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Hazard Communication Program

I. INTRODUCTION.  

As part of the overall safety and health program for the University of North Florida, a chemical Hazard Communication Program has been established.  This Hazard Communication Program complies with the Occupational Safety and Health Administration (OSHA) Hazard Communication standard, 29 CFR 1910.1200. 

II. OBJECTIVE.  

The objective of the Hazard Communication Program is to prevent occupational injuries and illnesses related to chemical exposure by educating employees about workplace chemical hazards. 

III. SCOPE.  

The Hazard Communication Program applies to all work areas where hazardous chemicals are known to be present both under normal conditions and in a foreseeable emergency.  Directors of individual departments are responsible for program implementation in their respective areas. 

 

The Hazard Communication Program has four major components:

  • Container Labeling and Other Forms of Warning
  • Material Safety Data Sheets (MSDSs) 
  • Employee Education and Training 
  • Written Program and Chemical Inventory

IV. HAZARDOUS CHEMICALS 

The definition of "hazardous chemicals" as given by OSHA is "any chemical which is a physical hazard or health hazard".  Physical hazard characteristics of chemical substances include:

  • Combustible
  • Organic Peroxides  
  • Compressed Gases
  • Oxidizers
  • Explosive
  • Pyrophoric (may ignite when exposed to air)
  • Flammable
  • Unstable

 

Health hazards related to chemical exposure include:

  • Toxic or Highly Toxic
  • Irritants 
  • Sensitizers 
  • Carcinogens
  • Target Organ Effect

Further explanation can be found in Appendix A of the OSHA Hazard Communication standard.   

 

V. HAZARD COMMUNICATION PROGRAM. 

This written Hazard Communication Program outlines and describes how the following information will be organized and transmitted. 

  1. List of hazardous chemicals known to be present in the workplace 
  2. Information on precautionary labels and other forms of warning for known hazardous chemicals in the workplace  
  3. Material Safety Data Sheets (MSDSs) for known hazardous chemicals in the workplace  
  4. Methods used to provide employee information and training  
  5. Methods used to inform employees of hazards on non-routine work  
  6. Methods used to inform contractor employers of any hazardous chemicals to which contractor employees may be exposed

VI. CHEMICAL INVENTORY LIST.

Each department must maintain a written list of the hazardous chemicals known to be present in the department and/or work area.  The chemical/product identity must be easily referenced to the applicable MSDS for each product.  The list must be available to all employees in each work area. 

VII. PRECAUTIONARY LABELING.

A. Containers in the Workplace.  Supervisors are responsible to insure that all known hazardous chemicals present in the work area must display, in English, a precautionary label stating the identity of the hazardous chemical and appropriate hazard warnings.  In the event of an improperly labeled hazardous chemical container, a proper label can be requested by telephone or letter from the chemical supplier.  All labels on incoming chemicals must not be defaced in any way.  Observation or other detection of defaced labels must be immediately reported to supervision so appropriate labels can be applied. 

 

B. Portable Containers.  All portable containers of hazardous chemicals must be labeled.  The exception to this policy is that portable containers do not have to be labeled if they contain chemicals transferred from a labeled container and are intended only for immediate use during one 8-hour shift.  These unlabeled containers must also remain in the constant control of the employee who performed the transfer of chemicals from one container to another.  Employees who have questions about portable container labeling should contact their immediate supervisor or EH&S.  The employee who uses the portable container is responsible for placing the label on the container, and the supervisor is responsible to see that labeling is done. 

VII. MATERIAL SAFETY DATA SHEETS (MSDSs).

A. MSDS Format. 

MSDSs are written or printed material concerning product hazard determination.  They are prepared and distributed with chemicals by the manufacturers and distributors.  MSDSs are written in English and contain the following information. 

  • Identity of the chemical as provided on the container label 
  • Physical and chemical characteristics of the material 
  • Physical hazard of the material 
  • Health hazards of the material 
  • Primary routes of entry
  • Exposure limits, Threshold Limit Values (TLV), OSHA Permissible Exposure Limit (PEL), or supplier-recommended exposure limits 
  • Whether the material or components have been found to be a potential carcinogen by the International Agency for Research on Cancer (IARC), National Toxicology Program (NTP), or by OSHA  
  • Applicable precautions for safe handing and use  
  • Applicable control measures 
  • Emergency and first-aid procedures 
  • Date of preparation and date of last change 
  • Name, address and telephone number of the chemical manufacture, importer, employer or other responsible party, who can provide additional information 

B. Obtaining MSDSs. 

All purchase requisitions for any chemical should include the notation "MSDS Required" if a current MSDS is not on file for that product.   Each work section is responsible for obtaining an MSDS.  An MSDS should be available for every hazardous chemical listed on the inventory list.  In the event an MSDS is not available, the following procedures should be used to obtain the MSDS. 

  1. Contact the supplier by telephone and letter to request the MSDS.
  2. If a supplier should not satisfy the first written request within 30 days, a second written request for an MSDS should be sent to the supplier.

C. Review of MSDSs.

Each department impacted by this program is responsible for reviewing all incoming data sheets for new and significant health/safety information.  Any new information will be transmitted so that appropriate measures can be taken to inform affected employees. 

D. MSDS Maintenance.  

Each department is responsible to maintain an MSDS for each product to which respective employees are exposed.  MSDSs for chemicals are maintained by supervisors in a notebook. They must be accessible to employees during each work shift. 

IX. EMPLOYEE TRAINING AND EDUCATION.

Effective employee training and education is the most critical component of the hazard communication program.  A properly conducted training program will ensure that UNF employees are aware of hazards in the workplace and that appropriate control measures are in place to protect employees from overexposure.  The Director, Environmental Health and Safety, coordinated the employee training and education program and department heads are responsible for implementation of this program.

A. Program Outline.

All employees who work in areas where hazardous chemicals are used and/or maintained and those who may be exposed in an emergency are involved in the employee training and education program. The program is conducted in two phases. 

  1. General Information Training (Office of Environmental Health and Safety). 
    1. Explanation of the Hazard Communications Standard
    2. Location and availability of the written Hazard Communication Program 
    3. Operations in work areas where hazardous chemicals are present 
    4. General introduction of chemical hazards, labeling and Material Safety Data Sheets  
     
  2. Specific Hazard Training (All Departments). 
    1. Location of hazardous chemicals in the work area
    2. Discussion of methods and means of determining or detecting the presence or release of hazardous chemicals in the work area 
    3. The chemical physical and health hazards in the work area
    4. Explanation of labeling requirements
    5. Review of appropriate work practices, personal protective equipment and emergency procedures  
    6. Access to safety and health information 
    7. Work area list of hazardous chemicals and Material Safety Data sheets 
    8. How to obtain additional information
     

B. Reassigned/Transferred Employees. 

Employees reassigned or transferred to other work areas will undergo a review of specific hazard training in the new work area. The supervisor is responsible for scheduling and ensuring that this retraining session is conducted and initiated on the first day of employment in a new work area.  

C. New Hires.  

Each department will provide Hazard Communication training and education for new employees at the time of initial assignment. 

D. New Hazard.  

There are three ways in which a new hazard may be introduced. 

  1. A new hazardous chemical may be added to the workplace by the department 
  2. A current hazardous chemical in use may expose additional employees in the same work area
  3. A former non-hazardous chemical may be used in a manner that is hazardous 

 

When any of the above new chemical hazards are introduced into the workplace, the respective department where the new hazard is introduced will provide specific hazard training to all affected employees prior to the introduction of the new hazard. 

X. NON-ROUTINE WORK.

Employees may be asked to perform non-routine work, which is defined as work not normally performed by an employee during the performance of daily tasks.  Examples of non-routine work could be, but are not limited to: 

  • Confined Space entry work
  • Welding and cutting operations
  • Floor stripping/coating
  • Intensive maintenance activities during system/plant outages
  • Building and structural repair
  • Using internal combustion engines in enclosed areas 

 

The following procedures will be used when employees perform non-routine work. 

 

Maintenance Coordinators will determine the need for non-routine work and its associated hazards. 

 

Shop supervisors will train employees who perform the non-routine work regarding associated hazards and the correct procedures and/or permits required to perform this work safely.  This training should be given prior to performing the non-routine work each time the work is performed.  Employees must inform supervisors before non-routine work is performed to make sure that the supervisor is aware of the work to be performed.  Employees should contact immediate supervisors with questions concerning non-routine work. 

 

XI. CONTRACTORS.  

When contractors work on UNF property, the contractor must comply with all applicable state and federal occupational safety and health standards and requirements.  The Hazard Communication standard requires the university to inform all contractors about the hazardous chemicals in university work areas that contractor employees may be exposed to as well as appropriate protective measures for those exposures.  This information will be provided so that contractors can properly train their own employees.  In addition, contractors will inform the university about hazardous chemicals the contractor plans to introduce and use on our campus so that the university may adequately protect staff, students and visitors from exposure.  The following procedures will be used with contractors prior to the start of work. 

 

A. Responsibilities.

  1. The Director, Environmental Health & Safety, will provide contractors with a list of university owned or supplied hazardous chemicals to which contractor employees may be exposed prior to the start of work.  Material Safety Data Sheets (MSDSs) for listed chemicals will also be made available to the contractor.
  2. The contractor will provide the university, in writing, a list of chemicals to which university employees may be exposed.  The contractor will also provide Material Safety Data Sheets with this written list.  The director, Environmental Health & Safety, will review the chemical list and the MSDSs provided by the contractor and will notify respective supervisors of potential exposure and appropriate protective measures. 

XII. PROGRAM REVIEW.

The Hazard Communication Program will be reviewed annually.