Policy

Scope

The Hazard Communication Standard (HCS), went into effect on May 25, 2012, OSHA adopted portions of the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS), Revision 9.

The revised HCS provides standardized criteria for classifying chemicals and requires specific label elements on shipped containers and mandatory 16-section standardized safety data sheets (SDSs). 

The purpose of the Hazard Communication Program is to provide you the safety information you need work with chemicals safely. To reduce exposure to chemicals to the least amount possible. Reading labels before using a chemical and following the information provided in Safety Data Sheets is important step to take when working with any chemical. 

Categories of the Hazard Communication Standard

The HCS contains six major categories: Written Hazard Communication Program, Hazard Classification, Labels and other Forms of Warning, Safety Data Sheets, Employee Information and Training and Trade Secrets.

Written Hazard Communication Program (29 CFR 1910.1200(e)). It requires employers to fully document the actions taken to comply with all of the provisions of the HCS and to list the responsible person(s) for each area of the program. A copy of the written program (policy and procedures) must be made available, upon request, to all employees and OSHA officials.

Hazard Classification (29 Code of Federal Regulations (CFR) 1910.1200 (d)) requires chemical manufacturers and importers to evaluate the chemicals produced in their workplaces or imported by them to determine the hazard classes, and, where appropriate, the category of each class. Mandatory classification considerations are given in 29 CFR 1910.1200 Appendix A (Health Hazard Criteria) and Appendix B (Physical Criteria). Nine pictograms are used to specific hazard information.

Chemicals exempt from the standard include: wood and wood products (except wood dust), regulated hazardous waste, tobacco products, food, drugs, cosmetics, alcoholic beverages, agricultural or vegetable seed treated with pesticides, various types of pesticides, nuisance particulate and articles. These are exempt because they are all regulated by separate government agencies.

Labels and other Forms of Warning (29 CFR 1910.1200(f)), requires chemical manufacturers, importers or distributors to ensure that each container of hazardous chemicals leaving their workplace is labeled, tagged or marked with the following six elements:

1. Product Identifier - name or number used for a hazardous chemical on a label or SDS and a unique means to identify the chemical.
2. Pictogram - symbol plus other graphic elements to convey specific hazard information. There are nine pictograms under GHS. The HCS requires eight of the nine - environmental hazards are not governed by OSHA.
3. Signal Word is used to indicate the relative level of severity of hazard. DANGER is used for the more severe hazards and WARNING is used for less severe hazards.
4. Hazard Statement - describes the nature and degree of the hazard(s).
5. Precautionary Statement - phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure or improper storage or handling.
6. Supplier Information - name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

The signal word, hazard statement(s), and pictogram(s) must be grouped together on the shipped container label and NOT separated on the container or outside packaging.

Each shipped container and workplace label must be prominently displayed in English, however other languages may also be included if appropriate for your workplace.

Safety Data Sheets (29 CFR 1910.1200(g)) requires that chemical manufacturers, importers, or distributors provide SDSs for each hazardous chemical to downstream users to communicate information on the hazards. All of the information on the SDS must be in English and be available to employees working with or near the hazardous chemical. 

SDSs are now presented in a consistent user-friendly, 16-section format.

1. Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restriction on use.
2. Hazard Identification includes all hazard statements and precautionary statements, pictograms, signal word, regarding the chemical; required label elements.
3. Composition information on ingredients include information on chemical ingredients; trade secret claims.
4. First-aid measures include important symptoms/effects acute, delayed; and required treatment.
5. Fire-fighting measures list suitable extinguishing techniques, equipment; and chemical hazards from fire.
6. Accidental release measures list emergency procedures, protective equipment; proper methods of containment and cleanup.
7. Handling and storage lists precautions for safe handling and storage, including incompatibilities.
8. Exposure controls/personal protection list OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; and personal protective equipment.
9. Physical and chemical properties list the chemical’s characteristics.
10. Stability and reactivity list chemical stability and possible hazardous reactions.
11. Toxicological information includes routes of exposure; related symptoms, acute and chronic effects and numerical measures of toxicity.

Sections 12 through 16 - ecological information, disposal considerations, transport information and other regulatory information, and other information including the date of preparation or last revision.  

1. Ecological information provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment.
2. Disposal considerations provide guidance on proper disposal practices, recycling or reclamation of the chemical or its container and safe handling practices.
3. Transport information provides guidance on classification information for shipping and transporting of hazardous chemicals by road, air, rail, or sea.
4. Regulatory information provides guidance on classification information for shipping and transporting of hazardous chemicals by road, air, rail, or sea.
5. Other information includes the date of preparation or last revision.

Employee Information and Training (29 CFR 1910.1200(h)), requires employers to provide employees with: 

Effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new physical or health hazard is introduced into the area. 

The training must include methods and observations used to detect the presence or release of the chemical, physical and health hazards, protective measures, labeling and explanation of the SDS.

Trade Secrets (29 CFR 1910.1200(i)). The chemical manufacturer may withhold the chemical identity, including the chemical name and other specific information, from the SDS. If a trade secret is claimed, it must be indicated on the SDS. However, under special conditions, the substance’s proprietary information may be obtained by health care professionals immediately if a medical emergency exists or requested in a non-emergency situation. Provisions for a written statement of need and confidentiality agreement will be based on the situation circumstances.

Procedures

1. Introduction

St. Norbert College is committed to preventing accidents and ensuring the safety and health of our employees. Under this program employees are informed of the contents of the OSHA Hazard Communications Standard, the hazardous properties of chemicals with which they work, safe handling procedures and measures to take to protect themselves from these chemicals. These chemical hazards may be physical or health related.

2. Identifying Hazardous Chemicals

This list identifies all hazardous chemicals with a potential for employee exposure at this workplace - (Master Chemical Inventory by Department). Detailed information about the physical, health, and other hazards of each chemical is included in a Safety Data Sheet (SDS); the product identifier for each chemical on the list matches and can be easily cross-referenced with the product identifier on its label and on its Safety Data Sheet.

3. Identifying Containers of Hazardous Chemicals

The labeling system used by St. Norbert College will follow the requirements in the 2012 revision of the OSHA Hazard Communication Standard to be consistent with the United Nations Globally Harmonized System (GHS) of Classification of Labeling of Chemicals. The label on the chemical will convey information about the hazards posed by the chemical through standardized label elements, including pictogram symbols, signal words and hazard statements.

All hazardous chemical containers used at this workplace will have:

1. The original manufacturer’s label that includes a product identifier, an appropriate signal word, hazard statement(s), pictogram(s), precautionary statement(s) and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party
2. A replacement label with the appropriate label elements just described 
3. Workplace labeling that includes the product identifier and words, pictures, symbols, or combination that provides at least general information regarding the hazards of the chemicals.

(a) Mark Musser – Chemical Hygiene Officer and any employee accepting chemicals at St. Norbert College will ensure that all containers are appropriately labeled. No container will be released for use until this information is verified. Workplace labels must be legible and in English. Information in other languages is available (Please contact Mark Musser at mark.musser@snc.edu)

(b) Small quantities intended for immediate use may be placed in a container without a label, provided that the individual keeps it in their possession at all times and the product is used up during the work shift or properly disposed of at the end of the workday. However, the container should be marked with its contents.

4. Keeping Safety Data Sheets The distributor or supplier of the chemical is required to provide this SDS to St. Norbert College.

SDS’s are readily available to all employees during their work shifts. Employees can review SDS for all hazardous chemicals used at this workplace. (Online at Chemical Hygiene Officer Site)

The SDS’s are updated and managed by Mark Musser – Chemical Hygiene Officer (CHO). If a SDS is not immediately available for a hazardous chemical, employees can obtain the required information by calling Mark Musser- CHO at 920-403-4019.

5. Training Employees about Chemical Hazards

Before they start their jobs or are exposed to new hazardous chemicals, employees must complete a hazard communication training that covers the following topics:

1. An overview of the requirements in OSHA’s Hazard Communication Standard (see Policy).
2. Hazardous chemicals present in their workplace.
3. Any operations in their work area where hazardous chemicals are used.
4. The location of the written hazard communication plan policy and procedures (HR Website).
5. How to understand and use the information on labels and in Safety Data Sheets.
6. Physical and health hazards of the chemicals in their work areas.
7. Methods used to detect the presence or release of hazardous chemicals in the work area.
8. Steps we have taken to prevent or reduce exposure to these chemicals.
9. How employees can protect themselves from exposure to these hazardous chemicals through use of engineering controls/work practices and personal protective equipment.
10. An explanation of any special labeling present in the workplace.
11. Emergency procedures to follow if an employee is exposed to these chemicals.

Mark Musser – the Chemical Hygiene Officer is responsible to ensure that employees (those using the labs) receive this training. After attending the training, employees will sign a form verifying that they understand the above topics and how the topics are related to our hazard communication plan.  Human Resources will also send out general training to all employees though Workday which includes this policy and procedures for ther review.

Prior to introducing a new chemical hazard into any department, each employee in that department will be given information and training as outlined above for the new chemical hazard.

6. Informing Employees who do Special Tasks

Before employees perform special (non-routine) tasks that may expose them to hazardous chemicals, their supervisors will inform them about the chemicals’ hazards. Their supervisors also will inform them about how to control exposure and what to do in an emergency. The employer will evaluate the hazards of these tasks and provide appropriate controls including Personal Protective Equipment all additional training as required.

7. Informing contractors and other employers about our hazardous chemicals

If employees of other employer(s) may be exposed to hazardous chemicals at our workplace (for example, employees of a construction contractor working on-site) It is the responsibility of the Department Manager to provide contractors and their employees with the following information:

1. The identity of the chemicals, how to review our Safety Data Sheets, and an explanation of the container labeling system.
2. Safe work practices to prevent exposure.

The Department Manager will also obtain a Safety Data Sheet for any hazardous chemical a contractor brings into the workplace.

Figure 1. Label Contents

First two sections of a Safety Data Sheet

Example of Tables from the Globally Harmonized System of Classification and Labeling of Chemicals