Table of Contents
- Designated Responsibilities
- MSDS Procurement
- MSDS Updating Procedure
- MSDS Access Procedure
- Hazardous Chemicals List
- Container Labeling
- Information and Training
- Performing Non-Routine Tasks
- Outside Contractors
The Hazard Communication (HC) 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 HC 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 which act on the hematopoietic (blood) system, and agents which 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 HC Standard, including: labeling, MSDS access, training, and maintaining a list of all hazardous chemicals used.
This MHC Chemical Hazard Communication (HC) Program describes how the requirements of the OSHA HC Standard are met by the College and includes, as a separate document, a list of the hazardous chemicals present in the workplace. This HC Program and the Hazardous Chemical List are available to employees, or their designated representatives, upon request. This HC Program is maintained as an on-line document on the College web site. Paper copies are available upon request.
This HC 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, and the MHC Science Center Safety Handbook. The Handbook describes which departments and programs meet the OSHA definition of a laboratory.
There are several HC Standard exemptions and labeling exemptions that are applicable to the MHC HC Program. These exemptions are summarized in Appendix A.
The following designated responsibilities play key roles in carrying out the HC Program. Details of each function are described in subsequent sections.
The HC Coordinator coordinates the HC 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. Abstract from the College Hazardous Chemicals List separate lists of hazardous chemical present in each department and send these lists to each department.
- Maintain the College master MSDS File.
- Distribute MSDS to the appropriate departments.
- 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 and record keeping.
- Coordinate periodic chemical surveys to ensure that MSDS are on file for all hazardous chemicals.
- Maintain and update the HC Program as necessary and distribute to all applicable department heads, supervisors, HC Trainers and MSDS Monitors.
- Perform duties of the HC Trainer for those departments, including academic departments, who do not have an assigned department HC Trainer.
Each department has a designated MSDS Monitor who is responsible for the following specific duties:
- File and distribute, as necessary, MSDS and the department Hazardous Chemicals List received from the HC Coordinator.
- Ensure that MSDS are readily available to employees in their work areas during their work shifts.
- Make this HC Program, the department Hazardous Chemical List, and the OSHA HC Standard available for review to employees upon request.
Department heads keep the HC Coordinator informed of who is serving as the Department MSDS Monitor. For offices the copy machine key operator serves as the MSDS Monitor.
The Dining Services Department has a designated HC Trainer. The HC Coordinator serves as the HC Trainer for other departments. The HC Trainer trains all new and transferred employees who may be exposed to hazardous chemicals in their work areas under normal operating conditions or in foreseeable emergencies; and, also, updates training when new hazards are introduced into the work area. Employees are trained at the time of their assignment to a position requiring training. HC Trainers keep training records for all employees trained.
Department heads keep the HC Coordinator informed of who is serving as the Department HC Trainer.
The College Purchasing Coordinator, the Dining Services Purchasing Manager, and the Facilities Stockroom Supervisor are collectively called the Purchasing Staff for the purposes of this HC 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 MSDS for each chemical purchased for which a MSDS is not already available.
- Upon receipt of MSDS send it to the HC Coordinator. (Laboratory MSDS are sent directly to the ordering Department.)
- Monitor receipt of requested MSDS and follow up with the manufacturer if MSDS are not received.
- Contact the manufacturer upon notification by the HC Coordinator that a hazardous chemical container label does not meet the requirements of the HC Standard.
- Establish and enforce policies necessary to ensure that MSDS are received for all hazardous chemicals purchased by the administrative and non-laboratory academic departments for which they are responsible.
Supervisors and academic faculty and staff monitor compliance with the requirements of the HC Program within their work areas, including the following specific duties.
- Conduct periodic chemical surveys as initiated by the HC Coordinator, to ensure that MSDS are available for all hazardous chemicals in their work areas.
- Make sure MSDS are obtained for all products purchased on blanket purchase orders, or that is otherwise not purchased through the Purchasing Staff (e.g., sample products).
- Notify the HC 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 a MSDS is not available.
- Affix labels as necessary to meet the employer's labeling responsibilities as described in Section VII. Labels are available from the Department MSDS Monitor or the HC Coordinator.
- Notify the HC 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 HC Coordinator regarding label content.
- Forward all MSDS received to the appropriate Purchasing Staff.
Human Resources provides the HC Coordinator a list of the names of all new and transferred employees and their position titles and Departments. Each new employee receives a one-page summary of the HC Program for Mount Holyoke College (Appendix B).
Manufacturers, importers and distributors are responsible for providing a MSDS with the initial shipment of any hazardous chemical sold and with the next shipment after a MSDS is updated. Mount Holyoke College specifically states, as per 29 CFR 19l0.l200(g)(5), that the completeness and accuracy of the MSDS are the responsibility of the manufacturer or importer.
The Purchasing Staff requests MSDS at the time of the initial purchase order and monitors to ensure that the MSDS are received. If the chemical is not hazardous or is an article as defined by the HC Standard, the vendor is asked to provide written confirmation of that determination.
Department supervisors and academic department faculty and staff obtain MSDS for chemicals purchased on blanket purchase orders or that are not purchased through the Purchasing Staff and forward them to the appropriate Purchasing Staff.
If a MSDS is not received with the initial order, the Purchasing Staff contacts the manufacturer or distributor to ensure that a MSDS is received.
Upon receipt of a MSDS for an administrative or non-laboratory academic department, the Purchasing Staff sends it to the HC Coordinator.
Upon receipt of new or updated (revised) MSDS from the Purchasing Staff, the HC Coordinator updates the following College records:
- The Hazardous Chemicals List.
- The MSDS master file.
- The department MSDS file and Hazardous Chemical List.
- Labeling instructions.
Department MSDS files are available for review by the employee or their authorized representative in their work area. For employees with multiple work areas, MSDS files are kept at the location to which they regularly report.
If a 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 HC Coordinator. The employee is not required to work with the hazardous chemical if s/he is not satisfied with the information provided until a 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 HC Coordinator.
The Hazardous Chemicals List is updated as new/revised MSDS are received. Given this updating frequency, the List, while an integral part of the HC Program, is maintained as a separate document. The Hazardous Chemical List for each department is sent by the HC Coordinator to each department's MSDS Monitor to be kept with each department's set of MSDS for access by the HC Trainer, MSDS Monitor, supervisors, employees and their representatives.
The manufacturer or distributor of hazardous chemicals must label each container of hazardous chemical leaving their workplace with the following information:
- Identity of the hazardous chemicals.
- Appropriate warning for each physical and health hazard.
- Name and address of the chemical manufacturer, distributor or other responsible party.
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:
- Identity of the hazardous chemical (for a mixture the trade name can be used if it corresponds to the MSDS and to the Hazardous Chemicals List).
- Appropriate hazard warnings for health and physical hazard.
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.
This procedure ensures that (1) 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 HC Coordinator of any manufacturer's containers that have inadequate labels and receive instructions from the HC 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 HC Coordinator as necessary.
- Department supervisors and academic department faculty and staff 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.
- The HC Coordinator periodically inspects the workplace, bringing labeling inadequacies to the attention of the supervisor or academic faculty or staff.
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. Employee training includes specific instruction on the labeling systems. Labels are available from the department MSDS Monitor or the HC Coordinator.
The HC Coordinator or department HC Trainer 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.
All new employees are given a one-page summary of the HC Program during benefits orientation. Training updates are provided periodically and when new hazards are introduced. The HC Trainer 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 MSDS are reviewed.
- The precautions indicated on the MSDS 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 HC Standard, the HC 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 Mount Holyoke College faculty, staff and students.
- 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 MSDS are exchanged. If MSDS are provided to the contractor, a record of the MSDS provided is kept with the project file.