Contents
Cal Poly Pomona

Environmental Health & Safety Strategic Plan

Environmental Factors

The major environmental factors that will significantly impact the Strategic Plan for Environmental Health & Safety are the ever increasing legal requirements, individual department's resistance to comply with safety requirements, and the lack of financial and technical/human resources. These factors will adversely effect this department's ability to implement the elements of the plan. The effect of each of these factors is discussed below.

In regards to increasing legal requirements, the number of legal mandates for protecting employees and the environment have continued to increase exponentially for more than twenty years. There is no indication that this trend will change in the near future. This continually increase in legal requirements has forced the department to continually change or implement new compliance programs. A current list of required programs can be found in the enclosed table titled: "Summary of Required Programs".

Resistance to change is a very human trait. In an area where constant change has become the norm, it is a continuing challenge to motivate departments and individuals on campus to accept responsibility for safety and environmental issues as they relate to the job being performed. We are asking departments that are attempting to deal with their own resource shortages to take on yet another job, safety. It is hoped that with increased training will come the knowledge and awareness of how safety and the environment relate to the work place and in doing so, validate their importance. To directly address resource issues within departments, Environmental Health & Safety must become an advocate for obtaining the resources departments need for safety and environmental issues.

The implementation of the Environmental Health & Safety's Strategic Plan will require additional financial and technical resources not currently available to the department. The goals and objectives cannot realistically be met without additional funding. Without additional funding, Environmental Health & Safety will continue to handle situations as they arise on a priority basis and work towards the goals listed in the action plan that can be accomplished by the existing department staff.

Action Plan

The action plan for the Environmental Health & Safety Strategic Plan is based on the list of Regulatory Compliance Goals.

Measuring Success

The Regulatory Action Plan includes the development and implementation of inspection programs to monitor compliance. Success will be measured when these inspections indicate that the University is in compliance.

Summary of Required Programs & Areas


Regulatory Requirement Regulatory Agency Legal/regulatory Daily Fines Description/Comments
Accident Investigation Cal OSHA 8 CCR 3203 $15-25,000 Investigate employee accidents and take corrective action.
Air Pollution Episode Response South Coast Air Quality Management Rule 701 etc. $32,500 Notify departments regarding poor air quality and response.
Air Toxic Hot Spots Plan South Coast Air Quality Management 17 CCR $32,500 Develop biennial plan to determine toxic emissions.
Air Toxic Hot Spots Report South Coast Air Quality Management 17 CCR 93300 etc. $32,500 Develop biennial report documenting toxic emissions.
Asbestos Control Program Various 8 CCR 5208 $27,500 Requires written program, inspections, corrective actions.
Campus Safety Inspection Program Cal OSHA 8 CCR 3203 $15-25,000 Campuswide inspection of safety hazards in public areas.
Bloodborne Pathogens Standard Cal OSHA 8 CCR 5193 $15-25,000 Requires written program to safely manage infectious agents.
Compressed Gases Training Cal OSHA 8 CCR 4648 $15-25,000 Requires training on the handling of compressed gases.
Confined Space Training Cal OSHA 8 CCR 5156 etc. $15-25,000 Requires written program for safely entering manholes etc.
Electrical Lock-Out Program Cal OSHA 29 CFR 1910.147 $15-25,000 Requires written program to safely work with electricity etc
Elevated Work Training Cal OSHA 8 CCR 3620 etc. $15-25,000 Requires training of employees working on above the ground.
Fire Extinguisher Inventory Cal OSHA 8 CCR 6151 $15-25,000 Maintain and distribute campus inventory of Fire Extinguishers
Food Sanitation Program L.A. County Dept of Health H&S Div 22 $5,000 Review and approve/disapprove distribution of food.
Forklift Operators Training Cal OSHA 8 CCR 3649 $15-25,000 Requires training of employees using forklifts.
Hazard Communication Training Cal OSHA 8 CCR 5194 $15-25,000 Requires training on the use of each hazardous material.
Hazardous Materials Inventory Various 19 CCR 2729 $5,000 Maintain campus Hazardous Material Inventory.
Hazardous Material Bus Plan Inspections L.A. County Fire Department 19 CCR 2620 etc. $5,000 Requires inspections of areas using/storing hazardous materials.
Hazardous Material Business Plan Report L.A. County Fire Department 19 CCR 2731 $5,000 File Annual Report on Hazardous Material Spill Response/Prevention.
Hazardous Material Bus Plan Training L.A. County Fire Department 19 CCR 2732 $5,000 Requires training regarding the handling of hazardous materials.
Hazardous Material Spill Response Plan Cal OSHA4 8 CCR 5192 $15-25,000 Requires written plan to prevent/respond to hazardous Material spills.
Hazardous Material Spill Response Plan Toxic Substances Control 22 CCR 66262.34 $27,500 Requires written plan to prevent/respond to hazardous waste spills.
Hazardous Waste Disposal Toxic Substances Control 22 CCR Div. 4.5 $27,500 Maintain qualified contractor to dispose of Hazardous Waste.
Hazardous Waste Inspections Toxic Substances Control 22 CCR 66262.34 $27,500 Requires inspections of hazardous waste storage locations.
Hazardous Waste Management Training Toxic Substances Control 22 CCR 66262.34 $27,500 Requires training of employees handling hazardous waste.
Hazardous Waste Minimization Plan Toxic Substances Control H&S 25244.12 $27,500 Requires written plan to reduce hazardous waste generated.
Hazardous Waste Minimization Report Toxic Substances Control H&S 25244.12 $27,500 Requires written report characterizing waste generated.
Hazardous Waste Storage Toxic Substances Control 22 CCR Div. 4.5 $27,500 Requires waste to be shipped within fixed time periods.
Hearing Conservation Program Cal OSHA 8 CCR 5095 etc. $15-25,000 Requires exposure monitoring and protection of hearing.
Heavy Equipment Operator Program Cal OSHA 8 CCR 3649 etc. $15-25,000 Requires certified training of employees.
Injury/Illness Prevention Plan Cal OSHA 8 CCR 3202 $15-25,000 Requires the identification of hazards/elimination of injuries
Inventory of Radiation Sources Radiologic Health 17 CCR 30100 etc. $2,500 Complete quarterly physical inventory of radiation sources.
Laboratory Chemical Hygiene Plan Cal OSHA 8 CCR 5191 $15-25,000 Requires written program to protect laboratory workers.
Laboratory Safety Training Cal OSHA 8 CCR 5191 $15-25,000 Requires training of all laboratory workers.
Leak Tests of Radiation Sources Radiologic Health 17 CCR 30100 etc. $2,500 Perform semiannual leak tests of radiation sources.
Material Safety Data Sheet Distribution Cal OSHA 8 CCR 5194 $15-25,000 Provide requested copies of sheets to departments.
Medical Waste Disposal State Departmentof Health H&S 25015 etc. $2,500 Maintain qualified contractor to dispose of Infectious Waste.
Medical Examination Program Cal OSHA 8 CCR $15-25,000 Maintain qualified contractor to provide annual medical exams
Pesticide Safety Training Agriculture Commissioner 3 CCR 6724 $25,000 Requires training of employees using economic poisons.
Radiation Awareness Training Radiologic Health 17 CCR 30100 etc. $25,000 Requires training of maintenance employees regarding radiation.
Radiation Safety Committee Radiologic Health 17 CCR 30100 etc. $25,000 Insure that the committee meets on a quarterly basis.
Radiation Safety Inspections Radiologic Health 17 CCR 30100 etc. $25,000 Complete quarterly inspections of radiation laboratories.
Radioactive Waste Disposal Radiologic Health 10 CFR 61 $25,000 Maintain qualified contractor to dispose of Radioactive Waste.
Respirator Training Cal OSHA 8 CCR 5144 $15-25,000 Requires training of all employees utilizing respirators.
Response to Safety Complaints Cal OSHA 8 CCR 3203 $15-25,000 Respond to employee safety complaints.
Safety Training Development Various 8 CCR and 22 CCR $15-25,000 Development of required employee training programs.
Sight Conservation Program Cal OSHA 8 CCR 3380 etc. $15-25,000 Coordinate procurement of prescription safety glasses.
Trench Shoring Training Cal OSHA 8 CCR 1539 $15-25,000 Requires procedures protection of employees at/in excavations.
Underground Storage Tank Law L.A. County Public Works H&S 2610 etc. $5,000 Requires equip. & procedures to prevent/contain hazardous Material leaks.