HAZARD COMMUNICATION FOR NON-LABORATORIANS

 

The Hazard Communication Standard 29 CFR 1910.1200 (HCS) implemented by the Occupational Safety and Health Administration (OSHA) of the U.S. Department of Labor requires employers to provide information to employees regarding the hazardous chemicals in the workplace and the hazardous properties of these chemicals. This information must be disseminated through a hazard communication program involving labeling, material safety data sheets, employee training, employee access to written records, and a written hazard communication plan. The implementation of the Hazard Communication Program will ensure all employees the “right-to-know” the hazards and identities of the chemicals with which they work.

 

The HCS applies to any chemical that is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use, or in a foreseeable emergency. In accordance with OSHA regulations, laboratory employees are covered under Clemson University’s Chemical Hygiene Plan and are not included in the Hazard Communication Program. The OSHA standard, 29CFR 1910.1200 sets out a procedure for hazard determination and any substance determined to be hazardous under this procedure is subject to the program. The definition of “hazardous chemical” under the standard is extremely broad, and includes any chemical that is a physical or health hazard. For determination of physical and health hazards associated with products not synthesized at Clemson University, personnel should rely on the evaluation performed by the chemical manufacturer or importer transmitted via Material Safety Data Sheets.

 

Clemson University’s Hazard Communication Program is designed to:

 

 

·      Reduce the likelihood of injury or illness to employees by implementing specific procedures to identify and evaluate the chemical hazards in the workplace and then inform and train employees on those hazards.

 

·      Ensure that all individuals at risk are adequately informed about the chemicals used and stored in their workplaces.

 

·      Outline procedures for all employees working with hazardous chemicals.

 

 

 

The following Hazard Communication Plan was written to comply with the OSHA Hazard Communication Standard.

 

 

 

 

 

 

 

I. HAZARD COMMUNICATION RESPONSIBILITIES:

 

Clemson University’s Hazard Communication Program is overseen by the University’s Chemical Hygiene Officer (CHO) Naomi Kelly, who reports to the Director of Environmental Health and Safety (EHS).

 

Supervisory Personnel are responsible for:

 

1.     Creating and maintaining an inventory of all hazardous chemicals stored or used within their area of responsibility

 

2.     Ensuring that all hazardous chemicals/products are properly labeled, and that these labels are not removed or defaced

 

3.     Maintaining copies of Material Safety Data Sheets (MSDS) for each hazardous chemical in the workplace, and ensuring that the MSDSs are readily available to employees

 

4.     Identifying employees under their supervision who may be exposed to hazardous chemicals under normal operating conditions or in a foreseeable emergency based on hazard assessment.

 

5.     Informing employees of: Any operations in their work area where hazardous chemicals are present; the location and availability of the written Hazard Communication Plan; the chemical inventory; MSDS; and the requirements of the Hazard Communication Standard.

 

6.     Providing employees with training regarding hazards or practices specific to their work area at the time of their assignment and whenever a new hazard is introduced into their work area. Training records should be forwarded to the University CHO.

 

7.     Determine the required personal protective equipment (PPE) for the procedures and materials in use in their area. Contact EHS personnel for assistance in the selection of PPE.

 

8.     Ensure that the proper PPE is made available to employees.

 

9.     Ensure that the employees are trained in the use of PPE, that the PPE is properly maintained, and ensure that the employees wear the appropriate PPE where necessary/required.

 

10.  Develop safe procedures for work in their areas, as well as written procedures for emergencies

 

11.  Inform outside contractors of chemical (or other) hazards that they may be exposed to while working at Clemson University. Inform them of the location of the MSDSs.

 

12.  Inform employees about proper performance of non-routine tasks.

 

 

 

Employees are responsible for:

 

1.     Planning and conducting each operation according to the Hazard Communication Program.

 

2.     Maintaining his/her area in good order.

 

3.     Using the required personal protective equipment. Properly maintaining and storing the PPE assigned to him/her.

 

4.     Reporting any exposures, injuries, or safety problems to his or her supervisor.

 

5.     Reviewing MSDSs prior to using a chemical for the first time, then reviewing periodically thereafter as necessary.

 

6.     Attend required Hazard Communication training.

 

CHO is responsible for:

 

1.     Development of the written Hazard Communication Program.

 

2.     Develop a Hazard Communication training program.

 

3.     Providing technical support to the departments covered by the Hazard Communication Program.

 

4.     Conduct random safety reviews.

 

5.     Provide technical assistance in the selection of personal protective equipment.

 

6.     Review Hazard Communication Program at least annually, and make necessary changes.

 

Contractors are responsible for:

 

Developing and implementing their own Hazard Communication Program and informing Clemson University personnel of any chemical hazards they bring with them. They must also ensure the proper handling, use, and storage of these chemicals and provide access to MSDSs for them. Outside contractors must provide University project managers and EHS with information concerning hazardous materials to be brought into any Clemson facility to perform contracted work before the materials are brought onto campus. Attachment H should be filled out by the contractor and copies sent to the University’s contracting official(s) (project managers, Department heads, etc.) and EHS.

 

 

 

 

 

II. HAZARDOUS CHEMICALS INVENTORY

 

The supervisor, or his/her designee is required to maintain a list of all hazardous chemicals known to be present in each work area (i.e., maintenance shop, storage buildings, etc.) and update the list as necessary to ensure that it stays current. The inventory must identify each hazardous chemical by the primary name on the label (either chemical name or product name, but it must be consistent; i.e. if you choose to list chemicals by the common or product name, you must do so with all chemicals listed on the inventory), the manufacturer or distributor of the chemical, and chemical abstract number (CAS), the location (Building, room number, etc.), quantity, and date received. The inventory must be kept in the work area in a suitable format (see Attachment A), on a log sheet, or in electronic format (inventories kept in electronic format should be printed periodically (at least annually or if major changes in the inventory are made) and posted in the work area). This inventory shall list all hazardous chemicals (this includes compressed gases) found in the work area. This inventory must be submitted annually (by February 15) to Warren Wang (wangw@clemson.edu). The inventory should be submitted as an Excel or Filemaker attachment. The inventory may also be submitted directly using the online form found on our website at: http:\\ehs.clemson.edu\

See Attachment A

 

III. LABELING REQUIREMENTS

 

The supervisor must ensure that all containers of hazardous chemicals in his/her area of responsibility are properly labeled. Labels should list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer. Portable containers of working solutions must also be labeled appropriately. Labels must be legible and must be prominently displayed on the container. Labels on incoming containers must not be defaced or removed until the container is empty. Once the container is empty, the guidelines in the University Hazardous Waste Management Manual should be followed for container disposal. Whenever chemicals are transferred into another container, the container must be labeled with the full chemical name, appropriate hazard warnings, and the manufacturers name and address. The date of transfer, name or initials of the person making the transfer, and additional information about the possible health effects should also be included. In the event that labels must be created, the labels must be durable, legible, and must be firmly affixed to the container(s). Labels should be replaced whenever they fade, peel, or otherwise deteriorate so as to become difficult to read. All chemicals should be dated upon receipt. No chemical should ever be used without completely reading the label.

Contents of all vessels, pipelines, storage tanks, etc. must be adequately labeled.

Products that are synthesized at Clemson and distributed outside of the University proper must be labeled in accordance with OSHA’s Hazard Communication Standard. If they contain hazardous chemicals in concentrations greater than one percent (or 0.1% for carcinogens).

 

 

 

 

 

 

IV.          MATERIAL SAFETY DATA SHEETS

 

The purpose of Material Safety Data Sheets is to inform employees of the potential hazards associated with materials used or stored in their work area. A MSDS also advises employees on the appropriate way to handle hazardous chemicals, what PPE is required for handling the chemical, how to properly store the chemical, information on handling spill clean up, etc.

A Material Safety Data Sheet must be kept for every hazardous chemical used and must be readily available to employees at all times. The area supervisor or manager is responsible for acquiring and updating MSDS for all hazardous chemicals found in their work area. The MSDS should be reviewed by all personnel who will be using the chemical before the chemical is used. The MSDS should be filed alphabetically by chemical name and should be kept in a convenient location. MSDS should be reviewed at least annually to ensure that they are updated and the latest revisions are available. For chemicals where there have been revisions made to the MSDS, the current MSDS should be inserted and the old MSDS should be archived.

To obtain specific MSDS, request them from the manufacturer or distributor or copy them from the website of the manufacturer if they are available online. If you are unable to obtain a MSDS, contact the CHO (656-7554) for assistance. You may submit a request by submitting a fax , “Request of Material Safety Data Sheet” (Attachment B) or sending the request by interoffice or email.

For chemicals purchased locally from retail stores, MSDSs should be requested from the retailer.

A material safety data sheet must be developed and sent with those products that are synthesized at Clemson and distributed outside of the University proper in accordance with OSHA’s Hazard Communication Standard. If products contain hazardous chemicals in concentrations greater than one percent (or 0.1% for carcinogens), it is the responsibility of the laboratory synthesizing the product to develop and distribute the MSDS.

See attachments B and C.

 

V.            EMPLOYEE TRAINING AND INFORMATION

 

Employers must provide employees with effective information and training on hazardous chemicals that are located in their work area at the time of their initial assignment and whenever a new physical of health hazard is introduced into the work area.

 

Employees must be informed of:

 

1.     The requirements of the Hazard Communication Standard (29CFR 1910.1200).

2.     The location and availability of the written Hazard Communication Plan.

3.     Physical and health hazards of chemicals in the work area and their locations.

4.     Location of the hazardous chemicals inventory and the Material Safety Data Sheets for all hazardous chemicals in their work area.

5.     Methods and observation techniques used to detect the presence or release of a hazardous chemical.

6.     How to lessen or prevent exposure to these hazardous chemicals through usage of controls, work practices, and personal protective equipment (PPE).

7.     How to use the information provided on MSDSs.

8.     How to read and understand labels.

9.     Contingency plans for medical and accident response.

10.  The proper use, maintenance, and storage of any PPE required.

11.  Procedures implemented to provide employee information about chemical hazards for non-routine or special tasks.

12.  A record of the date, location, and facilitator of each training session, as well as a list of attendees. A copy of training records should be sent to Clemson’s CHO, or this information may be incorporated into the EHS online training database (http:\\ehs.clemson.edu\). The supervisor should also maintain a copy of these records.

      See attachments D and E. 

 

HAZARD DETERMINATION

All chemicals which pose a physical or health hazard in the workplace should be identified. By completing an inventory listing these chemicals and reviewing MSDSs, these chemicals can be identified. 

 

·      Physical Hazard

A physical hazard means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water reactive.

 

·      Health Hazard

A health hazard means a chemical 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.

Health hazards fall into two general categories: acute and chronic. Acute hazards occur rapidly as a result of short-term exposures. The acute effects referred to most frequently are irritation, corrosivity, sensitization, and lethal dose. Chronic hazards generally occur as a result of long-term exposure. The term chronic effect is often used to cover carcinogenicity, teratogenicity, and mutagenicity. The following is an explanation of specific acute and chronic effects.

 

Acute effects result from either breathing vapor, swallowing the material, or direct contact with the body. Headaches, nausea, dizziness, blurred vision, rashes, and burns are common examples of acute effects. When an employee becomes aware of acute symptoms, the fastest remedy is to flush the affected area using the appropriate emergency drench equipment (eyewash, drench shower or both) for at least 15 minutes in the case of contact with the eyes or body. There are some exceptions to this (i.e. Hydrofluoric acid, for which specific first aid treatment and is required). Employees should be made aware of these exceptions and receive specific first aid training if they are exposed to such chemicals. Campus emergency medical services should be called while initial flushing, etc. is being performed. In the case of headaches, nausea, dizziness, blurred vision, etc., the employee should leave the area and alert his/her supervisor.

 

Chronic effects result from the repeated, low level (usually) exposure to a material. Over a period of time, symptoms may become apparent. These may include: shortness of breath, loss of feeling in areas of the body, gradual drying of skin. If these types of symptoms occur, and you think they may be associated with exposure to workplace chemicals, inform your supervisor and EHS.

 

VI.  PERSONAL PROTECTIVE EQUIPMENT

 

Personal protective equipment (PPE) includes gloves, safety glasses, goggles, face shields, aprons, respirators, etc. The PPE necessary for protection while being exposed to hazardous chemicals, flying particles, damaging light sources, etc. must be provided to employees.

Proper use of protective equipment is essential to prevent exposure. Supervisors must instruct employees as to what personal protective equipment must be worn. This equipment must be kept clean and stored in such a manner that it is protected from contaminants, dirt, dust or any atmosphere that might cause damage or deterioration of the equipment. Protective clothing should always be free from holes, rips, or tears.

Gloves should be selected based on the chemicals being handled, or the task being performed. Safety goggles should always be worn whenever a potential chemical splash hazard or flying particle hazard exists. Goggles used for this purpose should have indirect vents (vents should be covered).

Eye protection, safety glasses or goggles, must meet ANSI (American National Standards Institute) Z87.1 standards. They must fit well, be reasonably comfortable, and not interfere with vision. If an employee wears prescription lenses, safety glasses or goggles must be worn over prescription glasses whenever eye protection is required unless the prescription glasses are approved safety glasses (ANSI Z87.1). Safety glasses must always have sideshields. Departments may choose to cover all or part of the purchase price of prescription safety glasses. Contact the CHO (656-7554) for information about the University contract for a local provider.

 

If the use of respirators is required for specific tasks, employees must be enrolled in the University Respiratory Protection Program. This covers all type of respiratory protection equipment, including dust/mist type masks. Contact EHS for information on the Respiratory Protection Program. No employee is allowed to wear a respirator until approval is given by EHS.

 

For additional information or assistance with the selection of PPE, contact EHS (656-7554).

 

 

VI.          NON-ROUTINE TASKS

 

Employees performing “non-routine” tasks can be exposed to chemicals from unusual and unsuspected sources. These “non-routine” tasks may include, for example, periodic tank or boiler cleaning or the replacement of seals and gaskets. Written procedures shall be developed for every “non-routine” task by the supervisor of the employees who will perform the task. The information will include chemical hazards associated with the performance of the tasks and appropriate protective measures required to perform the task safely. The procedures shall be included (or specific location referenced) in the local copy of the Hazard Communication Plan. The Office of Health and Safety will provide guidance and advice upon request.

 

 

 

 

 

 

 

 

 

Attachment A

Inventory of Hazardous Chemicals/Products

 

A complete inventory of all hazardous chemicals must be submitted to EHS by Feb 15 of each calendar year. The form found on the EHS website (http://ehs.clemson.edu/) must be used for submitting this information. Send as an attachment to: wangw@clemson.edu

 

Attachment B

 

CLEMSON UNIVERSITY

REQUEST FOR MATERIAL SAFETY DATA SHEET

 

The Occupational Safety and Health Administration Hazard Communication Standard (29CFR 1910.1200) requires us to maintain and distribute material safety data sheets (MSDS) for all hazardous chemicals used by our employees. To fulfill these requirements, we request a completed MSDS for the following chemicals.

NAME: (Last, First, MI)

 

DATE:

DEPARTMENT:

BLDG/RM NO.

 

PRODUCT NAME

 

PRODUCT NUMBER

MANUFACTURER

CAS NUMBER

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

MSDS(s) should be sent to the address provided below on or before the date the product(s) will be delivered.  We also request any additional information you currently have, or may acquire in the future, concerning the safety and health of these products be sent to:

 

___________________________________

 

___________________________________

 

___________________________________

 

___________________________________

 

Attachment C

 

REQUEST FOR MATERIAL SAFETY DATA SHEET

 

If there are chemicals for which you are unable to find a MSDS, you may list those chemicals on this form and fax to Naomi Kelly at 656-7630.

 

 

NAME: (Last, First, MI)

 

DATE:

DEPARTMENT:

BLDG/RM NO.

 

PRODUCT NAME

 

PRODUCT NUMBER

MANUFACTURER

CAS NUMBER

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Attachment D

 

Employee/Student Safety Checklist

 

                                                                                                        Supervisor        Employee

                                                                                                        Initials               Initials

 

1.     Individual employee’s responsibilities                                       _____                _____

 

2.     Location of Chemical Hygiene/HazCom Plan                           _____          _____                                         

 

3.     Location of Chemical Inventory and Material Safety

      Data Sheets and other information available relating

      to hazardous chemicals found in the work area                         _____            _____

 

4.     Minimum personal protective equipment requirements            _____              _____

              

5.     Specific personal protective equipment requirements              _____               _____

 

6.     Injury and Illness reporting                                                 _____              _____

 

7.     Non-injury incident reporting                                           _____                   _____

                                                                       

8.     Location and use of fire extinguishers                                _____                             _____

 

9.     Location and use of eyewash and safety shower equipment    _____                 _____

 

10.   Location of first aid kits                                                      _____                        _____

 

11.   Housekeeping                                                               _____                             _____

 

12.   Rules on food/beverage consumption in laboratories            _____                             _____

 

13.   Respirator use (must be enrolled in EHS Respiratory

Protection Program unless respirator is used for

non-respiratory (i.e., nuisance dusts) hazards                      ______                _____

                                                                

14.   Hazards of the job (i.e., chemical, biological, radioactive               

materials, mechanical, electrical, etc.)                                _____                              _____         

 

15.   Spill control, clean-up procedures, etc.                                          _____                              _____

 

16.   Fire and Disaster Evacuation Procedures                            _____                  &