Hazard Surveillance

Purpose

It shall be the mission of the University of Tennessee to proactively identify and correct noted safety, occupational health and environmental problems. As part of a comprehensive safety program the University will conduct routine hazard surveillance inspections. It is the responsibility of every employee to ensure their work area is free is hazards and unsafe conditions.

Scope and Applicability

Scope: This plan only applies to safety inspections (hazard surveillance) conducted by Environmental Health and Safety (EHS).  It is noted that other departments also conduct periodic safety inspections.   The scope of this procedure addresses facilities that fall under the purview of the University of Tennessee, Knoxville. Note that laboratory safety inspections may be handled slightly different and addressed in a separate policy (LS-2).

Applicability: This plan only applies to safety inspections (hazard surveillance) conducted by Environmental Health and Safety (EHS).  It is noted that other departments also conduct periodic safety inspections.  The safety inspections ensure compliance with federal, state and local safety requirements.  These requirements include, but are not limited to OSHA, TOSHA and the EPA.

Definitions and Abbreviations

EHS – Environmental Health and Safety

OSHA – Occupational Health and Safety Administration

TOSHA – Tennessee Occupational Health and Safety Administration

EPA – Environmental Protection Agency

NFPA – National Fire Prevention Association

Procedure

EHS shall:

1. Conduct safety inspections of all buildings on the UTK campus annually.
2. Coordinate and prioritize correction of hazards with Facilities Services or responsible department.
3. Train designated inspectors in procedures.
4. Conduct or coordinate follow-up inspections in ensure corrective actions have been accomplished.

Responsible Units shall:

1. Ensure that all citations issued under their responsibility are addressed within 45 days of receiving the inspection.
2. Assist EHS personnel during inspections.

Procedure Details

1. EHS will inspect all structures periodically. Exterior walking surfaces immediately adjacent to the building shall be inspected as part of the annual inspection. Off-site facilities shall be identified and inspected periodically.
2. Annual inspections are generally comprehensive in nature and seek to identify all hazards and deficiencies observed at the time of inspection. These reviews shall look at the facilities, equipment (fixed and portable) and practices (to the extent feasible).
3. Exterior walking surfaces that are remote from a building, such as a parking lot or sidewalk shall be inspected every three years. Those findings will be presented in a separate report.
4. Results are placed in tabular form in either an Excel or Word format and submitted to the appropriate individual or department via e-mail for correction.
5. All items should be corrected as soon as possible given available resources, logistics and the difficulty of repair. Department are expected to respond to the inspection report within 45 days of receipt indicating what actions have been, or will be, taken to address the finding. Note that a short response deadline applies to laboratory inspections.
6. Photographs may be taken as part of the inspection process and attached to the appropriate item on the report.
7. Equipment that is found to be dangerous (unsafe for use) shall be tagged out of service by EHS. The term “dangerous” can be subjective and involve a degree of professional judgment.
8. Focus inspections (limited in scope and nature) occur periodically in respect to requests or new information. Management of these inspections shall be similar to this procedure, but may also be handled on a case-by-case basis.
9. Beginning in 2015, EHS shall conduct analysis of inspection reports to determine trends and summarize findings.
10. Safety violations that have been noted on three or more consecutive reports shall be placed in red font. Items that are considered capital projects shall likewise be placed in red, italicized font. After these items have been posted three times, Capital projects will be added to a spreadsheet found on the EHS SharePoint web-site, where upon the findings will be reported to UT administration annually.

Recordkeeping

EHS shall keep a record of the inspection reports for at least 10 years. The records are currently maintained on the EHS department I drive, organized by year of inspection and building.

Regulatory Drivers and References

• OSHA 29CFR 1910.36(d)(2) and 137(k)(3), (n)
• NFPA-101, Life Safety Codes

Disclaimer

The information provided in this procedure is designed for educational use only and is not a substitute for specific training or experience.

The University of Tennessee Knoxville and the authors of this procedure assume no liability for any individual’s use of or reliance upon any material contained or referenced herein. The material contained in this procedure may not be the most current.

This material may be freely distributed for nonprofit educational use. However, if included in publications, written or electronic, attributions must be made to the author. Commercial use of this material is prohibited without express written permission from the author.