Hazard Communication Plan
II HAZARD DETERMINATION PROCEDURES
III LIST OF HAZARDOUS MATERIALS
A. LABELS AND OTHER FORMS OF WARNING
B. INFORMING CONTRACTORS ABOUT HAZARDS
C. CHEMICAL SPILLS AND ACCIDENTS
D. CHEMICAL HANDLING, STORAGE, AND DISPOSAL
V PERSONAL PROTECTIVE EQUIPMENT
A. SAFETY COMMITTEE MEMBERS
B. OSHA STANDARD 29 CFR 1910 SUBPART Z
C. MAPS OF PHYSICAL PLANT AND LABORATORY FACILITIES
D. MSDS PAMPHLET
E. SAMPLE INCIDENT REPORT
Wittenberg University seeks to protect its employees from all unsafe exposures to hazardous chemicals known to be present in the workplace. Employees have a responsibility to learn and follow the procedures we have established to assure basic awareness of hazards and safe use of materials in our workplace.
To ensure that all avenues are addressed, the following written hazard communication program has been established for all departments at Wittenberg University. These plans are to be reviewed by the Safety Committee at least every 12 months and updated as necessary to reflect significant changes in the status of our program.
A list of the Safety Committee members is contained in Appendix A. The Safety Committee is responsible for seeing that all aspects of the program are carried out. A copy of this Program and the applicable OSHA standards are available in the office of Human Resources for review.
II HAZARD DETERMINATION PROCEDURES
In accordance with the OSHA standard, we will rely upon the chemical manufacturer to identify and evaluate the various hazards of the chemicals they supply to us. The Safety Committee will rely upon information provided on the Material Safety Data Sheet (MSDS). The MSDS is to identify all of the chemical characteristics as required by the OSHA standard.
The Safety Committee will insure that MSDS's are readily accessible and that supervisors know their location.
A. Respective Department Heads should see that each MSDS sheet is reviewed when received to see that it contains the following information:
* Identities used on labels
* Chemical and common (generic) names
* Physical and chemical characteristics
* Physical hazards
* Health hazards (signs & symptoms of exposure, medical conditions aggravated by exposure)
* Primary routes of entry
* Air exposure limits
* Emergency and first aid procedures
* Date of preparation of MSDS
* Name, address and phone number of MSDS preparer or distributor
* Any generally applicable precautions for safe handling and use that are known to the chemical manufacturer or employer preparing the MSDS, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks.
* Any generally applicable control measures which are know to the chemical manufacturer, or employer preparing the MSDS, such as appropriate engineering controls, work practices, or personal protective equiopment.
* The OHSA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer or employer preparing the MSDS.
* Whether the hazardous chemical is listed in the National Toxicology Program Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency on Cancer Monographs or by OSHA.
B. The Safety Committee will write to the supplier for any missing information. If the supplier does not respond within 30 days the purchaser will be notified to find a new supplier or the Safety Committee will file a complaint with the local OSHA Area Office.
C. The Safety Committee will coordinate necessary monitoring for any chemical in the workplace which is questionable or required by law. Monitoring will be conducted in one of the following manners: (1) in-house using Wittenberg University equipment and personnel or (2) by an independent consulting firm.
III LIST OF HAZARDOUS CHEMICALS
The following departments will keep a copy of the Hazard Communication Program, a list of all hazardous chemicals known to be present in the work place, and one copy of the MSDS for each of the chemicals used in the department: Physical Plant, Art Department, Biology Department, Chemistry Department, Geology Department, Physics Department, Housekeeping and Food Service. A complete list of MSDS's for all chemicals used within the University will be kept in Human Resources. Further information such as the physical & chemical hazards of the chemicals,
detection methods and protective measures for each chemical can be obtained by reviewing the MSDS. Employees are entitled to a copy of the MSDS if they so request. The list of all hazardous chemicals shall be subjected to cross-rreference to the MSDS for each listed chemical.
IV PROCEDURES FOR LABELING AND OTHER METHODS OF COMMUNICATION
A. Labels and Other Forms of Warning.
As of December 1, 1990, all containers in the workplace are to be labeled. The purpose of labeling each container is to properly identify the contents of the container so that the employee is warned as to what type of hazard (if any) the contents of the container present.
a. Since chemical manufacturers are required to label their containers, Wittenberg will use these labels as our primary means of labeling. Such chemical manufacturers are required to label their containers to meet OSHA standards.
b. Chemicals removed from the original bottles will be identified by a label which shall contain the name of the chemical, the date on which the label was prepared, and the initials of the person preparing the label. Solutions will be labeled with the identity of the solvent, the concentration of each of the solutes, the date on which the solution was prepared, and the initials of the person who prepared the solution. For those chemicals and solutions for which a significant fire, explosion, health, or carcinogenicity hazard exists, the label shall identify the hazard and the severity of the hazard. For each type of hazard with a solution, the hazard severity information indicated on the label shall be, for that hazard, the most severe hazard indicated on the MSDS for any of the constituents of the solution. The MSDS will be used in each case where a label is lost or illegible.
c. The Safety Committee or their designee within the respective departments will ensure that all containers of chemicals in the departments are correctly labeled. Any container which does not have this information may be returned to the supplier, at the supplier's expense.
d. Each Department Head has the overall responsibility of ensuring that all containers of chemicals used in his or her department are correctly labeled.
e. Labels are not to be removed from any container, or defaced in any manner.
f. Empty containers are not to be re-used to store other materials unless the container has been cleaned, the old label removed, and a new label affixed in its place prior to its re-use.
B. Informing Contractors about Hazards.
To assist in evaluating potential exposures and to ensure that a contractor's employees are provided
with information regarding potential hazards, prior to any contractor entering the work site the Director of Physical Plant, in consultation with the appropriate department head, will notify the contractor of any potential hazards relating to chemicals. The Safety Committee is a resource for the Director of Physical Plant to use to assist in identifying any potential hazards in the work site.
C. Chemical Spills and Accidents.
a. Should a hazardous material spill or accident occur, immediate attention is required by the person causing the spill to minimize the spread of the spilled material. It is then the responsibility of the person causing the spill to report the spill to the department supervisor. Except for the most minor spills, the department supervisor will then notify the Chemical Hygiene Officer (please see the "Wittenberg University Chemical Hygiene Plan") who will arrange for the cleanup of the spilled material. Outside help will be called in to clean up the spill when the extent of the spill or the material involved in the spill are such that inside help is not capable of handling the situation.
b. In the event of a hazardous material emergency inside a building, the fire alarm system is available to signal people to evacuate the building. This alarm system is tested annually by the Physical Plant Department. As with all fire alarms, the Fire Department and campus Security will be notified and appropriate corrective action taken.
c. All laboratory operations are to be carried out in accordance with accepted laboratory practices to ensure the prevention of accidental spills. For chemical spills and accidents in the laboratory, please refer to the "Wittenberg University Chemical Hygiene Plan".
d. After the emergency, a Security Department "Incident Report" will be completed by the Security Department (sample "Incident Report" is shown in Appendix E). All accidents or near accidents will be carefully analyzed by the Safety Committee and the recommendations arising from the analysis will be distributed to all who might benefit from the information. Also, as a follow up to any safety related Incident Reports, a written recommendation will be sent to the Director of Security and a copy filed with the Incident Report for a permanent record.
D. Chemical Handling, Storage and Disposal.
Materials will be stored, insofar as is practicable, in their original containers. Bottles of chemicals should be placed on the storage shelves in such a way as to minimize the danger of bottles falling off the shelf. Chemicals will be stored on the shelves by chemical property. Highly toxic materials will be stored separately from other chemicals in a room which is locked when not in use.
Flammable materials will be stored separately from other chemicals in special cabinets. All chemicals will be examined at least annually to determine the need for replacement and the integrity of the container and label. Amounts stored within a laboratory should be as small as practical and the chemicals returned to the storerooms as soon as the need for the chemical exists in the laboratory.
The proper disposal of hazardous material wastes is necessary to protect people, plants, and animals from harm that could be caused by the improper and careless disposal of these wastes. Disposal of wastes shall conform to the regulations outlined in the document "Wittenberg University Waste Disposal Regulations". A copy of these regulations can be found attached to the Chemical Hygiene Plan.
V PERSONAL PROTECTIVE EQUIPMENT
Most personal protective equipment is provided by Wittenberg University to employees when and where necessary. It is the responsibility of each employee to be certain that the appropriate equipment is worn as necessary.
The assessment of any hazards associated with exposure to hazardous chemicals which require the wearing of personal protective equipment is the responsibility of Wittenberg University. It is the responsibility of each employee to wear personal protective equipment as provided by the University or as required by the University.
Eye Protection: Appropriate eye protection will be worn by all persons, including visitors, where chemicals are stored or handled. For specific regulations see a copy of the "Wittenberg University Eye Protection Policy" attached to the Chemical Hygiene Plan.
Hand Protection: Appropriate gloves will be worn when the potential for contact with toxic materials exists. Inspect the gloves before each use.
Lung Protection: Use appropriate respirator equipment when air containment concentrations are not sufficiently restricted by engineering controls. Inspect the respirator before use. For specific regulations see a copy of the "Wittenberg University Respiratory Protection Policy" attached to the Chemical Hygiene Plan.
Miscellaneous: Use any other protective and emergency apparel and equipment appropriate.
The University will provide employees with information and training on hazardous chemicals in their work area at the time of employment and whenever a new hazard is introduced into their work area. Annual refresher training will also be given. It is the responsibility of the Human Resources Department and the immediate supervisor of the newly hired employee to be certain he/she receives the initial training annual refresher training is the responsibility of the department supervisor. The Safety Committee, through Human Resources, will provide each new employee with a copy of the MSDS pamphlet (Appendix D). The department supervisor will cover the specific data sheets which apply to the new employee and will show where copies of the MSDS's are located.
The Safety Committee will be provided the names of those employees who have successfully completed training. These records will be maintained by the Human Resources Department.
Simply giving an employee a data sheet to read does not satisfy the intent of our program. Our training is to be an opportunity to explain to employees not only the hazards of the chemicals in their work area, but also how to use the information provided in our Hazard Communication Program. This training will be accomplished by the department supervisor in an on-the-job basis. Training will include an opportunity for employees to ask questions to ensure that they understand the information presented to them. Specifically, the training will include the following:
a. The requirements of the applicable OSHA standard 29 CFR 1910.1200.
b. The operations in their work area where hazardous materials are present.
c. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (visual appearance, odor, monitoring, etc.).
d. The physical and health hazards of the chemicals in the work area.
e. The measures employees can take to protect themselves from these hazards, including specific procedures Wittenberg University has implenmented to protect the employees from exposure such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
f. The details of this Hazard Communication Program; the location and availability of the written program; an explanation of the labeling system and the MSDS; and how the employees can obtain and use the information.
e. The engineering controls or administrative controls which the university has provided to protect against any hazards to employees (if any).
f. The personal protective equipment required for the employees specific job (if any).
APPENDIX A SAFETY COMMITTEE MEMBERS
APPENDIX B OSHA STANDARD 29 CFR 1910 SUBPART Z
APPENDIX C MAPS OF WITTENBERG UNIVERSITY PHYSICAL PLANT AND LABORATORY FACILITIES
APPENDIX D MSDS PAMPHLET
APPENDIX E SAMPLE INCIDENT REPORT