Only authorized Hillcrest departments and staff use substances with flammable, corrosive, or toxic properties, and the presence and use of these materials is minimized. In order to insure the safe use of these substances the following precautions are required:

1. Flammable substance and chemicals (e.g., gasoline for emergency generators, surface finishes such as paints and varnishes) are stored away from ignition sources and protected from open flames, static discharge, and sparking tools. Any bulk vessels containing flammable chemicals are grounded in accordance with NFPA codes. Appropriate fire extinguishing material(s) and equipment are kept available for fire emergencies.

2. Corrosive chemicals are managed to prevent spills. Personnel using corrosive materials will be protected with rubber gloves, safety goggles, and other appropriate personal protective equipment. Acids and caustics are stored away from each other.

3. Compressed gases are managed to prevent accidental damage to the cylinder or uncontrolled release of the contents because damaged cylinders can result in fire, explosion, or asphyxiation. Cylinders are secured to walls, benches, or other stable supports and, when not in use, protective covers are in place.

4. Swimming Pool Chemicals – Only trained personnel are authorized to handle swimming pool chemicals, and all personnel handling pool chemicals must adhere to procedures detailed in the HEC Pool Operators Manual.

5. Other: Some substances may contain more than one hazard. These substances are evaluated before use to determine if and how they can be safely used. Adequate ventilation is always necessary.

A. Hazard Determination
The manufacturer of any substance used by Hillcrest is responsible to determine if the substance is hazardous under OSHA Standards and any other applicable standards or regulations. Hillcrest will not test any purchased materials to determine their hazard properties. Hillcrest staff who deal with hazardous substances are aware of the following hazard determination procedures:
1. DOT hazard class labels and product container labels must be consistent with the hazards described on the Safety Data Sheet (SDS).
2. If initial experience indicates that the material has characteristics or properties different from those stated on the SDS, the supplier will be contacted for explanation or clarification before the substance is used.
3. If the SDS states the ingredients are a trade secret but gives no hazard warning, the supplier must provide a new and more complete SDS before the substance is used.
Hillcrest is in compliance with the Massachusetts ‘Children’s Protection Act of 2000’. This law applies to all Massachusetts public and private schools. It regulates the use of pesticides and pest management procedures, and requires notifications to students and staff when pesticides are to be used. The law also requires the development of an Integrated Pest Management Plan that is submitted to the state Dept. of Food and Agriculture, and that is periodically reviewed, evaluated and updated.
B. Labeling
1. All Hillcrest campuses preserve and use the labels already on the containers provided by manufacturers or suppliers. At a minimum it is expected that these labels will:
• Be written in clear, basic language.
• Be prominently displayed.
• Include the Hazardous Substance Identity, appropriate Hazard Warning information and the name and address of the manufacturer of the substance.
2. Whenever substances are transferred to other containers for later use, the new containers will be labeled immediately with the substance or product name as it appears on the manufacturer label. The new container will also include any hazard warning information.
3. Storage containers for bulk material (e.g., surface finishes) are labeled as indicated above. These labels will be weather proof and placed conspicuously on the container.
C. Safety Data Sheets (SDS)
1. Hillcrest requires that manufacturers, distributors and suppliers of products used by Hillcrest provide SDS information. Hillcrest will not use any substance with an SDS that does not, for any reason, include health and/or safety information.
2. The department that orders and/or uses the substance is responsible for obtaining SDS for all substances used by that department. No hazardous substance may be purchased, received or used without the appropriate SDS. The associated Department Head must determine the ability of the agency and/or campus to safely manage any new substance.
3. Each department that orders and/or uses the substance will ensure that every substance in inventory has a corresponding SDS and reviews the SDS file at least twice each year.
4. A master file of SDS is maintained in the specific department on each campus. This file is arranged so that particular SDS may be found quickly, and all department staff are oriented to that filing system.
5. Current departmental inventories of hazardous substances are maintained in specific, designated locations at each Hillcrest campus. These inventories coincide with the departmental SDS files for that campus.
6. SDS books are located in the lobby of the main building at each Hillcrest site in a “Right To Know” rack.
7. At Hillcrest sites that have swimming pools, a separate “pool only” SDS book is located at the pools where the chemicals are stored.

All Hillcrest employees and outside contractors are responsible for complying with the procedures for Hazardous Materials and Waste Management. It is recognized that the obligations and responsibilities associated with the management of hazardous materials are both shared and department specific. The leadership of Hillcrest Educational Centers and of each Hillcrest campus accepts the ultimate responsibility for:
• The effectiveness of the program.
• Annual review and improvement of the program.
• Providing the resources necessary to insure a safe environment of care.

Hillcrest’s Director of Quality Assurance and the Environment of Care Committees at each Hillcrest campus are responsible for the implementation and coordination of this program. The Environment of Care Committees will insure that the hazardous materials and waste program is evaluated annually as to its effectiveness and that adjustments and improvements are made to the program as needed.

The Director of Quality Assurance ensures that each campus conducts hazardous surveillance, that departmental, campus and organization wide hazardous materials procedures are developed and implemented, that orientation and continuing education are conducted, and that each campus Environment of Care Committee attends effectively to hazardous materials/waste issues, including the actions and procedures (e.g., clean up, reporting, investigation) associated with an accidental release of hazardous materials.

Housekeeping, Maintenance and Nursing Department Heads and Supervisors are responsible for the development and implementation of the hazardous materials and waste management procedures in their respective department. They:
• Establish criteria consistent with applicable law and regulation to identify, evaluate, and inventory hazardous materials and waste used or generated.
• Establish and manage the procedures for staff in their department on a material-by-material basis.
• Ensure that all employees who work with or near hazardous substances know the proper procedures in the case of an accidental release.
• Establish and manage the procedures, reporting and investigating any accidental release and/or exposure of a hazardous substance.

Bio-hazardous medical waste is defined as any potentially hazardous waste that is generated in the diagnosis, treatment, immunization or injuries/treatment of injuries of Hillcrest students or staff.

As noted, Hillcrest does not generate significant quantities of bio-hazardous medical waste. Types of bio-hazardous medical waste generated by Hillcrest generally are limited to:
Sharps (e.g., syringes, lancets). Sharps are the most common type of bio-hazard material generated by Hillcrest.
Materials (e.g., used bandages) requiring disposal in red bio-hazard bags. These types of materials are rarely generated by Hillcrest. Periodic disposal of all bio-hazardous medical waste is conducted through and by the Hillcrest Dental Office, a subsidiary of Hillcrest Educational Centers, in Pittsfield.

The primary objective of the Hazardous Materials and Waste Management Plan is to maximize the safety and well-being of Hillcrest students, clients, staff and visitors by effectively and safely managing the selection, handling, storage, transportation, use and disposal of hazardous materials and waste.

Information regarding all hazardous waste and substances used at Hillcrest is available in each department using and/or generating these substances. Hillcrest conducts training for employees who use or are exposed to such materials/waste to insure the highest level of user knowledge. All employees using or generating such materials/waste are expected to use this knowledge and training to protect themselves and others from harm, and to insure that hazardous materials are being appropriately handled and disposed of in a safe and legal manner. Therefore Hillcrest:
• Trains all associated employees in the safe handling of hazardous materials and wastes.
• Maintains the proper inventory tracking systems necessary to manage the presence and disposal of hazardous materials and waste.
• Maintains the proper space, equipment and information systems necessary for the safe handling, storage and disposal of hazardous materials and wastes.
• Effectively manages the accidental release of a hazardous material into the environment and the use of established reporting and investigation procedures.

Hillcrest will accomplish this objective in a manner compliant with regulations promulgated by the Mass. Dept. of Early Education and Care (DEEC), Mass. Department of Elementary and Secondary Education (DESE), standards established by the Joint Commission (JC), and all other applicable laws, regulations and standards.

The Hazardous Materials and Waste Management Plan is developed and implemented in order to:
• Insure a safe and supportive environment of care for Hillcrest students, clients and staff.
• Protect Hillcrest students, clients, employees, visitors and others from harm or injury resulting from the use or presence of hazardous substances or the presence of bio-hazardous medical waste.
• Be in compliance with regulations promulgated by the Mass. Dept. of Early Education and Care (DEEC), Mass. Department of Elementary and Secondary Education (DESE), standards established by the Joint Commission (JC), and all other applicable laws, regulations and standards.

This plan is also designed to support any necessary coordination with emergency responders in the community to ensure a safe process for any and all hazardous materials occurrences.

BACKGROUND AND INTRODUCTION
There are minimal quantities of hazardous materials used by, and minimal quantities of bio-hazardous medical waste generated by, Hillcrest Educational Centers.
Hillcrest students and clients are relatively free from any serious medical or physical problems. Hazardous substances that are used by the agency are used primarily by the Housekeeping and Maintenance Departments, and these are minimized and relatively routine and common substances (e.g., cleaning solutions, surface finishes such as paints and varnishes). Similarly, the Nursing Department generates relatively little bio-hazardous medical waste, and most typically that associated with blood tests (e.g., lancets).
Additionally, all Hillcrest programs provide relatively high staff-to-student ratios for supervision and support, including awake overnight staff at residential programs. These high staff-to-student ratios help to insure student and staff safety with regard to protection from and avoidance of exposure to hazardous substances, including accidental release.

Despite the relative absence of hazardous materials/waste, and the high level of supervision and support provided to Hillcrest students, however, Hillcrest manages such substances with the utmost care and safety.

This Plan shall be reviewed and evaluated each year for its effectiveness, scope, performance and objectives. The review and evaluation will be conducted between March and May of each year, by a work group minimally consisting of the Director of Quality Assurance, the Director of Facilities, and the Chairpersons from each campus EOC Committee and/or their designee. The results of the review and evaluation, and related recommendations, will be reported sequentially to the campus EOC Committees and the Senior Management Team for their review and approval. Barring unforeseen and unavoidable delays, this revised Plan shall be implemented each July at the beginning of the new Program Year.

All residential campus supervisors are trained in the use and safety for Hillcrest’s power generators, which are arranged to provide power to essential areas and equipment on each campus.

In the event of a power failure lasting more than 15 minutes that disrupts hard-wired fire/smoke detection equipment, Berkshire Communicators, the contracted fire notification company, and the local fire department are notified. At residential campuses, if a power failure disrupts hard-wired fire/smoke detection equipment for one (1) continuous hour, a fire watch is provided for each occupied building and maintained until power and the detection systems are restored. (See the Fire Safety Management Plan for details on Fire Watch Procedures.) The on-call Senior Manager is notified.

In the event that a malfunctioning utility system has to be shut down, Hillcrest will conduct shut down and repair procedures in a safe manner, with as much planning as possible, so as to cause the least disruption possible to program, and to student routines and comfort.

Whenever possible, Hillcrest Maintenance staff perform repair services. In the event that Hillcrest staff cannot repair the utility system, the appropriate outside contractor is contacted.

In the event of utilities issues/problems, non-residential Hillcrest sites, including Housatonic Academy and Hillcrest Psychological Services, will take appropriate measures consistent with their service functions ( e.g., transport students home; cancel appointments; suspend operations).

In the event of a power outage of any duration, in any Hillcrest building or location:

1) During the day shift (7am – 3pm), Monday through Friday, immediately contact the maintenance person assigned to your work site.

2) In the event of a power outage lasting more than 15 minutes before 7 AM or after 3 PM, on Residential or Overnight shifts, the Maintenance Emergency cell phone should be called # 413-770-9425

In the event of a power or computer network outage* in any Hillcrest building or location, call the IT Dept. immediately at 413-499-0607 between the hours of 7:30 am – 5:30 pm or 413-266-1124 outside of regular business hours.

* A computer network outage is defined as the inability to log on to HECnet from 2 separate computers during a 3 hour period.