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.
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.
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, Labelling, 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.
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.
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:
As an alternative to labeling all individual process containers, employers can:
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.
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:
Authorized SET faculty and/or staff will provide training and retention of the training records for the following groups:
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