Environmental Policy

Overview of Environmental Management System

Addendum No. 1 to Environmental Management System Manual

The Waltham Public Schools is committed to and values the protection of the environment. This commitment includes:

• preserving natural resources,
• preventing pollution and
• continual improvement of environmental management.

Implementation of this policy is the responsibility of each member of the school community. To this end, the Waltham Public Schools shall:

1. Comply with all appropriate and applicable environmental laws and regulations.
2. Effectively communicate this policy and our environment commitment to our students, their parents and the school community and request that they join us in these efforts.
3. Promote, when practical, positive impact on the environment by recycling, reuse and conservation of natural resources.
4. Enhance school curriculum in addressing environmental issues and conservation.
5. Place a high priority on ensuring proper fuel, chemical and waste management and storage.
6. Encourage proactive attitudes towards environmental management.
7. Evaluate environmental performance to ensure continual improvement through inspections and audits.
8. Implement toxic use reduction and pollution prevention measures as dictated by school operations and where practical.

Section 1: Introduction

The Waltham Public Schools has elected to implement an Environmental Management System (EMS) at all twelve of their public schools. The purpose of the EMS is to address environmental issues comprehensively, to achieve and maintain environmental compliance throughout the Waltham Public Schools and to integrate a commitment to environmental compliance and sound environmental management practices into the daily mission of the public schools. The EMS will encompass the following schools:

The purpose of this EMS Manual is to act as a reference for employees of the Waltham Public Schools in guiding staff members during EMS implementation. Training sessions have been and will be conducted to familiarize staff members from each school with the EMS. Certain staff members will also be instructed on training staff from their schools on key EMS concepts.

This EMS Manual describes the elements of the Waltham Public School’s environmental management system, the established policies and procedures that will be followed to meet applicable environmental legal requirements, and policies and procedures to comply with other EMS requirements. Sections 2 through 6 of this manual describe specific components of the EMS, namely, environmental policy, planning, implementation and operation, checking and corrective action and management review, respectively.

Section 2: Environmental Policy

The Waltham Public Schools’ Environmental Policy, provided on Page 2-2, has been developed based on input from senior management and staff members responsible for implementing the EMS. The policy has been authorized and approved by the Superintendent of Schools and the Waltham School Committee. The policy has been communicated to school department employees, and contractors, and is posted at each school and at the administrative offices of the Superintendent's office. The policy is available to students, teachers, other employees, the media, guests, regulatory agencies, neighbors, and the general public by contacting the Waltham School Department at (781) 314-5440 and asking for compliance / safety coordinator. Copies of the policy should be kept at each school’s principal’s office for distribution as requested.

Waltham Public Schools’ Environmental Policy

The Waltham Public Schools is committed to and values the protection of the environment. This commitment includes preserving natural resources, preventing pollution and continual improvement of environmental management. Implementation of this policy is the responsibility of each member of the school community. To this end, the Waltham Public Schools shall:

1. Comply with all appropriate and applicable environmental laws and regulations.
2. Effectively communicate this policy and our environment commitment to our students, their parents and the school community and request that they join us in these efforts.
3. Promote, when practical, positive impact on the environment by recycling, reuse and conservation of natural resources.
4. Enhance school curriculum in addressing environmental issues and conservation.
5. Place a high priority on ensuring proper fuel, chemical and waste management and storage.
6. Encourage proactive attitudes towards environmental management.
7. Evaluate environmental performance to ensure continual improvement through inspections and audits.
8. Implement toxic use reduction and pollution prevention measures as dictated by school operations and where practical.
9. Section 3: Planning

3.1 Environmental Aspects

Environmental aspects are the elements of the Waltham Public Schools’ activities that can interact with the environment and cause or have the potential to cause an impact to the environment. To minimize any impact to the environment, the Waltham Public Schools have identified environmental aspects and will continue to identify their aspects as infrastructure or operations change. On December 14, 1999, the EMS Implementation Team and Steering Committee identified the school’s environmental aspects for activities that can be controlled and over which the schools have influence. A list of the environmental aspects that were identified can be found in Appendix A. In addition, a modified list of aspects was generated to combine similar aspects into more general topics.

Environmental aspects are rated using criteria of significance. These criteria establish the parameters for identifying which environmental aspects are significant. The criteria of significance that were identified for the Waltham Public Schools are: legal, cost, frequency and severity. On January 12 and 25, 2000, the EMS Implementation Team rated each of the seven combined aspect topics to determine which aspects are considered significant based on the criteria of significance established. A copy of the Significant Environmental Aspect (SEA) Rating Worksheet is included under Appendix A. While those aspects that did not get rated as significant will still be considered as part of the EMS, the EMS will focus on SEAs in setting objectives and targets.

The Compliance / Safety Coordinator retains the list of rated aspects for the Waltham Schools. Significant environmental aspects are considered in the planning of objectives and targets and are reviewed on an annual basis by the EMS Steering Committee and revised as appropriate when new activities are introduced into the schools.

3.2 Legal and Other Requirements

The Compliance / Safety Coordinator is responsible for coordinating the identification of legal and other requirements that apply to the Waltham Public Schools’ environmental aspects. Legal requirements are those established by applicable legal and regulatory jurisdictions. Other requirements include those to which the school system adheres voluntarily, for example, school system policies and goals.

The Waltham Public Schools use a variety of means to identify and track applicable environmental laws and regulations. Primarily, the school system relies on the services of legal counsel and/or environmental consulting organizations to identify pertinent environmental regulations. In addition, the Compliance / Safety Coordinator uses a newsletter published by the Local Government Environmental Assistance Network (LGEAN) to track new or updated environmental regulations. The Compliance / Safety Coordinator also communicates, as needed, with regulatory agency personnel regarding the various regulatory requirements.

The Compliance / Safety Coordinator or designee performs a quarterly review of regulatory requirements to monitor the school system’s compliance with identified regulations and to track proposed changes to existing, or new applicable laws, rules, and regulations. Consultants may provide information about the interpretation of existing and proposed environmental law, regulations and policies that may affect the school system through direct communications (written or verbal) with the compliance / safety coordinator. The Compliance / Safety Coordinator also coordinates compliance audits at each school at least every five years using internal or external auditors. As part of these audits, the auditor assesses the school system’s compliance with applicable regulatory requirements.

A list of environmental laws and regulations, and how they affect the Waltham Public Schools is included under Appendix B. A more detailed description of the compliance management system that will be used as part of the Waltham Public Schools’ EMS can be found in Section 4.7 of this manual.

3.3 Objectives and Targets

The EMS Implementation Team and Steering Committee establish environmental objectives and targets. An objective is an overall goal that Waltham schools sets for it to achieve and the associated target is a performance requirement for that objective. Both objectives and targets should be quantifiable where practicable. In setting environmental targets and objectives, consideration is given to the list of significant environmental aspects; the legal and other requirements with which the Waltham Public Schools must comply, financial issues, and organization goals and policies.

The EMS Steering Committee and the EMS Implementation Team member responsible for each specific target will evaluate these objectives and targets for progress at least quarterly. Objectives and targets may be ended or changed at any point. However, the EMS Steering Committee must provide justification and document why the particular objective and target was ended or modified. The list of objectives and targets is maintained by the Compliance / Safety Coordinator and is reviewed during each EMS management review. Objectives and targets established for calendar year 2000 can be found in Appendix C.

3.4 Environmental Management Programs

Project managers are assigned to each objective to establish and implement action plans for achieving the objectives and targets. In the action plan, the Program Manager will include:

• What will be done to achieve the target
• Who will be responsible for tasks within the plan
• Estimated milestones for tasks
• Resources required
• How will progress in achieving the targets be measured

The action plans are reviewed by the EMS Steering Committee and Waltham School Committee to ensure their appropriateness and to approve resources required implementing the plans. The Compliance / Safety Coordinator keeps copies of the objectives and targets and associated action plans. Progress toward meeting the objectives and targets through the action plans is evaluated quarterly by the EMS Steering Committee and annually by the Waltham School Committee. Action plans for environmental management programs may be amended or changed at any time during the year provided that the EMS Steering Committee approves the changes and submits documentation of the changes to the compliance / safety coordinator.

Action Plans for environmental management programs for calendar year 2000 are included in Appendix C.

Section 4: Implementation and Control

4.1 Structure and Responsibility

The Waltham Public Schools are committed to the protection of the environment through the development and implementation of an effective Environmental Management System. The school system demonstrates this commitment through documented environmental policies and procedures and by clearly defined roles and responsibilities. Management also provides the resources, including human resources and specialized skills, technology and financial resources, essential to the implementation and control of the EMS.

All Waltham school system employees and contractors are personally responsible to perform their duties in a manner protective of the environment and to immediately report any instances where an activity may endanger the environment. In addition to these basic responsibilities, responsibility for specific aspects of the Environmental Management System lies within the following areas:

a) Waltham School Committee

The School Committee is responsible for overall environmental leadership for the Waltham School System. The School Committee is involved in the EMS primarily through their interaction with the EMS Steering Committee. At a minimum, the EMS Steering Committee will report to the Waltham School Committee on a quarterly basis to report progress on the EMS.

b) EMS Steering Committee

The EMS Steering Committee consists of the Superintendent of Schools, the school system Business Manager and the Fiscal Coordinator. The EMS Steering Committee provides leadership, vision, and direction to the School System in the EMS activities.

The EMS Steering Committee is responsible for:

• Communicating with the School Committee regarding the EMS and all activities related to the environment;
• Developing and communicating the School System’s Environmental Policy;
• Ensuring that adequate resources, both human and financial, are allocated for the implementation, maintenance, and control of the EMS;
• Coordinating with the EMS Implementation Team to fully integrate the key EMS concepts into each school;
• Ensuring that the EMS is implemented and maintained in accordance with the requirements of the Final Judgment;
• Coordinating the development and implementation of the EMS training program and environmental management programs to meet objectives and targets;
• Ensuring that school committee reviews occur at a minimum of least every three months.

c) Compliance / Safety Coordinator

The compliance / safety coordinator, a member of the EMS Steering Committee, is responsible for overall coordination of the EMS program and managing the activities of school system staff to support the EMS. Specifically, the compliance / safety coordinator:

• Ensures that significant environmental aspects are reviewed and updated at least annually;
• Provides leadership in the development and implementation of environmental objectives;
• Reports on the performance of the EMS to the EMS Steering Committee Team on a regular basis;
• Coordinates and communicates with departments and schools system-wide regarding environmental compliance matters;
• Chairs and facilitates meetings with the EMS Implementation Team; and
• Maintains all written documents relating to the EMS.

d) The EMS Implementation Team consists of two representatives (School Environmental Coordinators, or SECs) from each of the 10 schools in the Waltham school system. As SECs leave the school system, the EMS Steering Committee shall appoint a new SEC to replace the departing SEC and review pertinent EMS material. The EMS Implementation Team primarily is responsible for designing and implementing the EMS. Specifically, the EMS Implementation Team:

• Identifies significant environmental aspects;
• Proposes targets and objectives to the EMS Steering Committee for final selection,
• Ensures adherence to applicable EMS procedures within their schools;
• Forms the primary communication link between the EMS Steering Committee and the individual schools throughout the system.

e) School Environmental Coordinators (SECs) are designated by the EMS Steering Committee for leading the development and execution of environmental programs within each individual school. These SECs are responsible for:

• Planning and implementing specific programs and action plans to achieve the objectives and targets established by the EMS Steering Committee;
• Coordinating meetings, activities and findings to address the action plan(s); and,
• Conducting the program(s) within the relevant schedules and budgets.

f) Waltham School System employees are responsible for:

• Understanding the environmental policy and the extent to which they are responsible for controlling environmental impacts;
• Understanding emergency procedures;
• Complying with school environmental policies and supporting regulations, targets, and objectives; and,
• Striving for continual improvement in areas related to the EMS.

The Waltham School System EMS Organizational Structure is shown on Figure 4-1.

4.2 Training

Training is conducted throughout the Waltham Schools to provide an understanding of the environmental management system and how each person’s activities within the school may have an impact on the environment. This "awareness" training focuses on Waltham Schools Environmental Policy, the significant impacts to the environment in the schools, the objectives and targets for improving the environment, and emergency preparedness. The members of the EMS Implementation Team conduct the "awareness" training throughout the 10 schools in the form of written communication, informal training and formal classroom training as required. Training material for SECs to conduct awareness training to staff at their individual schools is provided in Appendix D.

All personnel whose work activities may create a significant impact upon the environment shall receive appropriate training. SECs meet as a group twice each year to review the Waltham Public Schools’ EMS and if any changes, both internal and external have affected the EMS. The Compliance / Safety Coordinator and/or each SEC will assess annually the activities within the schools to determine where training for work impacting significant environmental aspects may be necessary.

4.3 Internal and External Communications

Employees communicate in order to insure an adequate flow of data and knowledge throughout their own schools and among other schools. Internal communications may be written or verbal. As SECs become aware of conditions or circumstances at their schools that may cause an impact (whether positive or negative) on the environment, the situation shall be communicated to other SECs.

External communications (e.g., inquiries from parents, the media, the public, or other stakeholders) concerning the environment are conducted through the Principal’s office or by one of the SEC within each school. Such communications may be either written or verbal. The Compliance / Safety Coordinator may assist the School Principals or SECs in responding to sensitive or non-routine environmental communications. The Compliance / Safety Coordinator maintains a copy of all written communications related to the EMS.

4.4 EMS Documentation

This EMS manual with its procedures and related documentation describes the Waltham Schools Environmental Management System. It has been organized to address each core element of an environmental management system modeled after the ISO 14001 Standard.

The Compliance / Safety Coordinator maintains the original electronic and paper master copy of the EMS manual from which other controlled copies are made. He/she maintains this manual and related documents within this manual, the objectives and targets and associated action plans, and the audits of the EMS. He/she provides information as required to internal parties on matters affecting the environment, this manual and related procedures.

The Compliance / Safety Coordinator also maintains procedures concerning the environment. He/she will retain obsolete documents for legal purposes for a minimum of five years. The Compliance / Safety Coordinator will ensure that obsolete procedures are removed from the school’s files. Procedures will be updated as needed when activities affecting the environment are added or modified within the schools. The EMS Steering Committee and / or the Compliance / Safety Coordinator must be informed of changes to any environmental related procedures or new environmental practices, before a revision can be made or the procedure issued.

4.5 Operational Controls

Operational controls are means by which an organization minimizes impacts to the environment. The EMS Implementation Team reviews the environmental impact of each significant environmental aspect and determines whether or not there is an operational control in place for each aspect. An operational control is usually a documented procedure but may also be on-the-job training.

If there is not an operational control for a significant environmental aspect, the EMS Implementation Team determines if a procedure could be written to minimize impact to the environment. Operational controls are documented for each significant environmental aspect and are reviewed when modifications are made to the significant environmental aspects. The Compliance / Safety Coordinator is responsible for maintaining the list of operational controls and distributing it to the schools as part of this EMS Manual. Operational controls in the form of procedures can be found in Appendix E.

4.6 Emergency Preparedness and Response

All Waltham Public School employees are required to know and understand the procedures to be undertaken in the event of an environmental emergency. As discussed in Section 4.2 – Training, a memorandum will be circulated to all employees that includes the procedures that employees should take in the event of an environmental emergency. An environmental emergency is described as any situation that could impact the environment or any situation that involves materials that has the potential to impact human health or the environment. Examples of an environmental emergency include, but are not limited to:

• release of petroleum products to the ground,
• activities that inadvertely impacts wetlands, water bodies or other ecological receptors,
• chemicals that are released to indoor air that may pose a threat to staff, students or others with the schools and
• equipment malfunction that has the potential to release chemicals or materials to the environment or floor drains.

Activities that should be undertaken to respond to an emergency situation are the following:

• If the first person on scene believes that the school or portions thereof should be evacuated, steps should be taken to evacuate the building or portions thereof either through an intercom announcement, a fire alarm or through verbal instruction to affected rooms;
• If the situation that is causing the emergency can be stopped through simply measures and the employee feels qualified to take these measures and feels that his/her well-being or the well-being of others in the school will not be affected by these actions, the employee should take such actions to mitigate the emergency situation.
• Call the Waltham Fire Department at 911 and explain the situation. Contact the schools SEC to report the incident who will in turn contact the Compliance / Safety Coordinator at 781-314-5694. If the Compliance / Safety Coordinator can not be contacted within five minutes, contact the EMS Management Representative (John Pinzone) at 781- 314-5420.
• The area where the emergency situation occurred or is occurring should be roped off to avoid having staff or students come into contact with conditions that may be harmful to their health or who could exacerbate the situation. A person from the school, preferable the school’s SEC should remain at the area to keep staff or students away until the compliance / safety coordinator, EMS Management Representative or Waltham Fire Department has arrived on the scene. It is critical that the facts as to how the situation occurred are relayed to these individuals in a timely manner.
• Once the compliance / safety coordinator, EMS Management Representative or Waltham Fire Department have arrived on the scene, any response actions should be under their direction including the decision to call outside professionals.
• The schools SEC should complete a Corrective Action Report (CAR) in a timely manner to document the incident and corrective actions taken. A copy of a CAR form is included under Appendix F.

The decision to report the situation to the Massachusetts Department of Environmental Protection (DEP) is typically made by the local fire department. As owner/operator of the school, the Waltham Public Schools have a legal obligation to notify DEP when a release of a chemical has occurred in excess of Massachusetts Reportable Quantities listed in the Massachusetts Contingency Plan at 310 CMR 40.1600. As reference, RQs for gasoline, kerosene, heating oil, petroleum-based oils, synthetic oils, transformer oils, waste oil, hydraulic oils, diesel fuel and lubricating oil is 10 gallons.

4.7 Compliance Management

The development and implementation of an EMS must ensure that the organization strives for compliance with applicable and relevant environmental laws and regulations. This section of the EMS Manual addresses compliance management.

The first step in developing a compliance management system is to identify the laws and regulations that apply to the Waltham Public Schools operations. A summary table of applicable laws and regulations and which aspects of the Waltham schools apply to the regulations is provided in Appendix B. Areas of applicable activities or operations include, but are not limited to: hazardous waste generation, storage, transport and disposal, UST regulations, release reporting for oil or hazardous materials, marking of PCB equipment, work near wetlands, water supply cross connections, asbestos-containing material, air quality, employee right-to-know, discharges to MWRA sewers and chemical storage.

Every six months, SECs from different schools shall perform a compliance audit of a school other than their own. An easy to follow audit checklist has been developed for SECs to use during these audits. The intent of the compliance audits are to determine if each school is in compliance with environmental laws and regulations and to prevent environmental incidences from happening. The procedure for nonconformances and corrective and preventive actions described later in Section 5 should be followed upon discovery of any nonconformance. The Compliance / Safety Coordinator and/or an outside environmental firm will review the audit results every six months.

4.8 Tank Management

Table 4-1 provides a summary of information on the fuel oil underground storage tanks (USTs) at the Waltham Public Schools. The USTs have been the subject of a recent program designed to bring them into compliance with current federal, state and local regulations. An underground storage tank inventory assessment was completed by CDM in the late summer of 1998. The findings of that investigation were submitted to the city of Waltham in a report dated October 1998. In accordance with a recommendation from that report, tank tightness testing was performed on all City-owned USTs including those located at the Waltham public schools. Based on the results of that testing, USTs were either scheduled for upgrade or removal. Tanks which failed tightness testing or had been out of service included two USTs located at the Kennedy Middle School and one UST at the Vocational School. These three USTs were successfully removed and disposed in the late summer of 1999. UST upgrading included the installation of spill containment buckets and overflow prevention devices at 12 USTs located at 11 Waltham Public Schools (see Table 1 for details). The UST upgrade program was successfully completed in the summer of 1999.

4.8A

Under the new school building construction all underground storage tanks are being removed and new schools are heated with gas. All existing underground storage tanks are tested yearly and records are kept on file in the Facilities Department.

Regulatory Requirements

Underground Storage Tanks (USTs) are subject to federal, state and local regulations. The primary federal regulations are provided in 40 CFR 280. The primary state regulations are covered in 527 CMR 9.00. Copies of these regulations are kept with the compliance / safety coordinator. Additional local regulations may be enforced by the local fire department or building department.

The major UST regulations applicable to the USTs located at the Waltham Public School facilities are identified below:

The USTs which are associated with the building heating systems are defined as "consumptive use" fuel oil tanks and as such are exempt from the UST upgrade requirements of 527 CMR 9.05 (G) (4) through (13). The UST upgrade requirements went into effect on December 22, 1998. Consumptive Use is defined in the Massachusetts regulations as "fuel oil used exclusively for area heating and/or the heating of domestic water on the premises where stored. Consumptive use USTs are also exempt from the federal UST regulations.

The consumptive use USTs were subject to the upgrade requirements for retrofitting with spill containment manholes and overfill prevention devices. These upgrades have been completed at the 10 public school USTs this past summer. The spill containment manholes have a capacity of five gallons. They are designed to catch any minor spills occurring during tank filling operations. The spill containment manholes are equipped with a hand pump which draws from a small sump in the manhole and is designed for rapid removal of any excess liquid collected in the manhole. Discharge from the pump is through a plastic tube which can be directed into the fill pipe if the excess liquid is fuel oil or out of the manhole if water has collected in the manhole.

The overfill prevention device requirements at 527 CMR 9.05 (G) (3) allow for a device which either shuts off flow at no more than 95% full or a device which alerts the delivery person when the tank is no more than 90 % full by restricting flow into the tank or triggering a high level alarm. At the Waltham Public Schools, 11 USTs received overfill prevention devices designed to prevent the overfill of the tanks by providing a positive shut-off of product delivery. The overfill valves initially restrict the allowable flow rate into the tank before closing completely (at approximately 95 % of the tank capacity) before the tank can overfill. Manufacturer’s information on the overfill prevention devices is provided in the appendix. The UST at the Lawrence School was equipped with a device to signal an audible alarm when the tank fuel volume approaches capacity.

The Waltham Public School Consumptive Use UST’s are exempt from the upgrade requirements for leak detection and cathodic protection. The new 2500 gallon double-walled fiberglass UST for the emergency electric power generator at the Waltham High School is equipped with leak detection and corrosion protection.

Although the 12 heating fuel oil USTs are exempt from the leak detection requirements included in 527 CMR 9.05, because of the advanced age of these tanks a program to protect against the possibility of petroleum leaks is recommended. As such, a program for annual tank tightness testing has been implement and provides some measure of protection against the possibility of a leak. Tank tightness testing results are kept on file by the compliance / safety coordinator.

In addition, a program for inventory monitoring is recommended as an additional means of leak detection. A weekly dipstick reading and recording, as well as, immediately after fuel deliveries would serve to provide a record of typical fuel usage and allow for timely notice of any unusual fuel usage rates which could signal a leak. Fuel deliveries and the dipstick readings should be maintained on-site in a notebook.

In addition, as part of the leak detection program, particular attention should be paid to the regulatory requirements on water levels detected in the UST. 527 CMR 9.05 (E) (1) (d) defines an abnormal gain in the water level inside any tank as more than one inch in a 24 hour period. In the event of an abnormal gain of water, the water shall be removed and properly disposed of and the tank checked for water 24 hours later. Apart from abnormal gains of water, any tank in which water has accumulated to a depth of three inches or more shall have the water removed and disposed of by a licensed waste hauler at a legally permitted disposal facility.

Information from tank gauge charts show that depending on the specific dimensions of the tank, several inches of water on a tank bottom actually represents a very small volume of liquid compared with the total tank volume. Multiplying the allowable percentage of water for No. 2 fuel oil of .05% by a tank capacity of 10,000 gallons shows that 5 gallons of water could theoretically accumulate in the tank from each complete fuel fill up. For a typical 10,000 gallon tank, the bottom one inch of tank depth holds approximately 15 gallons of liquid. This information shows that several inches of water could theoretically develop in a tank during a heating season when the tank is receiving numerous oil deliveries over a short period of time. A small volume of water may develop in a tank over time associated with the quality of the fuel deliveries and may not be indicative of a leak in the tank. Monitoring the tank water level therefore becomes another important method of leak detection in the absence of standard leak detection equipment.

Additional Suggestions

1. Paint fill covers and at least 6 inches onto the adjoining surface area green (fuel oil) to decrease potential for incorrect fuel delivery.

2. Product Transfer- The owner/operator should ensure that the volume available in the tank is greater than the volume of product to be transferred to the tank before the transfer is made and that the transfer operation is monitored constantly to prevent overfilling and spilling. It is the responsibility of the owner and/or operator to make available to the person delivering product the proper tank chart.

3. Post a response to leaks procedure in the maintenance room of each public school facility and ensure that facility staff have read them and know where they are posted.

4.9 Toxic Use Reduction

As part of the implementation of an Environmental Management System, the Waltham Public Schools are undertaking an initiative to purchase Environmentally Preferable Products (EPP) and Recycled Products. EPPs are defined as a product that has a lesser or reduced effect on human health and the environment when compared with competing products that serve the same purpose and perform to the satisfaction of the user. Recycled products means goods which contain materials which have been diverted from the solid waste stream, including post-consumer materials, and materials and/or by-products which have been wholly or partially remanufactured.

To the extent practical, the proposed vendor shall provide cleaning and maintenance products that are listed in the Commonwealth of Massachusetts Recycled and Environmentally Preferable Products and Services Guide prepared by the Operational Services Division, dated January 2000. In addition, the selected vendor, as a condition of their contract, shall provide Material Safety Data Sheets for every chemical supplied and product labels for every one gallon of chemical provided.

4.10 Pollution Prevention

Pollution prevention measures should be undertaken by school staff to mitigate potential impacts to human health or the environment. Day-to-day common sense pollution prevention measures that staff should undertake include the following:

Storm water catch basins should only carry uncontaminated water

Oil/water separators should be maintained to meet their intended purpose

Solid waste should be properly stored in dumpsters

Chemicals should be stored inside buildings, however, if they are stored outside, containment structures with 110% capacity should be used

• Where catch basins are within 50 feet of an UST fill port, the catch basins should be covered during fuel delivery
• Absorbent materials should be stored near oil storage and use
• HVAC systems should be maintained adequately to allow for proper ventilation
• As described in Section 4.9, where more EPP are available and meet their intended purpose, these products should be used
• When work within 100 feet of a wetland or 200 feet of a Riverfront Area is proposed, the local Conservation Commission should be contacted to determine the need for a Notice of Intent (NOI)
• Training should be provided to employees who frequently handle chemicals
• Equipment such as pumps, hoses, traps and drains should be inspected regularly for signs of leakage, any leaks that are discovered should be fixed
• Keep chemical containers securely closed when not in use
• Employ conscientious housekeeping
• Utilize a well organized system for filing of MSDSs and make certain that chemical containers have adequate labels

Section 5: Checking and Corrective Action

5.1 Monitoring and Measurement

Significant Environmental Aspects are monitored and measured for compliance to relevant environmental legislation and regulations, relevant operational controls, and compliance to objectives and targets. The environmental objectives and targets established by Waltham Schools will be monitored quarterly by the Compliance / Safety Coordinator and biennially by the EMS Steering Committee. Measurement parameters will, where practical, be quantifiable and measurable. Project Managers should establish a baseline as the performance level against which they will measure future progress.

Any equipment used to measure verification will be calibrated or certified for accuracy on a regular basis in accordance with manufacturer’s instructions. Each school’s custodian staff will keep records of calibration activities.

Inspections and audits (both formal and informal) of the Waltham schools are conducted by each school’s SEC, by the Compliance / Safety Coordinator or by an outside party to ensure conformance to operational controls. Copies of the inspection checklists and audit reports will be kept at each school by the SEC or in the school’s Principal office.

5.2 Nonconformance and Corrective and Preventive Actions

This EMS Manual section describes the environmental nonconformity, corrective and preventive action process. An environmental nonconformity may be reported electronically or in writing to the compliance / safety coordinator. Corrective and preventive action shall be taken by the appropriate parties to control and mitigate any environmental accident or incident.

The Waltham Public Schools has established and maintains procedures for defining responsibility and authority for handling and investigating nonconformance, taking action to mitigate any impacts caused, and for initiating and completing corrective and preventive actions. The purpose of this manual section is to establish procedures for the identification, reporting, investigation, plan of action, documentation, and analysis for environmental non-conformities, whether potential or actual. Any changes in the documented procedures described in this manual that result from corrective and preventive action must be recorded.

Corrective action is generally a reactive process used to address problems after they have occurred. Corrective action is initiated using the Corrective Action Report (CAR) document as the primary vehicle for communication. A CAR is included in Appendix F. Corrective action may be triggered by a variety of events, including accidents, incidents, internal audits, management review, student, staff or school community complaints, or unfavorable monitoring and measurement results.

Preventive action is generally a proactive process intended to prevent potential problems before they occur or become more severe. Preventive action is initiated using the Preventive Action Report (PAR). Preventive action focuses on identifying negative trends and addressing them before they become significant. Events that might trigger a PAR include monitoring and measurement, trends analysis, tracking of progress toward achieving objectives and targets, responses to emergencies and near misses, employee suggestions, and staff feedback, among other events. It is important that PARs get distributed to all SECs so that an adequate sharing of knowledge is used to prevent environmental incidences.

At each school, the SEC will work in conjunction with the appropriate employee for determining the reason for the noncompliance, insuring that corrective actions take place in a timely manner, and in such a way as to minimize the possibility of any recurrence. As needed, the Compliance / Safety Coordinator will provide an individual or outside entity to work to facilitate the appropriate corrective action. Non-conformances are not considered closed until the CAR for the specific situation is signed off by the compliance / safety coordinator.

5.3 Record Management

The Compliance / Safety Coordinator maintains the EMS Manual, copies of CARs and PARs, records of previous audits, waste manifests and other environmental records. All environmental records will be maintained for a minimum of three years unless otherwise required by law.

5.4 Internal EMS Audits

Internal audits are systematically carried out to ensure the continual improvement of our EMS. Trained EMS auditors will conduct these audits during a formal audit in January 2001 and January 2002.

An internal EMS audit procedure is included under Appendix E. This audit system is established to determine whether the Waltham Public Schools’ EMS conforms to the EMS described in this manual. EMS audit reports and corrective action reports are retained by the Compliance / Safety Coordinator with copies provided to other members of the Steering Committee and Implementation Team.

Section 6: Management Review

The EMS is reviewed and evaluated at least once a year to maintain the suitability and effectiveness of the EMS in the light of changing conditions both within and outside the Waltham schools. The Waltham School Committee in conjunction with the EMS Steering Committee conducts these management reviews.

The management reviews include: