Hazard Communication Program

Prepared By: Patrick R. Norton, Environmental, Health, and Safety Officer

Approved by: Michael J. Adanti, President

DATE: July 1993

Instruction: 1910.1200

REV. 0

SUBJECT

Chemical manufacturers and importers must convey hazard information to downstream employers by means of labels on containers and material safety data sheets (MSDS's). In addition, all employers are required to have a written hazard communication program to provide this information to their employees by means of container labeling, other forms of warning, MSDSs and training. Compliance with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard, 29 CFR 1910.1200, will ensure that all employers receive the information they need to properly train and inform their employees and to design and implement employee protection programs. It will also provide the necessary hazard information to employees so they can participate and support the protective measures instituted in their work places. 

PURPOSE

SOUTHERN CONNECTICUT STATE UNIVERSITY is located in New Haven, Connecticut. Activities involved at the University utilize chemicals that are classified by the (OSHA) Standard 29 CFR 1910.1200 as hazardous materials.
The goal of this Hazard Communication Program is the goal of the Standard; to reduce the incidence of chemical source illnesses and injuries.

This program is designed to comply with the OSHA Hazard Communication Final Rule dated August 24, 1987.

This program is not designed to comply with various State worker Right-to-Know laws that have been superseded by the OSHA Standard, or with the Community Right-to-Know laws established by SARA Title III.

SCOPE

This program applies to all facilities for which SOUTHERN CONNECTICUT STATE UNIVERSITY is responsible, to all employees of SOUTHERN CONNECTICUT STATE UNIVERSITY , to all outside contractors and agencies performing work at any SOUTHERN CONNECTICUT STATE UNIVERSITY facility.
HAZARD COMMUNICATION PROGRAM OUTLINE To Top

This outline will describe how SOUTHERN CONNECTICUT STATE UNIVERSITY will comply with the following elements of the Hazard Communication Standard.

I. Hazard determination

II. Inventory of Hazardous Chemicals

III. Method used to inform employees of the hazards of routine tasks.

IV. Method used to inform employees of the hazards of non-routine tasks

V. Method used to inform SOUTHERN CONNECTICUT STATE UNIVERSITY contractors and outside agencies of hazardous chemicals to which their employees may be exposed

VI. Procurement of chemicals

VII. Labeling of containers of hazardous chemicals

VIII. Maintenance and preparation of Material Safety Data Sheets

IX. Training and information

I. Hazard Determination

  1. To determine if purchased substances are hazardous, SOUTHERN CONNECTICUT STATE UNIVERSITY will rely on the evaluations performed by our suppliers, the chemical manufacturers, and distributors.

    This information is communicated to the University by the product Material Safety Data Sheets (MSDS).

  2. The department head or dean will review supplier-provided MSDSs for accuracy and completeness. Generally, MSDS's are relied on for their health and safety information unless they are obviously erroneous or incomplete.

    • If questions arise as to criteria listed above, the department head or dean will directly contact the manufacturer to inquire as to the nature of the product hazard

      If the manufacturer cannot satisfactorily answer questions or concerns, the product will be returned

    • The Environmental, Health, and Safety Officer will assist departments as requested.

II. Inventory of Hazardous Materials

  1. Each department at SOUTHERN CONNECTICUT STATE UNIVERSITY will perform an inventory of all materials for which a MSDS sheet is required by OSHA. An initial inventory will be performed immediately and updated annually by June 30th or as changes occurs. The inventory will list the materials by name, manufacturer, building name and room, storage location, average amount on hand and maximum amount which may be present at any one time.

    • The same "identity" that is found on the appropriate MSDS and container label appears on the inventory list.

    • The inventory will submitted to the Environmental Health and Safety Officer on magnetic disk via the appropriate Vice President. The Environmental Health and Safety Officer will provide formatted disks for the purpose.

  2. Each department will maintain a current inventory and insure the availability of the inventory to personnel in the department.

  3. The Environmental, Health, and Safety Officer will ensure that:

    • The list of hazardous materials present in the workplace is compiled annually.

    • The current inventory is distributed to the appropriate personnel and filed, on an annual basis.

    • Annual audits of the inventory are performed, and any changes or corrections are made.

    • The inventory is readily accessible to facility employees and applicable regulatory agencies.

    • Copies of the Campus wide inventory are maintained at Campus Police Headquarters, each police vehicle, Environmental, Health, and Safety Office, Facilities Planning and Engineering, Central Receiving and the Main Power Plant.

  4. Material Safety Data Sheets will be forwarded to the Environmental Health and Safety Officer with the first inventory. New or updated MSDS will be submitted with subsequent inventories.

III. Method Used To Inform Employees Of The Hazards Of Routine Tasks

The inventory of hazardous materials will perform the basis for informing employees of the hazard associated with their work.

Hazards associated with routine tasks will be minimized by informing SOUTHERN CONNECTICUT STATE UNIVERSITY employees of the hazards involved and the protective measures that can be utilized for protection against these hazards. Each department will develop a program(s) that effectively communicates these hazards to their employees. This may be accomplished by:

IV. Method Used To Inform Employees Of The Hazards Of Non-Routine Tasks

Non-Routine Tasks are defined as operations that are outside the normal scope of work
 

Hazards associated with non-routine tasks will be minimized by informing SOUTHERN CONNECTICUT STATE UNIVERSITY employees of the hazards involved and the protective measures that can be utilized for protection against these hazards. Each department will develop a program(s) that effectively communicates these hazards to their employees. This may be accomplished by:

  • The development of written standard operating procedures (SOPs) for such evolutions as tear down of equipment for non-scheduled maintenance, operation of specialty equipment, etc.

  • Specialized training programs prior performing Non-Routine evolutions to review the procedures to be used in the evolutions.

  • Development of a departmental checklist for Non-Routine Tasks. Supervisors would review and approve procedures specified in the checklist. The checklist would specify the exact procedure to be followed and the employees who are to perform the evolution.

V. Methods Used To Inform SOUTHERN CONNECTICUT STATE UNIVERSITY Contractors Of Hazardous Materials

  1. All SOUTHERN CONNECTICUT STATE UNIVERSITY Contractors will be informed of hazardous chemicals that Contractor's employees may be exposed to while work in being done at any SOUTHERN CONNECTICUT STATE UNIVERSITY facility. Suggestions for appropriate protective measures should be made known to the Contractor. Information will be conveyed to our Contractors in several ways. These methods include:

    • A packet of information which explains how Contractors will be informed concerning hazards at SOUTHERN CONNECTICUT STATE UNIVERSITY, Appendix II.

    • SOUTHERN CONNECTICUT STATE UNIVERSITY will be informed of the hazards of Contractor products used while work is being performed at SOUTHERN CONNECTICUT STATE UNIVERSITY .

    • Discussions and meetings with an SOUTHERN CONNECTICUT STATE UNIVERSITY representative.

    • Access to Material Safety Data Sheets which describe normal precautionary measures and emergency procedures.

  2. Contractors and outside agencies will be required to sign the Contractor notification form before work will be performed at any SOUTHERN CONNECTICUT STATE UNIVERSITY facility.

  3. The SOUTHERN CONNECTICUT STATE UNIVERSITY representative for the work to be done at the facility has the responsibility for conveying hazard and protective measures information to the Contractor during preliminary talks, contract negotiations or at any other time prior to the start of the work. The SOUTHERN CONNECTICUT STATE UNIVERSITY representative responsible for the service contract will insure the contractor is updated at each contract renewal, but not less than annually. 

  4. Any safety and health hazards that the Contractor may have on-site could potentially expose SOUTHERN CONNECTICUT STATE UNIVERSITY employees. This possibility should be discussed and steps initiated to minimize any possible exposure by communication at the earliest time in our contractual relationship. Copies of the contractors inventory and Material Safety Data Sheets shall be provided to the University, and will be maintained in a special folder for that contractor. Copies of this folder will be maintained with the Universities Material Safety Data Sheets located at Campus Police Headquarters, Environmental Health and Safety Office, Facilities Planning and Engineering, Central Receiving, and the Main Power Plant.

    • Examples of such situations include chemicals, welding operations, construction activities and the shutdown of ventilation systems for maintenance.

    • Any contractor on site shall comply with the requirements of the Connecticut State Fire Code, Connecticut Department of Environmental Protection, U. S. Environmental Protection Agency, and the Occupational Safety and Health Administration, while engaged in any operations at SOUTHERN CONNECTICUT STATE UNIVERSITY.

VI. Procurement of Chemicals

  1. Each department will develop an approved list of chemicals and materials which will be utilized. Only items which are on this listing may be purchased by the department. In developing this list, the department head/chairman will consider the following items before adding a material to the approved listing:

    • Are proper storage facilities available to store the requested amount of materials. Look at proper segregation of chemicals, potential reactions with other materials, requirement for flammable storage lockers, proper containers, secondary containment requirements, labeling, and any other special requirements mandated by the Connecticut State Fire Code, U. S. EPA, and OSHA. Proper storage must be available to support the maximum amount of material which may be present. Materials in excess of the amount which can be properly stored will be removed from the University.

    • Safety requirements for using the materials must be evaluated, including proper safety equipment such as fume hoods, ventilation requirements, personnel protective equipment, special containers and in process equipment.

    • Training requirements for personnel must be accomplished prior to utilization.

    • Any requirements for special programs such as medical surveillance requirements must be established and implemented prior to usage of the material.

    • Requirements for the correct storage and disposal of any wastes generated must be established prior to generating the waste.

    • Material Safety Data Sheets should be obtained and reviewed prior to product procurement to evaluate the above requirements. Again, if proper storage does not exist for the material, it must be removed from the University.

    • The department head or chairman will submit a copy of the approved listing to the Environmental, Health and Safety Officer for review.

    • The Environmental, Health, and Safety Officer will assist departments is establishing regulatory requirements for specific materials. The department must provide a copy of the Material Safety Data Sheet in order to determine the regulatory requirements. All evaluations must be requested in writing to the Director of Public Safety.

  2. The department head or chairman will review and sign all purchase orders. Signing of the purchase order indicates that the specified purchase is in compliance with the requirements of this instruction.

  3. All purchase orders will bear the statement that "SOUTHERN CONNECTICUT STATE UNIVERSITY will not accept materials without a Material Safety Data Sheet". The Material Safety Data Sheet must be received no later than at delivery of the material. If a MSDS is not on file or included with the shipment, the materials will be returned to the supplier.

  4. All materials are to be received at Central Receiving at Warehouse 6. Direct deliveries to a department will not be accepted.If additional labeling is required, it will be attached at Central Receiving before the material is distributed on campus. 

  5. If additional labeling is required, it will be attached at Central Receiving before the material is distributed on campus. 

  6. If a material is picked up directly by open purchase, it must be taken to Central Receiving for receipt and labeling. No chemical or hazardous material may be admitted to the campus without first being taken to Central Receiving.

VII. Labeling Of Containers Of Hazardous Chemicals

  1. Incoming containers of hazardous chemicals, regardless of size, must be labeled in a manner that provides the employee with the identity, the hazard warning appropriate for the contents and the name and address of the chemical manufacturer.

    • Note that a precaution such as, "Wear Glasses" is not a hazard warning but a precaution. A statement that the product could cause "Skin Irritation" provides the required warning information.

    • Containers of hazardous chemicals shipped to SOUTHERN CONNECTICUT STATE UNIVERSITY that are not labeled as described above will be labeled at Central Receiving prior to distribution to the University.

     

  2. Labeling is required for all portable containers that are used to transfer chemicals from one container to another or for use at another location. This will be accomplished by the person that performs the transfer.

    Containers require a label that has the identity and hazard warning that corresponds with the original shipping container and the MSDS. 

  3. Labeling will be required for all vessels, tanks, and containers that hold a reagent, waste, and - or virgin product.

    • Containers require a label that has the identity and hazard warning that corresponds with the original shipping container and the MSDS.

    • The department responsible for the container, will insure the container is properly labeled. 

  4. SOUTHERN CONNECTICUT STATE UNIVERSITY will incorporate three labeling systems (Appendix III) to comply with the procedures above.

    • Department of Transportation (HM-181) labels affixed to containers to comply with shipping requirements meet all requirements of the Hazard Communication Standard

    • NFPA-704M labels may also be affixed to containers to inform employees of the level of Health, Flammability, Reactive, and Special Hazards associated with the product:

      Product name, manufacturer, and hazards must be included when this labeling format is used

    • Hazardous Waste Accumulation labels will be used per EPA requirements in addition to labels required under the OSHA standard.

    • Examples of acceptable labels are illustrated in Appendix III. 

  5. All SOUTHERN CONNECTICUT STATE UNIVERSITY employees are to ensure that:

    • All containers of hazardous chemicals, regardless of size, are properly labeled.

    • The labels on containers are not removed or defaced.

    • The label on any container of hazardous chemicals in the facility matches the identity and hazard warning on the MSDS, the shipping label as provided by the manufacturer and the facility inventory.

    • The department head or supervisor is informed of any changes to the container label's identity and/or hazard warning.

VIII Maintenance Of Material Safety Data Sheets

  1. For all hazardous materials used at SOUTHERN CONNECTICUT STATE UNIVERSITY, an MSDS will be on file in each department where the hazardous products are used or handled.

    • Each department will maintain a copy of this program, the chemical inventory list, and MSDS's for all materials used in the department will be kept in the Right to Know Station readily accessible to all employees. It will be available to employees during all shifts that personnel are present.

      Requests for MSDS's or additional information may be made through the chemical manufacturer or supplier.

    • Complete sets of all MSDS sheets will be maintained at Campus Police, and the Main Power Plant. These locations will support access to the data 24 hours per day for emergency response purposes.

    • A complete set of MSDS sheets will be maintained at Central Receiving. Newly received MSDS will be compared to existing. If the MSDS is new or a revision, it will be distributed to the master lists and to applicable departments with the materials.

  2. The Department Head or Chairman Will Ensure That:

    • A current MSDS is available for all hazardous chemicals which are present in their department. The MSDS must be the one issued by the chemical manufacturer or importer.

    • Generic MSDS sheets such as those on CD Roms, will not be used as substitutes for the actual manufacturers or importers MSDS, they can be used for evaluating chemicals prior to purchase.

  3. When chemicals are ordered or a new chemical is added to the SOUTHERN CONNECTICUT STATE UNIVERSITY chemical inventory list, an MSDS is received with each initial shipment or following a change in the product's formulation that may require a revision of the MSDS.

  4. If SOUTHERN CONNECTICUT STATE UNIVERSITY purchases a product from a different vendor, a new MSDS will be procured to assure that hazard levels are the same. Both MSDS will be maintained.

  5. Newly received MSDS's are to be reviewed by the department ordering the material to determine for adequacy.

    • If MSDS's are found to be incomplete, revised sheets will be requested from the chemical manufacturer or distributor.

    • Newly received MSDS's are reviewed to determine if the chemical poses a new hazard requiring additional training.

    • Newly received MSDS's are reviewed to determine if an update to the facility MSDS books is necessary. If so, a copy is to be forwarded to Central Receiving with instruction to disseminate to all MSDS files.

      A copy of the MSDS for every hazardous chemical is in a central control file in Central Receiving.

    • The MSDS's are filed alphabetically by identity and then by manufacturer in the MSDS books for all hazardous chemicals used or handled.

      The identity is the one that matches the name found on the inventory, the MSDS and the label.

    • MSDS's to be filed in the MSDS binder be obtained as soon as possible, upon receipt of the hazardous chemical.

    • Records are kept documenting requests for MSDS's from product manufacturers.

IX. Training And Information

  1. Training and information on the hazardous chemicals used or present at the facility must be provided at the time of initial assignment and whenever a new hazard is introduced into the facility. This training will include information on the anticipated hazardous chemicals normally encountered in the facility.

  2. The department heads and chairman will ensure that SOUTHERN CONNECTICUT STATE UNIVERSITY employees are:

    • Trained and informed of hazardous chemicals in the facility upon initial assignment to the facility.

    • Retrained if a new hazard is introduced into their facility.

    • Trained in the methods and observations that may be used to detect the presence or release of a hazardous chemical.

    • Informed of the location and accessibility of the facility MSDS book and the written hazard communication program.

    • Trained in; understanding an MSDS, the physical and health hazards of the chemicals in their area, the measures that can be taken by personnel to protect themselves from the hazards of the chemicals and be informed of what Personal Protective Equipment (PE) is available to them and in the details of the written hazard communication program.

    • Informed of any operations where hazardous chemicals are present.

  3. The department head or chairman will compile and maintain:

    • Records of type of training completed using Appendix IV.

    • Copies of training materials, course outlines and hand out materials.

  4. Training will include completion of a video - workbook session, lectures, and discussions on the specific hazards of SOUTHERN CONNECTICUT STATE UNIVERSITY chemicals.

     

  5. The department head or chairman will forward to the Environmental Health and Safety Officer copies of the following:

    • Records of type of training completed using Appendix IV.

    • Copies of training materials, course outlines and hand out materials.