Hazard Communication Program


University of Wisconsin - La Crosse
Environmental Health and Safety Standard

Subject: Hazard Communication Program
Original: November 12, 1998
Last Updated: October 13, 2009

I. APPLICABLE DOCUMENTS

  1. Occupational Safety and Health Administration, 29 CFR 1910.1200; Hazard Communication.

  2. Wisconsin Department of Commerce, Chapter 32; Public Employee Safety and Health.

  3. Wisconsin Statutes, Section 101.11, Regarding Safe-Place of Employment.

II. PURPOSE

The Hazard Communication Standard (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 conveyed 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 HCS applies to any hazardous chemical which 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. The definition of “hazardous chemical” under the standard is extremely broad, and includes any chemical which is a physical hazard or a health hazard. The OSHA standard sets a procedure for hazard determination, and any substance determined to be hazardous under this procedure is subject to the program.

This written hazard communication program (HCP) applies to all UW-L employees, students, or building frequenters who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. This HCP applies to students and frequenters as stipulated in Wisconsin Statutes, Section 101.11, regarding safe-place of employment. The Wisconsin safe-place statute requires provision of safe physical conditions on the premises. UW-L employees (such as office workers), students, or building frequenters who encounter hazardous chemicals only in non-routine, isolated instances are not covered by the HCS and this HCP.

This standard identifies the policies, procedures, and guidelines for management of the Hazard Communication Program at the University of Wisconsin-La Crosse (UW-L). It was developed to protect UW-L employees, students, and frequenters who use hazardous chemicals at UW-L. The policies set forward in this document are intended to ensure compliance with Federal and State regulatory requirements.

III. SCOPE AND POLICY

A safe and healthful campus environment shall be provided for all UW-L employees, students, guests, and residents of the community. This written HCP requires each Department/Division/Unit to achieve the following minimal standards.

  1. Take reasonable precautions to provide a campus environment that is free from recognized hazards.
  2. Ensure that chemical hazards are identified within each work area.
  3. Make available chemical hazard information to all personnel who may be potentially exposed.
  4. Rely on MSDS information provided by chemical manufacturers in determining chemicals covered by the provisions of this document.

IV. DEFINITIONS

Chemical - Any element, chemical compound, or mixture of elements and/or compounds. This includes all liquids, gases, alloys, powders, inks, paints, adhesives, and similar materials.

Chemical Name - The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation.

Container - Any bag, barrel, bottle, box, can, cylinder, drum, pipe, reaction vessel, storage tank, or vat, or other receptacle that contains a chemical substance.

Employee - An individual in a fiscally compensated (wage/salary) and employed status who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers who encounter hazardous chemicals only in non-routine, isolated instances are not covered.

Foreseeable Emergency - Any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.

Hazardous Chemical- Any chemical which is a physical hazard or a health hazard.

Health Hazard - 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. The term "health hazard' includes chemicals which are carcinogens, toxic, or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.

Immediate Use - The hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift that it is transferred.

Label - Any written, printed, or graphic material displayed on or affixed to containers of chemicals.

Material Safety Data Sheet (MSDS) - Written or printed material concerning a hazardous chemical provided by the chemical manufacturer/distributor.

Physical Hazard - A chemical for which there is evidence that it is combustible, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water reactive.

V. RESPONSIBILITIES

A. Environmental Health and Safety (EH&S) Responsibilities

  1. Develop and provide overall administrative guidance and supervision for the Hazard Communication Program (HCP), including interpretation of the regulations when clarification is required.
  2. Provide initial training to University faculty and staff.
  3. Maintain a file of documentation and records associated with the HCP, including but not limited to:

a. Training records
b. Chemical inventories
c. MSDS (paper copy and electronic database)

B. Department Chair/Manager/Supervisor Responsibilities

  1. Attend Employee Hazard Communication Program (HCP) training sessions covering the requirements of this program and management responsibilities.
  2. Ensure that each paid employee using a hazardous chemical in the assigned unit has completed the HCP training and is familiar with the chemicals used in the workplace. (For students see section V.B.10.)
  3. Ensure that all training is documented.
  4. Ensure that training is provided to new paid employees at the time of the initial assignment to their area, and whenever the paid employee is reassigned to an area using new or different chemicals and/or processes.
  5. Provide refresher training whenever new chemical hazards are introduced into the work area.
  6. Send all training documentation rosters to the Environmental Health and Safety office which identifies the trainer, trainee, course title, and training date.
  7. Ensure that containers are labeled according to the specifications outlined in Section VI, Labeling.
  8. Ensure that information and materials for appropriate labeling are provided to the employee.
  9. Ensure that contract employees and volunteers under their administrative control are informed about hazardous chemicals in the workplace.
  10. Ensure that department faculty provide and document HCP training for students.

C. Paid Employee Responsibilities

  1. Attend training seminars on the Hazard Communication Standard.
  2. Label all containers in accordance with university policy as outlined in Section VI.
  3. Use safe work practices, protective clothing and equipment required for the job or task.
  4. Submit the original MSDS for hazardous chemicals to Environmental Health and Safety for inclusion in the site MSDS inventory. A copy may be retained for individual files.

VI. LABELING

As a minimum, all hazardous chemicals are subject to the labeling requirements of the Hazard Communication Standard (HCS). Each container shall include the chemical or trade name, appropriate hazard warning and manufacturer name. The manufacturer name is not required when a chemical is synthesized on campus.

All containers of hazardous chemicals shall be correctly labeled as described below. The Environmental Health and Safety (EH&S) office will provide container labels for stationary and portable containers upon request.

-Labels and other forms of warning must be legible, in English, and prominently displayed on the container.
-Existing labels on containers shall not be removed or defaced unless re-labeled immediately with the required information.
-Secondary containers (safety cans, plastic bottles, etc.) shall be labeled with the trade and/or chemical name, manufacturer name when not site synthesized, and hazard warnings (health, reactivity, flammability, PPE). The use of unmarked, portable containers of hazardous chemicals is allowed when the material will be immediately used by one person.
-For stationary process containers, regardless of size, alternative identification methods may be used if the hazards of the chemical are effectively conveyed to the employee. Alternate methods of labeling are; signs, placards, and batch tickets (tags). CAS numbering or lettering system may be an acceptable form of identification on the above types of labels. However, all employees must be trained to understand this method of identification and know where to find the applicable MSDS in their work area.

VII. MATERIAL SAFETY DATA SHEETS (MSDS)

The Material Safety Data Sheet (MSDS) is a detailed technical document containing the physical and chemical properties and hazard information about a specific product. In accordance with the HCS, an MSDS is to be prepared by manufacturers and/or distributors of chemical products. MSDS’s for all chemicals and/or chemical mixtures will be provided by chemical manufacturers and/or distributors in accordance with State Procurement Procedures (PRO-D-4). UW-L will rely upon this method of obtaining accurate, complete, and current MSDS’s.

When hazardous chemicals are not purchased through Purchasing Services (e.g., Procurement Card) the individual buying the hazardous chemical shall obtain an MSDS for the product. MSDS acquisition is a requirement of UW-System Purchasing procedures. A copy of all MSDS’s obtained from the manufacturer or distributor should be sent to Environmental Health and Safety (EH&S) for inclusion in the Site Master MSDS file.

Prior to the purchase of a new chemical, it is recommended that a complete and current MSDS be requested. Every new product should be reviewed before being ordered.

A copy of individual MSDS’s for each chemical will be maintained in a master file in the EH&S office. MSDS’s will be made available and accessible during all work shifts. In the event that an MSDS is not available for a chemical used in a particular work area, an MSDS can be requested from the EH&S office.

Supervisors must ensure that employee requests for MSDS’s are promptly handled. The employee must be notified of any delays in responding to an MSDS request. EH&S will forward a copy of the MSDS directly to the employee once it is received from the manufacturer/distributor. Electronic copies of MSDS’s and the Site Chemical Inventory are readily available on a document in the UW-L Environmental Health and Safety Home Page.

VIII. TRAINING

A. Job Specific Training and Education

The hazards associated with chemicals used in the work area must be communicated to employees. The UW-L written Hazard Communication Program shall be made available to all employees. Hazard information for chemicals that the employee may come in contact with during their work can be found on the Material Safety Data Sheet (MSDS).

Working with the Environmental Health and Safety (EH&S) Manager, the Department Chair, Manager or Supervisor will be responsible for ensuring employees receive initial training in the Hazard Communication Program. Training will:

  1. Indicate the location and availability of the written hazard communication program, including the list(s) of hazardous chemicals.
  2. Explain what an MSDS is, how to read the MSDS (i.e. what each section contains and where to look for specific information), where MSDS’s are kept, and how to obtain a copy of an MSDS.
  3. Explain the labeling system used at UW-L as outlined in Section VI.
  4. Encourage employees to familiarize themselves with the chemicals they use. Information should be updated as needed and before the employees work with new chemicals to ensure maximum understanding and employee protection.
  5. Describe methods and observations that may be used to detect the presence or release of a hazardous chemical.
  6. Explain what to do in case of a chemical emergency such as a mechanical accident, spill or leak.
  7. Familiarize employees with caution or other warning signs used in the work area.
  8. Inform and encourage employees to use any required personal protective equipment and follow safe work practices to protect themselves from hazards.
  9. Inform employees about the proper performance and possible hazards of any non-routine tasks.

B. Training Documentation

Each paid employee will be asked to sign an employee Training Attendance Roster form during the training session. The original roster should be forwarded to the Environmental Health and Safety Office. A copy should be retained by the trainer.

IX. CONTRACT EMPLOYEES NOTIFICATION

University of Wisconsin - La Crosse personnel who manage contracts with non-university service providers are responsible for instructing all outside contractors to contact the Environmental Health and Safety Office for specific information regarding hazardous chemicals within the University that may pose a risk to contract employees. These same individuals will require all contractors to provide the EH&S Office with information concerning hazardous chemicals brought into any UW-L facility to perform contracted work before that work begins.

X. APPROVAL

The Hazard Communication Program is effective immediately. All University of Wisconsin - La Crosse employees shall fulfill their responsibilities as designated within this written standard.