Final Report

Table of Contents

Executive Summary
1.0 Introduction
1.1 Background
2.0 Problem Statement
2.1 Key Questions
3.0 Systems Design and Analysis
3.1 Systems Diagram
3.2 Actor Systems
3.3 Baseline Conditions
4.0 Methods
5.0 Results
5.01 Photographs
5.1 Interviews
5.2 Comments from Ian Fraser
5.3  Kevin Stewart — Director of Safety
5.4 Audit
5.5 Undergraduate Survey
5.6 Graduate Survey
6.0 Discussion of Results
6.1 Audit
6.2 Survey of Undergraduate Students
6.3 Survey Chemistry Graduate Students
7.0 Recommendations
8.0 Further Studies
9.0 Conclusion
10.0 Annotated Bibliography
11.0 Appendix A-Survey Questions
11.1  Appendix B - Interview Questions
11.2 Appendix C - Policy 34



Objective of Report

This report will evaluate the sustainability of hazardous materials handling at the University of Waterloo and will identify and evaluate any improvements made since the 1996 ERS 285 Report.  The results and recommendations from this study will be incorporated in the Fall 1999 WATgreen State of the Environment Report to the Executive Council.


Three different data collection techniques were used. The survey of undergraduate and graduate students was performed to determine any breakdown in the hazardous materials system at UW, specifically with respect to WHMIS training and improper laboratory disposal; the audit was conducted to determine level of compliance and to identify initiatives since the 1996 report; key informant interviews provide a level of detail on the system that is not available through simple observations and background research. The report identifies criteria for evaluation and improvement of the system.

Basic Results

The University of Waterloo has an innovative system to treat and dispose of hazardous materials generated by campus research and operations.  The level of compliance with respect to municipal, provincial and federal regulations is high.  The ESF is continuously improving its services, equipment and procedures to move towards safety and sustainability.  The student population is generally unaware of the ESF, of the meaning of WHMIS training and responded that there is frequent improper hazardous materials disposal in the laboratory.


These are highlights from the final recommendations for the University of Waterloo as a system.  They should not be taken as recommendations for any specific department.  Some will apply to the Safety Office, while others may apply to Plant Operations or the Chemistry Department.



After reviewing the results of this study, we have concluded that the University of Waterloo has a high rate of compliance with hazardous materials handling.  The system is under constant review and, with each iteration, becomes more sustainable.


    In the fall of 1999, the WATgreen Advisory Committee will present the University of Waterloo’s State of the Environment Report to the Executive Council. The report focuses on university environmental issues and will require information from faculty, departmental, and operational sectors of the University.  This particular report will provide information on the current state of the handling of hazardous materials on campus.  Because hazardous materials have the potential to cause serious damage to the environment and human health, they will likely be one of the main issues discussed at the fall meeting.  Our client is Patti Cook, Waste Management Coordinator, who will report our findings to the WATgreen Advisory Committee in preparation for the Executive Council presentation.

    The areas to be examined in this project are the Environmental Safety Facility (ESF), formerly the Hazardous Materials Handling Facility (HMHF), Chemistry Stores, and the Safety Office.  A previous group of ERS 285 students performed an audit of the HMHF in 1996 to determine if chemical disposal was handled both sustainably and in compliance with government regulations.  The objectives of this project are to assure that safety measures are continuing under the proper protocol described in that audit, and that the goal of sustainability is satisfactorily addressed.   In addition, if through research it is obvious that improvements are necessary, any suggestions will be implemented into the final report.

1.1 Background

    This system encompasses a myriad of departments around campus.  At the University of Waterloo, the Safety Office and Chemistry Stores oversee the handling of hazardous waste.   The handling of these wastes can affect the surrounding area pertaining to health and safety issues as well as environmental effects.
    The purpose of this system is to plan and administer programs that ensure proper handling of hazardous chemical, radioactive and biological materials on the University of Waterloo campus.  The ESF provides access to these facilities.   Pick-up and drop-off of substances for disposal or re-use are offered to avoid improper disposal of these substances.  Scott Paterson (ESF), posts pick-up times at various loading docks around campus to allow for easy participation in this program.


 We wish to explore the sustainability of the system at the University of Waterloo that is involved in treatment and disposal of hazardous materials.  This will require three research methods: audit of past reports on the system and first-hand observations, surveying of undergraduate and graduate students, and personal interviews with key staff members in the system.

2.1 Key Questions



3.1 Systems Diagram Go to Systems Diagram

3.2 Actor Systems



    Note that the Core Actors may have the power to research and investigate, but they may not have the power of some Supporting Actors, like Executive Council members, who hold power to implement change at the University of Waterloo.   The relationships between actor groups, especially in terms of core actors providing relevant information to the decision-makers is critical to making informed decisions

    A shift in administrative duties of this system when it is working properly could upset the relationship between the Safety Office and the Chemistry Department.  Currently, all groups cooperate to provide the most efficient pick-up and disposal of the hazardous materials on campus.   However, there are still many points where the system could fail.  For example, a breakdown in this system could occur if the hazardous materials were not properly labeled or tested, possibly resulting in contamination of the environment and reducing the system's overall sustainability.

3.3 Baseline Conditions

3.3.1  1996 WATgreen Project

The Hazardous Materials Handling Facility (now ESF)

 The Hazardous Materials Handling Facility (HMHF) was developed in 1992, and is located in the Earth Sciences and Chemistry building, serviced by Chemistry Stores under direction from Safety Office.  It is now known as the Environmental Safety Facility (ESF).  The ESF is designed to collect and dispose of all hazardous materials that are generated by Plant Operations, in campus laboratories and studios, including all chemical, biological, and radioactive wastes produced by undergraduates, graduates, and post-graduate students.  Since disposal costs are generally increasing, the main goal of the ESF is to find methods to reduce the volume of wastes.  Therefore, "high-cost" wastes can become "low-cost" wastes.

    The ESF achieves this goal by implementing the ideals of re-using and recycling wastes, ultimately improving the sustainability of the overall system.  Hazardous materials that can be reclaimed for reuse are redistributed within the University of Waterloo faculties and research facilities.  This decreases unnecessary disposal and demand for new materials inputted to the system.  The ESF is actively engaged in volume reduction of some hazardous materials, like distilling solids out of wastewater, which reduces the resources required in the eventual off-campus decommissioning of these wastes.  Because less waste is being sent out to companies like Safety-Kleen, the University can reduce the amount of money spent on disposal.  Therefore, less waste is ultimately sent out into the natural environment where it may remain for years before losing toxicity or radioactivity.  These two methods reduce energy and time, as well as costs for the ESF and the Safety Office, and promote sustainability.

The HMHF/ESF System:

    The ESF is located in the Earth Sciences and Chemistry Building, Room 150.  Laboratories from adjoining buildings can deliver wastes to the ESF from 11:00 am to 12:00pm, from Monday to Friday.  Hazardous wastes are also collected from B. Matthews Hall, Environmental Studies, the Student Life Center, and Engineering 1 every Tuesday afternoon.  Collections can also be scheduled one week in advance from other locations at the university.  All material, whether delivered or collected, must be in the proper ESF packaging and must be labeled correctly.  Correct labeling includes the name of the hazardous substance, department from which it came, and the name of the supervisor.  Once in the ESF, the substances are catalogued and the best method of treatment or disposal is determined according to staffing, economics, regulation or guideline and known disposal methods.  The substance has two fates: to be reused or recycled, or treated, stored and shipped off campus.

3.3.2  The HMHF/ESF System

*This diagram was compiled by Lisa Lienhart (group member).

Goals of the 1996 HMHF Project

    The goal of this report was to assess the Hazardous Materials Handling Facility and evaluate performance standards of the policies and regulations concerning transportation, handling, storage, and disposal of hazardous wastes on campus at the University of Waterloo.  This audit focused on whether the HMHF was in compliance with all applicable policies and what safety and quality control procedures were in place to handle hazardous substances.
Project Boundaries

    The HMHF System Diagram illustrates the flow of hazardous materials.  This system outlines the collection of hazardous materials brought to the HMHF where the final outcome is determined.  This HMHF system exists within another larger system of waste management on campus.  The boundaries for this project, as for the 1999 report, only included the functions within the HMHF system.
Criteria of the Project
 The criteria to evaluate the HMHF system focused on the following:
• compliance of the HMHF with provincial, municipal, and university policies, codes, and laws
• knowledge of the HMHF staff, and effectiveness regarding safety measures, storage facilities, personal protective equipment, and emergency procedure
• condition and integrity of HMHF equipment and storage containers

Means of Data Collection:
The audit was conducted using data collection methods such as:
•  reviewing university, municipal, provincial, and federal policies, laws, and codes
•  creating a checklist to view compliance or accepted standards of  policies, laws, and codes by the HMHF
• interviewing Safety Office personnel

Summary of Findings and Recommendations

    There were a total of eighteen findings/recommendations regarding the ESF in the 1996 report.  The audit looked at four major areas regarding the ESF: transportation, handling, storage, and disposal of hazardous wastes.  Some of the main findings of this study led to changes by the ESF, while some of the findings were erroneous or inapplicable.  Highlights of those findings that led to recommendations which instigated change are summarized below.

     It must be taken into account that the data evaluation in the 1996 report included ‘errors’ such as failure to compact biomedical waste, so the compliance rate was likely much higher than reported.  The statistical results are questionable because of the errors made in checking regulatory compliance, such as the transportation approval.  The degree of accuracy provided in the report is to one decimal place and it seems highly unlikely that such accuracy could be achieved through a checklist method.

3.3.3 Recent Initiatives

Environmental Safety Facility

Since the early 1990’s, the Environmental Safety Services Facility has greatly improved hazardous materials handling methods and procedures in an effort to create a healthier state at the UW campus environment.  From the information obtained through e-mail contact with Kevin Stewart, Director of Safety, during the 5-year period from 1993 to 1997, the University of Waterloo took extensive and necessary actions to safeguard against spills and accidents relating to hazardous materials and to create a more streamlined organized approach to chemical distribution.  This was achieved through the more efficient organization and access of chemical inventory information and through several preventative measures taken to foresee and correct possible problems with chemical spills and leakage before they occur, the adoption of a barcoding inventorying system as an example.  Below is a list of the specific initiatives taken by the E.S.F. to regulate, monitor and reduce environmental health hazards during the 1993-97 period.

1) 100% of high-level PCBs decommissioned and removed from service.
2) Online chemical inventory of reusable chemicals.
3) Collaboration with WLU to provide WLU with services available through UW’s Hazardous Materials Handling Facility.
4) 24-hour campus spill response team established.
5) Underground storage tanks either removed or upgraded.
6) Regularly scheduled pickup of hazardous wastes.
7) Spill procedures revised and made available electronically.
8) Facilitated application of bioremediation technology to campus projects.
9) Improved procedures for removal of hazardous materials from decommissioned labs.

In 1998, the E.S.F. has continued the trend of improving the disposal methods of chemicals to ensure a safer, cleaner environment at UW.  The latest initiatives focus on reducing wastes produced in the chemical waste disposal process with a greater effort to recycle materials whenever it is feasible. The specific initiatives are briefly listed below for the 1997/98 year.  The compliance will be evaluated in a later section.

1) Over 95% of PCBs in storage disposed of by destruction.
2) Donation from Natural Resources Canada of solvent recycler.
3) Revised purchasing practices of lecture bottles (small compressed gas cylinders) from single use to reusable.
4) Clean-up of 12 000 litres of contaminated water.
5) Recycled 4 000 litres of photographic wastes and 2 400 litres of oil.
6) 50% of all materials received at Hazardous Materials Handling Facility are removed from the hazardous materials waste stream. I.e. half-life storage, recycling and reuse. (Kevin Stewart, pers. comm, 1999)



To gain an accurate and comprehensive insight into how hazardous materials are handled, transported and disposed of at UW, a variety of primary and secondary sources and research techniques were essential.  Past reports, on-site observations, students using chemicals in their labs, instructors, and university safety and environmental personnel were all necessary resources to consult to gain a solid understanding of how the hazardous materials life cycle operates at UW.

Selected Procedures

The selected methods of data collection are composed of 4 main parts.  This information was gained from a wide variety of direct and indirect resources using various research techniques.  The methods used were an audit, interview, surveys and a review of past reports done on this issue.  Each method will be explained followed by a summary of actions taken to date.


The audit was composed of two main parts: legal compliance and observation.  An investigation was conducted to determine how UW hazardous waste facilities comply with current applicable federal, provincial, municipal and UW laws, regulations, codes and policies.  The results were then compared with those obtained from the past WATgreen report on Hazardous Waste Management from 1996 and will be evaluated according to high, medium and low rates of compliance because an actual percentage is an unrealistic evaluation.  The observation aspect was composed of an on-site tour of the ESF to observe their waste handling procedures as they are occurring.  This was a necessary component of the audit to assess current procedures in practice in order to make recommendations on how the ESF could change its practices to improve handling and reduction of waste.


Personal interviews were conducted with the most knowledgeable and experienced personnel at UW who work with hazardous waste treatment, transportation and disposal on a day to day basis.  Interviews were conducted with several safety personnel and ChemStores staff members.  Ian Fraser, the Environmental Health and Safety Co-ordinator, was interviewed to determine the safety measures on campus regarding hazardous materials, education and exact figures on UW’s hazardous waste production.  Scott Nicoll, the Chemical Stores Supervisor was interviewed to gain an understanding on how the store functions, how much waste is produced there and the procedures for preparing for the re-use of chemicals.  Scott Patterson, Manager of the Environmental Safety Facility, was interviewed to determine the life cycle of hazardous waste on campus and any possible risks of improper use or disposal.  Kevin Stewart, Director of Safety, was interviewed in person and through e-mail to contribute a general understanding of the entire system and its components in use.


All five group members surveyed 60 undergraduate students of chemistry, chemical engineering and science and recorded verbal responses to ensure a more accurate response and to conserve paper.  Approximately 85 Chemistry graduate students at UW were sent the survey via an e-mail list, and 13 people responded.  This selection of students represents the primary users of hazardous materials in the classrooms at UW.  A copy of the survey questions is in the appendix.


A thorough review of the past WATgreen project report done on hazardous materials handling at UW was conducted.  The results of this report were compared to the results gained from this project and recommendations were made based on old and new findings.  In addition, some recommendations in the old 1996 report were found to be incorrect and unrealistic in its goals of attainment.

Analytical Procedures

The procedures for data analysis will encompass the essential elements of critiquing an issue: Effectiveness, Efficiency and Fairness.  These elements are incorporated into a series of analytical questions and criteria for evaluation and improvement of current hazardous materials handling practice.  The primary focus is on law and regulation compliance, sustainability of disposal, storage and transportation methods and the level of competency and knowledge possessed by the students and teaching assistants handling hazardous materials in the classroom.  The tools for assessment are separated into two main categories entitled Criteria for Evaluation and Criteria for Improvement.

Criteria for Evaluation

1) Is the system environmentally sound? (I.e. are materials being recycled and properly disposed of?)
2) Is the system economical? (I.e. is UW saving money on recycling and reduced use of chemicals or are supplies still wasted?)
3) Are environmental safety procedures for handling hazardous materials followed by staff and students?
4) Is UW fulfilling its legal and regulatory obligations for handling of hazardous materials?

Criteria for Improvement
1) Is disposal actually occurring according to standard ESF protocol?
2) Are any hazardous materials escaping the system by being poured down the drain?
3) Are students, professors and lab technicians practicing lab etiquette according to ESF protocol?


5.01 Photographs Go to photographs

Photos of Essential ESF features.

5.1 Interviews

The results of the interview with Scott Nicoll and Ian Fraser are summarized below by category.  Interview questions can be found in the appendix.

Organization of Hazardous Materials handling at UW:
    ESF deals with all hazardous waste on campus (Plant Operations, laboratories, research projects etc.).  UW pays for everything to make it accessible and avoids drain pouring or other improper disposal.  This reduces waste and provides a uniform system (improves sustainability).  ESF has given some information seminars to Concordia and Windsor, Queen’s is also looking into this system.  Some universities (Western) still send all untreated waste out to private contractors.  Academic & non-academic working together results in expertise and better buy-in (ChemStores already has the staff and expertise, so the Safety office doesn’t have to hire an extra person plus all the administration).

Compliance Issues:
    UW must adhere to municipal sewer by-laws and there is periodic testing of sewage outflow by university (twice/year) and the municipality (four times/year) for items such as suspended solids, nitrogen, mercury and other chemicals.  The University is in compliance in all areas except for suspended solids when during the summer months the solids are not diluted by the usual water stream passing from residences through the sewer system. During off times in the summer, water does not reach sewer systems and there are more suspended solids because there is less water.  The city understands this problem and the only alternative to this is to waste clean water to dilute the solids.  The answer is to allow the slight overage (plus 30 ppm) and conserve water.  The municipality is aware of this technicality and has accordingly agreed that this is an acceptable overage.

    Anything that is not ‘household’ waste, the Region comes and checks each load for landfill disposal.  These loads go as often as is necessary, based on the waste generated by the University.  They will not take anything that does not comply, i.e. if it does not have approval from the Ministry or Region guidelines on waste.  For example, they would not take a drum of solvents with regular laboratory wastes such as glassware or paper.

    Chemical waste is handed by Safety Kleen (former Laidlaw).  This is entered into an electronic database (who, where, when), drums are labelled and shipped out.  The Ministry of Environment tracks these and ensures that each load goes to the correct location for that type of waste and that all steps in the disposal process are appropriate.  Disposal does not occur until all terms in the approval are fulfilled.

Disposal Costs:
    The cost/unit is going up, but UW has reduced the volume it sends out by more efficient packaging and distilling etc. and reuse by ChemStores reduces the overall amount of chemicals purchased and sent out for disposal.  Disposal costs in 1998 were $36 000 chemical wastes, $4000 for oil and $6000 for biological wastes.  This is likely due to expensive disposal costs for PCBs.  Ian Fraser noted that the costs for biological wastes are increasing and aside from generating less at UW, there are no methods of reducing this waste at the ESF since it is illegal to compact biomedical waste.

    For compounds like contaminated water, ESF distills solvents off contaminated water, producing a sludge of waste and clean water, again reducing the amount of waste that would have historically been untreated and shipped away.  This reduces costs to UW and adds to sustainability of the system.  However, the steam distillation prototype is powered by CO2 producing generators.

    Chem Stores sells part bottles of reused chemicals for 2$, regardless of which chemical it is.  This is useful to those who need only a small portion of a chemical and replaces the former practice of buying an entire new bottle.  Scott Nicoll also keeps an inventory of chemicals sent out within departments so if an individual is looking for a small amount of a chemical, he can refer them to someone who has recently purchased this and may be willing to provide some for them, again preventing the input of new chemicals into the system.

    ChemStores and ESF treatment effectively circulate useful chemicals until they are gone, be it for disposal or use in experimental procedures.
Chemicals cleared out of retired professors’ labs are sent to ESF and ChemStores for identification and assessment for reuse and are generally stored in ChemStores inventory.

    The adoption of protocol for waste treatment and storage depends on how much waste is generated and is based on regulatory requirements, time, size, equipment, and labour.  The procedures are out of published journals or occasionally come upon advice of UW faculty and staff.
For example, there is now a new dispensing method for solvents in ChemStores using a siphon developed by Scott Nicoll and UW students.  Instead of funneling the solvents from the drum into a smaller container, a pumping system retains any excess solvent and fumes.  Previously, the solvents could spill out over the funnel and released fumes into the general air vents, where it would exit through the main exhaust at the front of the Earth Science and Chemistry building where people often smoke.  The volume of contaminated air has decreased, and the new fumehood and vent system reduces chemicals lost to venting and protects the health and safety of ChemStores employees and the UW community.

    The ESF provides labels and containers that must be used once the chemicals are their responsibility.  Laboratories often use different labels within the laboratories, but ESF will not accept chemicals without the proper container and label.

Poly Chlorinated Biphenyls:
    Last year 99% of PCBs were sent to be destroyed at Swan Hill, Alberta.  This amounted to 90 drums, with each drum containing 210 litres (45 gallons) of PCB material.  This could be liquid from transformers containing 50% PCB, or it could be ballasts containing trace PCBs.  The exact quantity of PCB material contained in the drums is not available.  PCBs can be removed from campus only upon approval from the Ministry of Environment.  The only existing technically non-complying PCB cleaned transformers are awaiting the official stickers (Environment Canada has yet to decide upon the design of these labels, but UW is in compliance).

Spills Response Plan:
    There is a comprehensive spills response plan which is executed by the Safety Office and the numbers and procedures are posted in laboratories and on-line. There is the potential for a range of spills, from minor spills of acid to a major leak. The Safety Office co-ordinates a spills response team composed of personnel from the Science Faculty and Safety Office. In the event of a large spill Team 1, a spills clean up company, is on call. In terms of PCB facilities inspection, Ian Fraser does this monthly to monitor any changes or leaks in storage.

There was no real structural change upon the adoption of the new name.  The name was most likely changed to sound less threatening, similar to the use of the term Magnetic Resonance Imaging instead of Nuclear Magnetic Resonance because there is a perceived fear of accident or safety risk.

Fire Code:
A new ventilation system was recently installed in response to Part 4 of the Fire Code in Winter 1999.  This was an upgrade that involved new air intake and exhaust systems to improve the safety of the ESF.

Student Labs:
The laboratory demonstrator deals with safety measures in the laboratory and is familiar with chemicals used in the lab, the potential risks and how to deal with these.  Staff are extensively trained on these procedures and students are sent through WHMIS training but staff do the disposal and handling.

All waste will be bar-coded and tracked through this system.  This provides a quick and accurate information database from which to count, track and verify any aspect of a chemical storage units contents or whereabouts.  This also reduces the requirement for labour to manually track and manipulate data.  This will be an excellent tool for compliance checking.

5.2 Comments from Ian Fraser

    The annual disposal costs for the Safety Office were $86 000 in 1998; $46 000 for external contractors such as Safety Kleen for things like biomedical and reduced-volume solvents, and 35 000 to contract services from ChemStores treatment and staff, and another $5 000 for supplies.  The cost per unit of waste have remained relatively stable for disposal.  The quantity fluctuates on campus due to the nature of research in a given year.
There are a number of regulations that the Safety Office has the University comply with:

    The Transportation of Dangerous Goods Act requires a waste manifest training and placards for the movement of waste on public property.  This is not required or allowed on private property.  The requirement however, is to train the workers, have a list of goods and a spill response program.  The University of Waterloo has all of this.  All containers that are flammable are now labelled as such in response to the last ERS 285 audit.

    The University of Waterloo must comply with the Region of Waterloo municipal Sewer Use By-Law I-90.  Part 4 of the Fire Code has changed since 1997.  It is with accordance to Part 4 (Flammable and Combustible Liquids).
    University of Waterloo Policy 34 (see Appendix C) provides for a safe and healthy working and living environment on campus.  It insists that all members of the UW community adhere to standards, policies and procedures outlined in the policy and all applicable regulations such as the Environmental Protection Act and the Fire Code.

5.3  Kevin Stewart — Director of Safety

    Kevin Stewart, Director of Safety, signs a document once each year for the Board of Governors to verify that the University of Waterloo complies with the first four regulations listed by Ian Fraser.  An example of one such document is in Appendix D.  It is essentially a document which lists UW’s efforts to limit liability with respect to legislation and lists the basic requirements of a particular act, the EPA for example, and provides the corresponding UW Policies and actions to comply with this.  For example, a requirement in the EPA for operators having a licence to clean or empty a sewage system is managed by UW by using only licenced contractors.

5.4 Audit

ESF Tour
The on-site tour of the ESF conducted on March 24, 1999 revealed many environmental initiatives and safety precautions in the handling and storage of hazardous materials by the ESF and the Chemical Store.  It was observed that the ESF is efficient and organized in its procedures of sorting and separating chemicals and is proactive in its approaches in recycling and preventing safety hazards.  The following is a list of the various safety precautions and environmental initiatives observed from the ESF tour:

1) The ESF has separate, self-contained rooms for different classifications of chemicals.  Extremely hazardous materials, flammable and recycled chemicals are stored in different rooms with the necessary safety precautions for each category of chemical in each room.

2) Solvents are not poured from the barrels.  Instead they are siphoned through pipes and tapped out to avoid dangerous solvent exposure to air.

3) Explosion panels and under-floor sewer basin is built into the self-contained room for extremely dangerous chemical storage so that spills will not escape from the room into the rest of the facility.

4) Labels with extensive information including the description of the chemical, the quantity, date, name of person who deposited at the EMF, their department, building and room number are all included on each chemical label as soon as the chemical is properly identified.

5) The EMF stores radioactive half-life chemicals, dates the labels and stores them until they can be sent safely to a landfill instead of using up unnecessary space in a hazardous waste treatment facility by having the chemical treated before it becomes a non-hazardous substance on its own.

6) Any chemicals that can be recycled are separated and put back into the Chemical Store for re-use.

7) The ESF provides a wide variety of containers for departmental needs to ensure safe disposal.

8) The EMF has a security system with motion detectors that is monitored by the UW police 24 hours a day.

9) The recommendation of the 1996 report to re-arrange barrels to enable easy access to chemical barrels has been effectively implemented.

10) Rooms storing especially hazardous substances are equipped with a CO 2 sprinkler system to immediately douse and suffocate fires if they break out.

11)  The equipment for the 24-hour spill team is located in an area of easy accessibility and clearly labeled.

12)  All cupboards storing chemicals and barrels are clearly labeled for quick access and identification.

    As evidenced from the tour, it appears that here is a constant up-grading of technologies to enable the EMF to recycle more chemicals to save UW money and to reduce the amount of hazardous materials sent to SafetyKleen and other treatment facilities.

    Ian also mentioned that there is a source of contamination of the environment that is outside the boundaries of the system of this study.  In UW parking lots and along roadways, people occasionally pour oils and other contaminants into the sewers, where it immediately flows into Laurel Creek or other waterways.  The Safety Office and Plant Operations have essentially no control over this breakdown on campus.  Ian suggested that an efficient and effective solution to this problem would be to paint fish symbols on sewer grates to serve as a visual reminder that the sewer leads directly to the natural environment.  This could perhaps be an area for further study in future 285 projects.

Objectives of the ESF Tour
1. Observe first —hand the storage and treatment facilities for hazardous materials on campus.
2. Ensure that waste is properly stored with respect to container labels, positioning, ventilation, drainage, flammables.
3. Look for areas of improvement to enhance sustainability at UW.

Questions for Scott Nicoll, Manager of ChemStores
1. Please verify your pickup procedures based on the 1996 HMHF Report.  What has changed?  Why were those changes made?  How does it improve the efficiency, safety and sustainability of hazardous materials handling at UW?
2. Are all flammable materials clearly labelled (Fire Code S.
3. Does the fire code state they should be closed containers?  (this could cause an explosion)
4. Have the drums been rearranged for easier viewing and access to leaking units?
5. Do you now use a yellow flame resistant cabinet for flammable materials?

Purchasing Figures

    We requested information on the volume and expenditure for hazardous materials at the University in early March, but the Purchasing Department did not provide this information.  This would have been a useful way to examine the inputs and outputs of the system.  A cost analysis on the amount of money UW saves by recirculating chemicals and if any reductions in new chemical purchases have been made would have shed light on the efficiency and sustainability of the system.

5.5 Undergraduate Survey

    A survey was performed on undergraduate students to gauge whether or not proper safety procedures were being used in their laboratories.  This survey was performed by accidental sampling (randomly approaching students in residence and on campus).  The questions have been included as well as the table below as tools for discussion:


5.6 Graduate Survey



    From the survey response, these observations were compiled.  Most T.A.s do not prepare hazardous substances for use in the lab.  A head demonstrator is in charge of this.  The majority of Chemistry Graduate Students use hazardous chemicals for their own research but do not purchase them from ChemStores.  If more information or advertising was available, then the number without this knowledge may decrease.  All Chemistry Graduate Students are required to go through training in order to use the laboratories on campus.  Four people said they did not participate in such training.  This may be because they perform theoretical research or they do not recall taking the training.

    Only half of the respondents of the survey said that they were T.A.’s for undergraduate laboratories.  Please see above comments to Question number seven.  It was interesting to note that only two respondents had heard of the Environmental Safety Facility.  This could be due to a name change in recent months.  If more information were available on the re-structuring of this facility in 1999, general knowledge of UW’s hazardous materials handling initiatives would increase.


6.1 Audit

    It was noted that many of the appropriate recommendations made in the 1996 report were implemented — labeling and the fireproof cabinet for example.  The Safety Office and ChemStores are using the latest technologies to handle hazardous materials both more sustainably and with greater regard for health and safety.  The ESF is primarily interested in safe disposal of hazardous materials and is as accessible as possible to provide convenient services.  Hopefully, this will avoid driving illegal disposal ‘underground’.

6.2 Survey of Undergraduate Students

    All of the people who answered questions for this survey said that they handled hazardous substances while at the University.  Nearly everyone has disposed of hazardous materials as well.  The majority of these students handled these substances in labs at least once a week. All students are required to participate in a safety-training program applicable to the handling and disposal of hazardous substances.  All University of Waterloo students require WHMIS (Workplace Hazardous Materials Information System) before performing a lab.  Two students who answered our survey did not believe that they had participated in such a course.  The number of people who knew what WHMIS stood for was surprisingly low.  Nearly half of the people surveyed did not know the meaning of the acronym.  More emphasis on safety techniques might be a remedy for this. If WHMIS is brought up more in the laboratory, then awareness of the procedures may be greater.

    The majority of students in this survey agreed that their professors and Teaching Assistants encourage safe handling and disposal of hazardous substances at the University but the number that did not believe they were properly encouraged was relatively high considering that all professors and TAs should encourage safe disposal.  Approximately half had been informed of the Environmental Safety Facility’s safety standards and all had heard of the ESF and its operations.

    Virtually all students surveyed had witnessed improper handling or disposal of hazardous substances.  They were primarily poured down the drain.
The majority of students that were surveyed were first or second year.  Unfortunately, this could show the lack of knowledge about hazardous materials handling of the University of Waterloo’s lower year students.  If a more representative sample had been gathered, it might show that the experience of upper year students might have shown a greater knowledge base.

6.3 Survey - Chemistry Graduate Students

The majority of Chemistry graduates do not prepare hazardous substances for laboratory use.  A head demonstrator for the course in which they are involved as Teaching Assistants primarily does this. More than half of the people (9 of 13) who answered the survey use hazardous chemicals for their own research.  It was a fairly uniform split between once a month, once a week, to several times a week. A handful of people had used the Chem. Stores to purchase recycled chemicals. The majority agreed that they had been through an applicable safety-training program.  A few Chemistry Graduates said they hadn’t been through any safety training programs.  They would have been required to partake in WHMIS as well as a laboratory orientation as part as their Orientation Week. The majority of the people who answered the survey did not know about the Environmental Safety Facility.  One person inquired about further information.


    It is important to stress the importance of WHMIS on campus.  It currently is not taken very seriously and improvements could be made to increase the awareness of hazardous materials on campus.  Laboratory manuals should really stress the importance of proper handling of hazardous materials.

    Drain disposal is a main concern for the University of Waterloo.  It should be stressed through strict warnings that this is a serious offence and fines should be placed upon repeat offenders.  Fines should not be in the form of money.  It would be more  poignant if fines were in the form of a reduction of fifteen percent on the lab marks.  On the day of a lab or in lecture, the TA’s and Professors should emphasize  how serious not following ESF protocol actually is.   More disposal buckets at each fumehood could be provided in order to reduce the laziness factor of improper disposal.

    The TA’s should be properly trained before the commencement of the labs.  In order to encourage proper communication between the TA’s and the students, a reduction in the language barrier for discussion is greatly needed.  TA’s need to put the instructions in a language that the students will understand as well as having proper knowledge of the English language.

    More information should be available for undergraduate and graduate students alike about the ESF and Chem. Stores.  Information about Chem. Stores would pertain more to graduate students.  Information on how the ESF operates and what is it in charge of will increase awareness of its importance on campus.  There was a vested interest recorded in both surveys about the importance of the ESF.


    Future studies may be directed at examining how the University of Waterloo could serve as a model to other universities who handle wastes differently, the University of Western Ontario, for example.  Another project could focus on how to increase student compliance in laboratories.  An internal investigation of the Faculty of Environmental Studies laboratories may identify breakdowns in the disposal system as there are currently no figures available on the relationship between input and output of hazardous materials.  As previously mentioned, Ian Fraser’s suggestion about painting sewer drains to reduce the amount of untreated contaminants entering the Laurel Creek.



    In this integrated synthesis of our data, it is important to comment on whether or not the ESF achieved the criteria for sustainability and improvement listed in the methods section.  The system is environmentally sound.  For example, materials received at the ESF are recycled into ChemStores for reuse, thereby avoiding the purchase of new chemical supplies.  Distillation and other treatment methods reduce the waste volumes, which translates to fewer materials sent to landfill and disposal sites where it could cause environmental contamination and degradation.

    Because the system is environmentally sound, economic efficiency is achieved.  Fewer wastes are sent out for disposal by contractors and this has helped the University reduce its costs and achieve a more sustainable system. Staff at the Safety Office and ChemStores follow safety procedures, but many students had either witnessed or performed improper waste handling in laboratories on campus.  This is a concern because discharge into the drains is difficult to trace and the resulting breakdown in the system is a source of contamination to the environment.

    The employees at the Safety Office and ChemStores are fulfilling their legal and regulatory obligations for handling hazardous materials at UW.  The Director of Safety, Kevin Stewart, is responsible for complying with new regulations and, with Safety Office staff, designing protocols and equipment changes to meet the requirements.  The Board of Governors requires a signed document to verify that the University of Waterloo has taken the necessary steps to conform with specific regulations in each pertinent statute.

    There are still improvements to this system that can be made.  Not all disposal of chemicals that is occurring is following standard ESF protocol.  Unfortunately there is still a notable amount of hazardous chemicals that are escaping the system.  This is primarily of the escapement of chemicals being poured down the drain.  The recommendations outlined in this report suggest improvements in order to begin dealing with this challenge.  Professors and laboratory technicians are following ESF protocol by informing students of the detriment of improper handling and disposal of chemicals. Proper waste buckets are available in each laboratory to allow for proper disposal.  Students, perhaps out of convenience have the tendency not to follow ESF protocol as set out by their demonstrators.

    Although the system is currently sustainable, the recommendations outlined in this report could be taken into account by the University of Waterloo as a whole in order to continue the system’s sustainablility.



Lisa, Kate, Colleen, Erin and Christy gratefully acknowledge the following people for their invaluable insight and contribution to our work:

Patti Cook, Ian Fraser, Scott Nicoll, Jim Porter, Kevin Stewart, Susan Wismer, UW students


Chemstores, Allan Fleming, Oct. 7, 1998.
Contains links to pages with information on people at the ChemStores, Chemicals, Health & Safety, Services, Inventory and Facility Information.     This is where you can find out information about specific chemicals and their properties, where to get chemicals at UW (the redistributable inventory or new stock), phone numbers for health and safety questions and problems,  spill procedures, MSDS searches for chemical information.   This will be a useful guide to what typically goes on in the lab and what protocol students and staff follow when handling chemicals and what information they rely on for spills and questions about chemicals.

Cook, Patti, Waste Management Coordinator, University of Waterloo, Personal Interview, DC 3608, Jan 18, 1999.
Patti gave us the websites for the varioius WATgreen projects related to our assignment.  She also mentioned various contacts at UW who handle, use, or develop programs and procedures for hazardous materials.  She also believes that this topic will be of particular interest to the Executive Council because it has such disastrous potential if not carefully handled.

Environmental Safety Facility,, Scott Paterson.
Home Page of the ESF.  Has links to its mission statement (recovery and reuse of chemicals and wastes), Collection Schedules, packaging instructions, and hours of operation.  This will be valuable to those group members who plan to audit the compliance of UW’s hazardous materials handling.

Estrin, David and John Swaigen. Environment on Trial:  A Guide to Ontario Environmental Law and Policy, 3rd Edition, Canada: Edmond-Montgomery, 1993.
This book contains a comprehensive overview of the Canadian and Ontario legal systems.  It has excellent descriptions of cases and legislation up until 1993.  Provides many excellent sections including Waste Management, Pollution and Resource Management Problems.  This will be useful when checking compliance.

Gibaldi, Joseph.  MLA Handbook for Writers of Research Papers: 4th Edition.  New York: The Modern Languages Association of America, 1995.

This book gives examples of how to use the MLA style of writing.  It also discusses such topics as the mechanics of writing and how to format a research paper.  This book gave us a good idea of where to start with regards to writing drafts and note taking.  We will likely use this source further when we are writing our final draft.

Fraser, Ian and Kevin Stewart, Tour of the ESF at UW, March 24, 1999.
Ian Fraser and Kevin Stewart from the Safety Office provided an insightful tour of the Environmental Safety Facility.  We gathered essential information about recent initiatives taken by UW on hazardous materials handling and were able to observe how the system physically works.

Fraser, Ian and Scott Nicoll, Interview, March 1, 1999.
This interview was an introduction to the system at UW and provided a good background to launch our study.

Handling Chemicals Sheila Hurley, Sep 30, 1998.
A list of ten rules when handling chemicals (like reading the Materials Safety Data Sheet MSDS before using a chemical, use the fume hood, never use unlabelled chemicals, pour chemicals into containers specified by lab instructors).  There is a link to the Computability Chart where users can find out if two chemicals will react violently when stored in proximity.  This is a useful list to start to generate questions for the student survey. E.g. do you ever use unlabelled chemicals?  Do your instructors tell you where to dispose of used chemicals?

Hawthorne, Craig, et al.1992.
This site is the final report from a previous Waterloo student project on hazardous materials at UW.  It contains useful information about sources of chemical waste, important contacts on campus, student surveys and education initiatives.  We can use this to see where the ESF has gone using these and other recommendations and if it has been successful.

Hazardous Materials Handling Facility,, G. Reuss et al, Aug. 29, 1997.
The final report on the HMHF as it was in 1997, including many of the aspects we plan to study.  We will use it to gauge the ESF’s success in further improving upon the HMHF’s procedures.

Hazardous Waste — Health and Safety Program Manual,, Sheila Hurley, Aug. 14, 1998.
This site gives the location, times and dates for pickup of hazardous materials.  There is also a list of each type of waste and which container it must be stored in and how it must be labeled before pickup.

Stewart, Kevin.  Interview, March 29, 1999.
Kevin provided information about how the University ensures compliance.  This was essential to evaluating the system in the report.

Turabian, Kate L.  A Manual for Writers of Term Papers, Theses, and Dissertations: 6th Edition.  Chicago: The University of Chicago Press, 1996.
This book was useful because it gave us ideas on how to divide responsibilities.  We also used it to help with grammar and punctuation as well as the overall flow of the report.


Undergraduate Survey

The survey is given orally as follows:

We are second year environmental studies students in ERS 285 under the supervision of Professor Susan Wismer.  In order to investigate the working environment of the University of Waterloo, through the operations of the Environmental Safety Facility, Chemical Stores and the Safety Office, an independent project is under way.  In order to aid in the investigation, we would appreciate your assistance with this survey.

Our purpose is to obtain information regarding the use and removal of hazardous wastes by students at the University.

1a).   Do you handle hazardous substances at the university?    [yes, no]

1b).  If yes to 1a), do you dispose of hazardous substances at the university?  [yes, no]

2.   If you answered 'yes' to questions 1a, check how often    [once a month, once a week, several times a week]

3.  Have you participated in a safety training program applicable to the handling and disposal of hazardous substances?    [yes, no]

4.  Do you know what W.H.M.I.S. stands for?  If 'yes', please state.    [yes, no]

5.  Does your professor encourage the safe handling and disposal of hazardous substances at the University?    [yes, no]
    If 'yes', please explain.

6.  Does your TA encourage the safe handling and disposal of hazardous substances at the university?    [yes, no]
    If 'yes', please explain.

7.  Are you aware of safety standards set by the Environmental Safety Facility regarding the handling and disposal of hazardous  substances?    [yes, no]

8.  Do you follow these or other safety standards when handling or disposing of hazardous substances?    [yes, no]

9.  Have you ever witnessed improper handling or disposal of hazardous substances?  [yes, no]
    If 'yes', please give a description.

10.  Do you know about the Environmental Safety Facility and its operations?    [yes, no]
    If 'yes', please explain.

Surveyee Information

**The identity of all survey participants and their survey answers will be kept 100% confidential.

Co-op:  [yes, no]
Enrollment:    Full-time    Part-time

Graduate Student Survey

 The survey is sent on the Chemistry Graduate Student e-mailing list as follows:

    We are second year environmental studies students in ERS 285 under the supervision of Professor Susan Wismer.  In order to  investigate the working environment of the University of Waterloo, through the operations of the Environmental Safety Facility, Chemical Stores and the Safety Office, an independent project is under way.  In order to aid in the investigation, we would appreciate your assistance with this survey.

    Our purpose is to obtain information regarding the use and removal of hazardous wastes by students at the University.
        1.    Do you prepare hazardous substances for laboratory classes at UW?  [yes, no]
        2.    If 'yes' to question 1, check how often.
                once a month            [ ]
                once a week              [ ]
                several times a week  [ ]

        3.    Do you use hazardous substances for your own research at UW?  [yes, no]

        4.    If yes to question 3, check how often.
                once a month            [ ]
                once a week              [ ]
                several times a week  [ ]

        5.    If you purchase chemicals for your laboratory research, have you ever purchased re-cycled chemicals from ChemStores?

        6.     Have you participated in a safety training program applicable to handling and disposal of hazardous substances?  [yes, no]

        7.    If you are a demonstrator/TA for undergraduate laboratory classes at UW, please briefly explain safety measures you take to ensure that hazardous substances are disposed of properly.

        8.     Do you know about the Environmental Safety Facility and its operations?
                    If 'yes', please briefly explain.

            We thank you for taking the time to fill out this survey and sending it back.  This information will be kept in 100% confidentiality and the identity of the surveyees will not be made public.


Ian Fraser

Scott Nicoll


Number: 34
Effective Date: August 1, 1993
Cancels: October 1, 1991


 The University of Waterloo strives to provide a safe, healthy work and educational environment for its students, employees and visitors.  The University insists on compliance with legislative requirements and regulations contained in, but not limited to, the Occupational Health and Safety Act (OHSA), the Fire Code and the Environmental Protection Act, plus all related University of Waterloo policies and procedures.
 The OHSA, and its Regulations, require minimum standards for healthy and safe working conditions and practices for all sanctioned University activities either on or off campus.  The OHSA defines, and places duties on, three categories of individuals which, for University application, are interpreted as follows:

  A. Employer: The University of Waterloo.
  B. Supervisor: One who has charge of a workplace or authority over a "worker".
  C. Worker: One, including a student, who performs work or supplies services for remuneration.

 Except for research students and faculty members, the above interpretations are straightforward.
Depending on the function being performed at the time, a faculty member can be either a "supervisor" or a "worker". Thus, a faculty member in a classroom or teaching laboratory is a "worker" (with respect to student activities), but if there is direct supervision of one or more Teaching Assistants, or Teaching Laboratory Technicians, for those latter activities the faculty member is a "supervisor". Faculty members who supervise the activities of paid research workers (Student Research Assistants, Post-Doctoral Fellows, Technicians, etc.) have the duties and responsibilities of a "supervisor" as defined by the OHSA (Section 27).
Students in receipt of a Research Assistantship are "workers" while performing their research activities, as are Teaching Assistants when performing their assigned instructional duties.

 A. The University recognizes that persons performing required tasks without remuneration (e.g., students in laboratory courses required for their academic programs) are not "workers" as defined by the OHSA and, therefore, are not legally covered by the provisions of that Act. However, the University also recognizes that, frequently, persons who are not receiving remuneration will be performing tasks of a nature similar to those of "workers", and often these tasks will be done in the same location (e.g., a research laboratory). The University insists that all members of its community and those outside its community while performing duties for the University campus (including those who receive remuneration for services performed and those who do not, e.g., students, Adjunct Professors, Visiting Professors, contractors, sub-contractors) adhere to the requirements of the pertinent municipal, provincial and federal statutes and standards, and University policies and procedures. It insists on the application of those standards, policies and procedures as they apply to any and all activities of the University, and will ensure that its faculty and staff members and students are aware of, and adhere to, those standards, policies and procedures.
 B. Each faculty member, staff member, student and visitor has the primary responsibility for her/his own safety and actions and for others affected by her/his actions. Supervisors and all other persons in authority must provide for health and safety, including training in specific work tasks, in areas and operations under their control.
 C. Management responsibility for design and implementation of the health and safety program lies with the Director of Safety. The Director of Safety is specifically charged with the responsibility and the authority for ensuring that the University's various facilities and services conform to health and safety standards and for educational programs for faculty and staff members and students, to inform them of their responsibilities and instruct them in safe practice.
 D. The Director of Safety is empowered to take any action or steps necessary to ensure the health and safety of all members of the University community, including the authority to order the cessation of any process or procedure, or to correct any condition, which the Director judges to be unsafe. The Director of Safety shall be supported by the Vice-President, Academic & Provost in cases where a lack of response to an identified hazard requires the Director of Safety to exercise such powers.


 A. Where a laboratory or research area within a department's or section's overall space allotment is shared by several groups, or several persons, who are not all responsible to the same supervisor, overall responsibility for health and safety in that specific location must be assigned to one person in a manner acceptable to the Director of Safety.
 B. Such locations may be designated by the Director of Safety, who is prepared to offer suggestions appropriate to the particular circumstances on how this responsibility may be satisfactorily designated.

"Supervisors", "workers" or others using chemicals and other hazardous or potentially hazardous materials or equipment are to use the following as a minimum standard:

 A. At the time they start work on a research project, all persons are to be informed (preferably in writing) by the supervisor of the physiochemical properties, hazard ratings (acute/chronic toxicity, etc.), necessary safety precautions, etc., for all chemicals and other potentially hazardous materials or equipment expected to be used for any purpose. The supervisor and researchers should also review all other required safety practices at that time.
 B. Any potentially hazardous substance or equipment should not be used by any researcher who is unfamiliar with its physiochemical properties, hazard ratings and safe handling procedures. No research worker or student shall implement use of any such substances or equipment unless the supervisor is informed in advance.
 C. Any persons engaged in research regularly should review, at least annually, experimental conditions and practices as they relate to health and safety.


 A. Under the OHSA, workers must report to their supervisor(s) any hazardous conditions which are contrary to good health and safety practices or which contravene any requirements of the OHSA. It is the supervisor's responsibility to ensure that corrective action is taken at once.
 B. All members of the University community must report to their supervisor any injury or illness related to their work or assignments. It is the supervisor's responsibility to ensure that prompt first aid and health care treatment is obtained, if necessary, and that University reports are completed by the end of the next University business day.
 C. It is the unconditional right of all members of the University community to bring, without prejudice, health and safety concerns to their supervisors, or to the Director of Safety, or to the Joint Health and Safety Committee. The supervisors in every case must be informed of a concern before a complaint is taken elsewhere.
 D. All members of the University community have the right to refuse work or assignments that they believe are unsafe. This includes situations where the equipment they are to use or the condition of the workplace is unsafe and/or violates the law. In such cases members of the University community must report their refusal to their supervisor. The supervisor must investigate the situation in the presence of the person refusing and their health and safety representative. If the work refusal is not resolved the supervisor must then notify the Director of Safety or designate who will notify a Ministry of Labour inspector. OHSA (Section 43) sets out a specific procedure that must be followed by supervisors and workers.


 A. The Joint Health and Safety Committee is an advisory group of worker, management and student representatives who meet regularly to discuss health and safety concerns. The Committee's functions under the OHSA include: receiving health and safety concerns from members of the University community; providing input on the University's health and safety program; conducting workplace inspections; ensuring that a worker member is present during a work refusal situation; investigating cases of critical injury or fatality. Members of the University community are encouraged to contact any member of the Joint Health and Safety Committee to discuss health and safety related concerns.
 B. The Director of Safety will be advised by the Joint Health and Safety Committee and shall serve as a resource person for the Committee.
 C. Departments are required to post the names and work locations of Joint Health and Safety Committee members in the workplace where they are likely to come to the attention of workers.
 D. The membership of the Joint Health and Safety Committee is listed in Appendix A. of this policy.


 A. As part of its function of maintaining University physical facilities, the Department of Plant Operations will be responsible for correcting unsafe conditions that result from normal wear and tear of buildings and grounds and will, in some cases, respond to changes in building codes or similar regulations.

B. Most health and safety hazards identified by the Director of Safety or the Joint Health and Safety Committee are to be corrected by members of the University community acting through routine University channels. When a health and safety problem cannot be solved in this manner it will be reported by the Director of Safety to the senior University administrator{1} responsible for the workplace in which the hazard exists, usually with a recommended solution. The decision whether to act on a recommendation rests with the appropriate senior administrator, as does accountability for safety in the area managed. Under most circumstances, alterations to buildings or grounds required in response to safety concerns will be paid for from already existing financial resources which exist within the senior administrator's budget. If, after determining that the risk level is acceptable, a senior administrator decides not to act on a recommendation, this decision, and the accompanying reasons, must be communicated in writing to the Director of Safety. If a senior administrator agrees with the recommendation but feels that the associated costs clearly exceed what a line manager might reasonably be expected to pay, the senior administrator may submit a request for special funding to the Vice-President, Academic & Provost, who holds the ultimate authority for the allocation of University funds.

C. In addition to receiving reports periodically from the Director of Safety, the Provost receives and reviews major health and safety concerns coming from
the Joint Health and Safety Committee which have been identified by the Director of Safety as being of a magnitude that requires a University-level response. Based on the advice and recommendation(s) received through whatever mechanism the Provost deems appropriate, the Provost shall determine what may be an acceptable level of risk, or a remedial action, and shall make such decisions known to the Joint Health and Safety Committee.
Revisions approved by Executive Council, July 1993


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