Environmental Health & Safety
 

                           Hazard Communication Program 

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Table of Contents 

1.  Introduction 

2.  Chemical Inventory and Materials Safety Data Sheets 

3.  Signs and Labels 

4.  Exclusions 

5. Exposure  

6. Training    

7. Fire Safety  

8. Outside Contractor’s Responsibilities  

9.  Asbestos Notice and Labeling   

 

 

1.  Introduction

 

1.1 Almost every workplace contains some substances which could pose potential health problems to employees if exposed to them in concentrations or in a manner not prescribed. Rose-Hulman Institute of Technology recognizes that its employees have the right and need to know the properties and potential safety and health problems of substances to which they may be exposed. With this policy, Rose-Hulman Institute of Technology intends to ensure the transmission of necessary information to employees regarding substances in the workplace, pursuant to the Federal Occupational Safety and Health Act Hazard Communication Standard, 29 Code of Federal Regulations 1910.1200.

1.2 A hazardous substance is defined as any substance that is a physical hazard or a health hazard, i.e. compressed gases, explosives, flammables, oxidizers, carcinogens, toxins, irritants, or corrosives. Hazardous substances generally have a Material Safety Data Sheet (MSDS) provided by the manufacturer.

1.3 This policy is established to:

a.       Ensure compliance with the applicable state and federal standard.

b.       Safeguard the health and safety of Institution employees.
 Create guidelines to follow for implementation and maintenance of a hazard communication program.

 

1.4 The Hazard Communication Program for Rose-Hulman Institute of Technology shall be administered by the Environmental Health & Safety Coordinator, whose line of administrative authority is through the Director of Administrative Services. The Hazard Communication Coordinator has been designated as the Master Record Keeper.

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2. Chemical Inventory and Material Safety Data Sheets

 

2.1 Annual updates of the Chemical Information Lists (CIL) beginning with the fiscal year July 1, 2002, are required. Individual department supervisors shall complete and mail Chemical Information Lists (CIL) to the Master Record Keeper no later than August 1 of each year. CIL's must be submitted in alphabetical order and shall be verified for completeness by the appropriate department head. Each CIL is subject to audit by the Master Record Keeper. The Master Record Keeper will provide copies of the CIL to the Local Fire Department and the Local Emergency Planning Committee.

2.2 A master CIL shall be created and maintained by the Master Record Keeper in a manner that will allow a listing of hazardous substances by manufacturer, department, building, and room.

2.3 Each building on campus shall have a CIL. The CIL shall include a listing of all hazardous substances present. The Master Record Keeper will develop an overall building CIL by combining the individual lists supplied by each department/area in the building.

2.4 Each time a department receives a new hazardous substance; the substance shall be added to the departmental CIL within 30 days. A copy of the CIL, along with the original copy of the Material Safety Data Sheet (MSDS) for the new substance, must be sent to the Master Record Keeper.

2.5 Material Safety Data Sheets (MSDS's) provide detailed information on a hazardous substance. The sheets include information such as product name (hazardous substance), chemical abstract service number(s), ingredients, physical data, fire and explosion hazard data, environmental and disposal information, health hazard data, first-aid instructions, and handling precautions.

2.6 Department Heads must assure that MSDS's for all hazardous substances in the work place are obtained. A copy of the MSDS's must be kept in the department and be readily accessible to employees who work with the hazardous substances. The original copies of MSDS's must be sent to the Master Record Keeper to be placed in the master file. Copies of the MSDS's should be placed in a filing cabinet, notebook, etc., and marked with an MSDS label available from the Master Record Keeper.

2.7 Purchase orders for any hazardous substance, regardless of the quantity ordered, shall require that a MSDS be obtained. It is the responsibility of the ordering department (Department Head) to make every effort to obtain an MSDS from the manufacturer. If difficulties are encountered, the Master Record Keeper can assist.

2.8 Areas that store hazardous substances for distribution to other departments must obtain MSDS's for these substances and prepare a CIL. When the storeroom sells or transfers a hazardous substance to another department, the manager of the storeroom shall assure that the receiving department or individual receives a copy of the MSDS. Likewise, if the storeroom prepares a substance by any process for distribution to another department or individual, then the storeroom has assumed the role of the manufacturer and must prepare an MSDS for the substance. The Department Head over the storeroom areas shall assure that the above steps have been completed.

2.9 Should the supervisor of an area dealing with hazardous substances become aware of any information that is significant in regard to the health hazard of a substance (that does not appear on the MSDS), he/she must add the information to the MSDS within a period not to exceed 30 days. The supervisor must also report this information to the Master Record Keeper. The information will be added to the master file and reported in writing to the appropriate state agency for follow up investigation with the chemical manufacturer.

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3. Signs and Labels

 

3.1 All existing labels on containers of hazardous substances must remain intact. The labels must be legible and written in English. Where labels are not present or are not legible, a Hazardous Identification Information System (HMIS) label will be affixed to those containers holding the hazardous substance.

3.2 It is the responsibility of Department Heads to assure that each container of a hazardous substance in the workplace is marked, labeled or tagged with the...

a. Common/trade name of the substance.
b. Appropriate hazard warnings: Health, flammability, reactivity, and personal protective equipment.
c. Chemical abstract service number (CAS).

HMIS labels are available from the Master Record Keeper for this purpose.

3.3 Portable containers filled with hazardous chemicals transferred from a labeled storage container must be labeled if:

a. The material is not used within the work shift of the employee making the transfer.
b. The employee that made the transfer leaves the work area.
c. The container is moved to another work area and is no longer in possession of the employee who filled the container.

Labels on portable containers are not required if the employee who made the transfer uses all of the contents during the work shift.

 

3.4 Storage tanks shall be labeled with the identity of the substances that it contains. The label must show the health, flammability, reactivity, and physical hazards associated with the substance. The National Fire Protection Association (NFPA) rating system must be used to show these ratings.

3.5 Containers used by outside service contractors shall be properly labeled with either a manufacturer's label or an HMIS label prior to the use of the hazardous substance on Institution property.

3.6 Employees that work in the storeroom areas, where sealed containers of hazardous substances are received for distribution to other departments, shall assure that the manufacturer's labels are not defaced or removed. If the labels are removed or defaced, follow the procedure outlined in 3.02 for replacement of the labels. In addition, if a spill or leak occurs in a container of hazardous substance, the employees should leave the area, go to a place of safety, and call the Environmental Health and Safety Department for assistance. MSDS's for all substances in the storeroom must be obtained and be readily accessible to employees.

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4. Exclusions  

 

4.1 These regulations do not apply to any substances which are foods, drugs, cosmetics, or tobacco products intended for personal consumption by the employees while in the workplace. Additionally, these regulations do not apply to any consumer products and foodstuffs packaged for distribution to (and intended for use by) the general public. Consumer products are packaged and used as a normal consumer would use the product as defined in the Consumer Product Safety Act and Federal Hazardous Substances Act.

4.2 The term "laboratory" is intended to mean a workplace where relatively small quantities of hazardous chemicals are used on a nonproduction basis. All research laboratories may be excluded from the standard except for the following requirements:

a. Complete a CIL and submit a copy to the Master Record Keeper.
b. Conduct a training and education program that shall be designed to      inform employees of appropriate work practices, protective measures, and emergency measures regarding hazardous materials in the workplace.
c. Supply employees with the chemical name of all hazardous substance.
d. Maintain MSDS's and make them readily accessible to employees.
e. Ensure that containers of hazardous substances bear a legible manufacturer's label or an HMIS label.
f. Develop and implement a written chemical hygiene plan and provide a copy to the Master Record Keeper. Use the RHIT Laboratory Safety Manual as a guide to develop the Chemical Hygiene Plan. 29CFR 1910.1450.

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5. Exposure

 

5.1 Exposure or exposed means that an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.), and includes potential (e.g. accidental or possible) exposure as referenced by the MSDS. When the employer discovers that an employee has received a potentially hazardous exposure to any substance or agent, the employer must immediately notify the employee and take such steps that may be necessary to provide medical evaluation, monitoring, or treatment. Likewise, an employee that has received a potentially hazardous exposure to a substance or agent must immediately notify the employer of such exposure.

5.2 After the appropriate safety and health precautions have been taken, it is the responsibility of the employee's supervisor to fill out an Employee Exposure Report (EER). EER forms are available from the Master Record Keeper. The completed EER should be submitted to the Master Record Keeper (original copy), with a copy retained at the department and a copy provided to the employee.

5.3 The Master Record Keeper will retain the original EER and send a copy to the Risk Management and Human Resources offices. The Human Resources Office will place the EER in the employee's permanent personnel file to be retained for the length of employment plus 40 years.

5.4 An affected employee (or designated representative) may make a request to the Master Record Keeper or employing department for access to copies of the appropriate CIL and MSDS's. Access to the appropriate CIL and MSDS's shall be granted within a reasonable time, place, and manner, but never later than one working day after the request for access is made. In addition, whenever an affected employee or designated representative requests a copy of the CIL and/or MSDS's, the Master Record Keeper shall, within 15 days, assure that either a copy or a mechanical means to copy is provided.

5.5 An employee that has requested information as stated in section 5.04, and has not received the requested information within the specified time period, may refuse to work with the substances or refuse to work at the location for which the request was made. An employer may not discharge or initiate any adverse personnel action against any employee because the employee has exercised his/her right to the requested information. Furthermore, an employer may not request or require an employee to waive any rights under this policy. Any such waiver executed shall be null, void, and unenforceable.

5.6 Employees working in areas where exposure(s) to hazardous substances exist shall be required to perform their jobs in accordance with precautions communicated to them during training and education programs. A supervisor may take the appropriate disciplinary action when an employee does not comply with the precautionary measure this policy indicates.

5.7 The Department Head or designee shall be responsible for providing the following in all departmental areas having contact with hazardous substances:

a. Chemical name of each hazardous substance.
b. Correct labeling of each hazardous substance.
c. Availability of any MSDS for each hazardous substance present in the immediate work area.
d. Training and education of employees on work practices, protective measures, and emergency measures in the work place.

5.8 Periodic checks for program integrity will be made by means of an audit team comprised of personnel from the Environmental Health and Safety Office.

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6. Training  

 

6.1 The Master Record Keeper will present a Train-the-Trainer Program for department heads/designated employees of campus departments who will be responsible for the training of their employees on the Hazard Communication Program.

6.2 All employees of Rose-Hulman Institute of Technology must receive Hazard Communication training. All employees will include temporary, work-study, part-time, graduate assistants, teaching assistants, and full-time personnel. New employees will receive a general information on Hazard Communication from Human Resources at the start of employment.

6.3 Department supervisors shall inform their employees of the requirements of the Hazard Communication Standard (cover the four stages of the program), any operations in their department where hazardous substances are used, the location and availability of the MSDS's and CIL, and a review of the department Contingency Checklist. In addition, the training must cover the methods used to detect the presence of a substance released and the steps to take after the release is detected, the physical and health hazards in the department, the measures and equipment used for personal protection, and the details of the written plan. The training must occur within 30 days of employment for new employees. Any time a new hazard is introduced into the workplace, employees must be trained on the hazard; and an annual retraining session is required for all employees.

6.4 Training and education provided to employees and others must be documented with detailed records of training maintained by the department. The training records must be kept for the length of employment plus 40 years. A copy of all training records must be sent to the Master Record Keeper.

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7. Fire Safety  

 

 

7.1 The Master Record Keeper will create a building CIL package consisting of floor maps and rooms CIL. The building CIL packages will be submitted to the Local Fire Department and will be updated annually by the Master Record Keeper.

7.2 In addition to the annual update requirement for the CIL, each department/area on campus is required to complete and submit a Contingency Checklist. The Contingency Checklist should be completed and sent to the Master Record Keeper at the same time the annual CIL is sent. The Contingency Checklist is needed to prepare and update the Campus/County-wide Contingency Plan. The Contingency Checklist forms are available from the Master Record Keeper.

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8. Outside Contractor’s Responsibilities  

 

8.1 Any time an outside contractor brings a hazardous substance(s) into the workplace, a CIL and MSDS(s) for the substance(s) must be received. Similarly, a CIL and MSDS(s) for all hazardous substances in the area that the contractor will be working must be provided to the contractor. This exchange will be coordinated by whoever is granting the contract. A contractor safety form must be signed stating the contractor agrees to this provision.

8.2 Service contractors whose work or materials pose a health hazard to employees shall be responsible for the training and education requirements outlined under the training section of this policy.

8.3 The above cross-training must be documented and the records must be retained in the department where the work is performed. Copies of the cross-training records must also be sent to the Master Record Keeper.

8.4 Outside contractors must comply with all of the provisions of the Hazard Communication Standard while serving on the OSU Stillwater campus. Periodic audits from the Master Record Keeper will be performed to assure compliance.

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9. Asbestos Notice and Labeling  

 

9.1 Pipes, boilers, storage vessels, structural members, or equipment with insulating material that might be removed, penetrated, damaged or otherwise disturbed by repair, remodeling, renovation, maintenance or other activity, shall be labeled with cautionary labels. Such caution labels shall be printed in letters of sufficient size and contrast as to be readily visible and legible. Each room or area where the conditions require that labels exist shall have a minimum of one such label, and additional labels as is necessary, to insure ready visibility and legibility. Equipment with asbestos-containing material shall bear the following label:

DANGER

Contains Asbestos Fibers
Avoid Creating Dust
Cancer and Lung Disease Hazard


9.2 Areas with asbestos-containing material used as acoustical material on ceilings or walls shall post the following notice:


NOTICE TO EMPLOYEES
This facility has been inspected
for the presence of
Asbestos-containing material.
Asbestos-containing material is present in this facility.
Asbestos-containing material may cause health problems.

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