Hazard Communication Program

Policy

All employees have both a need and right to know the hazards and identities of the chemicals they are exposed to when working as identified in the Hazard Communication Program.

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Scope

The Hazard Communication Program establishes requirements for informing University employees who work with or are exposed to hazardous chemicals and the physical and health hazards posed by those materials. This applies to any 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.

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Exception

The Hazard Communication Program applies to laboratories only as follows:

  • Employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced;
  • Employers shall maintain all Safety Data Sheet (SDS) for incoming containers of hazardous chemicals and ensure that they are readily accessible to employees;
  • Employers shall ensure that employees are provided information and training on the associated hazards of chemicals in their workplace; and
  • Laboratory employers that ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor under this rule, and thus must ensure that any containers leaving the laboratory are labeled in accordance with the labeling requirements of this document and that a MSDS is provided to distributors and other employers.

For additional exceptions to this policy, please refer to Hazard Communication Product Exemption.

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Authority and Responsibility

Environmental Health and Safety has the primary responsibility and authority for the implementation and enforcement of the Hazard Communication Program and is responsible for:

  • Developing, implementing and evaluating the Hazard Communication Program annually to ensure compliance;
  • Providing general information and training relating to hazard communication for affected University employees;
  • Maintaining and updating the SDS Program;
  • Developing and implementing a universal hazardous chemical labeling system;
  • Establishing emergency procedures to properly handle hazardous material releases. Refer to the Emergency Response Plan for Hazardous Materials; and
  • Identifying appropriate personal protective equipment (PPE) for employee use.

Departments are responsible for:

  • Notifying all employees of the purpose and intent of the Hazard Communication Program;
  • Ensuring that affected employees are trained in general hazard communication;
  • Providing department specific information and training relating to hazard communication for affected University employees; and
  • Providing PPE and clothing in accordance with prescribed training.

Employees are responsible for:

  • Complying with the Hazard Communication Program procedures;
  • Participating in the University’s general Hazard Communication training session and department specific training sessions;
  • Understanding how to read chemical labels and SDS;
  • Understanding and taking necessary precautions when handling hazardous chemicals; and
  • Using PPE.

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Information and Training

Employees shall receive information and training on hazardous chemicals in their work area at the time of their initial assignment, whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area and every three years. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical specific information shall always be available through labels and SDSs. Environmental Health and Safety shall provide all general hazard communication training. This training shall utilize the “Hazard Communication” training booklet generated by Environmental Health and Safety.

This general training program shall provide an introduction to the following:

  • The requirements of the Hazard Communication regulation;
  • Any operations in the work area where hazardous chemicals are present;
  • The location and availability of the written Hazard Communication Program;
  • The details of the Hazard Communication Program including an explanation of the labeling system and SDS and how employees can obtain and use the appropriate hazard information;

Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area;

  • The physical and health hazards of the chemicals in the work area; and
  • The measures employees can take to protect themselves from these hazards, including work practice controls, emergency procedures and PPE.

Department specific training shall be conducted upon employment, and whenever a new hazard (e.g., new class of chemical hazards, a change in assignment or a new process which may be hazardous) is introduced into an employee’s work area. Department specific hazard communication training shall include information on:

  • Specific chemical hazard classes found in the work area;
  • Location of the University’s Hazard Communication Program within the department;
  • Specific location and availability of the department’s MSDSs;
  • Available PPE (Refer to the Personal Protective Equipment policy) and appropriate emergency procedures for chemicals found within the work area as outlined by the MSDSs; and
  • Location and availability of appropriate chemical labels.

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Safety Data Sheets (SDS)

SDS are the primary source of information intended to outline the special precautions and controls necessary for handling specific hazardous chemicals and responding to emergency situations.  SDS’s are typically provided by the chemical manufacturer or chemical supplier and are required to be presented in a consistent 16-section format;  

The Safety Data Sheet sections are as follows:

  1. Composition/information on ingredients;
  2. Hazard(s) Identification;
  3. Composition/information on ingredients;
  4. First-aid measures;
  5. Fire-fighting measures;
  6. Accidental release measures;
  7. Handling and storage;
  8. Exposure controls/personal protection;
  9. Physical and chemical properties;
  10. Stability and reactivity;
  11. Toxicological information;
  12. Ecological information;
  13. Disposal considerations;
  14. Transport information;
  15.  Regulatory information; and
  16. Other information.

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Obtaining SDSs

SDSs are readily available upon request 24 hours a day and at Safety Data Sheets.

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Labeling

To ensure that appropriate information concerning the hazards of a chemical are accessible to employees, all containers of hazardous chemicals shall be labeled. Labels shall be legible, in English (additional languages may be included as necessary), and prominently displayed on the container. Chemical manufacturers, importers, and distributors shall ensure that every container of hazardous chemicals entering the workplace is appropriately labeled with the identity of the hazardous chemical(s) (common and/or chemical name), appropriate hazard warnings; and the name and address of the chemical manufacturer, importer or other responsible party.

If a chemical label in the workplace becomes damaged, illegible, or is inadvertently removed from a container, it shall be replaced immediately by the supervisor or designee.

Replacement labels shall include, at a minimum, the identity of the hazardous chemical(s) common and/or chemical name, appropriate hazard warnings or alternatively, words, pictures, symbols or combination thereof, which provide at least the general information regarding the hazards of the chemicals.

Chemicals which are transferred from the original container into a secondary container shall be identified by a label on the secondary container. If is not necessary to label the secondary container if it is used immediately by the employee who performs the transfer.

Non-hazardous substances (e.g., distilled water) should be labeled in order to avoid confusion.
To comply with labeling requirements, the University has adopted the National Fire Protection Association (NFPA) labeling system.

The labels can be purchased from the Fisher stockrooms located in:

  • Searle Chemical Laboratory, Room 104, 773-702-0672; and
  • Gordon Center for Integrative Science Building, Room 143, 773.702.3328.

The following colors are used to represent the hazards on the NFPA label:

  • Red represents the fire hazard;
  • Blue represents the health hazard;
  • Yellow represents the reactivity hazard; and
  • White represents the specific hazard.

Each diamond except the white one has a number between 0 (least hazard) and 4 (worst hazard). The white diamond has a symbol to indicate reactivity with water, oxidation, polymerization, radiation, extinguishing agent, or required protective equipment.

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Shipping Hazardous Materials

Any employee offering or accepting international, interstate or intrastate transportation of hazardous materials shall be in accordance with the Hazardous Materials Transportation Program.

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Globally Harmonized System (GHS) of Classification and Labeling of Chemicals

The Occupational Health and Safety Administration has adopted the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. Starting in 2013.

The hazard classification differences between GHS and NFPA include:

  • Rating scale between the two systems varies; and
  • The NFPA rating usually appears on the label and MSDS while the GHS rating will typically only be displayed in the SDS.

HMIS/NFPA Hazard Ratings

  • 0 - Minimal Hazard
  • 1 - Slight Hazard
  • 2 - Moderate Hazard
  • 3 - Serious Hazard
  • 4 - Severe Hazard

GHS Hazard Categories

  • 1  -Severe Hazard
  • 2 - Serious Hazard
  • 3 - Moderate Hazard
  • 4 - Slight Hazard
  • 5 - Minimal Hazard

Labeling Requirements

  • A signal word;
  • Hazard statement;
  • Precautionary statement
  • Product identifier;
  • Supplier identification; and
  • Hazard pictograms.

There are nine pictograms the GHS uses to convey health, physical, and environmental hazards. They are required to be on a white background, framed by a red border.  The pictograms are made up of the following:

  • Health hazard;
  • Flame;
  • Exclamation mark;
  • Gas cylinder;
  • Corrosion;
  • Exploding bomb;
  • Flame over circle;
  • Environment (non-mandatory); and
  • Skull and crossbones.

Reviewed: August 2017

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