Written Workplace Safety Plan

Revised July 2021

Organization and Management of University of Nevada, Reno Safety Programs

Administrative Responsibilities (NAC 618.540 1(a))

Environmental Health and Safety Department

Through the Vice President for Research & Innovation, the President of the University of Nevada, Reno has delegated to the Director of the Environmental Health & Safety (EH&S) Department the responsibility and authority for administering overall compliance with University safety standards and applicable safety regulations. The full-time professional EH&S faculty and staff, with oversight guidance from the various safety committees, are qualified and authorized to assess, identify, analyze, and control new and existing hazardous conditions. In addition, EH&S monitors and manages hazardous materials and situations. Faculty and staff remain current on regulatory requirements and on the latest professional practices which can be applied to effectively reduce risks and achieve compliance with regulatory requirements.

The EH&S program specifically manages radioactive materials and regulated waste chemicals. It also assists with management of biological hazards; conducts industrial hygiene projects; audits compliance with workplace safety requirements; supports multiple aspects of laboratory safety and emergency preparedness; assists in identification, assessment, and potential mitigation of risks; and provides various forms of safety education and training to faculty, staff, and students. Overall, the department helps to develop, communicate and uphold high University safety standards which, in the process, will also meet regulatory expectations. Progress reports related to tasks or information requests, along with reports of recent events and incidents are submitted to the specific safety committees.

Supervisors must ensure that employees and students are aware of hazardous products, operations, or situations and that they understand how to avoid or limit risks. High levels of safety awareness and positive safety attitudes developed by supervisors will lead to good judgments among staff and students when specific rules are not established. Employees are also responsible for safe practices, for following safety programs, and for looking out for each other. Supervisors are expected and encouraged to request information and assistance from the Environmental Health & Safety (EH&S) Department when necessary. Policies developed by the numerous safety committees will be referenced, along with specific regulations which may exist, when supervisors define “good practice” in their areas of responsibility.

All faculty, staff and students must be vigilant to avoid unsafe acts which could jeopardize their own health and safety, or which could put others at risk. All persons are expected to learn and follow approved standards and procedures which apply to their activities and to check with their supervisors when they have any doubts concerning potential hazards or individual obligations to protect the environment. Supervisors are responsible for ensuring compliance with safety policies. Persons willfully disregarding safety policies will be disciplined via the applicable progressive discipline procedures.

BCN Risk Management

This office is responsible to manage and oversee the workers compensation and risk management programs for the University of Nevada, Reno in accordance the Nevada System of Higher Education Procedures and Guidelines Manual, Chapter 10 – Risk Management and Safety – Section 2. This includes investigating, adjusting, and settling workers’ compensation claims, monitoring the implementation of corrective action plans to prevent the recurrence of accidents leading to injuries and providing statistical reports of injury trends and costs.

Safety and Health Program

Policy

It is a goal of the University of Nevada, Reno, to ensure safe and healthy learning, research, work, entertainment, health care, and student living environments for faculty, staff, students and visitors. In support of this policy, the University gives high administrative priority, applies appropriate financial support, and provides professional expertise in the ongoing effort to eliminate or reduce facility and operational hazards that could threaten the health and safety of persons, property, or the environment. Along with the highest quality of teaching, research and community service, safety of individuals and protection of the environment are core values of this institution.

Safety Inspections (NAC 618.540 1(b))

EH&S Inspections of External Campus Infrastructure

EH&S performs exterior campus infrastructure inspections annually. These areas include building exteriors, sidewalks/walkways, parking lots and other common areas. The inspections focus on access to buildings, access to emergency infrastructure, and potentially unsafe conditions resulting from vandalism, landscaping issues, surface irregularities, etc. Unsatisfactory conditions are immediately reported to necessary personnel either through the work order system or direct communication.

EH&S Inspections of Laboratories

The laboratory safety section in the EH&S Department conducts environmental health and safety assessments of laboratories. Virtually all laboratories use hazardous chemicals and many also use biological agents. Safety assessments consider all hazards, to include chemicals and biological agents, and the corresponding waste streams, physical hazards, personal protective equipment, and facility safety equipment. Laboratory assessments are documented to indicate identified deficiencies, the basis of each deficiency, requested corrective actions, and corrective action due dates. Laboratory assessment reports are sent to the responsible laboratory supervisor. Deficiencies are tracked until corrected. If deficiencies are not corrected by the assigned due date, the laboratory supervisor is notified, with increasing levels of administration also notified with each subsequent reminder. Laboratory radiation hazards are assessed separately by the radiation safety section in the EH&S Department to ensure accountability and security of radioactive materials, safe handling to minimize personnel exposure, and proper accumulation and disposal of radioactive waste.

EH&S Inspections of Other Work Areas

In addition to laboratories, the EH&S Department inspects and works with all areas of campus to assist in identifying, analyzing, and controlling new and existing hazardous conditions.

Facilities Work Areas

Safety in areas under the control of the Facilities Services Department, in particular the trade shops, is overseen by a departmental Safety Manager. The Safety Manager is responsible for identifying, analyzing, and controlling new and existing hazardous conditions. This group works closely with EH&S to accomplish these tasks.

Safety Training (NAC 618.540 1(c))

EH&S staff provide training courses on many safety topics on a regular basis. While many of these training courses are provided as in-person workshops, EH&S has also developed online training for many topics via its Learning Management System (LMS). In addition to online courses, the LMS also houses all training records and materials for a minimum of three years, allowing individuals to access their own training history (NAC 618.542(1c)).

A training matrix has been produced for supervisors and employees to identify necessary training to be completed upon initial assignment as well as the requisite refresher intervals. Laboratory personnel must complete safety training consisting of a series of online courses, followed by a hands-on session in the EH&S Safety Training for Academic Research training laboratory (STAR Lab). EH&S also employs several individuals trained and certified through the American Heart Association to provide training in cardiopulmonary resuscitation (CPR) and the use of an automated external defibrillator (AED). (NRS 618.384) All EH&S training courses are offered at no cost to members of the University community.

The general safety topics covered by EH&S training courses satisfy many local, state, and federal requirements. However, it is the responsibility of each department and each supervisor to identify training needs above and beyond the scope of these courses, and to ensure that employees receive the appropriate training before performing their work duties. Supplemental training provided by qualified departmental personnel, outside contractors, or a customized training program developed in concert with EH&S can all satisfy these needs.

A calendar of scheduled training events and available online courses can be found on the EH&S website. Workshops may also be scheduled by contacting the EH&S Training Manager or appropriate instructor. A list of available topics, training materials, and other resources can be found on the EH&S Training page.

Accident Investigations (NAC 618.540 1(d))

Procedures for responding to workplace accidents vary from simple administration of first aid to activation of emergency response procedures. Accident investigations are conducted for observed and reported accidents and specifically for each Notice of Injury (C 1) Report and each Claim for Compensation (C 4) Report that is received. Near-miss and vehicle accidents causing only property damage are also investigated. Corrective actions are identified and follow up to ensure that the corrective actions have occurred is initiated periodically.

In conjunction with NSHE BCN Workers’ Compensation Office, accident investigation procedures have been developed and training for supervisors is provided. A variety of forms exist to facilitate record keeping associated with investigations. A summary of incidents and injury claims is provided by the Workers’ Compensation Office to the University Safety Committee (i.e., Nevada Safety Committee) and EH&S for quarterly review. Laboratory incidents are also investigated and reports provided by laboratory personnel that include corrective actions are reviewed by the appropriate safety committee.

Safety Rules (NAC 618.540 1(e))

University policies related to workplace safety are posted in the University Administrative Manual and on the EH&S Department web site. Written safety plans are also posted on the EH&S web site. Procedures and guidance related to storage, use, and disposal of hazardous chemicals in laboratories are contained in the Chemical Hygiene Plan. Procedures and guidance on the storage, use, decontamination, and disposal of biological agents are contained in the Biosafety Manual, Bloodborne Pathogens Exposure Control Plan, and Biohazardous Waste Operations Plan. Procedures and guidance on other safety topics are also posted on the EH&S Department web site, to include the Ventilation Plan, Respiratory Protection Plan, as well as more general safety topics such as electrical safety. Supervisors are responsible to enforce adherence to safety policies and procedures and employees who fail to comply are subject to progressive disciplinary actions, according to University and State policy.

Safety Committee (NAC 618.540 (2))

The mission of the Nevada Safety Committee is to support the University of Nevada, Reno’s overall mission of excellence in teaching and learning, research and discovery, and outreach and public service by providing leadership and services to ensure a safe and healthy environment for all members of the University community. The Nevada Safety Committee promotes a safe and healthy campus environment by reviewing injury and illness statistics for improvement to safety programs, formulates safety procedures and policies where warranted, and assists EH&S and BCN Risk Management in communicating the importance of safety.

Members are selected for their expertise in certain safety areas and for their responsibility over areas that are of concern. The membership includes individuals who have been selected to represent employees. The committee meets at least twice per year and maintains written records of the safety and health issues which were discussed and the attendance of those persons who participated in the meeting. (NAC 618.542)

This deliberative body advises the Executive Vice President and Provost, the Vice President of Research & Innovation, the BCN Risk Manager, and the EH&S Director of safety issues. The committee also administratively coordinates the various safety-related efforts of the university, and guides and supports BCN Risk Management and EH&S. Through proactive assessment of potential health and safety issues, by responding to concerns raised by members of the campus community, and with respect to applicable regulatory requirements, this committee develops and recommends to the President and the Executive Vice President & Provost, policies and actions that will reduce sources and levels of risk. The committee maintains a procedures document that describes the manner in which members are selected, the purpose and duties of the committee, and the frequency of committee meetings per NAC 618.540(2).

In addition, the Laboratory Safety Committee, Institutional Biosafety Committee, and Radiation Safety Committee are faculty and staff-driven committees that are administered by EH&S. Safety issues, policies, and procedures are authored by these committees on these topics. The Institutional Biosafety Committee and the Radiation Safety Committee also evaluate material use protocols, as required by regulation and University policy. Safety committee minutes are made available to all employees upon request.

Training on Recognition of Hazards

Identification and Control of Hazards

Self-assessments performed within work and administrative units will be performed by supervisors and other employees following checklists appropriate for identifying sources of risk and needed safety improvements. Written assessment results will be used to guide corrective actions and to provide information to workers. Self-assessment checklists for laboratories are located on the EH&S website for assistance in self-identification of needed safety improvements.

On a periodic basis, depending on risk and other factors, EH&S personnel perform work site inspections which may be more extensive than self-assessments. Specific compliance items will be noted along with recognition of possible opportunities to improve work safety practices. Area employees may be interviewed to determine that training requirements are met, and that employees comprehend recommended safety behaviors and methods. On these occasions, EH&S inspectors will solicit employee recommendations for safety improvements and invite reporting of employee safety concerns.

COVID-19 Prevention Program

Nevada OSHA considers COVID-19 a recognized hazard. Employers are required to protect employees from all recognized hazards, including COVID-19. The University of Nevada, Reno has developed guidance to protect employees from the virus. Human Resources maintains the most current general COVID-19 guidance for employees and departments on their web page.

Review the most current COVID-19 guidance and recordkeeping requirements from Nevada OSHA for more information.