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Hazard Communication 

Policy

 

I.      Purpose

Winthrop University establishes this Hazard Communication Program pursuant to Occupational Safety and Health Administration (OSHA) regulations (29 CFR 1910.1200) in order that all chemicals used on campus and all potential hazards are evaluated and the information concerning these hazards conveyed to employees and students.  The Hazard Communication Program involves labels, material safety data sheets (MSDS), employee training and use of personal protective equipment (PPE), employee access to written records, and a written hazard communication plan.

 

The hazard communication regulations apply to any hazardous chemical that is known to be present in the workplace in such a manner that employees and/or students may be exposed under normal conditions of use, or in a foreseeable emergency.  The definition of “hazardous chemical” under the standard is extremely broad, and includes any chemical that is a physical hazard or a health hazard.  The OSHA standard sets out a procedure for hazard determination, and any substance determined to be hazardous under this procedure is subject to the program.

 

II.  Hazard Communication Responsibilities

 Department heads, supervisors or instructors are responsible for:

1.     Creating and maintaining an inventory of all chemicals and supplying this inventory to the university safety manager.

2.     Ensuring that all chemicals are properly labeled, and that these labels are not removed or defaced.

3.     Informing employees and/or students of any tasks in their work area which involve the presence of hazardous chemicals as well as the location and availability of the written hazard communication program, the inventory, and the MSDS.

4.     Obtaining an MSDS from the vendor for each chemical; placing a copy of the MSDS in an easily accessible location near the chemical; sending a copy of each MSDS received to the university safety manager; and ensuring that if a chemical is being used that a copy of the MSDS is nearby.

5.     Training employees and/or students about specific hazards relating to the work or instruction area or practices therein.

6.     Determining the required PPE for the procedures and materials in use in their area.

7.     Ensuring that the proper PPE is available and that the employees and/or students are trained and encouraged in its use.

8.     Developing safe procedures for work or instruction in their area, as well as written procedures for emergencies and evacuations, and training employees and/or students in those procedures.

9.     Informing employees and/or students about proper performance of non-routine tasks ( See Section VI).

 

Employees and students are responsible for:

1.      Planning and conducting each operation according to the Hazard Communication Program.

2.      Maintaining his or her work area in good order.

3.      Using the required PPE and taking proper care of said equipment.

4.      Reporting immediately any exposures, injuries or problems to the supervisor or instructor.

5.     Reviewing the MSDS prior to using a substance for the first time, and reviewing it periodically thereafter.

 

The university safety manager is responsible for:

1.     Maintaining a master list of all chemicals on campus and coordinating the annual updates. 

2.     Maintaining in the Facilities Management office a current MSDS for every chemical on campus.

3.     Supplying the Rock Hill Fire Department with a copy of the chemical inventory.

4.     Serving as information resource to the Winthrop community, the Rock Hill community and the Rock Hill Fire Department on chemicals at the University.

5.     Conducting inspections to ensure compliance with the Hazard Communication Program.

6.     Maintaining a copy of all training records.

7.     Assisting department heads or supervisors when the need arises.

8.     Evaluating this program and updating it as needed.

 

The Purchasing Department is responsible for:

1.    Instructing all outside contractors to contact the university safety manager for specific information about hazardous chemicals within the University that may pose a risk to contract employees.

2.    Requiring all contractors to provide the university safety coordinator and department heads or supervisors with information concerning hazardous chemicals brought into any Winthrop facility to be used in contracted work before that work begins.

3.    Forwarding upon receipt all MSDS received to the university safety manager.

 

The Central Receiving Department is responsible for:

1.    Forwarding upon receipt all MSDS received to the university safety manager.

2.    Not accepting any chemical without a copy of the MSDS.

 

III.  Hazardous Chemicals Inventory

The supervisor or instructor is required to maintain a list of all chemicals known to be present in each work area.  The inventory must identify each chemical by the primary name on the label, average quantity on hand, and the location of the chemical.  The inventory must be kept in the work area in a suitable format, on a log sheet, or in a computer.  The inventory must be available during the work period.  The inventory, along with any changes, additions or deletions, must be relayed to the university safety manager immediately. 

 

IV.  Labeling and Storage Requirements

The supervisor or instructor must ensure that all hazardous chemicals in his/her area of responsibility are properly labeled.  Labels should list the chemical identity, appropriate hazard warnings and the name and address of the manufacturer, importer or the responsible party.  Portable containers of working solutions must be labeled appropriately unless they are intended for immediate (during a day’s work-shift or class period) use by the employee or student who prepares it.  The contents of all vessels containing chemicals or products such as cleaning solutions must be identified by name on the container.

Chemicals stored in bulk quantities, pipelines and storage tanks are required to be adequately labeled.  Storage tanks or drums can be labeled collectively rather than labeling individual containers if they are not removed from the labeled area and if the hazards are the same.  It is the responsibility of the supervisor or instructor ordering and using these bulk chemicals to ensure adequate labeling.

 

 V.  Material Safety Data Sheets (MSDS)

MSDS are an integral part of the safety of the Winthrop community. MSDS provide employees, students and Rock Hill citizens with specific information on the chemicals used by Winthrop University.  It is the policy of Winthrop University that a copy of each MSDS for each chemical used by the University remain on file with (1) the department and (2) Facilities Management.  It is the obligation of every department head to assure that the departmental procedures for handling and storing of chemicals are in compliance with federal, state and local regulations.  DO NOT receive or remit any new chemicals until both the department and the university safety manager, whose office is located in Facilities Management, has obtained a copy of the MSDS (this includes any samples).  Inform each member of the department as to the location of the list and the MSDS sheets. This information must be readily available to all who may come in contact with the chemical.

 

Updating

Upon arrival of a previously non-listed chemical, the vendor will present an MSDS.  This MSDS should be filed with that department or division head and the university safety manager before the chemical is used.  Upon arrival of a previously listed chemical, the vendor may present an updated MSDS.  This MSDS should be filed with that department or division head and the university safety manager as soon as possible.  The division or department head will update his or her MSDS collection immediately upon arrival of a new MSDS.  The departmental MSDS collection will be updated annually to ensure an accurate MSDS file.  The MSDS at the Facilities Management office will be updated immediately when a new MSDS arrives.  Furthermore, the MSDS at the Facilities Management will be updated annually.  All MSDS of chemicals that are not in use or storage at the time of the annual update will be placed in a binder containing old MSDS and be kept for 30 years.

  

VI.  Non-Routine Tasks

Employees have to be informed of what, if any, hazardous material they may encounter while performing a job or task that they do not normally perform.  It is the responsibility of the supervisor to provide appropriate information and appropriate protective measures required to safely perform the task.

 

VII.  Employee Training and Information

Employees and/or students must receive hazard communication training when working in a new area, whenever a new material or procedure is introduced into the workplace, or whenever the instructor, university safety coordinator, or supervisor feel that refresher training is in order.  This training must include:

1.     Physical and health hazards of chemicals in the work or instruction area.

2.     Methods and observation techniques used to detect the presence or release of a hazardous chemical.

3.    How to lessen or prevent exposure to these hazardous chemicals through usage of controls, work practices and PPE.

4.     How to use MSDS information.

5.     How to read and understand labels.

6.     The proper use of any required PPE.

All training shall be documented by recording the training session subject(s), date and attendees.  The university safety manager will maintain a copy of these records.

Information about the University’s Hazard Communication Program will be disseminated to all new employees.  All new employees must be trained by their supervisor concerning hazardous chemicals in the workplace at the time of initial assignment and whenever a new hazard is introduced into the work area.


 

 

 

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