HAZARD COMMUNICATION PROGRAM

  •  
Introduction
  •  
Identification and Labels
  •  
Safety Data Sheets
  •  
Employee Training and Information
  •  
Hazardous Non-Routine Tasks
  •  
Contractor Information
  •  
Chemicals in Unlabeled Pipes
  •  
List of Hazardous Chemicals
  •  
Optional Labels
  •  
Optional Chemical Hazard Safety Warnings
Definitions of Physical and Health Hazards
OSHA Comparison of NFPA 704 and HazCom 2012 Labels
OSHA Quick Card - Hazard Communication Labels
OSHA Quick Card - Hazard Communication Safety Data Sheets
OSHA Quick Card - Hazard Communication Pictograms

INTRODUCTION

It is the desire and intent of the University of the Sciences that employees be informed about the hazardous substances they may encounter in the workplace, and learn the appropriate protective measures for working safely with these substances. The Hazard Communication Program, which is described in this document, is intended to comply with the requirements of the OSHA Hazard Communication Standard 29 CFR 1910.1200 and to provide information for everyone who may be exposed to hazards on our campus.

Hereafter, the University of the Sciences will be referred to in the text as the University, and the OSHA Hazard Communication Standard 29 CFR 1910.1200 will be referred to in the text as the Standard.

Upon request, this Hazard Communication document will be made available to employees or their designated representatives.  The written program for the University is located in:

* The EHRS Department: McNeil Science & Technology Center, room #223
* EHRS Website  

Employees may request to see the written program by contacting their Departmental Supervisor, the EHRS Department, or it may be viewed on-line at: http://www.usciences.edu/safety/hcmanual/index.htm

IDENTIFICATION AND LABELS

Hazard Classification Requirements

The University does not manufacture products (SIC Code outside 20-39) and are thus exempt from the Hazard Identification requirements under section (b) (4) or section (b) (5) of The Standard.

The University will rely upon the hazard evaluations, identifications and classifications performed by the chemical manufacturer/importer of all raw materials or products purchased by the University. Labels and Safety Data Sheets obtained from suppliers on all chemicals purchased shall be used in determining the health and physical hazards of materials present at the University.

The persons responsible for ensuring that incoming containers are labeled with the required information are:

  • Director of Environmental Health and Radiation Safety
  • Directors/Managers of Facilities Services
  • Manager - Central Scientific Stockroom
  • Hazardous Materials Specialist
  • Manufacturing Laboratory Manager
  • Vivarium Director/Supervisor
  • Laboratory Supervisors
  • Department Heads, Managers, Supervisors
  • New Chemical Labeling System

    • Labels on containers from chemical suppliers must have a manufacturer supplied label.
    • Manufacturers, importers or distributors must ensure all incoming (shipped) chemical containers are labeled, tagged or marked with a proper label. The label shall include the required information; including product identifier, signal word, pictogram(s), hazard statement(s), precautionary statement(s), and manufacturer/distributor name, address and phone number.

      A container should not be accepted unless it is properly labeled with the required information. (Chemical manufacturers, importers, distributors may ship products labeled under the old system until December 1, 2015.)

      This label will not be removed or defaced but shall remain on the container throughout the use of the chemical.

      However, containers must be re-labeled with the required information if labels have fallen off or are defaced (faded, washed-off, torn, etc.)

      All labels on containers must be legible, in english, and prominently displayed. (Another language may be added to the label.)

    • Workplace (in-house) Labels and Labeling of Transfer Containers
    • When labeling any workplace (in-house) container or when transferring chemicals to another container (e.g., for dilution of cleaning chemicals), these containers must be labeled, tagged or marked with:

      1. The same information that is on a manufacturer supplied label, or;

      2. The full chemical name (product identifier) and;

      words, pictures, symbols or a combination thereof, providing general information regarding the physical and health hazards of the chemicals. (physical and health hazards) This may include, but is not limited to:

      a. The use of the pictograms pictured below (when using pictograms on workplace labels, the pictograms may have a black border, rather than a red border), or

      b. Label alternatives that meet the requirements of the Standard. For example:

      i) NFPA 704 Label (Click here to see an example of this label)

      ii) HMIS Label (Click here to see an example of this label)

    It is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. However, transfer containers used between workshifts and/or used by different workers must be labeled with the required information.

    Contact the EHRS Department for assistance with labeling. Hazard labels and pictograms may be requested or ordered through the Central Stockroom.

    Supervisors must check manufacturer supplied and workplace (in-house) containers periodically to ensure they are clearly labeled and that the labels are complete.

    Containers must be re-labeled if labels have been removed or are defaced (faded, washed-off, torn, etc.)

    University of the Sciences must update alternative workplace labeling and the Hazard Communication Program by June 1, 2016. Employees must be trained on the new label elements by December 1, 2013.

    Globally Harmonized System (GHS)
    OSHA Hazard Communication Standard Pictograms and Hazards
    [These pictograms/hazards are required on manufacturer supplied and shipped containers.]

    Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s).

    HCS Pictograms and Hazards

    Health Hazard

    • Carcinogen
    • Mutagenicity
    • Reproductive Toxicity
    • Respiratory Sensitizer
    • Target Organ Toxicity
    • Aspiration Toxicity

    Flame

    • Flammables
    • Pyrophorics
    • Self-Heating
    • Emits Flammable Gas
    • Self-Reactives
    • Organic Peroxides

    Exclamation Mark

    • Irritant (skin and eye)
    • Skin Sensitizer
    • Acute Toxicity
    • Narcotic Effects
    • Respiratory Tract Irritant
    • Hazardous to Ozone Layer (Non-Mandatory)

    Gas Cylinder

    • Gases Under Pressure

    Corrosion

    • Skin Corrosion/Burns
    • Eye Damage
    • Corrosive to Metals

    Exploding Bomb

    • Explosives
    • Self-Reactives
    • Organic Peroxides

    Flame Over Circle

    • Oxidizers

    Environment
    (Non-Mandatory)

    • Aquatic Toxicity

    Skull and Crossbones

    • Acute Toxicity (fatal or toxic)

    Please Note: The physical and health hazard class categories under the UN's Globally Harmonized System (GHS) are rated 1 - 4 (1 being the most hazardous, 4 being the least hazardous). This is the opposite of the NFPA 704 and HMIS systems used solely in the United States. The GHS hazard category numbers are not required to be on labels but are required to be on SDSs, in Section 2.

    Review OSHA's Quick Card Comparison of NFPA 704 and HazCom 2012 Labels at https://www.osha.gov/Publications/OSHA3678.pdf.

    Optional Labels (additional) You may include other symbols, labels and hazard code numbers in addition to the elements required on a 1) manufacturer supplied label or the 2) workplace (in-house) label:

    1) Symbols for hazards that may also be attached may be viewed here.

    2) In-house hazard code numbers that indicate specific hazards of a material may also be included and viewed here.

    Labeling of Piping Systems

    If applicable, pipes containing hazardous substances shall be labeled. In addition, tags specifying the identity of the hazardous substance will be affixed to exit points of the pipeline system.

    Safety Data Sheets for those materials will be maintained in the Facilities Services Department and will be readily accessible to employees.

    The person responsible for labeling the pipes and exit valves is the Director of Facilities Services.

    SAFETY DATA SHEETS (SDS) [Formerly known as Material Safety Data Sheets (MSDS)]

    The Environmental Health and Radiation Safety Department is responsible for establishing and monitoring the University's SDS program. Each department must obtain and maintain an SDS for each chemical/hazardous material in their work area(s). The Departmental Supervisor/Manager is responsible for ensuring that SDS's are maintained in the assigned areas in his/her department. As you receive SDS's, place these immediately into your SDS binder or file. Forward new or updated SDS's to EHRS in order to maintain a central location of SDS's.

    SDS's shall be readily accessible to all employees in their work area(s) during each work shift. If an SDS is not available, immediately contact the manufacturer/distributor or go to their website and under product detail, print one out.

    Chemical manufacturers or distributors shall ensure that employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated. The chemical manufacturer or distributor shall either provide safety data sheets with the shipped containers or send them to the employer prior to or at the time of the shipment.

    If the safety data sheet is not provided with a shipment that has been labeled as a hazardous chemical, the responsible department shall obtain one from the manufacturer, importer or distributor as soon as possible. The manufacturers and/or distributors shall be contacted a second time if the SDS is not received or is found to be inadequate. The responsibility for obtaining SDS's is assigned to the individual or department purchasing the material for use. However, call the EHRS Department if assistance is needed.

    In addition, copies of SDS’s for all hazardous chemicals in use are available:

    • In the Central Stockroom - Griffith Building room #B10 (Individual departments should forward new or updated copies to EHRS).
    • By linking to the on-line SDS Program, ChemWatch Chem Gold on the EHRS website at http://www.usciences.edu/safety/msds.shtml.
      Log-in information is not needed when on-campus.

    Electronic access and other alternatives to paper copies are permitted as long as no barriers to immediate employee access are created. If alternatives to paper copies are used, the format used and how workers can access the SDS's should be described.

    The chemical manufacturer or importer preparing the Safety Data Sheet must ensure that it includes the following section numbers and headings and associated information under each heading, in the order listed:

    Section 1, Identification; includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
       
    Section 2, Hazard(s) identification; includes all hazards regarding the chemical; required label elements.
       
    Section 3, Composition/Information on ingredients; includes information on chemical ingredients; trade secret claims.
       
    Section 4, First aid measures; includes important symptoms/effects, acute, delayed; required treatment.
       
    Section 5, Fire-fighting measures; lists suitable extinguishing techniques, equipment, chemical hazards from fire.
       
    Section 6, Accidental release measures; lists emergency procedures, protective equipment; proper methods of containment and cleanup.
       
    Section 7, Handling and storage; lists precautions for safe handling and storage; including incompatibilities.
       
    Section 8, Exposure controls/personal protection; lists OSHA's Permissible Exposure Limits (PEL's); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
       
    Section 9, Physical and chemical properties; lists the chemical's characteristics.
       
    Section 10, Stability and reactivity; lists chemical stability and possibility of hazardous reactions.
       
    Section 11, Toxicological information; includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
       
    Section 12, Ecological information; (Not enforced by OSHA)
       
    Section 13, Disposal considerations; (Not enforced by OSHA)
       
    Section 14, Transport information; (Not enforced by OSHA)
       
    Section 15, Regulatory information; (Not enforced by OSHA)
       
    Section 16, Other information, includes the date of preparation or last revision.

    Chemical manufacturers, importers, distributors and employers must comply with these new SDS requirements by June 1, 2015. Employees must be trained on the new SDS format by December 1, 2013.

    EMPLOYEE TRAINING AND INFORMATION

    Employees, paid student workers and volunteers must receive training by their Supervisors or Managers/Directors at each work area :    

    * at the time of their initial assignment, and
    * whenever a new chemical hazard is introduced into their work area.

    On-the-job training dealing with specific hazards or classes of chemicals/hazardous substances, signs and symptoms associated with exposure, safe use of equipment and tools, proper safety and personal protective equipment and clothing, and safety practices and emergency procedures relating to an employee's work area will be provided and documented by Departmental Supervisors.

    Training and information should include:

    * Any operations in their work area where hazardous chemicals/substances are present; and
       
    * The location and availability of the written Hazard Communication Program and Safety Data Sheets for the hazardous chemicals/materials used or stored.
       
    *

    Methods and observations that may be used to detect the presence or release of a hazardous chemical/material in the work area, such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc. Contact EHRS for assistance, when needed.

       
    *

    An explanation of the labels received on shipped containers and the workplace (in-house) labeling system.

       
    * The Physical and Health Hazards of chemicals, and simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as other hazards and chemicals not otherwise classified by OSHA, in the work area.
       
    *

    The measures employees can take to protect themselves from the hazards, for example:

       
     
    • specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices (e.g., dilution, closing containers, standard operating procedures and safety precautions)
    • engineering controls (e.g., ventilation, machine guards, interlocks)
    • emergency procedures (e.g., spill, fire, accident, exposure)
    • personal protective equipment (PPE) and clothing (e.g., gloves, hearing protection, respirator, eye protection, safety harness, face shields) and training on how to use it properly. Training on PPE should include when and what PPE is necessary, how to wear and remove, any limitations of the PPE, and proper care, disposal and its useful life. Complete the PPE Hazard Assessment Form to document the OSHA-required assessment and training.

    If the work requires the use of a respirator, you must receive special training from EHRS or from your supervisor who has been properly trained by EHRS.

    General information on the Hazard Communication Standard and Program requirements is provided during the EHRS session of New Employee Orientation classroom training. Training may also be provided through another classroom session, training document or web-based training, with a quiz. EHRS training and information will include:

    *

    The applicable requirements of the Hazard Communication Standard.

       
    * The hazard communication training and information program developed by the employer, including:
       
     
    • an explanation of the labels received on shipped containers, and
    • an explanation of in-house labeling system requirements, and
    • the safety data sheet, including the order of required information, and
    • how employees can obtain and use the appropriate hazard information, including how to protect oneself.

    All employees potentially exposed to hazardous substances are to participate in the training and information program established by the University.

    You may contact EHRS at X8925 for assistance with the technical aspects of the training.

    Employees must be trained on the new label elements and SDS format by December 1, 2013.

    HAZARDOUS NON-ROUTINE TASKS

    Special hazards which workers may encounter when performing non-routine tasks in the course of their work must be discussed with the worker before the job begins. It is the responsibility of the supervisor to ensure that workers receive specialized training, as needed. EHRS may be contacted to provide assistance in evaluating the hazards.

    CONTRACTOR INFORMATION

    Safety shall be a prime concern of the Contractor at all times. The Contractor shall be solely responsible for and have control over the means, methods, techniques, sequences and procedures for coordinating and constructing the work, including site safety, safety precautions and programs, and compliance with OSHA and other applicable local, state and federal regulations.

    The Contractor will be responsible for having all chemical/hazardous substance containers properly labeled.

    While working with hazardous substances, equipment and energy sources, the Contractor shall ensure the use of safe procedures, provide the proper safety and personal protective equipment (PPE) and clothing and proper training and information to their employees and subcontractors on the potential hazards.

    The Contractor should prepare and submit for the University's review, a written Safety Program detailing safety precautions, accident prevention measures and emergency response plans. The Contractor will initiate and maintain Lock Out/Tag Out and Hot Work programs as appropriate to the nature of work being performed. Written copies of these programs should be submitted for review prior to beginning operations at the site.

    The Contractor is expected to provide SDS's or provide a means of access to SDS's for the hazardous materials that may potentially be introduced into the work area in the course of their work at the University. The Contractor must also provide information regarding where chemicals/hazardous materials will be used and stored.

    The Contractor shall inform the Director of Facilities Services, or his/her designee, or the hiring Department Supervisor about these and other precautionary measures, if needed, to protect University employees during the performance of the contractual work.

    University Departments must inform outside Contractors of the hazardous substances which may be encountered during the contractor's work at the University. This includes providing the Contractor with a means of access to SDS's (location where SDS's will be maintained) and the written Hazard Communication Program, and communicating any precautionary measures to be taken.

    CHEMICALS IN UNLABELED PIPES

    If work activities are performed by employees in areas where chemicals are transferred through unlabeled pipes:

    • As part of the supervisor training program, employees will be informed about the hazardous chemicals in unlabeled pipes.

    • Prior to starting work in these areas, the employee shall contact the Director of Facilities Services, or his or her designee, for information regarding:

    A)  Chemicals in the Pipes
    B)  Potential Hazards
    C)  Safety and Handling Precautions

    LIST OF HAZARDOUS CHEMICALS

    It is policy to develop a list of hazardous chemicals used in each work area.   This list is developed as a result of the facility inventory, and is located in the Central Stockroom Office, Griffith Building - Room #B01.  Further, information on each chemical may be obtained by consulting the Safety Data Sheets (SDS) located in the areas where chemicals are used or stored or in the Central Stockroom, Room #B10. The chemical inventory is maintained by the Environmental Health and Radiation Safety Department and/or the responsible Department.

    OSHA Resource

    Link to http://www.osha.gov/dsg/hazcom for helpful information on OSHA's Hazard Communication Standard.

    OPTIONAL ADDITIONAL LABELS

    Labels

    NFPA

    OPTIONAL ADDITIONAL CHEMICAL HAZARD SAFETY WARNINGS

    1. Poison
    2. Suspected carcinogen
    3. May cause adverse reproductive effects
    4. May be fatal or cause blindness if swallowed: cannot be made non-poisonous
    5. May be fatal if inhaled
    6. May be fatal if absorbed through the skin
    7. May be fatal if swallowed
    8. Causes severe skin and eye burns
    9. Causes severe eye burns
    10. May cause delayed lung injury
    11. May cause lung injury
    12. May cause nervous system injury
    13. May cause blood disorders
    14. May cause liver injury
    15. May cause kidney injury
    16. May cause cyanosis
    17. May cause chloracne
    18. May cause cardiovascular system injury
    19. May cause thyroid injury
    20. May cause allergic respiratory reaction
    21. Gas extremely irritating to eyes and respiratory tract
    22. Vapor extremely irritating to eyes and respiratory tract
    23. Dust extremely irritating to eyes and respiratory tract
    24. Extremely flammable
    25. Causes skin and eye burns
    26. Causes eye burns
    27. Causes skin burns
    28. Lachrymator, causes eye irritation
    29. Contact with acids liberates poisonous gas
    30. Highly reactive
    31. Water reactive
    32. Heat sensitive, can violently decompose if heated
    33. Heat and shock sensitive, impact or heating can cause violent decomposition
    34. Unstable at room temperature, may violently decompose
    35. Strong oxidizer, contact with other material can cause fire
    36. Strong reducing agent, contact with other material can cause fire
    37. Ignites if exposed to air
    38. Can explode on impact if water content is 10% or below
    39. Forms explosive peroxides
    40. Contact with water may cause flash fire
    41. Contact with water forms flammable vapor
    42. Contact with water forms flammable liquid
    43. Do not allow water to get into container because of violent reaction
    44. Flammable
    45. Flammable solid
    46. Flammable mixture
    47. Harmful if inhaled
    48. Harmful if absorbed through skin
    49. Harmful if swallowed
    50. Radioactive
    51. Gas irritating to eyes and respiratory tract
    52. Vapor irritating to eyes and respiratory tract
    53. Dust irritating to eyes and respiratory tract
    54. Oxidizing material
    55. Reducing agent
    56. Spontaneously combustible
    57. May form explosive peroxides
    58. Unstable at room temperature, may decompose
    59. Heat and shock sensitive, impact or heating can cause violent decomposition
    60. Heat sensitive, can decompose if heated
    61. Impact or elevated temperatures can cause violent decomposition
    62. Can violently decompose at elevated temperatures
    63. Repeated exposure to vapor or dust may cause eye injury
    64. Causes skin and eye irritation
    65. Causes skin irritation
    66. Causes eye irritation
    67. May cause allergic skin reaction
    68. Stench
    69. May violently polymerize
    70. Do not allow water to get into container because of reaction
    71. Reacts with water
    72. Contact with amines may form shock sensitive mixtures
    73. Contact with metals may form shock sensitive materials
    74. Combustible
    75. Combustible mixture
    76. Potential peroxide former
    77. Can ignite when heated in presence of moisture
    78. May polymerize
    79. Contents under pressure
    80. Powdered material may form explosive dust-air mixtures
    81. Can decompose at elevated temperatures
    82. Impact or elevated temperatures can cause decomposition
    83. Decomposes in water
    84. Contents may develop pressure if exposed to water
    85. Contents may develop pressure upon prolonged storage
    86. Contents may develop pressure on prolonged exposure to heat
    87. Dried product residue can act as an oxidizer, drying on clothing or other materials may
          cause fire 
    88. Do not allow water to get into container because of possible reaction
    89. Since emptied containers retain product residue, follow safe warning even after container is emptied
    90. Low hazard or usual industrial handling
    91. The toxicological properties of this material have not been investigated
    92. The toxicological properties of this material have not been fully investigated
    93. The physical-chemical properties of this material have not been investigated
    94. The physical-chemical properties of this material have not been fully investigated
    95. The physical-chemical and toxicological properties of this material have not been investigated
    96. The physical-chemical and toxicological properties of this material have not been fully investigated              
    100. Flush to sewer with copious amounts of water
    101. Neutralize with sodium bisulfate and flush to sewer with copious amounts of water
    102. Neutralize with sodium bicarbonate and flush to sewer with copious amounts of water
    200. Dispose of in an approved chemical incinerator, compounds containing halogens or sulfur
            and suspected carcinogens should be disposed of in an incincerator equipped with an
            afterburner and scrubber
    400. Dispose of in an approved chemical landfill
    500. Uncontaminated material may be disposed of in a sanitary landfill. Check local codes.
    600. Irritant (unspecified)
    601. Toxic (unspecified)
    602. Hygroscopic (unspecified)
    603. Lachrymator
    604. Cancer suspect agent
    605. Mutagen
    606. Corrosive
    607. Moisture-sensitive
    608. Light-sensitive
    609. Teratogen
    610. Explodes when heated
    611. Harmful (unspecified)
    612. Readily absorbed through skin


    University of the Sciences in Philadelphia • 600 South Forty-third Street • Philadelphia, PA 19104-4495 • phone: 215-596-8800 • email: safety@usp.edu