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Exposure Control Plan

1. Purpose

The University’s Exposure Control Plan (the “Plan”) is designed to promote the safety of all faculty, staff, and students by establishing basic procedures and recommendations to mitigate common hazards in the living, learning, and working environments.

2. Scope

This Plan applies to all faculty, staff, and students and meets the requirements set forth by federal, state, and local regulations regarding occupational and environmental exposures. The Plan also serves as the basis for department-specific policies and procedures.

3. General Industry Standards - OSHA 1910

4. Environmental Protection Agency (EPA) Recommendations

5. Roles and Responsibilities

  1. University
    The University is responsible for promoting the safety of all faculty, staff, and students by using best safety practices in its operations, on each of its campuses and in properties owned, leased, or controlled by the University. The University provides leadership support and necessary resources to meet federal, state, and local safety regulations.
  2. Departments
    Each department is responsible for establishing their own safety policies and procedures based on their specific roles and work functions. This may include but is not limited to: (i) providing safety training beyond what the University provides, (ii) developing their own emergency procedures, (iii) implementing safeguards beyond what the University provides, and (iv) purchasing safety equipment.
  3. Employees
    Each employee is obligated to:
    1. Comply with this Plan and their department’s exposure control procedures and policies;
    2. Participate in adequate trainings before using safety equipment;
    3. Maintain any safety equipment for which they are responsible;
    4. Inspect safety equipment prior to each use;
    5. Report any injury, illness, or property damage resulting from a workplace incident to their department chair or supervisor; and
    6. Follow all OSHA regulations, manufacturer recommendations, and direction from Environmental Health and Safety (EH&S).
  4. Environmental Health and Safety
    Environmental Health and Safety is responsible for overseeing the University’s compliance with all federal, state, and local regulations pertaining to occupational and environmental safety and for assisting departments with their safety policies, procedures, and personnel training.
  5. Contractors
    Contractors working on any Moravian campus or property are required to follow University and relevant departmental exposure control plans, department policies and procedures, and federal, state, and local regulations. All contractors are required to supply their own personal protective
    equipment.

The University reserves the right to: (i) request safety inspections for any or no reason, and (ii) suspend or terminate contracted work if necessary for the safety of our employees, students, and/or the contractors themselves.

6. Specific Workplace Hazards

  1. Asbestos
    Asbestos is a mineral fiber found naturally in the ground. Known for its strength and fire retardant properties, it was commonly used in building construction both as an insulator and building material. While older buildings have the potential to contain asbestos, if left undisturbed, asbestos does not pose a risk.
    When disturbed, the fibers become airborne and hazardous when an individual is exposed for a long period of time. To help prevent asbestos from being disrupted, keep all items at least eighteen (18) inches away from insulated pipes, including not hanging items from insulated pipes.

    The University has an Asbestos Management Plan in place and has taken steps to identify and actively mitigate known and exposed asbestos. Faculty, staff, and students who believe they have discovered disturbed asbestos should report the concern immediately to Facilities Management, Planning & Construction (FMPC) and EH&S. FMPC will determine the appropriate response and work with licensed asbestos consultants as necessary.
     
  2. Bloodborne Pathogens
    Bloodborne pathogens are pathogenic microorganisms residing in blood and other bodily fluids which can cause potentially disease or infection. Exposure to bloodborne pathogens may cause a wide range of potentially serious health issues.

    Each department is responsible for identifying potential bloodborne pathogen exposures in their living, learning, and/or working environments. Departments likely to encounter these hazards should use the University’s to develop and maintain a departmental exposure control plan. Plans should include clinical settings and laboratories.

    The University has a Bloodborne Pathogens Exposure Control Plan (BPECP) in place. Faculty, staff, or students who believe they may have been exposed to a potential bloodborne pathogen should report immediately to their department chair/supervisor and . Exposed individuals should seek medical evaluation at the closest emergency department or urgent care center. Individuals exposed in the course of their work should also contact Human Resources (see Section 14 below).
     
  3. Environmental Exposures
    Environmental exposures, such as mold and radon, are found naturally in different work, living, and learning environments. The University is committed to recognizing and minimizing these hazards through appropriate mitigation processes.
     
    1. Mold
      Mold naturally grows in all environments, however some buildings may see more growth due to conditions such as leaky roofs or pipes, or basements that either trap moisture or have high humidity as a result of poor ventilation.

      Once a mold colony becomes established, it will begin to layer creating “black” mold visible to the naked eye. These colonies may contain different species of mold, some of which could potentially cause respiratory health issues for individuals with heightened sensitivities. Individuals with allergies, asthma, and other respiratory conditions are encouraged to limit time in areas of significant mold growth and to wear personal protective equipment such as a disposable N95 respiratory mask to minimize exposure.

      Although OSHA does not regulate mold, the Environmental Protection Agency (EPA) recommends that with a significant level of mold be remediated in order to minimize effects on individuals with sensitivities. FMPC implements practices to minimize mold growth including, but not limited to increasing ventilation, installing dehumidifiers, and utilizing cleaning products designed to kill mold.
       
    2. Radon
      Radon is a naturally occurring radioactive gas which, when exposed over long periods of time, can cause lung cancer. Radon levels may fluctuate under certain conditions including geographical location, time of the year, and the makeup and structure of a building.

      Although OSHA does not regulate radon, the Environmental Protection Agency (EPA) recommends a (PEL) of less than 4 pCi/L for fixed residential buildings or housing areas within mixed use facilities.
       
  4. Residence Halls and Mixed-Use Buildings
    The University periodically performs short-term radon testing in buildings where the ground and first floors are consistently occupied for more than eight (8) hours a day to confirm radon levels are consistently lower than 4 pCi/L.

    If the recommended PEL is exceeded, a licensed third party professional will perform long-term testing to determine the best course of action to reduce radon levels to under 4 pCi/l. Radon levels can often be reduced by increasing ventilation by opening windows or installing passive radon ventilation systems.
     
  5. Low Occupancy and Minimum-Use Buildings
    Buildings where the ground and first floors are occupied for less than eight (8) hours a day or less than twenty (20) hours a week are at a lower risk of radon exposure. These buildings are still periodically monitored and action will be taken to reduce radon levels as needed.

    Should any building be repurposed as housing, the University will reevaluate and monitor the PEL.

Faculty, staff, or students who believe they have discovered either mold or radon should report the concern immediately to Facilities Management, Planning & Construction (FMPC) and EH&S. FMPC will assess accordingly. If a significant amount of mold or radon is discovered and cannot be easily mitigated, a licensed third party professional will perform testing and advise on the best course of action for remediation.

7. Laboratory Safety

The University’s Chemical Hygiene Plan (CHP) complies with OSHA’s laboratory standards and the EPA’s (RCRA). This plan outlines prevention and response to risks generally associated with exposure to hazards in a laboratory setting.
Faculty, staff, and students are expected to follow laboratory safety practices and are not permitted to work with chemicals, biological substances, or radioactive materials that exceed PELs.
Recommended safety practices include, but are not limited to, using chemical fume hoods, biosafety cabinets, and personal protective equipment.

Faculty, staff, or students involved in a laboratory safety incident or who have been potentially exposed to a hazard should report immediately to their department chair/supervisor and EH&S.

Exposed individuals experiencing acute signs and symptoms should seek medical evaluation at the closest emergency department or urgent care center. Individuals exposed in the course of their work should also contact Human Resources (see Section 14 below).

8. Occupational Noise Conservation Program

The University’s Occupational Noise Conservation Program is designed to minimize noise exposure in the workplace and learning environment. Faculty, staff, or students who work in an area which exceeds OSHA’s PEL of 85 decibels (dBA) or higher over an eight (8) hour period per day are subject to long-term hearing loss or impairment. These individuals are required to take part in the Occupational Noise Conservation Program.

Employees may be required by the University to take a hearing test as part of their onboarding process and periodically thereafter to determine if they have hearing loss due to high noise levels in the workplace.

EH&S will monitor these workplaces and learning environments by periodically testing the noise levels to determine if they are within acceptable PELs and, as needed, make recommendations on how to further reduce noise levels.

9. Radiation Safety Plan

At the time of implementing this Plan, ˿Ƶ does not have a license to purchase and/or conduct research with radioactive materials and substances beyond commercially available products approved for teaching. Should the University become licensed to work with radioactive material and substances in the future, there is an approved Radiation Safety Plan.

10. Respiratory Protection Program

The University’s Respiratory Protection Program helps to protect faculty, staff, and students from exposure to respiratory hazards in their living, learning, and working environments. This program complies with federal, state, and local regulations for training, fit testing, and using respiratory protection.

Departments should take all precautions necessary to eliminate respiratory hazards before issuing a respirator and/or Powered Air Purifying Respirator (PAPR) to an authorized individual. Individuals who require a respirator must participate in the Respiratory Protection Program.

11. General Chemical Exposure Investigation

Despite training and prevention efforts, accidents involving chemicals do occasionally occur. In the event of an exposure, EH&S will work with the department chair, supervisor, or impacted employee to collect the following information:

  1. Suspected chemical(s);
  2. Other chemicals in use by individual(s);
  3. Other chemicals used and/or stored in same area;
  4. Symptoms experienced by individuals(s);
  5. Symptoms on Safety Data Sheets (SDS) or otherwise known for the above chemicals;
  6. Which control measures were being (properly) used (hoods, clothing, etc);
  7. Whether any monitoring was being done that could have measured actual levels;
  8. How the symptoms being experienced compare to the information on the SDS; and
  9. The adequacy of present control measures and safety procedures.

12. General Environmental Monitoring

If faculty, staff, or students believe that their workplace or learning environment exposure level may exceed OSHA and/or NOISH’s recommended PELs, they must contact EH&S to initiate environmental monitoring. This includes but is not limited to:

  1. Initial Monitoring - performed if there is reason to believe an individual’s exposure to any substance regulated by a standard could routinely exceed the Action Level (usually one half the PEL), or in the absence of an Action Level, the PEL.
  2. Periodic Monitoring - performed if the initial monitoring discloses an exposure over the Action Level, or, in the absence of an Action Level, the PEL, and the exposure monitoring provisions of the relevant standard must be adhered to.
    Note: Monitoring may be terminated in accordance with the relevant standard.

EH&S will generally notify the affected individuals of the monitoring results within fifteen (15) business days after receipt. The results will be either individually distributed in writing or posted in a location accessible to all affected individuals.

13. Medical Surveillance and Consultation

Certain chemical or environmental substances and concentrations may require medical surveillance and consultation due to their hazardous properties or negative effects on the human body. Medical surveillance may also be required in the event of an occupational exposure.

  1. a. Affected individuals are to seek medical evaluation under the following circumstances:
    1. When an individual develops signs or symptoms associated with an occupational exposure;
    2. Where environmental monitoring reveals an exposure level is routinely above OSHA permissible
      exposure limits or NIOSH recommendations of a regulated substance for which there are
      exposure monitoring and medical surveillance requirements; and
    3. When a chemical release event occurs in the workplace resulting in the likelihood of a hazardous
      exposure.

14. Reporting an Occupational Exposure

  1. Acute Exposure
    If there is reason to believe that an individual has been acutely exposed to hazardous materials or substances such as chemicals, the exposure should be reported immediately to EH&S and the individuals’ department chair or supervisor. Any individual working with hazardous materials or substances will be directed to the closest emergency department (see the end of this Section 14 for a list of Emergency Department and Urgent Care locations) for medical evaluation and/or treatment.

    Moravian employees (full-time, part-time or student employees) must contact Human Resources to report a work-related exposure. Information about workers compensation may be found here.

    Employees are responsible for any follow-up examinations deemed necessary by the workers compensation case worker and their healthcare care provider.
    Students who are not employed by ˿Ƶ or who are not working at the time of the exposure must utilize their primary health insurance for coverage
     
  2. Chronic Exposure
    If a health care provider determines that an active or former employee, inclusive of student employees, has developed a medical condition as a direct result of a chronic occupational exposure in the workplace, the active or former employee is responsible for submitting a worker’s compensation claim to Human Resources with the required documentation.

    Note: To avoid cross-contamination, additional exposure, and for their own safety, all other individuals not affected by the exposure are expected to follow their department protocols and to avoid the area(s) and affected individual(s).

Emergency Department and Urgent Care Locations

15. Recordkeeping

Each department, as well as EH&S, are required to keep records of all individuals who report a potential workplace exposure. Records may include, but are not limited to, employee medical records, environmental monitoring, and other related documentation.

  1. Medical Records
    Individuals who report to an emergency department or an urgent care center for a potential exposure will be medically evaluated and potentially begin the treatment process. Upon discharge, the individual will receive paperwork from the facility documenting their potential workplace exposure.
  2. Faculty and Staff
    As part of this Plan, employees who report an exposure must provide Human Resources with any necessary medical records and all related documentation as part of their Worker’s Compensation claim.
  3. Student Employees
    Students who are employed by the University will report their potential exposure to Human Resources, along with a copy of their medical records and related documents.
  4. Students
    Students who are not working for the University at the time of exposure will follow the direction of their personal medical provider overseeing their exposure treatment. These records may need to be submitted to the University to engage in any grievance process, and will then be protected under FERPA.
  5. Environmental Health and Safety
    EH&S will conduct a thorough investigation into any reported exposure incidents, including a request to access medical records for workplace incidents.
  6. Human Resources
    Medical records maintained by Human Resources pursuant to this Plan are private and will be shared only on a need to know basis as permitted by FERPA and/or applicable employment law. Such records will be maintained for thirty (30) years after the employee’s last day of employment.

If requested, even after employment ends, an individual has the right to access their records at any time.

16. Access to Employee Exposure and Medical Records

University employees, active and former, and inclusive of student employees, may request their employee exposure and medical records at any time. The University will keep a record of the following:

  1. Any recommendation(s) for further medical follow-up;
  2. Results of the medical examination and any associated tests;
  3. Any medical condition that may be revealed in the course of the examination, which may place the employee at increased risk as a result of exposure found in the workplace; and
  4. A statement that the employee has been informed by the physician of the results of the consultation or medical examination and any medical condition that may require further examination and/or treatment.

All documentation will be maintained by EH&S as part of this Plan and in compliance with the University’s Records Management and Retention Policy.

17. Training

Faculty, staff, and students working in departments or who are enrolled in programs which have a significant risk of an exposure are required to complete the necessary safety training before beginning work or clinicals. Departments with a specific workplace exposure control plan must address required safety training in their plan.

For more information about safety training contact Environmental Health and Safety at ehs@moravian.edu.