Q & A ON OSHA's HAZARD COMMUNICATION STANDARD

WHAT IS THE PURPOSE OF OSHA'S HAZARD COMMUNICATION/RIGHT-TO-
KNOW STANDARD?

• The purpose of these laws is to ensure that each of you is able to identify chemical and other hazards and know what to do to protect yourself from them.

HOW DOES OSHA DEFINE A HAZARDOUS CHEMICAL?

• OSHA defines a hazardous chemical as a substance for which there is statistically significant evidence, based on at least one scientific study, showing that acute or chronic harm may result from exposure to that chemical. Basically, this broad definition applies to most chemicals used in the workplace.

WHERE IS OUR WRITTEN HAZARD COMMUNICATION PROGRAM LOCATED?

WHAT DO I DO IF THERE IS A CHEMICAL SPILL IN MY DEPARTMENT?

Anticipate spills by having the appropriate safety equipment on hand.  Understand the properties of the spill equipment. If a spill occurs, immediately alert personnel in the area and do what is necessary to protect life. Warn others to stay out of the area and to avoid walking nearby. Secure the area.

• If it is a small spilll, your Supervisor is responsible for cleaning up the spill or making sure that it is cleaned up properly. Confine or dike the spill to keep the area involved smaller, decrease the evaporation rate, and to protect floor drains. (Whenever unsure how to handle a spill, contact the Environmental Health and Radiation Safety (EHRS) Department at X8925, X8843or X3141.)

Use an absorbent material that will neutralize the spill or suppress the flammable vapors, whenever possible.

If the spilled chemical is flammable, extinguish flames and all other sources of ignition (such as brush type motors) if safe to do so.

Protect floor drains or other means for environmental release, if possible.  Absorbents and spill socks may be placed around drains, as needed.

Maintain fume hood ventilation (if applicable).

Always wear the proper personal protective equipment when cleaning up spills! For example, rubber gloves, goggles, booties, a lab coat, or a bunny suit if there may be splashing.

Place all spill clean-up materials and residue into yellow hazardous waste bags or an appropriate container.  You may use a dustpan and brush to scoop the spill residue into the container. Decontaminate the area with soap and water after clean-up.

Seal bags or containers securely. Use strong tape on bags, and label the container/bag with the chemical name(s) and as "spill debris."   Bring the bag to the central stockroom for disposal. Make sure someone is there to accept it.

The EHRS Department must be informed of the spill. (X8925, X8843 or X3141) (Complete laboratory incident report, if applicable.)

• If the spill is large, flammable, toxic or a threat to personnel, students or the public, notify the EHRS Department (X8925, X8843 or X3141) or Public Safety (X7000) immediately. Ventilate or maintain fume hood ventilation, if possible.

Be prepared to report:

• The name of the chemical spilled. (spell the chemical name)
• The amount of the chemical spilled.
• Location of the spill.
• Whether it is still leaking and/or is contained.
• Any noticeable properties. (i.e., fuming)
• If anyone has been injured or exposed.

If the spilled chemical is flammable, extinguish all nearby flames and sources of ignition, (such as brush-type motors), if safe to do so.

Confine or dike the spill of your way out, if possible.

Protect floor drains or other means for environmental release, if possible. Absorbents and spill socks may be placed around drains, as needed..

Evacuate the area, warn others to leave and stay out of the area. Avoid touching the spill, walking in it, or breathing it, whether it has an odor or not. (Close the door, post a waring sign, if it is safe to do so.)

Remain on the scene, but at a safe distance, to receive and direct EHRS/Public Safety personnel when they arrive. You are needed to relay, and possibly receive, important hazard information.

See the Chemical Spill section of the Safety Manual for more information.

WHAT DO I DO IF I EXHIBIT ANY SIGNS OR FEEL ANY SYMPTOMS WHILE WORKING WITH A CHEMICAL?

Overexposure to hazardous materials can:

-    make you feel dizzy
-    make you sick to your stomach
-    make your eyes, nose and throat irritated
-    give you skin rashes
-    make you feel nervous or sluggish   

When an injury or exposure occurs:

	Any employment-related injury or illness to faculty or staff is to be reported immediately to the employee's supervisor, including those related to hazardous substance exposures.
	If it is an emergency, call 911 and Public Safety (X7000).  If Public Safety transports the employee to the hospital, someone other than the Public Safety Officer (co-worker, supervisor, etc.) must accompany the injured employee into the medical facility.
*	Do not move a seriously injured person unless they are in further danger.
*	In the event of a hazardous substance exposure, do what is necessary to prevent further injury or illness. (i.e., flush skin or eyes with copious amounts of water for approximately 15 minutes, leave the area and get fresh air for an inhalation exposure) Also, someone should forward the Material Safety Data Sheet (MSDS) to the medical facility.
*	Supervisors must complete Human Resource's Supervisor's Accident Investigation Report as soon as possible after the accident. If an employee refuses medical treatment, their signature must be documented on Human Resource's Supervisor's Accident Investigation Report.
*	Laboratory incidents (i.e., injury, hazardous substance exposure, fire) involving employees, students or visitors, must also be documented on a Laboratory Incident Report. Principal Investigators or Laboratory Supervisors must complete this form and forward it to the EHRS Department within at least 5 days of the incident.

Student and Visitor Accidents/Hazardous Substance Exposures

Students must notify their instructor or resident director of all injuries or illnesses occurring at the University, including those related to hazardous substance exposures. The incident must then be immediately reported to Public Safety (X7000) so that it can be documented properly. If a student refuses medical treatment, their signature must be documented on Public Safety's Incident Reporting Form.

Visitor accidents or incidents must also be immediately reported to Public Safety.

If it is an emergency, call 911 and Public Safety at X7000. If Public Safety transports a student to the hospital, someone other than the Public Safety Officer (i.e., fellow student, instructor) should accompany the student into the medical facility.

Do not move a seriously injured person unless they are in further danger.

In the event of a hazardous substance exposure, do what is necessary to prevent further injury or illness. (i.e., flush skin or eyes with copious amounts of water for approximately 15 minutes, leave the area and get fresh air for an inhalation exposure) Also, someone should forward the Material Safety Data Sheet (MSDS) to the medical facility.

Any student who is working for the University, and their injury or illness occurs during the performance of their duties, will be covered under the University's worker's compensation carrier. Therefore, Human Resource's Supervisor's Accident Investigation Report should be completed, and procedures followed, as required under the "Employee Accidents" section.

See Accident Reporting in the Safety Manual for more information.

WHAT DO I DO IF I GET SPLASHED OR COME IN CONTACT WITH A CHEMICAL OR HAZARDOUS SUBSTANCE?

• Check the MSDS for what to do in an emergency before you work with the chemical. However, as a general rule of thumb, flush contaminated area with copious amounts of water for at least 15 minutes. For eye splashes, hold eyes open and use eyewash to flush with water for at least 15 minutes.
  
  Seek medical attention immediately. Call 911 and contact Public Safety (215-596-7000).
  
  
• Flush your eyewash at least once a week for a minimum of 3 minutes to prevent the build-up of amoeba and bacteria in the stagnent water. This will prevent eye infections, which can lead to blindness, during its use in an emergency.

See the Chemical Contamination section of the Safety Manual  for more information.

See the Skin and Body Contamination section of the Radiation Safety Manual for more information.

WHAT DO I DO IF MY JOB REQUIRES THAT I REGULARLY ENTER A LABORATORY?

Review the document entitled "Safety Reminders for Non-Laboratory Personnel When Entering Laboratories" before initally performing any cleaning or maintenance activities in a laboratory. This document provides detailed information on what to do and what to be aware of.   The review of this document is required annually.

No one may perform work in a laboratory until they have attended the EHRS New Employee Safety Orientation or until their Supervisor has reviewed the document along with the Hazard Communication Safety Guide with them.

Never move or handle containers, hazardous waste or laboratory equipment in a laboratory. Do not clean or conduct maintenance without initially checking with laboratory personnel.

Wear eye protection whenever entering laboratories.

Contact the Laboratory Supervisor or EHRS at X8925 if you have any questions about entering laboratories.

Whenever entering a laboratory:

	*	Wear eye protection when entering the laboratory.  This is to protect yourself from work that you may be doing and to protect yourself from what laboratory personnel and students are doing.
		A case history:
		Here at USP, an undergraduate student prepared a glassware cleaning solution and was allowing it to cool in the hood.   Three hours later, all of a sudden, it exploded.  The explosion shot acid and glass all over the floor, the walls, and the hood.  Unfortunately, the hood sash (door) was not lowered while she was allowing the solution to cool.  Even if it looks like no work is going on in a laboratory, you still want to protect yourself.
	*	Wear gloves and change them frequently. No glove is impermeable indefinitely. It is just a matter of time until a substance or chemical works its way through a glove. So take them off immediately if you think they are contaminated. Then wash your hands. Never touch your eyes, nose, mouth, phones, equipment or radios with potentially contaminated gloves.
	*	Before cleaning or doing maintenance work, check with laboratory personnel first.   If there a specific hazard that you should be aware of?
	*	Do not handle, move, or remove containers, bottles, bags, or equipment without checking with laboratory personnel.  Laboratory personnel should be contacted in advance to move these materials.
	*	If doing work near a fume hood, make sure that the hood sash is closed, all chemicals are capped or closed, and no experiments are gong on.  If performing maintenance work in a hood, make sure that laboratory personnel have the hood cleared and cleaned out and that you wear proper personal protective equipment.
	*	If there is a spill on the floor, do not clean it up without checking with laboratory personnel or the EHRS Department first.

- It may look like water - but, it could be a chemical, radioactive or biohazardous material.

A case history:

A custodial employee (at another institution) saw a puddle of what looked like water next to a refrigerator.  The employee mopped up the liquid and continued cleaning the rest of the building.  The refrigerator had a radioactive label on it, and the water was a radioactive liquid that spilled.  Well, now the radioactive material was spread throughout the entire building and the building had to be completely closed down and cleaned up.

WHAT IS AN MSDS, AND WHERE ARE THEY LOCATED?

• An MSDS is a material safety data sheet. There must be an MSDS for every chemical in your department and they must be available to all employees. An MSDS will provide useful information about the chemical.

• These are located in your department and in the central stockroom (Griffith Hall, Rm. #B-10).

• Click on MSDS Links to find an MSDS not available in your department.

PEL'S AND TLV'S ARE OFTEN FOUND ON AN MSDS.  WHAT ARE THEY?

• Pel’s are permissible exposure limits. These are the regulatory quantities that nearly all workers may be repeatedly exposed to day after day, without adverse effect. Because of wide variation in individual susceptibility, a small percentage of workers may experience discomfort from some substances at concentrations at or below the PEL.  PEL's are enforceable by law.  (OSHA) 

• TLV’s are threshold limit values. Their definition is the same as above, however, they are recommended limits by the American Conference of Governmental Industrial Hygienists (ACGIH). TLV's are reviewed with some regularity and, therefore, may be more up-to-date that PEL's.

IF I TRANSFER A CHEMICAL TO ANOTHER CONTAINER (e.g., diluting for cleaning, mixing, etc.) HOW SHOULD I LABEL THE SECOND CONTAINER?

• You must label the new container with a copy of the manufacturer’s label or at least the chemical name and a hazard warning.  Chemical and structural formulas are not acceptable!  All chemicals must be labeled properly.
  
• See labeling of secondary containers, under the Hazard Communication Program for more information.

WHAT IS THE DEFINITION OF A HAZARD WARNING?

• Hazard warning means any words, pictures, symbols or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical or health hazards of the chemicals in the containers. This must include the chemicals target organ effects. Ex.) hepatotoxin (liver effect), neurotoxin (affects nervous system).

HOW DO I FIND OUT ABOUT A CHEMICAL AND IT'S HAZARDS?

• Read the label.
  
• Read the MSDS and other appropriate reference sources.
  
• Talk to your supervisor or co-worker.
  
• Call the EHRS Department (X8925).
  
• Call the manufacturer of the chemical.
• View websites.

IF I COMPLETED A HAZARD COMMUNICATION SAFETY TRAINING GUIDE LAST YEAR, DO I HAVE TO HAVE TRAINING AGAIN THIS YEAR?

The EHRS safety training guide must be completed every 2 years. However, supervisors must provide initial hazard specific training for the employee and a refresher whenever new hazards are introduced.

Hazard specific training should be specific to the employee's tasks regarding the chemicals, substances and equipment being used or exposed to. This includes the hazards, safety procedures, PPE, waste disposal and emergency procedures.

Additionally, if an employee attended a New Employee Orientation Safety training class this year, the employee does not need to complete the Hazard Communication Safety Guide for another 2 years.  

If anyone has additional questions or needs help with training materials,
please do not hesitate to contact the EHRS Department (X8925)