Health and Safety Plan

Administration of Health and Safety 1-1.1 Health and Safety Committee

The Health and Safety Committee Chairperson is appointed by the President and CEO to assume the responsibilities identified in this plan. The Vice-President of Operations chairs and directs the activities of the Health and Safety Committee representatives of the institution's operations. The committee representatives are:

• Director of Human Capital Management
• Director of Facilities
• Director of the Customer Support Center
• Director of Regional Classroom Training
• Registrar
• Representative from the GS Floor Monitors and Leaders in Action

The primary responsibilities of the committee are:

• To promote health, safety and security consciousness throughout Graduate School USA.
• To conduct evaluations of all facilities, equipment, and operations in accordance with this manual and other standardized material as prescribed.
• To provide written recommendations to the administration concerning their findings, including suggestions for corrective actions, to promote school wide safety and security to insure a healthy learning environment.
• To assist in the investigation of School accidents and to render findings and recommendations.
• To develop and administer an ongoing program of safety, environmental health, and emergency procedures training.
• To revise this manual as warranted. 1-1.2 Employee Responsibilities

Each supervisor is responsible for insuring that safe working conditions are provided for those employees and under their supervision and for investigating reports of unsafe working conditions. Each supervisor is also responsible for knowing the safety and health guidelines, investigating accidents, reporting accidents and properly advising the administration and the Health and Safety Committee of appropriate situations. Similar responsibilities are expected of faculty members and department chairs with respect to the students they instruct or supervise on site and field trip settings. Similarly, supervisors and faculty should assist in maintaining and improving safety, health and security.

Each employee is to place health and safety requirements as first importance in the performance of their work duties for Graduate School USA. The protection of students, fellow employees, and the public on the school's property is a shared responsibility of every employee.

All employees are responsible for notifying their immediate supervisor of a violation or deficiency in safe and healthful working conditions and for recommending corrective measures, if possible. Additionally, the employee's immediate supervisor is to be notified of every injury or accident regardless of how trivial such accidents may appear at that time.

Inspections and Compliance Requirements

1-2.1 Annual Inspections

An annual inspection of the institution's facilities and operations will be conducted under the direction of the Health and Safety Committee. Each inspection report will record pertinent safety violations, noncompliance items, and observed deficiencies. Employee(s) directly involved in the operation of the facilities are to participate in the inspection process.

Annual audits will include an assessment of the following inventory:

• Environmental (lighting, dusts, noise)
• HVAC equipment
• UPS (switches, breakers, connections)
• Personal service/first aid supplies (drinking fountains, first aid supplies)
• Material handling equipment (Xerox)
• Building Structural openings ( floors, doors, stairways)
• Miscellaneous (any items not covered above)

1-2.2 Reporting Non-compliance

Observed violations of safety standards, deficiencies, and noncompliance items will be reported in the Facility and Operation Safety Information Form. Notification of the recorded violations and the arrangement for the accomplishment of appropriate corrective action will be given to the Health and Safety Committee and the person in charge of the facility or function being inspected. The responsible person is to respond to the Health and Safety Committee indicating corrective action accomplished with regard to each reported violation.

1-2.3 Imminent Danger Action

In the event that any manipulation, process, action, or condition is discovered which, in the opinion of supervisory staff, is considered to constitute an immediate threat to the life of any employee, student, or the public, the appropriate supervisory personnel may order the immediate cessation or modification of such manipulation, action, or condition.

1-2.4 Rights of Employees

Any employee who has a direct personal involvement in the facilities may report, to the Health and Safety Committee, any observed violations or deficiencies. The rights of employees will be exercised without retaliation on the part of any employee of the institution.

Reporting of Accidents

1-3.1 General

All serious accidents as defined below will be investigated by the Facilities and Human Capital departments.

• Serious injury to an employee, faculty, student or visitor.
• Serious injury caused anywhere within the institution's property
• Serious Injury caused to any employee while conduction business for the institution at other locations

The institution's Incident Report will be used to record details of the accident and will be forwarded to the Health and Safety Committee as soon as the investigation is complete.

1-3.2 Release of Information

In the case of serious accidents, supervisors and employees may not release information to the news media. Information is to be provided to the media by the institution through a designated spokesperson. If contacted by the media please refer these individuals to the Vice President for Operations immediately.

Reporting of Crimes on Institution Property

1-4.1 General Information

All of the institution's facilities are located within commercially owned buildings that provide 24/7 private guard services. Employees, faculty and students shall report crimes immediately in the following order:

• Local Police Department - 911
• Building's Security Office - Appendix C
• Institution Facility Department – (202) 314-3367

Note: The institution Incident Record will be used to record these events. Please note for the purposes of this policy, parking and traffic violations are infractions and are not included within the definition of a crime. No incident reports are required for these infractions unless the violation results in personal injury or property damage.

1-4.2 Altercations and Other Disturbances

Contact the Building Security Office immediately. If, in the opinion of the employee, faculty member, or student the incident warrants emergency service personnel, they may be called directly by the person reporting the incident. The employee should attempt to obtain the names of anyone who observed the incident or who might be able to provide any information useful in the investigation of the incident. After the incident has been investigated it will be recorded using the Institution's Incident Record.

Institution Facilities

1-5.1 Access to Institution Facilities

Institution security is a shared responsibility among all employees. Upon request employees are provided after hour access to the facilities by contacting the Facility Department.

Contractors may be provided temporary access to facilities to perform service or construction work during periods when the institution is closed. Special arrangements should be made with the Facility Department to assure that building security is provided during these periods. The Director of Facilities oversees the issuance of keys to employees for access to buildings and rooms the employee might need to enter to conduct their duties.

An employee may not lend any building key to another employee and is responsible for any misuse or breach of security that results from this transfer. Keys are not to be transferred from one employee to another nor any building key duplicated.

1-5.2 Escort Services

The Building Security Force is available to accompany individuals to their cars during evening hours or when staff feels that an escort is needed.

Medical Emergencies, First Aid, and Medical Treatment

1-6.1 Requests for Emergency Medical Assistance

After calling 911, the Building Security Office should be notified so that they may direct emergency vehicles to the scene.

1-6.2 Injury Reporting

The institution is required to maintain a listing of all workplace illnesses and injuries and to complete a summary report of the findings and make available upon request. An Incident Report is to be completed immediately following an injury, no matter how slight, with the Facility and Human Capital Management Offices.

1-6.3 Medical Return to Work Authorization

If an employee takes leave for their own serious health condition, the employee is required to provide medical certification that they are fit to resume work. For safety reasons, employees failing to provide the Return to Work Medical Certification Form from their physician will not be permitted to resume work until such certification is provided.

1-6.4 First Aid Kit Location

It is recommended that each department or office maintain a first aid kit for non-emergency medical care. The location of this kit should be communicated to all employees via the organization's Intranet and to students through program support located at the receptionist area on each classroom floor. The Facility Department oversees the distribution and restocking of the first aid kits to include influenza supplies.

Power Losses

1-7.1 General Information

The institution may experience power losses to one or more buildings due to storms, power company disruptions, or damage to the service lines entering the property. These interruptions can lead to conditions that may result in personal injury or damage to equipment or facilities. This section sets forth general procedures to be used in the event of loss of power.

Power losses greatly increase the likelihood of an accident due to the following:

• The loss of lighting increases the possibility of injury to those moving throughout the building/institution.
• The attendant electrical surge accompanying the restoration of power may damage electrical devices not switched off.
• The operation of electrical devices during a phase loss may result in damage to these devices.
• The electrical loss may disrupt telephone service and emergency devices such as fire alarms.

In the event of power loss, every effort should be made to immediately turn off all electrical equipment within an employee's work area before power is restored to protect the equipment within their area. When sufficient lighting exists during day hours to work safely and the building is comfortable without air conditioning, the building may remain open for operation. During evening operations, the building may be evacuated. Further directions concerning class schedules will be provided by the Customer Support Center and Evening Programs Office.

1-7.2 Reporting Power Losses

In general, the loss of power or the disruption in normal electrical service should be reported immediately to the Facility Department. After 5:00 p.m., reports should be made to the Building Security Office, who will contact the maintenance staff accordingly. Maintenance staff will investigate the scope and condition of power loss and proceed to correct the matter accordingly.

In instances when power loss is due to the disruption of utility service, the electric company will be called to restore services.

1-7.3 Emergency Lighting

During periods of power outages, emergency lighting will automatically come on in the hallways and stairways of all buildings that have these devices.

Weather Emergencies and Crisis Management

1-8.1 Weather Delays and Cancellations

The institution will delay or cancel classes when inclement weather poses concern for the welfare of students and staff. Information about delays or class cancellations will be communicated to employees via email, company website or telephone during day operations. When the institution is closed, information for students will be made available through local radio and television stations and the institution's website for updates on the schedule of operation.

1-8.2 Severe Weather

All reports concerning severe weather during day operations will be relayed to the Chief Executive Office or the VP of Operations Office in the CEO's absence. The acting administrator will notify institutional personnel and students of the impending danger by telephone, email alert or direct messengers sent announcing the severe weather condition.

1-8.3 Severe Weather Procedure

In the event of severe weather or tornado warnings, individuals should seek the safest areas possible away from exterior windows and doors and along the lowest interior portions of the building. Persons are to be instructed to crouch and face interior walls with their hands behind their heads and their head between their knees. They are to remain in this position until notified by institution personnel that the impending danger is no longer present.

1-8.4 Bomb Threat

In the event of a bomb threat:

• Call 911 via land line. Do not use cell phones or radios.
• Do not hang up on the caller. (Have another staff member call 911)
• Record the call if such capability is available.
• Make notes of the call using the checklist that follows.
• Note the caller's voice (angry, calm, crying, laughing, accent, deep, slow, raspy, excited, ragged, slurred, etc)
• Observe as much background noise as possible (street noises, music, factory, machinery, voices, office, house noises, animal noises etc.)

What do I ask when a bomb threat is made?

• When is the bomb going to explode or chemical set to release?
• Where is it right now?
• What does it look like?
• What kind of bomb or chemical agent is it?
• What will cause it to explode or release?
• Did you place the bomb or chemical agent yourself?
• Why are you doing this?
• What is your name?
• What is your address?

Try to determine the following:

• Sex of Caller­
• Approximate Age
• Race or nationality (if possible)
• Length of call

The first responders and local police authority will make the decision to evacuate a building. If the alarm is given to evacuate able employees and students are encouraged to assist with the evacuation of disabled and impaired persons when possible.

The Floor Monitors should direct students to exit the buildings consistent with the institutions fire evacuation procedures.

Re-entry into the buildings will not take place until a search is completed and after consultation with the police and/or emergency responders.

1-8.5 Crisis Management and Evacuation

This section shall detail the plan of the Graduate School in the event of a crisis situation.

Crises are extraordinary events that cannot be predicted or controlled. Due to the nature of these events, how an institution responds to such events can influence the impact on students and staff. Also the complexities of present communities make advanced planning and policy development for catastrophic events a practical necessity.

For the purposes of this document, crises may be defined as including but not limited to:

• Racially motivated incidents
• Violent crime on campus or threats of violence, i.e. bomb threat
• Incidents that lead to death, injury, disruption or physical loss
• Physical damage to property
• Disruption of vital service
• Natural disasters, such as floods, fires started by lightning, and tornadoes

The Graduate School shall establish a Crisis Management Team that will include personnel whose skills enable them to help the institution in minimizing the impact of occurrences and dealing with the typical human reactions to traumatic incidents. The general purpose of the Team is to minimize disruption of scheduled activities of the institution, avoid damage to its facilities, prevent personal injury, insure the release of correct information, and reduce liability risks to the organization. The Team will include:

• The CEO
• The Vice President for Operations
• The Chief Financial Officer
• The Director of Facilities
• The Director of Human Capital

Other administration personnel who should be available to assist the Team and be consulted as needed may include:

• Director of Customer Support Center
• Director of Information System Resources

Because of the need for quick response initially, members of the Team will be used to act appropriately when a crisis threatens. The VP of Operations shall determine by the nature of the crisis or the severity of the threat if the Team needs to meet to formulate a strategy to respond.

When dealing with a crisis of a violent nature, or those that involved emotionally disturbed behavior, the receiver of the call will immediately notify the local Police department. The building security office should then be notified followed by the Operations Office. If the crisis occurs when VP of Operations is out of town or unavailable, the VP of Operations' designee shall address the incident accordingly

All members of the Crisis Management Team will be kept informed as soon as possible. A special meeting of the team may be desirable and a report completed, which will included the institution's version of the events, details of actions being taken, and a look at what lies ahead.

In all cases, whether the emergency involves physical facilities or personal injury or death, the CEO shall designate a representative to the institution who shall be responsible for communicating with the media about the incident. The privacy of the persons involved in the crisis must be honored. The CEO or his designee will work with the Local Police to verify the facts, control media access and make news release or statements that will represent the official position of the institution. The CEO's representative may also be in charge of contacting disaster relief agencies.

When the incident involves a death at any facility of the institution, whatever the cause of death, the Local Police should be immediately notified. The Local Police will be responsible for notifying the proper authorities and next of.

The Crisis Management Team will meet following emergencies to evaluate crisis responses and suggest changes in policy.

New Employee Health and Safety Orientation

Within a short period after starting employment with the Graduate School, a new employee is scheduled for a new employee orientation meeting. During this meeting, the employee receives important information about the Graduate School's policies and procedures, including issues related to health and safety.

Smoking Policy

1-12.1 Policy

Smoking is prohibited in all institution facilities. Employees and students who violate this policy may be subject to disciplinary action.

Handling of Suspicious Mail and Packages

1-13.1 Policy

Employees are encouraged to use caution when handling incoming mail. Some characteristics of suspicious packages and mail include the following:

• Excessive postage
• Handwritten or poorly typed addresses
• Incorrect titles
• Title, but no name
• Misspellings of common words
• Oily stains, discoloration or odor
• No return address
• Excessive weight
• Lopsided or uneven envelope
• Protruding wires or aluminum foil
• Excessive security material such as masking tape, string, etc.
• Visual distractions
• Ticking sound
• Marked with restrictive endorsements, such as "Personal" or "Confidential"
• Shows a city or state in the postmark that does not match the return address

Upon seeing a suspicious package or device:

• Do not open, touch or otherwise handle the suspicious item or anything else on your own.
• Immediately warn those in close proximity and vacate the area.
• Call 911 via land line. Do not use cell phones or radios.
• Return to your place of work once the area has been determined to be safe.