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Safety and Health Compliance Guidance

 Accidents 

 Hazardous Chemicals 

 Hazardous Chemical Spills 

 MCPS Approved Products List 

  OSHA Logs  

  Respiratory Protection - MCPS Employees 

 Automated External Defibrillator (AED) Information 

 Disposal of Mercury-Containing Fluorescent Lamps and Bulbs   

 Lead Paint/Caulk Protocol

 MOSH Inspections 

 Traffic Safety

 Inflatables (moon bounces, bounce houses)

 Severe Weather

 Aerial Work Platforms (Lifts, Scaffolds) 

 Drones, Model Aircraft (Unmanned Aircraft Systems) 

 Lifting and Transferring Students  


 

 Accidents 

 Accidents

All accidents involving students should be reported to the Employee and Retiree Service Center (ERSC) by completing MCPS Form 525-2, Student Accident Report. A managed care program for employees injured on the job is administered by CorVel Corporation. Supervisors are responsible for calling CorVel Corporation at 1-888-606-2562 to file the Employer's First Report of Injury. Information to assist supervisors when calling into CorVel Corporation to report their employees’ work-related injuries and illnesses is available at: https://www.montgomeryschoolsmd.org/departments/facilities/safety/employee.aspx#reportinjury.  

  • When an employee driving in an MCPS county vehicle is involved in an accident (no matter how minor), the employee must call 911 immediately. In addition, the employee must notify his/her supervisor and contact Risk Management, ERSC, at 301-517-8100. Also refer to MCPS Regulation DIE-RC, MCPS Staff Vehicles.
  •  Maryland Occupational Safety and Health (MOSH) requires employers to maintain records at each work site of occupational injuries and illnesses on the Occupational Safety and Health Administration (OSHA) Form 300: Log of Occupational Injuries/Illnesses. A preprinted form, OSHA Form 300A: Summary of Work-Related Injuries and Illnesses, summarizing recordable occupational injuries and illnesses at your school/facility during the last calendar year will be distributed by February 1 for posting through April 30. Additional information is available at: https://www.montgomeryschoolsmd.org/departments/facilities/safety/employee.aspx#oshalog  
 

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 Hazardous Chemicals 

 Hazardous Chemicals/Materials

A list of hazardous chemicals stored in the workplace must be maintained, and MCPS requires that all facilities maintain and update a Chemical Information List (CIL) listing all their hazardous chemical products.  Hard copy CILs must be maintained in the main administrative office and made available upon request to employees, SSP, and government regulators.

Electronic chemical inventories and downloadable safety data sheets (SDSs) for all MCPS facilities will be available online (data are available for limited schools currently). 

 

 Chemical Information Lists

 

 Additions to Chemical Information List (CIL)

All MCPS facilities are required to provide information for CIL additions to Systemwide Safety Programs. Additions should be reported using the Additions to Chemical Information List (CIL) form below.

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 Hazardous Chemical Spills 

 Response Procedures for a Hazardous Chemical Spill, Including Any Mercury Spill

*Incidental spills may be cleaned up by employees.

For large chemical spills or any spills that present a serious safety or health hazard: 
  • Evacuate, isolate the room or immediate area;
  • Call 911 if severe, or immediate help is needed;
  • Provide first aid, as needed;
  • Open windows and turn off HVAC, if safe to do so;
  • Contact SSP 240-740-7710; 301-370-2141 or Environmental Services/Indoor Air Quality, Division of Sustainability and Compliance, 240-740-2520 immediately;
  • If safe to do so, sequester potentially contaminated materials and occupants in nearby hall or room;
  • Implement 'Shelter In Place', if needed;
  • Do not attempt to clean the spill. 

*An incidental spill is a spill of a hazardous substance that does not pose a significant safety or health hazard to people in the immediate vicinity or to the employee cleaning it up, and does not have the potential to become an emergency within a short time frame.  Incidental spills are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to people in the immediate work area and those assigned to clean them up.  An incidental spill may be safely cleaned up by employees who have completed MCPS chemical safety training and who understand the hazards of the spilled chemicals and how to safely clean them up.

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 MCPS Approved Products List 

 

Only MCPS-approved chemical products (on current procurement bid list) may be used and/or stored at MCPS schools/facilities.  Any new products must be reviewed and approved by Systemwide Safety Programs before they may be brought to MCPS facilities.  For the safety/health of students and employees, the use of hazardous chemicals should be minimized as much as feasible.  Unnecessary and redundant chemicals should not be used.   

The MCPS Approved Products List, which lists all chemical products reviewed for use in MCPS facilities, is currently under review.  For information related to approval status for chemical products not currently available from the MCPS warehouse, please contact Systemwide Safety Programs at 240-740-7752 or Peter_Park@mcpsmd.org.  MCPS employees may submit chemical products for evaluation using the MCPS Chemical Product Evaluation Request Form

 

 

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  OSHA Logs 

Maryland Occupational Safety and Health (MOSH) requires employers to maintain records at each work site of occupational injuries and illnesses on the Occupational Safety and Health Administration (OSHA) Form 300: Log of Occupational Injuries/Illnesses.  A preprinted form, OSHA Form 300A: Summary of Work-Related Injuries and Illnesses, summarizing recordable occupational injuries and illnesses at your school/facility during the previous calendar year will be distributed by February 1, for posting through April 30.  See the Employee Injuries/Illnesses page for more information, including the procedures for reporting work-related staff injuries and illnesses.  

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Respiratory Protection 

Respirator Use - MCPS Employees

Certain MCPS employees are authorized to wear air-purifying respirators in the course of their work.  Air-purifying respirators protect the wearer by filtering out air contaminants from the wearer's breathing air.  Respirator use must be approved by Systemwide Safety Programs, Department of Systemwide Safety and Emergency Management.  Employees who are required to use respirators for protection against potentially hazardous concentrations of air contaminants must be enrolled in an OSHA/MOSH-compliant respiratory protection program, requiring:

  • Medical evaluation and clearance for respirator use by an MCPS-approved clinic.
  • Annual fit testing.
  • Annual respiratory protection training.   

Filtering facepiece respirators (also known as dust masks) may be used voluntarily by MCPS employees for work involving non-hazardous, nuisance concentrations of air contaminants.  Employees must read, complete, and submit an MCPS Voluntary Respirator Use Form to Systemwide Safety Programs, Department of Systemwide Safety and Emergency Management, prior to voluntarily using a filtering facepiece respirator.

 

What is the difference between a filtering facepiece respirator (dust mask) and a surgical mask? 

With few exceptions, surgical masks (also known as face masks) are not approved by the National Institute for Occupational Safety and Health (NIOSH) for protection against air contaminants.  Surgical masks are designed to protect wearers from large droplets and splashed or sprayed fluids, not airborne particulate matter, gases, or vapors.  They also reduce the spread of respiratory secretions from the wearer to others.  Surgical masks (face masks) do not seal tightly to the wearer's face and should not be used for respiratory protection.  Surgical masks purchased by MCPS staff usually have only one headstrap or two earloops.  Both filtering facepiece respirators and surgical masks are disposable and should be discarded after use.

Filtering facepiece respirators are designed to seal tightly to the wearer's face and filter out airborne particles.  Most filtering facepiece respirators are designed only to filter airborne particles; however, some models are impregnated with a material (such as activated carbon) that provides limited filtration of certain gases and vapors.  They are typically equipped with two headstraps and can have an exhalation valve, which reduces heat and moisture inside the respirator by allowing exhaled air to escape easier.  Because they are intended to seal tightly to the wearer's face, filtering facepiece respirators may not be worn with facial hair (including stubble) or long sideburns that obstruct the sealing edge.

There are seven classes of filtering facepiece respirators, which are designated based on oil resistance and particle filtration efficiency (measured using 0.3 micron test particles).  The designations are:

  • N95: Filters at least 95% of airborne test particles; not oil-resistant.
  • N99: Filters at least 99% of airborne test particles; not oil-resistant.
  • N100: Filters at least 99.97% of airborne test particles; not oil-resistant.
  • R95: Filters at least 95% of airborne test particles; somewhat resistant to oil.
  • P95: Filters at least 95% of airborne test particles; strongly resistant to oil.
  • P99: Filters at least 99% of airborne test particles; strongly resistant to oil.
  • P100: Filters at least 99.97% of airborne test particles; strongly resistant to oil. 
  
 

Filtering facepiece respirator 

Surgical mask

Another surgical mask

If you have any questions related to respirator use, please contact Mr. Peter Park, Team Leader, Systemwide Safety Programs, Department of Systemwide Safety and Emergency Management, at 240-740-7710 or via e-mail.

 

 

 

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Automated External Defibrillators (AED) Information 

Link to MCPS AED Program webpage.

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 Disposal of Mercury-Containing Fluorescent Lamps and Bulbs 

MCPS has established procedures for disposal of mercury-containing fluorescent lamps and bulbs, including the following:

  • Compact Fluorescent Lamp (CFL) bulbs
  • LCD projector bulbs
  • Promethean board bulbs
  • Metal halide lights
  • Mercury vapor light
  • Fluorescent lamps/tubes

Exhausted (burnt-out) fluorescent lamps and bulbs are regulated as hazardous waste due to their mercury content and may not be discarded in the regular trash.  The following regulations apply to mercury-containing lamps and bulbs—40 Code of Federal Regulations (CFR) 760-765; Code of Maryland Regulations (COMAR) 26.13; 49 CFR Sub-Chapter C, Hazardous Materials (transportation requirement), and Occupational Safety and Health Administration (OSHA) Regulation 29 CFR 1910.1200, Hazard Communication.

Starting October 1, 2018, CNR Lighting will be handling all lamp recycling requests.  Schools will no longer need to request recycling boxes online.  In order to have lamps picked up, schools must contact CNR at 410-242-4172 (Sara ext.107 or Adrienne ext.115) to schedule a pickup or drop off.  Schools must follow the guidelines below when preparing lamps for shipment:

  • Lamps should be separated by type (Linear, U-Tube, CFL, HID, Incandescent)
  • Place separated lamps in taped boxes  (Schools can reuse the boxes that lamps came in)
  • Place separated Linear or CFL's in boxes or drum (if drum is provided)
  • CNR cannot accept crushed lamps unless placed in a sealed 55 gallon drum (if drum is  provided)
  • Box ends must be secured with tape. Three inch PVC tape is recommended. CNR will not accept containers for shipment that have lamps exposed or protruding from packaging
  • Do not tape lamps together

Schools and facilities may contact their building service supervisor for assistance with any questions.   

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  Lead Paint/Caulk Protocol 

Prior to any renovations or disturbance of caulk or paint in buildings constructed prior to 1978, MCPS will evaluate the caulk for Polychlorinated Biphenyls (PCBs) and/or the paint for lead to be in compliance with U.S. Environmental Protection Agency (EPA) regulations. Questions regarding the lead paint/caulk protocol may be directed to Environmental Services/IAQ, Division of Sustainability and Compliance, Department of Facilities Management, at 240-740-2520.

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  MOSH Inspections 

If a Maryland Occupational Safety and Health (MOSH) compliance officer visits an MCPS school or facility, the school or facility must immediately notify Mr. Peter Park, Team Leader, Systemwide Safety Programs, Department of Facilities Management, at 301-370-2141, or via e-mail (Peter_Park@mcpsmd.org) so that he can be present during the MOSH inspection. Additionally, the school or facility should ask the compliance officer if he/she can wait until a Systemwide Safety Programs unit member arrives before conducting the opening conference.

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 Traffic Safety 

For concerns related to traffic safety issues at MCPS schools or facilities, including signage, traffic flow, drop-off areas, student/pedestrian safety, please contact the Department of Transportation, at 240-740-6200.

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 Inflatables 

Inflatables (moon bounces, bounce houses) are permitted at MCPS facilities upon approval by MCPS Systemwide Safety Programs and ERSC. Requirements related to inflatable approval and use are provided below.

At least one month prior to the event date:

  • A representative photo and description of the inflatable(s) must be submitted to Peter Park, Team Leader, Systemwide Safety Programs, for safety review and approval.
  • A current certificate of insurance from the vendor must be submitted to Maria Torralba, Risk Management Specialist, ERSC, for insurance review and approval.
 

Installation and operation requirements for approved inflatables include:

  • The inflatable vendor must install and operate the inflatable(s) in compliance with all applicable regulations and industry standards.
  • Inflatables may not be used indoors.
  • Inflatables may not be used in strong winds, rain, or other severe weather conditions.
  • Inflatables must be placed on flat surfaces free of objects that can puncture the inflatable.
  • Inflatables must be located clear of buildings, walls, overhead power lines, utility equipment, trees, streets and parking lots, and other potentially hazardous objects.
  • The vendor must properly secure all inflatables, taking into consideration weather factors such as wind.
  • Underground utilities must be marked prior to inflatables installation, as needed (such as when stakes are used).
  • If stakes are used to secure inflatables, protruding ends must be covered to prevent impalement.
  • If inflatables are placed on hard surfaces, such as asphalt or concrete, adequate padding must be provided on top of the hard surface.
  • Portable generators must be positioned well behind equipment and far enough away to keep exhaust gases and odors away from people and buildings.
  • Fuel for the generator must be stored in an appropriate safety can and secured properly during the event, and the generator must be turned off while refueling.
  • A portable fire extinguisher, with a vendor employee trained to operate it, must be available when a generator is present.
  • Appropriate and undamaged electrical cords must be used, and cords may not be run into a building.
  • Electrical cords may not be placed on sidewalks or walking areas where they can create tripping hazards.
  • The vendor must have ample staff to supervise student use of the inflatable and to monitor/service equipment.  
 

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 Severe Weather 

All MCPS schools and facilities must be prepared to respond rapidly to severe weather conditions, such as strong storms, hurricanes, tornados, and earthquakes. Severe weather can occur at any time of the year, sometimes unexpectedly. The peak activity period for tornadoes is March through early July, according to the National Weather Service; however, tornadoes and earthquakes can occur at any time of the year. The Atlantic hurricane season is from June through November, with the peak season from mid-August to late October.

MCPS conducts an "all call" test via the emergency phones on Tuesday mornings. A test message is broadcast on NOAA weather radios on Wednesday mornings between 10:00 a.m. and 12:00 noon, unless postponed by a weather alert. In the event of approaching severe weather, MCPS will make every effort to provide a systemwide notification, and the weather service will broadcast an emergency message via the NOAA weather radio. Occasionally, however, the rapid arrival of a storm does not provide the opportunity to give ample advance notice.

All schools and facilities should:

  • Verify their emergency phones and NOAA weather radios are operational and located in areas that are monitored constantly during the school day.
  • Designate severe weather safe zones and install signage.
  • Conduct and evaluate weather-related emergency drills to ensure preparedness. At least one severe weather drill and one drop, cover, and hold drill (simulating an earthquake) must be conducted each school year by all schools and facilities.
  • When information of severe weather is received, remain alert to worsening conditions by monitoring local television or radio stations in order to observe the path of severe weather and take appropriate protective measures.
  • Consider activating the on-site emergency team (OSET) to assist in implementing a Severe Weather Shelter status when severe weather is expected.
 

Information about safety measures for hurricanes, tornadoes, and earthquakes is provided below.

Questions may be directed to the Department of Systemwide Safety and Emergency Management at 240-740-3066.

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 Aerial Work Platforms (Lifts, Scaffolds) 

MCPS must comply with OSHA/MOSH regulations and American National Standards Institute (ANSI) standards related to aerial work platforms. Several schools have vertical mast lifts (such as Genie lifts) that are used to perform various building services functions, such as changing light bulbs in gymnasiums and auditoriums. Maintenance and materials management personnel use various types of aerial work platforms, including lifts that require specialized training and equipment (such as fall protection training and body harnesses/lanyards for boom and vehicle-mounted lifts). Requirements for aerial work platforms include:

  • Only employees with documented training are permitted to operate aerial work platforms.
  • All aerial work platforms must be inspected annually by an MCPS-approved vendor (United Rentals).
  • Records of employee training and inspections must be maintained by the school.
  • Schools may only acquire aerial work platforms from an MCPS-approved vendor (United Rentals).
  • Schools may only acquire electric vertical mast-type lifts (30 feet maximum height).
  • Schools may not acquire boom or articulated lifts, scissor lifts, vehicle-mounted lifts, trailer-mounted lifts, material lifts, scaffolds, or boom or jib extensions.
  • Schools may not acquire multi-person, drive-able, or self-propelled aerial work platforms.
  • Aerial work platforms must be equipped and operated with MOSH-compliant guardrails and toeboards at all times.
  • Any aerial work platform believed to be damaged or defective may not be used until inspected, repaired (if necessary), and approved for use by an MCPS-approved vendor.
  • Aerial work platforms must be inspected at the start of each shift during which they will be used and the inspections must be recorded using the Manlift Pre-Shift Inspection Checklist below.
  •  Manlift Pre-Shift Inspection Checklist  

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  Drones, Model Aircraft (UAS) 

Recreational operation of unmanned aircraft systems (UAS), including model aircraft and drones, is not permitted at MCPS facilities. Additionally, Maryland Public Secondary Schools Athletic Association (MPSSAA) rules prohibit UAS operation in airspace over host school grounds or facilities conducting MPSSAA events.

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 Lifting and Transferring Students 

Some students have physical conditions that affect their ability to move themselves and they need to be lifted into and out of adaptive equipment by school staff. Injuries to students and staff can occur if proper lifting procedures are not used. The presentation below provides information about safe and efficient methods for lifting and transferring students. The presentation may be used in conjunction with required hands-on training for employees required to lift or transfer students.