Chancellors Office Audit

As many of you know, the chancellors office completed an internal audit of Humboldt's health and safety programs in May of 2019. The objectives of the audit were to ascertain the effectiveness of operational and administrative controls related to health and safety (HS) and to ensure compliance with relevant federal and state regulations; Trustee policy; Office of the Chancellor (CO) directives; and campus procedures. As a result a report was published, outlining areas that must be addressed no later that 6 months after the release of the report or December 18th, 2019. A copy of the report can be found here: https://www2.calstate.edu/csu-system/transparency-accountability/audit-reports

Many of the deficiency corrections were completed by EH&S by the due date specified, you may have seen portal announcements directing you to updated resources.  However, there are a few areas where departments have been tasked with completing the required programs which are specific to their operations. EH&S has met with the respective campus administrators to notify them of the specific elements for which their staff or faculty will be responsible. 

All departments must complete their department specific IIPP's- an excerpt from the audit reads: 

We found that although the IIPP included the key elements required by California Code Regulations (CCR) Title 8 §3203, Injury and Illness Prevention Program, the following elements were not fully implemented:

• Department-specific IIPPs were not always developed or maintained.
• Lab-specific chemical hygiene plans(CHP) were not always developed and maintained.
• Departments did not always have a designated department safety liaison (DSL).

Additionally, under the campus IIPP, departments are required to ensure that a regular and systematic inspection process is scheduled and followed for all departmental areas, and that departments involved with higher hazardous operations perform inspections at least every semester. However, we reviewed ten locations, and we found that departments did not perform HS inspections for any of them. Further, we found that the campus did not have a process to track or monitor the completion of these inspections.

All departments will be required to provide EH&S with their IIPP by December 18th. Additionally, each department must identify and report to EH&S their DSL.

Further, if labs are being operated by a department, EH&S must receive a current CHP by 12/18/19 (each lab may use the campus CHP with lab specific standard operating procedures or safety programs as appendices). 

Per the audit report, a monitoring process was developed and EH&S will be conducting inspections of each department to review compliance of each required element and report out findings. EH&S will also be requiring annual certification of required elements by the appropriate campus administrators.

As required by the IIPP, all departments are required to provide appropriate training documentation on request by EH&S. Contact Human Resources for information on required training.

For more information on IIPP's please visit CalOSHA's website at: https://www.dir.ca.gov/dosh/etools/09-031/what.htm

OSHA's lab safety standard can be found here: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1450

CHP fact sheet https://www.osha.gov/OshDoc/data_General_Facts/hazardouschemicalsinlabs-factsheet.html

To access the campus IIPP documents go to: https://www.humboldt.edu/risk-safety/injury-illness-prevention-plan

To expedite the process you may also request the most current google doc version of the department IIPP template that may be shared with others in your area and jointly modified to reflect your departments process and procedure and then share it back with EH&S by the due date, by emailing Sabrina.Zink@humboldt.edu. 

EH&S is available for consulting on the development of required programs and program elements. Email Sabrina Zink to request a meeting. 

NOTE: campus areas that utilize hazardous materials will be required to have all materials in the inventory system by December 18th.  EH&S has been contacting affected areas to notify them of this requirement. EH&S plans to visit each area to assess what existing materials need to be inventoried and plan to get the initial upload of those materials into the system by the deadline. Once all required materials have been inventoried, each area will be provided a breakdown of what materials were inventoried, why they were chosen (and what was excluded) and how to maintain compliance with this system moving forward. Each area will be handed over maintenance of the system by Spring 2020. For more information about this system go to: https://www.humboldt.edu/risk-safety/chemical-inventory