Hazard Communication

In March 2012, the Occupational Safety and Health Administration (OSHA) revised its Hazard Communication Standard to align it with the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). The revision to the Hazard Communication Standard (HCS) built on the existing standard, by requiring chemical manufacturers, importers, or distributors to follow specific criteria when evaluating the hazardous chemicals and when communicating the hazards through labels and safety data sheets (SDS).  The previous HCS standard required chemical manufacturers, importers, or distributors to communicate hazards through Material Safety Data Sheets (MSDS).  WCU is classified as a non-manufacturing employer where employees use a variety of hazardous chemicals during their employment.  Therefore, the HCS applies to any WCU facility or department that uses hazardous chemicals. 

The Hazard Communication Program applies to all employees who work with chemicals in a non-laboratory area or may come in contact with a hazardous chemical as part of their work and are subject to the requirements outlined in the program.  To comply with the OSHA Hazard Communication Standard (29 CFR 1910.1200) and ensure that all chemicals are evaluated and that information concerning their hazards is transmitted to the employees, the program must include the following elements:

• A written hazard communication plan
• Precautionary labels on containers
• An inventory of known chemicals to be present in the workplace
• Posted area warning signs
• Availability of Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS)
• Initial chemical safety training and when new chemicals are introduced into the workplace
• Advise outside contractors of any hazardous chemicals to which its employees may be exposed

Laboratory Application
Individuals who work with chemicals in laboratories are required to comply with the OSHA Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450), more commonly known as the Laboratory Standard.

The Hazard Communication Program applies to laboratories only as follows:

• Ensure that labels on incoming containers of hazardous chemicals are not removed or defaced.
• Maintain all existing Material Safety Data Sheets (MSDS) and Safety Data Sheets (SDS) for incoming containers of hazardous chemicals and ensure they are readily available to employees.
• Employers shall ensure that employees are provided information and training on the associated hazards of chemicals in their workplace.

Laboratories must comply with all hazard communication elements for non-lab chemicals being used i.e. housekeeping, maintenance activities etc.  Refer to the Western Carolina University Chemical Hygiene Plan for more information.

Safety and Risk Management 

Safety and Risk Management has the primary responsibility for the implementation and enforcement of the HCP and is responsible for the following:

• Developing, implementing, and evaluating the Hazard Communication Program (HCP) to ensure compliance.
• Providing general information and training related to hazard communication for affected university supervisors and managers.
• Assisting supervisors and managers with employee training.
• Assisting supervisors and managers in identifying hazardous substances present in the work area and evaluating potential hazards.
• Recommending appropriate engineering controls, administrative controls and personal protective equipment (PPE).

Supervisors and Managers   

Supervisors and Managers in support and administrative areas are responsible for providing the necessary direction and support to ensure the effective implementation of the HCP for their work areas.  Supervisors and Managers are responsible for the following:

• Notifying all employees of the purpose and intent of the HCP.
• Identifying hazardous chemicals in their work area that may pose a potential health or physical risk to employees.
• Ensure that affected employees are trained in general hazard communication.
• Establish and implement department specific hazard training program for affected employees.
• Ensure that all containers of hazardous substances are appropriately labeled.
• Obtain MSDS or SDS for all hazardous substances used in the work area.
• Ensure MSDS or SDS for all hazardous substances in their work area are readily available for employees.
• Ensure that employees follow established safety procedures.
• Adequately inform non-university personnel sharing the same work area of the hazardous substances to which their employees may be exposed while performing their work.

Employees

Affected Employees are responsible for the following:

• Complying with the HCP procedures.
• Attending and completing required general and department specific hazard training.
• Knowing the hazards and precautionary procedures for the hazardous substance used in their work area.
• Knowing the location and use the information provided by the MSDS or SDS.
• Planning and conducting operations in accordance with established procedures and good safety practices.
• Using personal protective equipment and clothing in accordance with prescribed training.

A complete list of definitions is located in the OSHA standard 29 CFR 1910.1200 (c).

Container:  Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank or the like that contains a hazardous chemical.

Exposure or exposed:  Any situation where in the course of employment an employee is subjected to, or potentially subjected to a chemical that is a physical or health hazard. This can occur by ingestion, inhalation, absorption or other contact.

Hazard warning:  Any words, pictures, symbols or combination thereof appearing on a label or other appropriate form of warning which convey the health hazards and physical hazards of the substance(s) in the container(s).

Health hazard:  A substance for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees.

Hazardous chemical:  Any chemical which is a physical or health hazard. This definition also applies to asbestos, a hazardous fibrous silicate mineral.

Immediate use:  The hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.

Label:  Any written, printed or graphic material displayed on or affixed to containers of hazardous chemicals.

Laboratory:  A facility where the laboratory use of hazardous chemicals occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis.

Physical hazard:  Means a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.

Safety data sheet (SDS):  Means written or printed material concerning a hazardous chemical that is prepared in accordance with the GHS. 

Use:  To package, handle, react, emit, extract, generate as a byproduct, or transfer.

Work Area:  Means a room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present. 

Workplace:  means an establishment, job site, or project, at one geographical location containing one or more work areas.

Hazardous chemicals are defined by OSHA as any chemical which poses a physical or health hazard.

Chemical physical hazard characteristics include substances which are:

• Combustible
• Compressed gases
• Explosive
• Flammable
• Organic peroxide
• Oxidizer
• Pyrophoric
• Unstable (reactive)
• Water reactive

Chemical health hazards include substances which are:

• Carcinogens
• Toxic or highly toxic agents
• Reproductive toxins
• Irritants
• Corrosives
• Sensitizers
• Toxic agents or substances that damage or destroy bodily organs

Toxic Effects of Chemicals

All chemicals have toxic effects at some dose level for some route of exposure.  It is therefore wise to minimize exposure to chemicals.  Chemicals can have local or systemic effects.  Local toxicity refers to the direct action of chemicals at the point of contact.  Systemic toxicity occurs when the chemical agent is absorbed into the bloodstream and distributed throughout the body, affecting one or more organs.  Toxic effects are also classified as acute or chronic.  Acute effects are observed shortly after exposure.  Chronic effects result from long term exposure and appear after a latency period.   

Routes of Exposure

There are four routes of exposure to chemical substances: inhalation, absorption, ingestion, and injection.
Inhalation: Inhalation of toxic vapors, mists, gases, or dusts can produce poisoning by absorption through the mucous membrane of the mouth, throat, and lungs and can seriously damage these tissues by local action.  Inhaled gases or vapors may pass rapidly into the capillaries of the lungs and be carried into the circulatory system. The degree of injury resulting from inhalation of toxic substances depends on the toxicity of the material, its solubility in tissue fluids, its concentration, and the duration of exposure.
Inhalation hazards are most often associated with gases and volatile products such as adhesives, wood finishes, or paint thinners. Dust and non-volatile liquids can also present an inhalation hazard. Materials in the form of dusts and particulates can become airborne when transferred from one container to another or by grinding and crushing.  Splash created from spills and during vigorous shaking and mixing also results in aerosol formation.  Many of the particulates generated during such procedures do not settle out but remain suspended in the air and are carried about by air currents in the room.  Some of these particulates are capable of being inhaled and deposited in the respiratory tract. For many operations it is not obvious that an aerosol is being generated and personnel may not be aware that a hazardous situation exists.
Absorption: One of the most frequent exposures to chemicals is by contact with the skin.  Spills and splash can result in overt contamination of the skin.  A common result of skin contact is localized irritation or burns.  However, some materials are also absorbed through the skin to produce systemic poisoning.  Skin contact hazards are often associated with caustic or acidic cleaners which are highly corrosive to skin tissue on contact or with petroleum based products which are irritating on repeated contact.
The eyes are of particular concern because they are so sensitive to irritants.  Ocular exposure can occur via splash or when contaminated hands rub the eyes.  Few substances are innocuous in contact with the eyes and a considerable number are capable of causing burns and loss of vision. The eyes are very vascular and provide for rapid absorption of many chemicals.
Ingestion: Occurs by the direct tasting of chemicals, and by ingesting contaminated food or applying contaminated personal items such as make-up on the face.  This mostly happens as a result of eating or drinking contaminated food, dirty utensils, or touching the mouth with contaminated hands.   
Injection: Occurs through needle sticks, broken glass, broken capillary tubes, or other sharp objects that have been contaminated with chemicals. 

Identification of Hazardous Substances

The responsibility of determining whether a chemical is hazardous lies with the chemical manufacturer or importer of a chemical.  Supervisors, managers, or employees may rely on the evaluation received from these suppliers, in the form of a MSDS or SDS and warning labels.  All identified hazardous chemicals must have a corresponding MSDS or SDS readily available in a binder or electronically accessed.  The binder must be identified with the same SDS acronym on the binder spine and the front cover should read “Safety Data Sheets”.  The electronic file must be identified with the acronym SDS in the file or folder name.   Both binder or electronic version must be accessible to every employee of that area during all working hours.  A hard copy is strongly recommended if there is limited accessibility of the electronic version. 

Each department or campus unit has the responsibility to compile and maintain an inventory list of known hazardous chemicals within their workplace.  The chemical list can be prepared by documenting the names of the chemicals that have warning labels indicating a potential hazard (e.g. flammable, corrosive, etc.). The chemical inventory shall be updated annually, or as new chemicals are introduced or when old chemicals are disposed of within the workplace.  The chemical inventory list must contain the following information for each hazardous chemical or product found in the workplace:

• The identity of the chemicals as specified on the MSDS or SDS for that chemical.
• The location (room number or work area) that the chemical is used or stored.
• The average quantity of the chemical that is generally kept at the location

A copy of the department chemicals inventory list or when any changes to the list are made shall be sent to the Safety and Risk Management office for recordkeeping.  Safety and Risk Management will compile a university master list of known hazardous chemicals used on campus.  Any employee who has questions about the hazardous chemical inventory list should contact their immediate supervisor or manager. 

Chemical manufacturers and distributors are required by OSHA to provide Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) to consumers.  A MSDS or SDS is provided to ensure the end-user of chemical products is informed of the hazards associated with the use of the chemical and what safety precautions should be utilized.  The same SDS may be used for several chemicals if they have similar hazards and contents.

Each department must maintain a complete and accurate MSDS or SDS for each chemical used in the workplace upon the purchase of a chemical.  The following shall apply:

• When new or significant information becomes available concerning the hazard of a chemical or improved method of protection for employees, the chemical manufacturer, importers, or distributors must provide an updated SDS with updated information.
• If the manufacturer, importer, or distributor fails to send a SDS with a shipment labeled as a hazardous chemical, then the supervisor or manager shall obtain one from the manufacturer, importer, or distributor prior to the use of the purchased material or ensure that the SDS is available through electronic retrieval.
• Should the SDS be incomplete or unclear, the supervisor or manager should contact the manufacturer, importer, or distributor to get clarification or obtain the missing information.
• If employees travel between workplaces, the SDS may be kept at a known central location. However, employees shall be able to obtain the required information in an emergency. 

Supervisors or managers have the responsibility to insure all known hazardous chemicals present in the workplace display a precautionary label.  With the changes in the HCS to include the Globally Harmonized System (GHS), the shipping chemical label is divided up into six sections.  Chemical manufacturers, importers, and distributors are required to properly label every container of a hazardous chemical entering the workplace with the following:

• Chemical Name: Simply identify the product or chemical name.  
• Signal word: Use to indicate the relative level of the severity of the hazard and alert the reader to a potential hazard.  The signal words are “Danger” for more severe hazards and “Warning” for less severe hazards.
• Hazard statement: These are phrases that describe the nature of the hazardous chemical and the degree of hazard(s).  Examples are: toxic if swallowed, may cause skin irritation.    
• Pictograms: There are nine different pictograms used to identify hazardous products with symbols.  They convey health, physical, and environmental hazard information assigned to a GHS hazard class and category.

• Precautionary Statement: Is a phrase that describes recommended measures to minimize or prevent adverse effects resulting from exposure to or improper storage or handling.   
• Manufacturer Information: Identifies the manufacturer’s company name, address, and phone number.
  If the chemical label on the original container becomes damaged, illegible, or is inadvertently removed from the container, it shall be replaced immediately by the department supervisor or manager.  Employees have the option to replace labels at the direction of their direct supervisor or manager.  The replacement label must include the same information that was initially provided by the manufacture, importer, or distributor.  All labels must be legible, in English, and prominently displayed on the container. 

Secondary Container Labels   

Chemicals which are transferred from the original container into a different secondary container shall be identified by a label on the secondary container.  All secondary containers shall use either the National Fire Protection Association (NFPA), Hazardous Materials Information System (HMIS), or manufacturer’ s label of the appropriate size for the container.  Supervisors or managers will ensure that appropriate labels are available.  Secondary labels need to include:

• Chemical name
• Date when transferred
• Associated hazards

Remember:  Whoever transfers a chemical from the original container to a secondary container is obligated to label the chemical container. 

NFPA Labels

The NFPA diamond was developed by the National Fire Protection Association to aid emergency responders in recognizing potentially hazardous situations.  Each colored diamond is associated with a different type of hazard and the degree of severity of Health, Flammability, and Instability hazards.  Hazard severity is indicated by a numerical rating that ranges from zero (0) indicating a minimal hazard, to four (4) indicating a severe hazard.

The bottom diamond represents special hazards and has a white background.  The special hazards in use include W, OX, and SA.  The symbol W indicates unusual reactivity with water and is a caution about the use of water in either firefighting or spill control response.  The symbol OX, indicates that the material is an oxidizer.  The symbol SA, indicates that the material is an asphyxiate gas.  Example gases are nitrogen, helium, neon, argon, krypton, or xenon.

HMIS Labels

Hazardous Materials Identification System (HMIS) is a system developed by the National Paint and Coating Association (NPCA) to help identify and provide information about chemical hazards.  The label contains four (4) different colored rectangular shapes that are related to different hazards similar to the NFPA system.  Hazard severity is indicated by a numerical rating that ranges from zero (0) indicating a minimal hazard, to four (4) indicating a severe hazard.  The Personal Protective Equipment (PPE) section of the label requires the use of a chart or table to determine which letter code corresponds to appropriate PPE that should be used when working with the chemical.  The HMIS PPE chart should be posted in the work area for quick and easy recognition by employees.  A labeling guide is available here.

All employees who work in areas where hazardous chemicals are used or maintained must receive Hazard Communication Training.  Employees must be provided with effective information and training on hazardous chemicals to ensure they are aware of hazards in the workplace and appropriate control measures to protect themselves.       

Non-university (i.e. contactor or contract workers) personnel working at any campus location shall be informed by the primary university contact (i.e. project manager, supervisor) about workplace hazards by providing SDS, communicating precautionary measures, and explaining labeling systems in place at the university. 

Contractors are required to provide the university with a list of the hazardous chemicals they will be bringing to the job site so that precautions can be taken.