Safety and Health Manual: Chapter V

Hazardous Material Communication Program

Police and Public Safety Policy  PS 09 00f

A. Purpose. The purpose of The University of North Carolina at Pembroke's Hazardous Materials Communication Program is to insure that all University employees and students are effectively informed concerning workplace and classroom safety and health hazards, especially chemical hazards.
B. Scope. This applies to The University of North Carolina at Pembroke, all University employees, students, and activities.
C. Policy. The safety of students, faculty, staff, and visitors is of utmost importance to the University's Board of Trustees and administration. It is the policy of this University to provide protection from hazardous materials.
D. General. This written hazardous materials communication program not only complies with OSHA standards and requirements, but also assures that all University of North Carolina at Pembroke employees and students are effectively informed concerning potential and existing workplace and classroom safety and health hazards. Hazardous materials communication is only one of the many important aspects of the occupational safety and health program including:

a. Management commitment and active support b. Engineering controls for safety and health hazards c. Effective education and training programs d. Enforcement of safety rules and procedures e. Recognition, evaluation, and control of occupational safety and health hazards f. Medical surveillance g. Assigned safety and health responsibility and accountability

It must be emphasized that safety and health hazards cannot be eliminated or effectively controlled unless they are recognized as \"hazards.\" Thus, hazardous materials communication is considered one of the first steps in establishing and maintaining an effective occupational safety and health program. Basic fundamentals used by The University of North Carolina at Pembroke to ensure that University employees and students are effectively informed concerning workplace and classroom safety and health hazards include:

a. Container labeling and other forms of warning b. Material Safety Data Sheets (MSDSs) c. Employee and student education, awareness, and training

Application
This hazardous materials communication program applies to:

a. Known occupational safety and health hazards b. Chemicals known to be present in the workplace and classroom in such a manner that employees and students may be exposed under normal conditions of use or in a foreseeable emergency.

Workplace and Classroom Safety and Health Hazards
The University of North Carolina at Pembroke identifies workplace and classroom safety and health hazards by:

a. Material Safety Data Sheets provided by chemical manufacturers and distributors b. Information provided by machinery and equipment manufacturers c. Safety and health standards, codes, and regulations d. University of North Carolina at Pembroke Job Safety and Health e. Analysis

Material Safety Data Sheets (MSDSs)
MSDSs are written or printed material concerning a hazardous chemical, which is prepared and distributed with chemicals by chemical manufacturers and distributors. All chemical manufacturers and importers must obtain or develop a MSDS for each hazardous chemical that is a physical hazard (i.e., flammable, oxidizer, etc.) or health hazard (causes acute or chronic health effects).
The Office of Safety and Health maintains a MSDS file for all hazardous chemicals used or handled in the University workplace and classroom. These data sheets are in English and contain:

a. The identity of the chemical b. The physical and chemical characteristics c. Physical and health hazards d. Exposure limits e. Precautions f. Controls g. Emergency and first aid procedures h. Name of manufacturer or importer

Business Services will ensure that a MSDS is obtained for every hazardous chemical, and will provide copies of new or updated sheets to the applicable work area supervisors, instructors, and Safety Officer.
No chemicals may be used without a MSDS. If a MSDS has not been received prior to the initial shipment of a chemical, use of that chemical will be delayed until a MSDS is obtained.
Availability
The Office of Safety and Health maintains copies of all MSDSs for each hazardous chemical in the workplace and classroom and makes them readily accessible during each workshift or class period to faculty, staff, and students when they are in their area(s) or classroom.
The work area supervisor or classroom instructor will maintain the MSDS(s) in their area. Employees and students may review their MSDS(s) by contacting their immediate supervisor or instructor.
Chemical and Safety Equipment Purchases
It is the policy of The University of North Carolina at Pembroke's Offices of Safety and Health and Business Services to review all chemical, safety equipment, and biological agent purchase requests prior to introduction into the workplace. Every effort should be made to ensure purchases are in compliance with established standards, regulations, or guidelines relating to safety. It is the responsibility of the using department to ensure that materials are suitable for the task they are to be used for and for the person(s) who will be using them. Protective clothing and equipment must meet all required safety standards. Qualified individuals(s), within and outside the department, should be sought out for advice. The Safety Officer shall be available for consultation. Considerations when making purchases include, but are not limited to, noise, ergonomics, fit, flammable, combustible properties, etc.
Machinery and Equipment Hazards
Each responsible department provides safety rules and procedures that include pertinent information provided by machine and equipment manufacturers. Also, some manufacturers provide warning signs, pamphlets, and other safety-related materials to protect employees and students.
It is the policy of Business Services and the Office of Safety and Health to review all equipment and safety equipment purchase requests prior to introduction into the workplace. Every effort should be made to ensure purchases are in compliance with established standards, regulations, or guidelines relating to safety. It is the responsibility of the using Department to ensure that machinery and equipment are suitable for the tasks they are to be used for and for the person(s) who will be using them. Protective clothing and equipment must meet all required safety standards. Qualified individuals(s), within and outside the department, should be sought out for advice. The Safety Officer shall be available for consultation. Considerations when making purchases include, but are not limited to, noise, safety recalls, known safety hazards, etc.
Safety and Health Standards, Codes, and Regulations
The University of North Carolina at Pembroke also uses numerous occupational safety and health codes prepared by safety, fire protection, health standard-making organizations, and governmental regulatory and research organizations.
Safety and health information obtained from sources is incorporated in all safety and health rules and procedures.
Job Safety Analysis (JSA's)
The University will conduct job safety analysis to review job methods and uncover hazards which:

a. May have been overlooked in the initial building layout and design of machinery, equipment, tools, workstations, and classrooms. b. May have been developed after initial operation. c. May have resulted from changes in work procedures, personnel, or instructions.

Basic Steps
The four basic steps used by University supervisors and instructors, with assistance of employees and students, and in conjunction with the Safety and Health Manager in making a job safety analysis (JSA) or classroom safety analysis (CRSA) are:

a. Select the job to be analyzed b. Break the job or classroom project into successive activities and observe how these actions are performed c. Identify the existing hazards and potential hazards d. Develop appropriate safety and health procedures to eliminate the hazard and prevent injuries and illnesses

Hazardous Chemical Lists
Each department maintains a list of the hazardous chemicals and MSDS(s) known to be present in the workplace or classroom. The identity of each chemical is referenced on the appropriate MSDS. Employees or students desiring to see this list should contact their immediate supervisor or instructor.
Labels and Other Forms of Warnings
Chemical manufacturers, importers and distributors provide labels, tags or other markings for containers of hazardous chemicals. This identification includes the following information:

a. Identity of the hazardous chemical b. Appropriate hazard warning c. Name and address of the chemical manufacturer, importer or other responsible party

The department also ensures that containers of hazardous chemicals in the workplace or classroom are labeled, tagged or marked with the identity of the hazardous chemical and appropriate hazard warning. In some cases, signs, placards, process sheets, operation procedures, or other similar accessible written materials are used in lieu of affixing labels to individual containers.
Portable containers of hazardous chemicals do not have to be labeled if they contain chemicals transferred from labeled containers and are intended only for the immediate use of the employee or student who performs the transfer.
All labels on incoming containers must not be defaced in any way. Observation of other detection of defaced labels must immediately be reported to the using department so appropriate labels can be reapplied immediately.
New Employees and Student Safety and Health Training
New employees and students are to receive appropriate safety and health information, education, and training during their initial assignment. This training includes information concerning hazardous chemicals in the workplace or classroom. Safety and Health training programs begin upon employment and/or registration. Some specific information in the safety and health training include:

a. General safety and health rules and procedures b. General chemical hazards c. Recognition, evaluation, and control of hazards d. Chemical labeling e. Material Safety Data Sheets f. Access to safety and health information g. Compliance with safety and health rules and procedures

The following are requirements of the OSHA hazard communication standard:

a. Specific operations in work areas where hazardous chemicals are present.
b. The location and availability of the written hazard communication program and all contents.

Departmental supervisors will utilize appropriate job safety and health analysis (JSA) sheets to train new employees and students when they are assigned to the work area or classes. Also, work area supervisors and instructors will train employees and students concerning methods and observations the employee or student may use to detect the presence or release of a hazardous chemical in the work area or classroom. These techniques will also include monitoring devices, systems, and visual appearance or odor of hazardous chemicals. Supervisors and instructors will also review the physical and health hazards of work area chemicals with new employees or students. Supervisors and instructors who conduct this training will use the MSDS(s) and other pertinent information. The measures that employees and students can take to protect themselves from hazards include pertinent work practices, emergency procedures, and personal protection equipment are covered.
All employees and students are informed by their supervisors or instructors concerning the University's Hazard Communication Program. An explanation of the labeling system - MSDSs - and how appropriate hazard information may be obtained is included.
Each department will ensure that all employees and students receive the proper safety and health training by supervisors and instructors. Each department is also responsible for ensuring that the proper safety protection is provided to employees, made available to students, and is utilized by them.
Retraining
It is necessary for work area supervisors to provide additional employee and student training concerning workplace and classroom hazards when:

a. New chemicals are introduced into the workplace or classroom.
b. Process or equipment changes are made which could cause new or increased employee or student exposures.
c. Procedures and work practices are introduced or changed which could cause changes in employee or student exposure.

When a new chemical is introduced into the workplace or classroom, the procedure listed on the new chemical training sheet will be followed. The supervisor or instructor conducting retraining will make a written record of the training provided and request the employee or student receiving the training sign and date the record. A copy of all training and retraining will be sent to the Safety Manager.
Program Availability
The Hazardous Materials Communication Program is available, upon request to:

a. Employees b. Students c. Designated employee representatives d. OSHA representatives e. NIOSH (National Institute for Occupational Safety and Health) representatives

Implementation When a hazardous chemical is received, the MSDS will be routed to the Safety Manager. At that time the master list will be updated (if a new chemical) and the location of the chemical noted.
A copy of the MSDS will be maintained in the supervisory area of the department in which the chemical will be located (curriculum, maintenance, etc.) The supervisory area of the department will be responsible for ensuring that a properly completed copy of the training sheet form, and the evaluation form for that chemical is returned to the Safety Manager within ten (10) days. The original of the training sheet form and evaluation should be retained by the instructor or supervisor and filed with his/her records.
When new students or new employees come on campus to begin working or taking classes in the area where these chemicals are located, new training sheet forms and evaluation forms should be prepared by each department.
E. References. None.
F. Rescissions. None.