ST. LAWRENCE UNIVERSITY
HAZARD COMMUNICATION POLICY
(Right to Know)
Revised: December 16, 2011 (Rev 5)
Chemical Hygiene Officer
Table of Contents
St. Lawrence University is committed to providing a safe and healthful work environment for our faculty, staff and students. The Hazard Communication Standard (HCS) as found in 29 CFR 1910.1200 (www.osha.gov) is based on a simple concept—that employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working1. Such employees will make knowledgeable decisions and support protective measures such as product substitutions, engineered improvements and use administrative controls and personal protective equipment.
- Availability of the Written Program
The Written Hazard Communication Policy is available to all employees. Copies of the written program can be obtained from the Environmental Health and Safety Web Site http://www.stlawu.edu/environmental_health_and_safety or by contacting the Chemical Hygiene Officer, Suna Stone-McMasters 229-5105, email@example.com. If employees have further questions they may contact the Environmental Health and Safety Director, Ted Coviello, 315-229-5913/5607, firstname.lastname@example.org.
The procedures contained in this program are applicable to all employees of St. Lawrence University who are exposed to or may be exposed to hazardous chemicals and toxic substances. Examples of hazardous chemicals can be found in:
- 29 CFR 1910, Subpart Z Toxic and Hazardous Substances, OSHA
- Threshold Limit Values for Toxic Substances and Physical Agents in the Work Environment, ACGIH
- National Toxicology Program (NTP), “Annual Report on Carcinogens”
- International Agency for Research on Cancer (IARC), “Monographs”
Portions of this program are applicable to suppliers of materials to St. Lawrence University and contractors or vendors hired to perform work on the SLU campus.
- Hazard Communication Program Overview
The St. Lawrence University Hazard Communication Policy consists of six (6) parts:
- Material Safety Data Sheet (MSDS)
- Contractor policy
- Chemical hazards and safety
The Chemical Hygiene Officer (CHO) maintains an inventory of all chemicals on campus in cooperation with the departments. The inventory is monitored by the CHO working in cooperation with the Science, Environmental Studies, Fine Arts and other academic Departments, Dining Services and Facilities Operations. All departments which use or store hazardous chemicals are required to do an annual physical inventory and send an excel spreadsheet of the updated inventory to the chemical hygiene officer.
- Material Safety Data Sheets
Material Safety Data Sheets (MSDS’s) are available for every hazardous chemical on campus. MSDS’s are the primary source of safety information for a particular chemical. St. Lawrence University has contracted with 3-E Company to provide material safety data sheets, 24 hours a day, seven days a week by calling 1-800-451-8346. The caller should identify themselves as a participant under the St. Lawrence University 3-E contract, and have a fax number available of where to have the MSDS faxed. The FAX number at Security can be used anytime for this (315-229-7414). Callers will be asked to provide the product name, manufacturer name, product number and UPC code (if available). A guide to reading MSDSs is located in the Chemical Hygiene Plan Appendix B (http://www.stlawu.edu/environmental-health-and-safety/resource/chemical-hygiene-plan). Employees may also access the online MSDS collection from a campus computer via hq.msdsonline.com/stlaw2436
Each department chair or director using hazardous chemicals and toxic substances at St. Lawrence University is responsible for labeling and maintaining labels. All containers must have a label that is prominently displayed. It must be in English and may not be defaced in any way.
Each container of hazardous chemicals or toxic substances shall be labeled, tagged or marked with the following information:
- Trade name or chemical name of the material (chemical symbols are not appropriate unless a chart or key is immediately available and on display)
- Appropriate hazard warnings (words, pictures, symbols, NFPA diamond, HMIS labels, etc.) including physical and health hazards
- Name and address of the chemical manufacturer, importer, or other responsible party.
When it is necessary to transfer the product into other containers, this label information must also be transferred. This may be accomplished by making a photocopy of the original container and fixing it to the transfer containers, or by manually transferring the information. Exemptions to this requirement are limited to:
- Portable containers into which materials are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer (i.e., mop buckets) for his/her own use during that particular work shift.
- Temporary laboratory containers need only be labeled as to the identity of their contents. Original containers, however, must maintain manufacturer’s labels which include additional information.
- Reactions vessels such as beakers, flasks, etc., which are intended to be under the immediate supervision of an individual and will be emptied and cleaned immediately after use.
- In house, stationary containers, pipes or storage tanks that are otherwise identified (by placard, etc.), however, all information must be available to employees.
- Distilled Spirits (alcohol)
- Items – as defined and covered by the Consumer Product Safety Act
- Hazardous Waste – Follow the Waste Management and Minimization Plan for labeling hazardous waste containers. (http://www.stlawu.edu/environmental-health-and-safety/resource/hazardous-waste-management-and-minimization-plan)
Labels are to be provided by the manufacturer or supplier and must include the following:
- Name and address of manufacturer or responsible party
- Identify – Full chemical name, Chemical abstract number
- Physical and Health Hazard Warning(s) – Written hazard statement and/or hazard symbols. Information on chemical hazards, handling and target organ effects.
- Date received, date opened and if necessary date expiring (i.e. peroxide formers).
- Secondary containers must contain all of the above information as well as the date the bottle is filled. This can be done by obtaining the information from the MSDS.
There are several systems and standards for labeling chemicals to communicate their hazards, but there is not a uniformly accepted system in use at this time. Each system and standard has advantages and limitations.
ANSI Z129.1: Precautionary labeling for hazardous materials has been developed by the Chemical Manufacturers Association (CMA) and the American Conference on Chemical Labeling and adopted as American National Standards (Z129.1) by the American National Standards Institute (ANSI). This precautionary labeling contains the name of the chemical, a signal word such as WARNING or DANGER, the key hazard such as flammable or vapor harmful, and statements of precautions to avoid the hazard. The use of a single term will not always provide adequate information because many chemicals have multiple hazards. Another problem is that the term corrosive includes materials that may be incompatible with one another. For example, strong mineral acids (hydrochloric acid) and strong alkaline materials (sodium hydroxide) are both corrosive but if they mix during storage or use, they will react vigorously.
NFPA 704: The National Fire Protection Association (NFPA) has developed a color coded system called NFPA 704. The system uses a color coded diamond with four quadrants in which numbers are used in the upper three quadrants to signal the degree of health hazard (blue), fire hazard (red), and reactivity hazard (yellow). The bottom quadrant (white) is used to indicate water reactivity, radioactivity, biohazards, or other special hazards. The emergency hazards are signaled on a numerical scale of 0 to 4.
The NFPA diamond is used primarily by emergency response personnel and for emergency planning and as such does not adequately signal occupational hazards or precautionary information. The NFPA system is good for alerting personnel to the degree of hazard of the chemical and helpful in drawing attention to storage needs and emergency equipment needed.
NFPA Example: In this example there are severe flammable and water reactive hazards.
DOT: The Department of Transportation (DOT) hazard labeling system uses a color coded diamond in which there is a symbol and a term describing the major hazard of the material. DOT hazard classes include explosive, gases (flammable, nonflammable, corrosive, and poison), flammable liquids, flammable solids, oxidizers, poisons, radioactive materials, and corrosives. Most chemicals are rated by what the DOT considers to be the single major hazard, but many chemicals have subsidiary hazard categories as well. The DOT system is used for the transportation of hazardous materials.
HMIS: The National Paint & Coatings Association (NPCA) Hazardous Materials Information System (HMIS) is one of the most popular systems for labeling hazardous chemicals. The system uses standard labels to communicate hazards through the use of colors, numbers, letters of the alphabet, and symbols. The HMIS is a five part rectangle that provides identification of the chemical, acute health hazard (blue), flammability (red), reactivity (yellow), personal protective equipment designations (alphabet), and chronic health hazard information. The chemical identity is conveyed by the chemical name and should be the same as the name on the MSDS. Chronic health hazards may be any abbreviated technique such as an asterisk communicated by placed on the label denoting reference to the specific Material Safety Data Sheet, or the actual chronic information may be written on the label if space allows (i.e. target organ).
GHS - The Globally Harmonized System (GHS) of Classification and Labeling of Chemicals is a worldwide initiative to promote standard criteria for classifying chemicals according to their health, physical and environmental hazards. The GHS regulations are international regulations created by the United Nations for the Classification and Labeling of Hazardous Chemicals. It uses pictograms, hazard statements, and the signal words “Danger” and “Warning” to communicate hazard information on product labels and safety data sheets in a logical and comprehensive way. The primary goal of GHS is better protection of human health and the environment by providing chemical users and handlers with enhanced and consistent information on chemical hazards.
OSHA is expected to publish an updated Hazard Communications standard in late 2011, or shortly thereafter, that will incorporate the major elements of the GHS. A 3 year transitional period is expected, which will allow companies to have enough time to fully implement the new standards in their facilities.
Products will be assessed for 16 physical and 12 health and environmental hazards. Each of these will have category levels. Many laboratory chemicals received on campus are now shipped with GHS -compliant safety data sheets and labels. There are pictograms that will be associated with the different physical and health hazards, which appear in the table “GHS Pictograms & Hazard Classes.”
Labeling requirements under GHS are very specific, as seen in the example label below called “GHS Label”
- Contractor Policy
- Contracted employees on campus who could be exposed to hazardous chemicals as a result of their work on campus must also be familiar with St. Lawrence University’s Hazardous Communication Program and the necessary precautions to take while working on campus.
- Persons Responsible for Supplying Information to Contractors: The liaison between Facilities Operations and the contractor (Facilities Managers, Grounds Manager or Director of Fac/Op) will determine if contractors working on campus may be exposed to hazardous chemicals located on campus as a result of their work on campus.
- Information: Outside contractors working on campus will be provided with all necessary information concerning the potential hazards of the substances to which they may be exposed, and appropriate protective measures required to minimize exposure as well as emergency and hazardous waste removal procedures. For major projects, information will be disseminated during the start up meeting and will involve the Contractor, the St. Lawrence University Project Manager, the Director of Campus Safety, the Environmental Health and Safety Director, and the Chemical Hygiene Officer. For smaller projects, the information will be conveyed by whatever means the liaison deems appropriate.
- All outside contractors will make available a list of hazardous chemicals and Material Safety Data Sheets for the hazardous chemicals that their employees bring on to the University's property.
- No hazardous materials will be introduced into the workplace by vendors, sales people, frequenters, or employees without an MSDS presented to the appropriate department head or supervisor.
- No particularly hazardous substances will be brought onto campus without prior approval from the chemical hygiene officer (see chemical hygiene plan).
- Procedures for Documentation: Contracts, meeting minutes, and other written documents will be used to verify that the contractor or representative received all necessary hazard communication information and that they understand St. Lawrence University’s policies and procedures regarding hazardous chemicals.
- Chemical Hazards and Safety
Hazardous chemicals include chemicals which present either physical hazards or health hazards. In many cases a chemical can present both types of hazards. The purpose of this section is to explain the nature of chemical hazards and how they are described on the material safety data sheets.
Physical Hazards of Chemicals: The physical hazards that chemicals may present include flammability and reactivity. Flammability is the tendency of the chemical to burn. Reactivity is the potential of the chemical to explode or react violently with air, water or other substances upon contact. Information about these properties of a chemical is available on the container’s label and on the MSDS. This information is provided as flashpoints and ignition temperatures for flammability and as chemical incompatibilities and severity ratings for reactivity.
Before using any chemical you should review the MSDS or another appropriate source to be sure you are aware of the hazards of the chemical. Follow the directions for the use of that chemical carefully. Accidents with hazardous chemicals can happen quickly and can be quite severe. Prevention of such accidents requires that people are aware of the hazards of the chemicals they are using.
Health Hazards of Chemicals: The health effects of hazardous chemicals are often less clear than the physical hazards. Data on the health effects of chemical exposure, especially chronic exposure, is often incomplete. This section outlines the general nature of the health effects of chemicals so that you can better understand the information provided on the MSDS.
The health hazards that a chemical presents depend not only on the properties of the chemical, but on the manner in which the chemical is used, and the resulting exposure to the worker. With the proper handling, highly toxic chemicals can be used safety. On the other hand, chemicals which are not highly toxic can be extremely hazardous if not handled properly. Understanding what factors influence the health effects of chemicals will help you better protect yourself.
Toxic Effects of Chemical Exposure: Whether or not a chemical exposure will affect a person’s health depends on many factors. The dose is the amount of a chemical which enters the body. The actual dose that a person receives depends on the concentration of the chemical as well as the frequency and duration of exposure.
In addition to the dose, the outcome of exposure is determined by: 1) the way the chemical enters the body, 2) the properties of the chemical, and 3) the susceptibility of the individual receiving the dose. Understanding these factors will help you know what precautions to take to protect yourself and others from chemicals you work with.
Routes of Entry: See the Chemical Hygiene Plan for detailed information on routes of entry, controlling chemical exposure and personal protective equipment (Chapters 7-9 and Appendix E and L).
Skin and Eye Contact (Absorption)
The simplest way for chemicals to enter your body is through direct contact with your skin or eyes. Many chemicals can penetrate your skin and enter your bloodstream. They can then have toxic effects on other parts of your body. Symptoms of skin exposure to chemicals are: dry, whitened skin; redness and swelling; rashes or blisters, and itching.
To prevent contact with chemicals, wear gloves and other protective clothing to minimize skin exposures which might be hazardous (Glove Selection Guide CHP Appendix L). Anytime you get a chemical on your skin you should rinse promptly and thoroughly using lots of water.
You should always be careful to protect your eyes, since chemical contact with the eyes is particularly dangerous. Eyes are more easily injured than skin and they provide an easier entrance to your body for chemicals. Chemicals in the eyes must be washed immediately – seconds count. Use the safety eyewash to flush eyes thoroughly and continuously for at least fifteen (15) minutes.
Respiratory Tract (Breathing/Inhalation)
Any airborne chemical can be absorbed into your body through your respiratory system. Factors that affect the absorption of gases and vapors in the lungs include the vapor pressure of the gas, the concentration of the gas in the inhaled air, and chemical properties of the gas. Symptoms of exposure to gases include headaches, increased mucus, and eye, nose and throat irritation. Narcotic effects, including headache, confusion, dizziness, and collapse can result from exposure to some substances, including many common hydrocarbon solvents.
Should you experience these symptoms, immediately reduce your exposure by working under a hood, closing chemical containers, and opening windows or leaving the area. If your symptoms persist, get medical attention.
Olfactory fatigue is an important phenomenon for you to be aware of. At high concentrations of some gases or after long exposure to some substances (such as hydrogen sulfide), you may no longer be able to smell them. So, once you smell a strange odor, investigate its source, even it if seems to disappear.
Gastrointestinal Tract (Ingestion)
Your gastrointestinal tract is an important route of entry for chemicals because it gives them access to your bloodstream. Many toxicity ratings are expressed in terms of oral LD50, which is the dose of the chemical which is required to kill half of the animal population which eats the chemical.
You have a great deal of control over preventing accidental ingestion of chemicals. Food, beverages, and cigarettes should never be brought into a work area or stored in refrigerators with chemicals. After working with chemicals always wash your hands thoroughly before drinking, smoking, eating or touching your face.
Another possible route of exposure to chemicals is through accidental injection. This too is an important route of entry because it provides direct access to your blood stream and thus no protection for your various organs from the effects of the chemicals. Injection of chemicals can occur through mishaps with hypodermic needles (especially when you are working with animals) or through accidents with pipettes, broken glassware, or other sharp objects which have been contaminated with chemicals. Cautious use of any sharp object is always important. Always dispose of sharps in the red ridged biohazard boxes (See Regulated Medical Waste Policy located on the EHS Web site for more information)
Toxic Properties of Chemicals
The effects of a chemical can be local or systemic. Local injuries involve the area of the body in contact with the chemical and are typically caused by reactive chemicals. Systemic injuries involve tissues and organs removed from the site of contact of the chemical and are a result of the chemical being carried through the body by the blood stream.
Toxicity is an indication of how severely the chemical affects the human body at a site removed from the site of contact. Toxic effects can be acute or chronic, depending on how the dose of the chemical is received. Acute toxicity results from a single short exposure, and its effects usually appear quickly and are reversible. Chronic toxicity results from repeated exposure over a long period of time. Its effects are usually delayed and irreversible.
Certain chemicals affect certain specific target organs. Examples of the target organ(s) of toxicity for certain chemicals include the brain, kidney, and red blood cells for lead, the immune system for isocyanates, and the liver and kidney for chloroform.
Susceptibility of Individuals
Factors influencing the susceptibility of particular individuals to the effects of hazardous chemicals include obesity, nutritional habits, physical condition, medical condition, drinking and smoking, and pregnancy. For any particular individual, all these factors must be considered in predicting the effects of a chemical on the individual.
An important phenomenon for some individuals is sensitization. Over a period of time daily exposure to some chemicals can lead to the development of an allergic rash or other reaction. Over time this can occur with further exposure to even small amounts of the chemical but goes away when exposure stops. This is called sensitization. Examples of sensitizers are: nickel salts, epoxy resins, isocyanates and formaldehyde.
Effects of Chemical Exposure on Human Reproduction
A developing fetus may be more sensitive to some chemicals than its pregnant mother, particularly during the first 12 weeks of pregnancy. Certain chemicals, called teratogens, are particularly likely to cause birth defects if the fetus is exposed to them. Proper handling of chemicals and use of protective equipment to reduce fetal exposure to chemicals is especially important.
Known human teratogens include: organic mercury compounds, lead compounds, ionizing radiation, some drugs, alcohol ingestion, and cigarette smoking. Some substances causing adverse reproductive effects in males include: 1,2-dibromo-3-chloropropane, cadmium, mercury, boron, lead, some pesticides, and some drugs. Chemicals are continually added to this list. For a list of known or suspected teratogens see Oxford University’s Chemical and Safety Web Site http://ptcl.chem.ox.ac.uk/MSDS/teratogens.html.
Chemical Hazards Summary
The safe use of hazardous chemicals is a problem not only for laboratory and chemical workers, but for everyone. Estimating the health hazard posed by the use of a chemical is controversial and complex. It involves more than determining its toxicity. It also depends on the chemical’s properties and the manner in which it is used. By learning about the potential hazards of the substances you use, and by practicing appropriate safety procedures for those substances, you can work in an informed and intelligent manner.
All employees have the right to be trained in chemical use and safety for any chemical they use or might be exposed to on the job. Employees will be trained during initial assignment, annually or when new physical or health hazards are introduced.
There are three levels of training depending upon job requirements.
- New Employee Orientation: Awareness level training on chemical safety and material safety data sheets (MSDS’s) will be provided to all new employees. This training will be provided by Human Resources as part of new employee orientation.
- Hazard Communication Training: Required for all employees who will work with hazardous chemicals (including work study students). This training will be provided by the Chemical Hygiene Officer, and will consist of an overview of the following:
- OSHA’s Hazard Communication Standard (HCS)
- Review of the Hazard Communication Plan
- Product labels and material safety data sheets
- Physical and health hazardous of the chemicals in the work area
- Methods and observations that may be used to detect the presence or release of a hazardous chemical (smell, visual observations)
- Symptoms of exposure
- Proper chemical handling practices
- Measures employees can take to protect themselves from exposure to the hazards, including work practices, selection and use of personnel protective equipment (PPE) and emergency procedures.
Employees that are required to receive hazard communication training include:
- All Facilities Operations employees (management & hourly, full and part-time)
- All Dining & Conference Services employees (hourly and management, full and part-time)
- All Security (officers and management, full and part-time)
- All faculty and staff in these academic areas:
- Technicians in Instructional Technology
- Librarian: anyone working on book/document restoration
- All Shipping, Receiving, and Mailroom employees
- Environmental Health and Safety
- Any other positions that require working with or near hazardous chemicals.
- Department Specific Training: Training provided to chemical users by their SUPERVISOR that addresses the SPECIFIC hazards and control measures required to abate injury and/or illness for their employees’ jobs. Training does not have to be formal and should be accomplished by whatever means are most appropriate for individual departments. Employees will be informed of the location of the MSDSs for the materials that they use, any labeling systems in effect, and departmentally developed procedures relating to their specific functions. Special training sessions will be conducted to cover non-routine tasks.
Security and Safety
2005 (Rev 1)
Updated Policy and removed information that is now part of the Chemical Hygiene Plan and the Waste Management plan.
11/7/05 (Rev 2)
Combined Right to Know with Chemical Right to Know and Hazard Communication Policies.
12/5/05 (Rev 3)
Reformatted, added table of content and Introduction section for brief overview of policy. Added employees requiring training.
Updated name of Chemical Hygiene Officer
Added msdsonline.com address for retrieving MSDS collection. Combined introduction sections “purpose” and “policy on Hazard Communication” into one section entitled “Purpose”. Added section 1.3 “Applicability”. Updated “labeling” section to correspond with OSHA standard. Added training content required, and when training must be provided. Added section on Globally Harmonized System of Classification and Labeling of Chemicals (GHS)