A. Major Provisions of the OSHA Hazard Communication Standard
The Hazard Communication (HazCom) Standard of the Occupational Safety and Health Administration (OSHA) requires that the hazards of all chemicals are evaluated and that hazard information is provided to employers and employees.
As defined by the HazCom Standard the term "chemical" refers to any chemical element or compound or mixture of elements or compounds that may or may not be hazardous. Similarly, the term "hazardous chemical" refers to any chemical element or compound or mixture of elements or compounds determined to be hazardous. OSHA defines a hazardous chemical as one that exhibits physical or health hazards.
Physical Hazard: 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 (ignites spontaneously), unstable, or water reactive.
Health Hazard: A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles the acute or chronic health effects may occur ... include... carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins(liver), nephrotoxins (kidney), neurotoxins(nervous system), agents that act on the hematopoietic (blood) system, and agents that damage the lung, skin, eyes, or mucous membranes.
Determining the hazard of a chemical is the responsibility of the manufacturer or importer. Information on the hazards is found on the label and Material Safety Data Sheet (MSDS) prepared by the manufacturer or importer.
Labels must contain information about the identity and hazard of a chemical. MSDS provide more detailed information including: physical and chemical characteristics; health hazards including symptoms of overexposure and routes of exposure (e.g., inhalation); safe handling precautions; and emergency and first aid procedures. The manufacturer or importer provides MSDS to the employer when chemicals are purchased.
Employers who use hazardous chemicals in their operations are required to develop a hazard communication program to provide information concerning chemical hazards to their employees. That program must include a written description of how the employer complies with the requirements of the HazCom Standard, including: labeling, MSDS access, training, and maintaining a list of all hazardous chemicals used.
B. Hampshire College Chemical Hazard Communication Program
This Hampshire College HazCom Program describes how the requirements of the OSHA HazCom Standard are met by the college and includes, as a separate document, a list of the hazardous chemicals present in the workplace. This program and the hazardous chemical list are available to employees, or their designated representative, upon request. This program is maintained as an on-line document on the College web site. Paper copies are available upon request.
This HazCom Program does not apply to hazardous chemicals used in college laboratories. Laboratories must comply with the OSHA Occupational Exposure to Hazardous Chemicals in Laboratories Standard, 29 CFR 1910.1450, The Cole Science Center Safety Manual details College procedures to comply with the OSHA Occupational Exposure to Hazardous Chemicals in Laboratories Standard.
There are several HazCom standard exemptions and labeling exemptions that are applicable to the college HazCom Program, which are summarized in Appendix A.
The following designated responsibilities play key roles in carrying out the HazCom Program. Details of each function are described in subsequent sections.
A. HazCom Coordinator (director of environmental health and safety, x6620)
The HazCom coordinator coordinates the HazCom Program, including the following specific duties:
B. Department MSDS Monitors
Each department has a designated MSDS monitor who is responsible for the following specific duties:
Department heads keep the HazCom coordinator informed of who is serving as the department MSDS monitor.
C. Purchasing Staff
All employees authorized to make purchases on behalf of the College are collectively called the purchasing staff for the purposes of this HazCom Program. They are responsible, for their areas of responsibility, for contacts with the manufacturer or distributor of chemicals and for the following specific duties:
D. Supervisors and Academic Department Faculty and Staff
Supervisors and academic faculty and staff monitor compliance with the requirements of the HazCom Program within their work areas, including the following specific duties:
E. Human Resources
Human Resources provides the HazCom coordinator a list of the names of all new and transferred employees and their position titles and departments.
Manufacturers, importers and distributors are responsible for providing an MSDS with the initial shipment of any hazardous chemical sold and with the next shipment after an MSDS is updated. Hampshire College specifically states, as per 29 CFR 19l0.l200 (g) (5), that the completeness and accuracy of the MSDSs are the responsibility of the manufacturer or importer.
The purchasing staff requests MSDSs at the time of the initial purchase and monitors to ensure that the MSDSs are received. If the chemical is not hazardous or is an article as defined by the HazCom Standard, the vendor is asked to provide written confirmation of that determination. If an MSDS is not received with the initial order, the purchasing staff contacts the manufacturer or distributor to ensure that an MSDS is received.
Upon receipt of an MSDS the purchasing staff sends it to the HazCom coordinator. Department supervisors and academic department faculty and staff who receive MSDSs also forward the MSDSs to the HazCom coordinator.
Upon receipt of new or updated (revised) MSDS, the HazCom coordinator updates the following college records:
Department MSDS files are available for review by the employees or their authorized representatives in their work area. For employees with multiple work areas, MSDS files are kept at the location to which they regularly report.
If an MSDS for a hazardous chemical has not been supplied by the manufacturer, the employee requesting the MSDS is made aware of that fact and given any alternate safety information available based on the container label and references available from the HazCom coordinator. The employee is not required to work with the hazardous chemical if s/he is not satisfied with the information provided until an MSDS is obtained for review by the employee.
To maintain readily accessible records of the hazardous chemicals present on campus, a list of hazardous chemicals is maintained by the HazCom coordinator.
The Hazardous Chemicals List is updated as new/revised MSDSs are received. Given this updating frequency, the list, while an integral part of the HazCom Program, is maintained as a separate document. The Hazardous Chemical List for each department is sent by the HazCom coordinator to each department's MSDS monitor to be kept with each department's set of MSDSs for access by employees and their representatives.
A. Manufacturer's Responsibility
The manufacturers or distributors of hazardous chemicals must label each container of hazardous chemical leaving their workplace with the following information:
B. Employer's Responsibility
The employer must ensure that every container of hazardous chemicals in the workplace (container means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like; pipes or piping systems are not considered containers) that contains a hazardous chemical is labeled with the following information:
Signs may be used instead of labels on stationary process containers.
Non-original (portable) containers into which hazardous materials are transferred from labeled containers do not require labels if (1) they are for the immediate use of the employee who transferred the material and, (2) the product will be completely used during the shift in which it is transferred. All other non-original containers must be labeled.
C. Labeling Procedure
This procedure ensures that (l) containers entering the workplace, (2) any material formulated on-site, and (3) any materials in portable or other non-original containers not used during the shift by the employee who made the transfer, are properly labeled.
D. Hampshire College Labeling System
For non-original containers, any labeling method that meets the requirements for identifying contents and hazards may be used, which may include the National Fire Protection Association (NFPA) or Hazardous Materials Information System (HMIS) numerical ranking system. Employee training includes specific instruction on these labeling systems. Labels are available from the HazCom coordinator.
The HazCom coordinator or other staff designated by the HazCom coordinator provide training for employees who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies, including new or transferred employees. On-line training customized to include specific college policies and requirements may also be used.
Training updates are provided periodically and when new hazards are introduced. The HazCom coordinator maintains training records for all employees trained.
Before employees are required to perform non-routine tasks, the department supervisor or academic faculty or staff responsible for the operation determines whether hazardous chemicals are involved and follows the procedure listed below:
When outside contractors perform work on campus the following conditions requiring an exchange of information may exist.
Both conditions are considered by the supervisor, or academic faculty or staff, responsible for bringing outside contractors into the workplace before any work begins so that appropriate MSDSs are exchanged. If MSDSs are provided to the contractor, a record of the MSDS provided is kept with the project file.