Environmental Health and Safety Compliance Calendar Washington and Lee University Annual Calendar of Significant Reporting Compliance Activities

¹Semi-Annual Fuel Certification
Operators of boilers must submit a semiannual report detailing any excess fuel emissions. The report is required by both the Virginia DEQ and the U.S. EPA, and is due by the 30th day following the end of each calendar half.

²Emergency Planning and Community Right-to-Know Act (EPCRA)
By March 1st of each year, the owner or operator of any facility which is required to prepare or have available a material safety data sheet for a hazardous chemical under OSHA shall prepare and submit an emergency and hazardous chemical inventory to the appropriate local emergency planning committee; the state emergency response commission; and the fire department with jurisdiction over the facility.

³OSHA 300 Log and Summary
If required by the Bureau of Labor Statistics for a particular year, employers with 11 or more employees must post, from February 1 to April 30, a summary of the total number of job-related injuries and illnesses that occurred in the prior calendar year (i.e. the annual totals of the information contained on the right-hand portion of OSHA Form 300, "Log and Summary of Occupational Injuries and Illnesses). The form is to be displayed wherever notices to employees are usually posted. Download the form at http://www.osha.gov/recordkeeping/RKforms.html

⁴Annual Fuel Usage Report
An annual fuel usage report is due by April 15th of each year. The report details the amount of fuel burned through certain boilers on campus, and is sent to both the Virginia DEQ and the U.S. EPA.

⁵Hazardous Materials Transportation Act of 1994
It has not yet been confirmed that this requirement applies to the University. Each person who transports or causes to be transported hazardous material shall prospectively file annually a complete and accurate registration statement on DOT Form F 5800.2 not later than June 30 for each registration year in which it is prospectively known that a placarded amount of hazardous material will be transported. Each registration year begins on July 1 and ends on June 20. If it is not known prospectively in June whether there will be any such hazardous material transported, the DOT Form F 5800.2 must be completed prior to transportation of the hazardous material.

⁶AST Financial Responsibility
Operators of certain aboveground storage tanks (ASTs) must demonstrate that they have the financial resources to pay for the costs of containment and cleanup in the event of a discharge of oil from a regulated AST. This documentation must be on file no later than 120 days after the end of the fiscal year, thus, by October 28th.

⁷HEOA Fire Safety Report

The university must annually publish (and submit the statistics to the Secretary of Education) a fire safety report containing information with respect to campus fire safety practices and standards, including:

a)  Statistics concerning the following in each on-campus student housing facility during the most recent calendar years for which data are available:

• i) The number of fires and the cause of each fire;
• ii) The number of injuries related to a fire that result in treatment at a medical facility;
• iii) The number of deaths related to a fire; and
• iv) The value of property damage caused by a fire;

b) A description of each on-campus student housing facility fire safety system, including the fire sprinkler system;
c) The number of regular mandatory supervised fire drills;
d) Policies or rules on portable electrical appliances, smoking, and open flames (such as candles), procedures for evacuation, and policies regarding fire safety education and training programs provided to students, faculty, and staff; and
e) Plans for future improvements in fire safety, if determined necessary by the university.

The university must also:
1) Make, keep, and maintain a log, recording all fires in on-campus student housing facilities, including the nature, date, time, and general location of each fire; and
2) Make annual reports to the campus community on such fires.