Environmental Health & Safety

Lord Jeffery Inn Policy


January 2010
A. Responsibility
B. Inspections
C. Containers and Labels
D. Hazardous Material Pick-Up
E. Discharge(s), Leaks and Spills

 



Scope:

The Lord Jeffery Inn Policy has been prepared in accordance with local, state and federal regulatory requirements, including those, which are mandated by the Occupational Safety and Health Administration (OSHA) 29 CFR 1910 and the Environmental Protection Agency (EPA). This policy, which includes plans, procedures and standard operating guidelines, conforms to the programs already established by Amherst College.

Purpose:

The purpose of this policy is to establish uniform plans, policies and procedures for the Lord Jeffery Inn that follow those requirements already developed, implemented and maintained by the College, in cooperation with the Environmental Health and Safety Committee(s). In as much as the work being executed at the Lord Jeffery Inn could directly effect Amherst College (lessors of the property), the College reserves the right to oversee and when necessary aid in the decision making process as it pertains to the health and safety of our employees and the environment.

Applicability:

This overall policy for the Lord Jeffery Inn shall incorporate all other applicable plans, policies and standard operating procedures that may be developed, implemented and maintained by personnel at the Lord Jeffery Inn, under the direction of the Senior Management Staff. The plans, policies and procedures addressed here-in shall be enforced by the Senior Management Staff and Supervisors of the Lord Jeffery Inn and will be applicable to all employees and responsible representatives of the Lord Jeffery Inn, the College and when applicable, users of the above referenced inn.

A. Responsibility

1. The Lord Jeffery Inn Senior Management Staff is ultimately responsible for the overall operations of the inn, which includes the both interior and exterior dining, the building, maintenance, the kitchen, shops and the inn itself.

2. Amherst College, being the lessor of the property shall from time to time inspect the location known as the Lord Jeffery Inn for local, state and federal regulatory requirements. The purpose of the inspection is to identify potentially hazardous conditions that may adversely affect the health and safety of the employees, or may pose a threat to the environment. Amherst College Environmental Health and Safety Department will perform the inspection in cooperation with representatives of the Lord Jeffery Inn.

3. Unless otherwise stipulated, the Environmental Health & Safety representative will first meet with the Lord Jeffery Senior Maintenance Supervisor. The inspection will take place at least twice per year:
1. December, before Christmas
2. July, Before the 4th of July
a. The inspection will focus on the handling and storage of chemicals, chemical waste disposal, storage and treatment, labeling, Material Safety Data Sheets, Heating Oil Tank Inspection, Universal Waste (lights and ballast's) cooking oil disposal, storage and building and fire code compliance.
b. All deficiencies identified during the inspection will immediately be brought to the attention of the Maintenance Supervisor. A copy of the inspection will be sent to that person with an additional copy to the Senior Management Staff.

4. Serious problems identified during the inspection will be brought the attention of the Senior Management , the Amherst College Environmental Compliance Committee and the Director of Environmental Compliance at Amherst College.

B. Inspections

1. The Lord Jeffery Inn shall conduct weekly inspections of the following areas and must maintain a log of said assessment that have to be made available to an inspector upon request. A person so designated by the Maintenance Supervisor can perform the inspections, but the ultimate responsibility for that inspection rests with the individual holding the title of Manager. The inspection, which includes written proof that it was performed shall include a visual observation and documentation of the;
a. exterior fuel oil tanks
b. storage and disposal of waste cooking oil
c. waste oil drum (55 gallon)
d. waste or unwanted chemicals that are no longer being used
e. universal waste, including fluorescent light bulbs and batteries

2. Environmental Health and Safety will, prior to their arrival, contact the Maintenance Supervisor about the upcoming inspections, at least (1) or (2) days in advance. These inspections, unlike those conducted by the state and federal governments will not be "surprise" inspections. In some cases they will be performed in conjunction with the local fire department, in order to limit the number of times different inspections must be performed. The Environmental Health and Safety Department will explain all deficiencies to the Maintenance Supervisor or other designated person during or at the end of the inspection. A written assessment will follow.

- Deficiencies should be taken care of on a priority basis. Those issues that could result in serious illness, injury or significant fine should be mitigated as soon as they are identified.

- Issues identified by the Maintenance Supervisor or his/her staff as potentially hazardous or financially risky shall also be taken care of as soon as possible. Do not wait for the office of Environmental Health and Safety to identify these issues, because failure to act immediately could result in a "willful violation" at a potential cost of greater than $50,000.

*Any and all questions or concerns can be immediately forwarded to the Environmental Health and Safety Manager or the Chemical Hygiene Officer for Amherst College.

3. The Maintenance Supervisor, Human Resource Director or the Senior Management Designee must keep a copy of each and every inspection log. Failure to maintain an inspection log could result in a fine for the Lord Jeffery and Amherst College.
The inspection log must have…
a. date
b. location (building, area and/or room)
c. concerns identified
d. how these issues were addressed, while on site
e. the name of the person performing the inspection.
All caps/covers must be in place (except when filling or discharging)
All containers shall have the proper labels and associated hazards identified

C. Containers and Labels

1. The Maintenance Supervisor is responsible for proper container labeling and hazard identification. Bottles, cans, containers, drums and other packages used to hold chemicals, cleaning agents and oil, both product and waste must be labeled in accordance with Massachusetts Right-To-Know Laws and the federal Environmental Protection Agency regulations as they pertain to hazardous wastes.
a. All containers must have the full name identified on the outside of the container, including water
- abbreviations such as H2O can not be utilized
b. All containers, unless they have the original labels in place must also have one of the following hazards identified, depending on the material;
1. corrosive
2. ignitable
3. reactive
4. toxic
c. All hazardous waste must be set in or on some type of secondary containment that is designed to restrict a discharge, leak or spill from said containers. The area(s) identified as the secondary containment area must be labeled as either;
1. Main Accumulation Area
2. Satellite Accumulation Area
In most cases, the area identified will be referred to as the latter, the Satellite Accumulation Area. It is at these locations that the Maintenance Supervisor must perform a thorough inspection.
- Are the caps / covers secured to the containers?
- Are the containers all properly labeled with full name and hazard?
- Is there only the one container of that specific type of waste?
- Is there any evidence of damage or leakage inside the secondary containment?

d. Are all bottles and containers of hazardous waste facing forward, with the labels easily identified?

e. Are the bottles and containers in good condition, free of damage, dust, leaks and spills?
f. Could the containers be considered " inherently waste like" ?
*bottles, cans and other containers that could be mistaken by the Department of Environmental Protection (State DEP) or by the Environmental Protection Agency (Federal EPA) as not being used, dust covered or rusty could cost the college or the golf course a monetary fine or notice of non-compliance.

D. Hazardous Material Pick-Up

1. The lessee's of the Lord Jeffery Inn are responsible for the proper collection, package and disposal of hazardous and universal waste.

2. The College has negotiated a contract with a licensed, bonded and insured Hazardous and Universal Waste Contractor. This particular contractor will handle all wastes generated on this campus.
*The above referenced contractor will pick-up waste (chemical, photographic, oil and paints) every 6 weeks to 2 months.
- It is the responsibility of the Lord Jeffery Inn to contact the Environmental Health and Safety Office or the Chemical Hygiene Officer to schedule a waste pickup.

3. In addition to the hazardous waste disposal, the contractor must also supply required training to all applicable employees and students who will be working with hazardous and universal wastes.
*The training will be coordinated through the Environmental Health & Safety Office or the Chemical Hygiene Officer and will be provided to any and all personnel that require such training.

E. Discharge(s), Leaks and Spills

1. All incidents involving hazardous materials and wastes must be reported to the Office of Environmental Health & Safety.
*Depending on the material released into the environment (air, sewer, soil, storm drain and water) the material may have to be reported as a "reportable quantity" to the state Department of Environmental Protection.
2. Amherst College has adopted a "Spill Control Plan".
*If the spill is incidental, a report can be directed to the Chemical Hygiene Officer or Environmental Health and Safety through the Amherst College Campus Police.
*If the spill is large scale, and there is a risk of fire or poisoning, contact the Amherst College Campus Police at 542-2111.

3. Any discharge, leak, rupture or spill that occurs inside or outside a building or area that threatens to enter a drain (sanitary sewer or storm) shall be immediately stopped from inflowing into it.
*Use a cover, sand or other material to prevent discharge into the drain and report the incident to Environmental Health and Safety via the Amherst College Campus Police.
*Sand should not be placed on top of the spill, but used to divert it to keep the spilled material away from the undesirable locations that may adversely affect the environment.