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 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. A copy of WCU's Hazard Communication Program is available for download here.

The purpose of the Hazard Communications Program (HCP) is to ensure employees are aware of the hazardous chemicals in the workplace and are provided information regarding the potential hazards associated with exposure to these chemicals.  

Responsibilities

Safety and Risk Management has the primary responsibility for the implementation and enforcement of the Hazard Communication Program.
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. 
Affected employees are responsible for complying with the HCP, completing the required training, knowing the hazards and precautionary procedures for hazardous substances in their work area, conducting operations safely and in accordance with established procedures, and using personal protective equipment (PPE) when necessary.

Hazardous Chemical List

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 Safety Data Sheet (SDS), formerly referred to as the Material Safety Data Sheet (MSDS), and container warning labels. All identified hazardous chemicals must have a corresponding SDS readily available to every employee of that area during all working hours.  The SDS/MSDS can be available in a binder or in electronic format; however, 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 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 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's chemical inventory list shall be sent to the Safety and Risk Management office for record keeping.  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.  

Maintenance of Safety Data Sheets (SDS)

Chemical manufacturers and distributors are required by OSHA to provide Safety Data Sheets (SDS) to consumers.  This information is provided to ensure that 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.

Each department must maintain a complete and accurate SDS (MSDS) 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 the 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.
  • SDS shall be in English and contain the standard sixteen (16) sections. 

Warning Labels

Supervisors or managers have the responsibility to ensure all known hazardous chemicals present in the workplace display a precautionary label. 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:  These are 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
A GHS Reference Guide detailing labeling requirements is available here.

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.  It’s recommended to use the HMIS systems for labeling secondary containers.  Secondary labels need to include: Chemical name, Date when transferred, and Associated hazards.  Remember:  Whoever transfers a chemical from the original container to a secondary container is obligated to label the chemical container.

Unlabeled Pipes
Employees will be informed of hazardous chemicals in unlabeled pipes and of the potential hazards involved in the event of exposure to these substances.  The extent of information provided will include the SDS and other available information.  Pipes that contain steam, condensate, or water will be unlabeled and possibly insulated.
Steam Plant Vessels
All steam plant vessels which routinely store bulk chemical products for use shall be labeled in the following matter:
Chemical name of the contents, Appropriate hazard warning(s) from manufacture, Identify the pipe lines served by the vessel.
When available, commercial warning labels can be used to identify the hazards.  If no standard commercial labels are available for a specific hazardous chemical, then a label will be prepared internally.  The SDS will provide the necessary information for appropriate hazard warnings.  

Employee Training

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. The training program is presented in two groups:
General Information Training is provided by the Safety and Risk Management Office and includes:

  • Requirements of the Hazard Communication Standard
  • Location and availability of the written communication program
  • Operations in the work area where hazardous chemicals are present
  • Introduction of the chemical hazards, labeling, and MSDS/SDS

Specific Hazard Training is provided directly by the supervisor or manager of the employee and includes:

  • Location of hazardous chemicals in the work area
  • Discussion of the methods and observations used to detect the presence or release of a hazardous chemical in the work area.  Example: monitoring devices, appearance, or odor
  • The chemical’s physical and health hazards associated with each chemical, as specified in the SDS
  • Action that employees can take to protect their own safety and health, including specific procedures that have been established for normal work practices, emergency procedures and policies on the use of person protective equipment.
  • Access to SDS / MSDS information within employee work area
  • How to obtain additional information

Non-Routine Task/Outside Contractors

Employees may periodically be required to perform hazardous non-routine tasks.  A non-routine task is one that the employee does not normally perform (because of infrequency, location, or type of work) and for which the employee has not previously been trained.  A non-routine task may include when an employee is to work with a chemical under conditions that arise infrequently. Before any non-routine task is performed that could involve exposure to hazardous chemicals, the employee’s supervisor or manager will review all potential hazards tasked to the employee.  The supervisor must ensure that employees are informed of the hazard control measures, including safe work practices, and proper personal protective equipment.

Contractors on Campus
Non-university (i.e. contractor 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.

 

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