Are You Compliant? - Electronic Resource Center

Are You Compliant? An Overview of
Facility Management Regulations
Keith McLean
Rich Township School District 227
Rob Rottersman, MS, CIH
• 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
• 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
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
Which Code???
• Building Officials and Code Administrators
• •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
• Don’t look the other way when you see a
violation..Door stops, clutter, Blocked egress
• 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
• ISBE Website
Great deal of history
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
• Yellow jacket stings are painful and can be lifethreatening 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
• 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
• 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
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
More information
• SPCA = Safer Pest Control Project
For IPM Training, Resources, Manuals and a list of
area IPM professionals
• Illinois Dept. of Public Health
• For information on new legislation and
manuals to help start an IPM program
Topics for Today
• Hazard Communication
• Personal Protective Equipment
• Lockout/Tagout
• Lifts & fall protection
A brief overview of a few select OSHA programs. Presentation should not be
construed as a comprehensive session covering all OSHA regulations.
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 information
2. MSDS (SDS in future)
3. Employee Information and Training
4. List of Hazardous Chemicals
5. Hazards of “non-routine” tasks
6. Outside contractor/visitor communication
*Program must be available upon request
HazCom vs. 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
– Existing HazCom training protocols still apply
GHS Timeline
Completion Date
December 1, 2013
Train employees
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
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.
Transition Period
Comply with either 29 CFR 1910.1200
(this final standard), or the current
standard, or both.
All chemical manufacturers,
importers, distributors and
* This date coincides with the European Union implementation date for classification of mixtures.
GHS Pictograms and Hazard Classes
Self Reactives
Emits Flammable Gas
Organic Peroxides
Self Reactives
Organic Peroxides
Acute Toxicity (severe)
Gases Under Pressure
Respiratory Sensitizer
Reproductive Toxicity
Target Organ Toxicity
Aspiration Toxicity
Environmental Toxicity
Dermal Sensitizer
Acute toxicity (harmful)
Narcotic Effects
Respiratory Tract
Container Labels Must Contain:
• Identity of hazardous chemicals
• Appropriate hazard warnings
• Name & address of manufacturer
• Don’t forget secondary containers
• Comply with GHS by 2015
Manufacturers label should be sufficient
All employees who use or could come in contact
with “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
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
• Required when danger of injury from falling or
rolling objects, objects may pierce the sole or feet
are exposed to electrical hazard
Eye Protection
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
(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
LO/TO Requirements
Written 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 Protection
Multiple references in the standard
OSHA CFR1910.21-1910.27 Appendix D
• Guards and rails
– Floor openings, uneven floor surfaces, etc.
• Ladders & Stairs
– Wood vs. metal & fixed vs. permanent
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 & Manlifts
OSHA CFR1910.66
Specific 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?
Bob’s school district
Floor wax manufacturer
Banana importer
Grocery store
Newspaper that advertised banana sale
The Banana farmer
All of the above
Presenter Contact Information
Robert Rottersman, MS, CIH
Senior Manager
ENVIRON International Corporation
Office: (312)288-3857
e-mail: [email protected]

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