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affect the campus chemical inventory
This is to notify you of compliance deadlines for updating two important environmental, health and safety programs-the Hazardous Materials Management Program (HMMP) and the Injury and Illness Prevention Program (IIPP). It is also to provide you with some information about ongoing inspections by the City of Berkeley. It is critical that each campus building and department/unit participate in the update process outlined in this memorandum. The timetable summarizes requirements for completion and submission of the HMMP and IIPP.

I. Background During the past few years there has been an increased emphasis on establishing a framework for all safety programs at the building and department level. Safety programs must be dynamic, which requires solid safety structures, active safety committees, updated essential information, and on-going training. Active involvement by Building Coordinators and Building Safety Committees is a fundamental element in the building safety structure. The department safety
structure includes a Department Safety Officer and a Department Safety Committee. Two major components of the department safety program are the IIPP (Title 8 California Code of Regulations, 8CCR n3203) and department information for the campus HMMP (California Health and Safety Code, Chapter 6.95 and Berkeley Municipal Code, Chapter 11.52). It is crucial that each level of administration play a role in ensuring programs are implemented. Major elements of these programs must be reviewed and updated at least annually. Under the direction of the EH&S Policy Committee, the Office of Environment, Health and Safety (EH&S), coordinates data collection for these programs, integrates the data in a central database, and submits compliance information to regulatory agencies.

II. Reporting Requirements Each campus building and department/unit is required to submit updated information for the following programs: 1) Chemical Inventory, 2) Emergency Preparedness, and 3) Illness and Injury Prevention Program. Requirements for each specific program element are described below. Note that the titles for each section specify the applicablemajor program (IIPP, HMMP) and designate the entities (Building, Department/Unit) responsible for the update. 1) Chemical Inventory (HMMP)-Departments/Units Departments/unitsare responsible for ensuring that inventories of all hazardous materials covered under the HMMP are updated annually. Please note that the chemical inventory due date has been changed; the new schedule allows each department to select one quarter when they will report each year. At the beginning of each quarter, EH&S will issue a memorandum and instructions to those departments/units detailing the information needed from Department Managers and Principal Investigators. Chemical inventory submittals to EH&S are due by the end of that quarter.

Some important notes:
Training department personnel on taking inventory and using the inventory software can be arranged with EH&S at the beginning of your reporting quarter. Significant changes in the chemical inventory (in addition to the annual update) must be reported to EH&S, who reports to the City of Berkeley within 30 days. Departments/units are responsible for notifying EH&S of room or other changes that affect the campus chemical inventory (e.g., an investigator moves to a new campus location or leaves the University). Locations with hazardous materials must have a current inventory on file with EH&S. Departments/units should review their inventory summary provided by EH&S and verify listed locations are current, accurate and complete (mark locations as to deletions, additions, corrections). Responsible persons should be notified to update or prepare a chemical inventory. Call or e-mail Anna Moore (3-9518; anna_moore@maillink) or Peter Carlson (3-8187; peter_carlson@maillink) with any questions concerning the chemical inventory.

2) Emergency Preparedness (HMMP)-Departments/Units and Buildings Building Coordinators are responsible for preparing and updating emergency response and training plans for their buildings and should coordinate their emergency plans with all department/unit plans in their building. Designated department personnel, usually Department Safety Officers, are responsible for preparingand updating emergency response and training plans for their departments. Emergency Response and Training Plans consist of 1) current plans for responding to all likely emergencies,including those involving hazardous materials, and 2) plans for training personnel to handle emergencies and hazardous materials. Summary HMMP status reports prepared from the most recent building and department submittals will be sent to Building Coordinators and department heads in April; these reports form the department and building emergency preparedness templates. Templates should be updated and returned to EH&S by June 5, 1995.

Additional information:
EH&S maintains a file of all emergency response plans and a database of contacts and other relevant information. A single department and building plan is sufficient for buildings
with only one department; however, both department and building templates must be prepared and sent to EH&S together with the procedures, floor plans, site plans and training plans. All emergency plans should be reviewed annually and updated as necessary to remain current. If you change your emergency plans, please send EH&S a copy. Additional copies of the templates (most recent information on file), blank templates, general guidelines and a checklist of building and department responsibilities for complying with HMMP regulations can be obtained by contacting Ave Tolentino (35734; ave_tolentino@maillink).

3) Injury and Illness Prevention Program (IIPP)-Departments/Units Departments/units are required to take appropriate steps to ensure safety management systems are in place for all employees and this must be documented by a written IIPP. IIPP requirements are listed in "The Interim Injury & Illness Prevention Program" handbook provided by EH&S; a summary of the general requirements includes: Identification and evaluation of workplace hazards; Proper labeling of containers of hazardous chemicals; Availability of appropriate hazard information, such as Material Safety Data Sheets; Implementation of a system of periodic inspections, investigations of incidents, and correction of deficiencies; Initial and periodic work place safety training and special training for persons who handle hazardous substances, are involved in hazardous operations, or are present where hazardous substances are used; Establishment of a system of communication between staff and employer representatives on safety matters; Recordkeeping of inspections, corrective actions, training, exposure monitoring, medical exams, and other activities relevant to the program. The Department Safety Officer working with an active Department Safety Committee can develop a safety structure which incorporates most of the requirements listed above. Many of the IIPP requirements can be coordinated with similar HMMP requirements. If you need assistance in developing your department IIPP, contact Carl Lukens (2-9333; carl_lukens@maillink). EH&S tracks some of the IIPP requirements, focusing on maintaining current IIPP contact information
and checking for completion of appropriate IIPP forms. Summary IIPP status reports containingcontact information will be sent to department heads in April. Updated contactinformation and copies of IIPP forms are due to EH&S no later than June 5, 1995.

III. Inspections The City of Berkeley has conducted campus inspections for compliance with the following programs: Hazardous Materials Management, Hazardous Waste, Underground Storage Tanks, Alameda County Urban Runoff Clean Water Program, and Ozone Depleting Compounds. EH&S works with faculty committees such as the Laboratory Operations and Safety Committee and the Hazardous Waste Management Committee on the scope of campus inspections. The City inspected laboratories of two departments in 1994 and has continued to inspect non-laboratory areas in 1995. Laboratory inspections may resume by the summer of 1995. If you think your department or unit may not be prepared for a laboratory inspection, please contact Anna Moore (3-9518) for general information and consultation. Other regulatory agencies have inspected the campus in the last year (e.g., CAL-OSHA for worker related incidents or complaints, and the Department of Toxic Substances Control for hazardous waste related issues).

I want to acknowledge that the campus response and cooperation on environment, health and safety programs continues to be excellent and has supported the efforts to bring the campus into compliance with regulatory requirements. Thank you for your continuing cooperation.