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 Safety Data Sheet (SDS), formerly known as Material Safety Data Sheets (MSDS), prepared by the manufacturer or importer.
Labels must contain information about the identity and hazard of a chemical. SDS 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 SDS 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, SDS 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. This program and the list of hazardous chemicals in the work area are available to employees, or their designated representative, upon request. This program is maintained as an on-line document on the College website. 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; these 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:
- Maintain records of the hazardous chemicals present on campus and keep the Hazardous Chemical List (see Section VI) up-to-date.
- Maintain the College master SDS Library.
- Upon request by a department supervisor, or academic faculty or staff, specify the labels required on non-original containers (i.e., containers into which employees transfer hazardous chemicals) and process tanks (i.e., fixed equipment containing hazardous chemicals).
- Periodically inspect the workplace, including labeling, training rpocedures, and record keeping.
- Coordinate periodic chemical surveys to ensure that SDS are available for all hazardous chemicals.
- Maintain and update the program as necessary.
- Provide HazCom training for new employees and periodic updates for existing employees as described in Section VIII.
B. 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:
- Request a SDS for each chemical purchased for which an SDS is not already available.
- Upon receipt of SDS send it to the HazCom coordinator.
- If a product is received without a SDS, inform the HazCom Coordinator of the product name, manufacturer, and product code.
- Establish and enforce policies necessary to ensure that SDSs are received for all hazardous chemicals purchased by the administrative and non-laboratory academic departments for which they are responsible.
C. 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:
- Conduct periodic chemical surveys as initiated by the HazCom coordinator, to ensure that SDSs are available for all hazardous chemicals in their work areas.
- Make sure SDSs are obtained for all products received that are otherwise not purchased through the purchasing staff (e.g., sample products).
- Notify the HazCom coordinator anytime they are aware of the presence of a chemical in their work area, including any being used on a trial basis, for which av SDS is not available.
- Affix labels as necessary to meet the employer's labeling responsibilities as described in Section VII. Labels are available from the HazCom coordinator.
- Notify the HazCom coordinator anytime an improperly labeled manufacturer's container of hazardous chemical is found in a work area.
- Properly label any hazardous chemical formulated under their supervision after consulting with the HazCom coordinator regarding label content.
- Forward all SDSs received to the appropriate purchasing staff or the HazCom coordinator.
D. 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 SDS with the initial shipment of any hazardous chemical sold and with the next shipment after an SDS is updated. Hampshire College specifically states, as per 29 CFR 19l0.l200 (g) (5), that the completeness and accuracy of the SDSs are the responsibility of the manufacturer or importer.
The purchasing staff requests SDSs at the time of the initial purchase and monitors to ensure that the SDSs 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 SDS is not received with the initial order, the purchasing staff contacts the manufacturer or distributor to ensure that an SDS is received.
Upon receipt of an SDS the purchasing staff sends it to the HazCom coordinator. Department supervisors and academic department faculty and staff who receive SDSs also forward the SDSs to the HazCom coordinator.
Upon receipt of new or updated (revised) MSDS, the HazCom coordinator updates the following college records:
- The on-line SDS library and Hazardous Chemicals List.
- The local back-up of the SDS library for use in the event the on-line library is unavailable.
SDS are available to employees on-line using MSDSonline. That system also provided the Hazardous Chemical List for each department.
Employees access the on-line SDS, though a link on TheHub, the College's administrative portal. The availability of the on-line library is communicated through training, the college web site, and posters in the workplace.
If an employee would like a printed copy of the SDS, it can be printed from the online system or a copy requested from the HazCom coordinator.
If an SDS for a hazardous chemical has not been supplied by the manufacturer, or is not available from the SDSonline library, the employee requesting the SDS 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 SDS 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 using the on-line system. Employees can access the list through the on-line system. If they would like a printed copy of the list, they can export and print it from the on-line system or ask the HazCom Coordinator to provide a copy.
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:
- Product Identifier
- Signal Words
- Hazard Statements
- Precautionary Statements and Pictograms
- Supplier Identification
B. Employer's Responsibility
The College 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:
- Identity of the hazardous chemical (for a mixture the trade name on the SDS should be used).
- Appropriate hazard warnings for health and physical hazard using the pictograms and/or hazard statements used on the SDS.
Signs may be used instead of labels on stationary process container.
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.
- Department supervisors and academic department faculty and staff must notify the HazCom coordinator of any manufacturer's containers that have inadequate labels and receive instructions from the HazCom coordinator as to the appropriate label.
- Department supervisors and academic department faculty and staff who are responsible for on-site hazardous chemicals formulation must ensure that containers are properly labeled, consulting the HazCom coordinator as necessary for label content.
- Department supervisors and faculty members inspect their work areas regularly to ensure that all containers of hazardous chemicals present are properly labeled. If unlabeled non-original (portable) containers of hazardous chemicals not in use are found, the supervisor identifies the employee responsible for the transfer of materials, reminds that employee of the labeling requirements, and supervises the placement of labels. If an improperly labeled container is found, the supervisor or faculty member is responsible for labeling consulting the HazCom coordinator as necessary for label content.
- The HazCom coordinator periodically inspects the workplace, bringing labeling inadequacies to the attention of the supervisor or academic faculty or staff.
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:
- The potential for exposure to hazardous chemicals is evaluated.
- The appropriate SDS are reviewed.
- The precautions indicated on the SDS are communicated to the employees involved.
- Any required protective equipment or clothing is provided before the task is begun, as is instruction on its proper use.
- If the supervisor or academic faculty or staff needs assistance to ensure the safety of employees or compliance with the HazCom Standard, the HazCom coordinator is contacted.
When outside contractors perform work on campus the following conditions requiring an exchange of information may exist.
- The contractor may bring hazardous chemicals to the work area, causing exposure of College faculty, staff, and students to those chemicals.
- The contractor's employees may be exposed to hazardous chemicals already in the workplace.
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 SDSs are exchanged. If SDSs are provided to the contractor, a record of the SDS provided is kept with the project file.