Related Policies and Additional References:
St. Mary’s University has established a Hazard Communication Plan (HCP) to meet the Occupational Safety and Health Administration (OSHA) requirements set forth in the Hazard Communication Standard (29 CFR 1910.1200).The HCP is intended to comprehensively address the employees “Right to Know” of potential chemical hazards in the workplace, communicate information concerning hazards and appropriate protective measures to employees, and promote a safe and productive work environment. The plan includes the changes and enhancements as required by the Globally Harmonized System (GHS) update with regards to hazard classification, labels, and safety data sheets.
The Hazard Communication Plan is applicable to all University faculty, staff, and students employed by the University that use, handle, and/or store chemicals that are not exempt under 29 CFR 1910.1200(b)(5) – (b)(6).
29 CFR 1910.1200, Subpart 2 of the code of Federal Regulations – OSHA Hazard Communication Standard.
Integration of GHS Updates into Hazard Communication Program
OSHA GHS updates implementation timeline
- 12/1/2013 – All faculty, staff, and students employed by the University with potential to use or handled hazardous chemicals shall be trained on the Globally Harmonized System updates for new labeling elements and SDS format. Assumes that all personnel have already been trained on the pre-GHS Hazard Communication Plan in effect on campus.
- 12/1/2015 – All incoming chemical containers shall be in compliance to the new labeling system.
- 6/1/2016 – All chemicals stored onsite shall include the new container labeling and have a Safety Data Sheet on file in the new format.
St. Mary’s Compliance Strategy
St. Mary’s University is not a manufacturer, importer or a distributor of chemical products, and therefore does not evaluate or assess the hazards of chemicals. The University will rely on the distributors, suppliers, and importers for information and determination of whether or not a chemical is hazardous as indicated on the container label and the SDS that accompanies the chemical.
- 12/1/2013: All faculty, staff, and students employed by the University with potential to use or handled hazardous chemicals have been trained on the Globally Harmonized System updates for hazards, labeling elements and SDS format.
- 12/1/2013 – 6/1/2016: The pre-GHS standard and the revised GHS standard will be both be in effect. Existing MSDS’s and container labeling be considered appropriate during this period. St. Mary’s will integrate the new GHS labeling and SDS format provided by the manufacturer to the existing chemical inventory for purchased chemicals. Existing chemical containers will be relabeled with the new label requirements.
- The requirements of the GHS updates will be fully implemented by the last day of the transition period.
Hazard Communication Program
St. Mary’s has established a Hazard Communication Program to provide all applicable employees information on potential chemical hazards in the workplace, communicate information concerning hazards and appropriate protective measures to employees, and promote a safe and productive work environment. As a result of the GHS updates that went into effect May 25, 2012, the training has been enhanced to address the four key areas of change: Hazard Classifications, Safety Data Sheets, Labeling, and Training.
Classifications of chemical hazards have been standardized to ensure that the intrinsic hazardous properties of chemicals and their respective toxicity ranges are the same across all countries regardless of where the chemical was manufactured or packaged for distribution. Three broad categories of hazards have been defined: 16-Physical Hazards, 10-Health Hazards, and 2- Environmental Hazards. Refer to Appendix – A for the specific hazards.
Chemical Inventory List and Safety Data Sheets
- Chemical Inventory Lists (CIL) and Safety Data Sheets (SDS) shall be maintained by each department and/or work area that handles, stores, and disposes of hazardous chemicals. The inventories and data sheets will be reviewed and updated on a periodic basis.
- The person or department purchasing a chemical is responsible to ensure the chemical is received with the new labels and SDSs that comply with the GHS updates.
- All new chemical purchase orders will be reviewed by the authorized department representative to ensure that disposal requirements can be met per Waste Disposal Management Plan
- The CIL and SDS’s for frequently used lab chemicals will be kept in an area readily accessible to all employees or students and in close proximity to the location in which the work is being performed.
- SDS’s will be made available upon request to employees, local authorities, health, and medical officers as required by law.
Safety Data Sheet (SDS) Format
After June 1, 2015, chemical manufacturers, importers, or other employers preparing the SDS must format it using consistent headings in a specified 16-section sequence. The new SDS format will include at least the following section numbers and headings and associated information within each heading, in the order listed:
Section 1 Identification-includes product identifier, manufacturer or distributor name, address, phone number, emergency phone number, recommended use, and restrictions on use
Section 2 Hazard(s) identification-includes all hazards regarding the chemical and required label elements
Section 3 Composition/Information on ingredients-includes information on chemical ingredients and trade secret claims
Section 4 First-aid measures-includes important acute or delayed symptoms or effects and required treatment
Section 5 Fire-fighting measures-lists suitable extinguishing techniques, equipment, and chemical hazards from fire
Section 6 Accidental release measures-lists emergency procedures, protective equipment, and proper methods of containment and cleanup
Section 7 Handling and storage-lists precautions for safe handling and storage, including incompatibilities
Section 8 Exposure controls/Personal protection-lists OSHA’s permissible exposure limits, threshold limit values (TLVs), appropriate engineering controls, and personal protective equipment (PPE)
Section 9 Physical and chemical properties-lists the chemical’s characteristics
Section 10 Stability and reactivity-lists chemical stability and possibility of hazardous reactions
Section 11 Toxicological information-includes routes of exposure, related symptoms, acute and chronic effects, and numerical measures of toxicity
Section 12 Ecological information*
Section 13 Disposal considerations*
Section 14 Transportation information*
Section 15 Regulatory information*
Section 16 Other information-includes date of preparation or last revision
* OSHA will not enforce the information requirements in Sections 12 to 15; however, the SDS must include at least the heading names for those sections.
GHS Labeling requirements
All new chemicals/ materials received shall have an appropriate container with labeling that conforms to GHS requirements. The labels must not be removed and must be replaced if illegible. All containers of chemical products must be labeled, including chemical cans and dispensers.
NOTE: The only exception is for immediate use, which means the chemical is under the control of and used only by the person who transfers it from the labeled container and uses it during the shift in which it was transferred.
The new container labels will include the following elements:
- A pictogram with one or more of the new hazard symbols inside a diamond-shaped box with a red border (See Appendix-B).
- A signal word, either “Danger” or “Warning”
- Hazard statements, such as “Highly flammable liquid and vapor.”
- Precautionary statements, such as “Keep container tightly closed.”
- The product identifier, such as product name and/or code.
- Supplier identification, including manufacture name, address, and phone.
- The label may also contain supplemental information, such as “Directions for use.”
- Labels or other forms of warning must be legible, in English, and prominently displayed on the container, or readily available in the work area throughout each work shift.
- Hazardous chemical containers must include either the label shipped with the chemical container or a product identifier and combination of words, pictures, or symbols that provide at least general information regarding the hazards of the chemicals and provide employees with the specific information about the physical or health hazards of the chemical.
Alternatives to Labeling
As an alternative to labeling all individual process containers, employers can:
- Substitute various types of standard operating procedures, process sheets, batch tickets, blend tickets, and similar written materials for container labels on stationary process equipment if they contain the same information as the labels.
- Post signs or placards that convey the hazard information if there are a number of stationary containers within a work area that have similar contents and hazards.
- Use alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard Rating and the Hazardous Material Information System (HMIS) as long as those systems are consistent with the GHS labeling system.
- All information supplied on the alternative labels must be consistent with the GHS label system; for example, there must be no conflicting hazard statement and pictogram.
Procedures to Correct Outdated Labels
If an employer becomes aware of any significant new information about the hazards of a chemical, the employer must revise the labels for the chemical within 6 months of becoming aware of the new information. The employer must also ensure that labels on containers of hazardous chemicals contain the new information.
Haz Comm Plan Review and Training
The Hazard Communication Plan will be reviewed annually by the Office of Administration and Finance, School of Science, Engineering, and Technology (SET) faculty, and Facilities Services Office. All faculty, staff, and students employed by the University with the potential to use or handled hazardous chemicals shall be trained on the Hazard Communication Program with the Globally Harmonized System updates for hazard classification, labeling elements and SDS formatting. Training will occur on a re-occurring basis and as new hazards are introduced into the work environment.
The Office of Administration and Finance will provide annual training and retention of the training records for the following groups:
- Facilities Services personnel
- Faculty Leadership and Lab supervisors within the School of Science, Engineering, and Technology (SET)
Authorized SET faculty and/or staff will provide training and retention of the training records for the following groups:
- Relevant faculty within SET that did not attend the training provided by the Office of EHS and RM
- Work-studies and any other personnel working in SET and that are considered employed by St. Mary’s University per Human Resources guidelines
All training records will be maintained by the office, department, or area conducting the training in compliance to the University record retention requirements.
Available in the Office of Facilities Services:
Appendix A: Hazards Classification
Appendix B: New GHS Hazard Pictograms