Hazard Communication

All employees have both a need and a right to know the hazards and identities of the chemicals they are exposed to when working as identified in the Hazard Communication Guidelines.  This document establishes the objectives and administrative requirements for the Bates College Hazard Communication Guidelines.

The guidelines set forth in this document are intended to ensure compliance with federal and state requirements.  Applicable regulations are the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) 29 CFR1910.1200, the Environmental Protection Agency (EPA) Community Right-To-Know (SARA), and 40 CFR Part 370.

Scope

The Hazard Communication Guidelines establish requirements for informing Bates College employees and students who are with or are exposed to those regulated chemicals which pose a physical and/or health hazard during routine or non-routine operations or during emergency conditions at any phase of the chemical’s “life cycle” including receipt/issue, use or disposal.

This document applies to all personnel who work with or supervise operations involving work with materials of concern in any Bates College building or property.

Exception: Research Laboratories are exempted from the provisions of the Hazard Communication Guidelines, however, they are subject to the requirements under the OSHA Laboratory Standard, 29 CFR1910.1450 that are addressed in the Laboratory Safety and Chemical Hygiene Plan.

The Hazard Communication Guidelines apply to laboratories only as follows:

  • Ensure that labels on incoming containers of hazardous chemicals are not removed or defaced;
  • Maintain all Safety Data Sheets (SDS) for incoming containers of hazardous chemicals and ensure that they are readily accessible to employees; and
  • Supervisors should ensure that employees are provided information and training on the associated hazards of chemicals in their workplace.

Elements

Chemical Inventory List: Departments should compile and maintain a workplace chemical list of the hazardous chemicals or products in their areas.  The chemical inventory list must contain the following information for each hazardous chemical or product normally present in the workplace or temporary workplace:

  • The identity of the chemical as specified on the container label or SDS for that chemical
  • The location (room number or work area) that the chemical is used and/or stored
  • The quantity of the chemical generally kept at the location

At Bates College, inventories should be maintained using Vertere, the online inventory provided by Bates College.  Departments are responsible for updating the workplace chemical list upon the introduction for a new chemical or product into the workplace annually.

Safety Data Sheets: Safety data sheets (SDS) are the primary data source intended to outline the special precautions and controls necessary for handling specific hazardous chemicals.  The purpose of the safety data sheet is to provide health and safety data about specific hazardous substances.  A safety data sheet must be kept for each hazardous chemical or product used in the workplace.

Safety data sheets are readily available up on request and shall be accessible by one of the following methods:

  • Accessing Vertere
  • Accessing www.toxnet.nlm.nih.gov
  • Contacting the chemical manufacturer
  • Contacting Bates College EHS

Labeling and Forms of Warning: To ensure that appropriate information concerning the hazards of a chemical are accessible to employees, all containers of hazardous chemicals should be labeled.

Chemical manufacturers, importers, and distributors shall ensure that every container of hazardous chemicals entering the workplace is appropriately labeled with the following:

  • The product identifier used on the safety data sheet
  • Signal word
  • Hazard statement
  • Pictograms
  • Precautionary statement(s)
  • The name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

If the chemical label on the original container becomes damaged, illegible, or is inadvertently removed from a container, it should be replaced immediately by the department supervisor or designee.  The replacement label must include the same information that was initially provided by the manufacturer or distributor.

Secondary container labels should be identified by a label which includes the product identifier used on the safety data sheet, signal word, and pictograms which provide general information regarding the hazard of the chemical.

Portable containers into which hazardous chemicals are transferred from labeled container, and which are intended only for the immediate use of the individual who performed the transfer are not required to be labeled.

For stationary process containers (i.e. 55-gallon drums, 33-gallon drums, 5-gallon carboy), alternate identification methods may be used if the hazards of the chemical (as specified in 29 CFR1910.1200(f)(4) are effectively conveyed to the employee.

Alternative methods of labeling:

  • Signs, placards, tags.  A numbering or lettering system may be an acceptable form of identification on the above types of labels.  However, all individuals should understand this method of identification and know where to find the SDSs in their work area during each shift.
  • Containers that are used for carrying daily use and/or storing chemicals (i.e. safety cans, plastic bottles, etc.) will be labeled with the trade and/or chemical name.  Hazard warnings do not have to be included if the primary container or SDS is located in the same area as the carrying, storing, or daily use containers, and if the primary container is identified with the appropriate hazard warnings (health, reactivity, flammability, PPE).
  • Pipes at Bates College are labeled only if they contain a hazardous gas or chemical.  Pipes that are unlabeled and insulated contain either steam, condensate, or water.

Shipping:  Any employee offering or accepting international, interstate, or intrastate transportation of hazardous materials shall be in accordance with the Department of Transportation 49 CFR 172.

Non-routine Operations: Individuals may periodically be require to perform hazardous non-routine tasks.  A non-routine task is one that the individual does not normally perform (because of infrequency, location, or type of work) and for which the employee has not previously been trained.  A non-routine task may include when an individual is to work with a chemical under conditions that arise infrequently.

Training and Recordkeeping

Supervisors are responsible for training or contacting EHS for whenever individuals will be performing non-routine tasks involving the use of hazardous chemicals.  Supervisors must ensure that individuals are informed of the hazards and required control measures, including safe work practices, and proper personal protective equipment.

Individuals should receive information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard to the individuals have not been previously been trained about is introduced into their work area.  General training may take the form of individual instruction, group seminars, audiovisual presentations, handout material, or any combination of these.

Information and training may be designed to cover categories of hazards (i.e. flammability, carcinogenicity) or specific chemicals.  Chemical specific information shall always be available through labels and safety data sheets.  EHS can provide general hazard communication training.  This general training program can provide an introduction to the following:

  • The requirements of the Hazard Communication Standard;
  • The location and availability of the written Hazard Communication guidelines for Bates College;
  • The details of the Hazard Communication guidelines including an explanation of the labeling system and the safety data sheet and how individuals can obtain and use the appropriate hazard information;
  • Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area;
  • The physical, health, simple asphyxiation, and other hazards not otherwise classified, of the chemicals in the work area;
  • The measures individuals can take to protect themselves from these hazards, including work practice controls, emergency procedures and personal protective equipment.

Department specific training should be conducted upon employment, and whenever a new hazard is introduced into an individual’s work area.  Department specific hazard communication training should include information on the following:

  • Any operations in their work area where hazardous chemicals are present;
  • Specific chemical hazard classes found in the work area;
  • Specific location and availability of the department’s Safety Data Sheets (SDS);
  • A review of what an SDS is and how to read the SDS, where the SDSs are kept in each work area, and how to obtain copies of SDSs as required;
  • The labeling system to ensure that all containers of hazardous chemicals are labeled with the product identifier and words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemical;
  • Available personal protective equipment and appropriate emergency procedures for chemicals found within the work area as outlined by the Safety Data Sheets;
  • Location and availability of appropriate chemical labels.

Departmental Supervisors shall be responsible for providing department specific training to covered employees.  Records of departmental training should be kept by the department and provided to EHS upon request.

Glossary

Chemical: Any substance or mixture of substances obtained by chemical process or used for producing a chemical effect.

Chemical Name: The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard classification.

Classification:  Means to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as hazardous according to the definition of hazardous chemical in this section.  In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards.

Container:  Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical.

Individual: An employee or student who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies.  Individuals such as office workers who encounter hazardous chemicals ONLY in non-routine, isolated instances are not included.

Hazard Class: The nature of the physical or health hazards, i.e. flammable solid, carcinogen, oral acute toxicity.

Hazard Not Otherwise Classified (HNOC): An adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health hazard classes.

Hazard Statement: A statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.

Hazardous Chemical: Any chemical which is a physical or health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

Health Hazard: A chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard.

Label: An appropriate group of written, printed, or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.

Physical Hazard: A chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gasses, aerosols, liquids, or solids); oxidizers (liquid, solid, or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.

Pictogram: A composition that may include a symbol plus other graphic elements, such as border, background pattern, or color that is intended to convey specific information about the hazards of a chemical.  See below.

Precautionary Statement: A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.Product Identifier: The name or number used for a hazardous chemical on a label or in the Safety Data Sheet.

Safety Data Sheet (SDS): Written or printed material concerning a hazardous chemical which is prepared in accordance with 29 CFR1910.1200(g).

Signal Word: A word used to indicate the relative of severity hazard and alert the reader to a potential hazard on the label.  The signal words used in this section are “danger” and “warning”.  “Danger” is used for the more severe hazards, while “warning” is used for the less severe.

Simple Asphyxiant: A substance or mixture that displaces oxygen in the ambient atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to unconsciousness or death.

Work Area: A room or defined space in a workplace where hazardous chemicals are produced and/or used, and where employees and/or students are present.