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California State Auditor Logo COMMITMENT • INTEGRITY • LEADERSHIP

California State University
It Has Not Provided Adequate Oversight of the Safety of Employees and Students Who Work With Hazardous Materials

Report Number: 2017-119

Summary

HIGHLIGHTS

Our review of the health and safety compliance of the CSU Chancellor’s Office and four campuses highlighted the following:


Results in Brief

The California State University (CSU) Chancellor’s Office (Chancellor’s Office) has not provided effective leadership to ensure that its campuses address health and safety concerns related to the presence of hazardous materials. CSU is subject to a number of state laws and regulations to ensure the safety of CSU employees who encounter hazardous materials in laboratory or other work settings. Nonetheless, the Chancellor’s Office has not actively ensured that campuses have adequate policies and processes to protect the health and safety of those who work with or near hazardous materials. For example, the Chancellor’s Office has not ensured that campuses consistently submit required annual reports regarding their health and safety programs, even though the reports are critical to its oversight efforts. Further, it has not ensured that when campuses submit these reports, they include information that would enable the Chancellor’s Office to identify risks to employees and students. CSU’s Office of Audit and Advisory Services (University Auditor) has repeatedly recommended that the Chancellor’s Office increase its oversight of the campuses’ health and safety programs, particularly as it relates to employee and student health and safety training and inspections of laboratory safety equipment and workplace hazards the campuses conduct. Despite the fact that many of these deficiencies have remained unresolved for nearly two decades, the Chancellor’s Office has not taken the steps necessary to hold the campuses accountable.

Further, neither the Chancellor’s Office nor the four campuses we reviewed—California State University Channel Islands (Channel Islands); California State University, Sacramento (Sacramento); San Diego State University (San Diego); and Sonoma State University (Sonoma)—ensured that they had critical committees to discuss safety concerns during our review period from July 1, 2014, through June 30, 2017. Specifically, despite the requirements in its agreement with one of its unions, the Chancellor’s Office does not currently have a systemwide joint safety committee that enables management and staff to work together to recommend safety regulations, guidelines, training programs, and necessary corrective actions related to maintaining safe working conditions. Additionally, the four campuses do not have similar campuswide committees.

State regulations require that any campus engaged in the laboratory use of hazardous chemicals have a chemical hygiene plan (chemical plan), which specifies the operating procedures that laboratory workers must follow when using hazardous chemicals. Although Sacramento’s and Sonoma’s chemical plans require their campuses to have committees to assist in evaluating the effectiveness of those chemical plans, neither campus has ensured that its committee meets regularly and discusses chemical usage policies and usage. Further, state regulations require that the campuses evaluate their plans annually for effectiveness and update them as necessary. Although all four campuses have established chemical plans, none could provide evidence that they had reviewed their chemical plans annually to determine their effectiveness. Considering that Sonoma has not updated its plan for six years and Sacramento has not substantially updated its chemical plan for 15 years, the lack of documented reviews of their plans’ effectiveness is especially troubling

The campuses have also not ensured that all employees receive required safety trainings. State regulations require that employers provide certain trainings to employees to ensure their safety and well‑being when working with hazardous materials. However, each of the four campuses failed to ensure that all relevant employees received those required trainings, including those related to laboratory safety and the disposal of hazardous waste. Officials at the campuses offered different reasons for not ensuring compliance with required training. For example, Sonoma’s Environmental Health and Safety (EH&S) director told us that due to limited resources, the EH&S office placed less focus on reviewing training records to verify employees consistently completed required safety training. By not ensuring that their employees are adequately trained, the four campuses have placed their employees and students at risk of injury from mismanagement of hazardous materials. Similarly, the four campuses could not always demonstrate that they provided students with training related to health and safety before they began working in laboratory environments.

Moreover, campuses have not regularly updated their chemical hygiene plans (chemical plan), which specify the operating procedures that laboratory workers must follow when using hazardous chemicals. Although Sacramento’s and Sonoma’s chemical plans require their campuses to have committees to assist in evaluating the effectiveness of those chemical plans, neither campus has ensured that its committee meets regularly and discusses chemical usage policies and usage. In addition, state regulations require that any campus engaged in the laboratory use of hazardous chemicals have a chemical plan that, among other things, designates the personnel responsible for implementing the chemical plan including assigning a chemical officer. Further, state regulations require that the campuses evaluate their plans annually for effectiveness and update them as necessary. Although all four campuses have established chemical plans, none could provide evidence that they had reviewed their chemical plans annually to determine their effectiveness. Considering that Sonoma has not updated its plan for six years and Sacramento has not substantially updated its chemical plan for 15 years, the lack of documented reviews of their plans’ effectiveness is especially troubling.

The campuses have also not ensured that all employees receive required safety trainings. State regulations require that employers provide certain trainings to employees to ensure their safety and well‑being when working with hazardous materials. However, each of the four campuses failed to ensure that all relevant employees received those required trainings, including those related to laboratory safety and the disposal of hazardous waste. Officials at the campuses offered different reasons for not ensuring compliance with required training. For example, Sonoma’s Environmental Health & Safety (EH&S) director told us that due to limited resources, the EH&S Office placed less focus on reviewing training records to verify employees consistently completed required safety training. However, he could not provide evidence that he had done so for the employees we reviewed. By not ensuring that their employees are adequately trained, the four campuses have placed their employees and students at risk of injury from mismanagement of hazardous materials. Similarly, the four campuses could not always demonstrate that they provided students with training related to health and safety before they began working in laboratory environments.

Moreover, three of the four campuses we reviewed failed to adequately monitor key safety equipment to ensure that it was in proper working condition. Specifically, Sacramento, San Diego, and Sonoma did not always conduct regular inspections of the working conditions of critical safeguards—safety equipment such as fire extinguishers, emergency eyewashes, and showers designed to mitigate or prevent individuals’ exposure to hazardous substances—as often as state regulations require. For example, according to state regulations, emergency eyewashes and showers must be activated at least monthly in order to verify they are operating properly, and fume hoods—which provide ventilation so employees and students can safely handle hazardous substances—must be inspected annually. However, only Channel Islands conducted the required inspections of all safeguards we reviewed. Sacramento, San Diego, and Sonoma each failed to routinely inspect all of the emergency showers and eyewash stations monthly, and Sonoma failed to inspect any of the 17 fume hoods we selected for more than three years. As a result, these campuses lack assurance that this critical safety equipment will function properly to maintain the health and safety of their employees and students.

Finally, some of the four campuses we reviewed also increased the risks to employee health and safety by not properly notifying employees of rooms that contained asbestos. State law requires owners of buildings constructed before 1979, which include certain campus buildings, to notify employees working within those buildings about the presence of asbestos by providing both initial and annual notices to employees. State regulations also require employers post signs at the entrances of mechanical rooms that contain asbestos or material presumed to contain asbestos. However, Sacramento and San Diego did not always comply with the requirements to post warning signs at the entrance to mechanical rooms containing asbestos. When they fail to post required warning signs, the campuses increase the risk that their employees will expose themselves to asbestos, which can have significant health effects.

Selected Recommendations

Chancellor’s Office

To more effectively monitor campus health and safety, the Chancellor’s Office should develop a uniform health and safety reporting template by November 2018 and require the campuses to use it to annually report information related to campus health and safety, as well as to any other areas the Chancellor’s Office considers critical to its oversight of health and safety compliance. The Chancellor’s Office should also follow up with campuses that fail to submit the required annual health and safety reports and take appropriate steps to ensure compliance with this requirement.

To ensure that it identifies systemwide trends and makes appropriate recommendations to address health and safety issues, the Chancellor’s Office should work with the appropriate union to form a systemwide joint committee, as agreed upon in its bargaining agreement with the union, by September 2018. It should also ensure that the systemwide joint committee meets and fulfills its responsibilities in accordance with the bargaining agreement by actively working with the union on an ongoing basis.

As part of the uniform health and safety reporting template, the Chancellor’s Office should require campuses to annually report on the timeliness of their inspections of safeguards and to identify the reasons for any delays. The Chancellor’s Office should follow up with campuses that report missed or delayed inspections and should require that the campuses develop action plans to ensure that they complete inspections as often as state regulations require.

To ensure compliance with state requirements to notify employees about the presence of asbestos, the Chancellor’s Office should immediately remind all of its campuses that state regulations require posting signage by the entrances to mechanical rooms that contain asbestos. By September 2018, it should ensure that campuses are compliant with that requirement.

Campuses

To ensure that they receive feedback from employee representatives on conditions associated with their work environments and that they develop appropriate interventions, the four campuses should ensure that their joint committees meet and fulfill their responsibilities in accordance with the bargaining agreement. If such committees do not exist, they should work with the union to form them by September 2018. In addition, they should ensure that their joint committees record meeting minutes, and provide copies of the minutes and other information to the systemwide joint committee, as requested.

To increase oversight of chemical safety, Sacramento and Sonoma should specify by June 2018 how often their chemical committees are to meet and then ensure that their committees meet as frequently as required.

To more effectively provide oversight of their chemical plans, the four campuses should annually evaluate those chemical plans for effectiveness and document the results of those evaluations, including their discussions of any recommended revisions.

To ensure the health and safety of employees working with hazardous materials, Channel Islands, Sacramento, San Diego, and Sonoma should review by June 2018 the training records of all employees to identify those that have not taken required trainings. They should make the required trainings available to these employees and establish procedures for ensuring that the employees have received all required trainings.

Sacramento, San Diego, and Sonoma should implement plans to ensure that they consistently complete inspections of critical safety equipment in the time frames state regulations require.

Sacramento and San Diego should immediately ensure that the entrances to all mechanical rooms with asbestos or material presumed to contain asbestos have signage to inform employees about the presence of that hazardous substance.

Agency Comments

The Chancellor’s Office provided a consolidated response in collaboration with the four campuses we reviewed, and generally agreed with our report’s recommendations and stated that it has already begun taking steps to address many of them. However, it disagreed with our recommendation that campuses should ensure their joint committees meet and fulfill their responsibilities in accordance with the pertinent bargaining agreement.



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