procedures, including evacuation, appropriate to the materials.

Adopted: April 18, 1991
Repealed by the Board and re-enacted and revised by the Superintendent: September 2, 2003

CROSS REFS.:
DJ, Purchasing
DJ-R, Purchasing Procedures
EBCA, Disaster Plans