HAZARD COMMUNICATION PROGRAM
1.0 INTRODUCTION
Approximately one worker in four is exposed to chemical hazards on the job. Exposure to chemicals can cause serious health effects such as skin rashes, burns, organ damage, birth defects, and cancer. In addition, many chemicals are fire and explosion hazards. Recognizing the seriousness of these problems, OSHA has adopted a Hazard Communication or Right-To-Know Standard. This Standard requires employers to inform workers of chemical hazards in the work place and to provide measures to minimize exposures. The goal of the Standard is to reduce the incidence of illness and injuries due to chemical exposure.
2.0 PROGRAM
1. The Safety Manager will manage, review, and update the Hazard Communication Program as necessary to ensure compliance with OSHA regulations. The effectiveness of the Program will be reviewed annually by the Safety Manager.
2. Copies of the program, chemical inventory, MSDSs, and further information on chemical hazards may be obtained from the Safety Office by calling 831-7790..
3. A copy of the university's written Hazard Communication Program will be made available to contractors upon request.
3.0 CHEMICAL INVENTORY
1. Departments using chemicals, other than laboratories and the warehouse, will maintain a list of all hazardous chemicals used in their area. Chemicals generated by a work process will also be included in the inventory.
2. The identity of the chemicals on the list will correspond to the MSDS and label.
4.0 MATERIAL SAFETY DATA SHEETS
1. An MSDS will be maintained for all hazardous chemicals used at the university. Departments will maintain files for chemicals used in their work areas to provide employees with immediate access to MSDSs.
2. MSDSs will be reviewed by supervision or the Safety Manager to ensure that they are complete and clearly written. If necessary, the Safety Manager will write a letter to the manufacturer requesting additional information or a complete MSDS. The university will rely upon the hazard determinations provided by the manufacturer.
3. The Safety Manager will attempt to obtain an MSDS from the manufacturer or MSDSonline as soon as possible if one is not on file. The local OSHA office will be notified if the manufacturer fails to respond after three documented requests.
4. The university will not use a hazardous chemical unless an MSDS can be obtained. Hazardous chemicals that omit physical properties and health effects on the MSDS because of trade secrets shall not be used.
5. A properly prepared MSDS will accompany any hazardous material shipped from the university.
6. The university contracts with KellerOnline to provide MSDSs to employees. Employees may obtain MSDSs by calling the Safety Manager during normal working hours at 831-7790 or 831-7800. After hours accessibility is available by calling the University Police Department at 831-5500.
7. In addition, employees can request an MSDS through the internet.
8. MSDS files will be updated by the Safety Manager if new information is provided by the manufacturer concerning health hazards of the chemical. Affected employees will be retrained if necessary.
5.0 LABELS AND OTHER FORMS OF WARNING
1. Supervisors will ensure that hazardous chemicals received at the university are properly labeled with the name of the chemical, appropriate hazard warning and the name and address of the manufacturer, importer, or other responsible party. Chemicals without proper labeling will not be accepted. If a chemical is regulated by OSHA, the Safety Manager shall verify that the label meets the requirements of the standard. Labels must not be removed or defaced unless the container is immediately marked with the appropriate information. Chemicals shipped from the university will be properly labeled.
2. Secondary containers not intended for use during the work shift must be labeled with the name of the chemical and appropriate hazard warnings. Signs will be posted near stationary process containers that have similar contents and hazards rather than labeling individual containers.
3. Pipes and piping system will not be labeled but their contents will be described in training sessions. Processes that generate hazardous chemicals shall be properly labeled.
4. In-house labels will allow hazards to be communicated in writing and/or by NFPA coding. Secondary labels will correspond to the information on the primary label and MSDS. These labels will be reviewed and updated as necessary by the Safety Manager.
6.0 EMPLOYEE INFORMATION AND TRAINING
1. Employees working with, or potentially exposed to, hazardous chemicals will receive information and training on the hazards of chemicals in their work area, safety procedures, and the requirements of the Hazard Communication Standard. Training shall be performed at the time of the employee's initial assignment and whenever a new hazard is introduced into the work area.
2. The Safety Manager will supervise the employee training program. Training shall consist of lectures, handouts, video tapes and/or slides, and contain the following information:
3. Information presented in the initial training session will be reviewed during regular safety meetings. Employees will have the opportunity to ask questions. Supervisors shall receive extensive training so they can answer employee questions and monitor safe work practices.
4. Records of participation in training classes will be maintained by the Safety Manager. The Safety Manager will periodically review and update the training program and solicit ideas from employees.
5. Employees required to perform non-routine tasks (e.g., cleaning tanks, entering confined spaces) that could involve exposure to hazardous chemicals shall be informed of the potential hazards and proper safety procedures. Employees will be informed of the hazardous chemicals in unlabeled pipes in their work area and the safety precautions to prevent exposure.
6. The Safety Manager, upon notification by the responsible supervisor, will inform outside contractors of the hazards associated with on-site chemicals, appropriate safety procedures, labeling system in use, and the location of MSDSs. Contractors will be responsible for training their employees in the hazards of chemicals they bring to the work area.