IUPUI Environmental Health & Safety

Industrial Hygiene > Hazard Communication Program

INDIANA UNIVERSITY-PURDUE UNIVERSITY at INDIANAPOLIS
IUPUI
• Department of Environmental Health and Safety •
620 Union Drive, Room 043, Indianapolis, Indiana 46202

Purpose

All employees have both a need and right to know the hazards and identities of the chemicals they are exposed to when working as identified in the Hazard Communication Program.
This document establishes the policies, objectives, and administrative requirements for Indiana University-Purdue University (IUPUI) Hazard Communication Program. The policies set forth in this document are intended to ensure compliance with Federal and State Requirements.
Applicable regulations are the Occupational Safety and Health Administration (OSHA) Hazard
Communication Standard (HCS), Employee Right-To-Know Law (RTK), 29CFR1910.1200, the Environmental Protection Agency (EPA) Community Right-To-Know (SARA), 40 CFR Part 370, and the Indiana State Board of Health Infectious Waste Rule, 410 IAC 1-3.

Scope

The Hazard Communication Program establishes requirements for informing Indiana University-Purdue University employees who work with or are exposed to those regulated chemicals which pose a physical and/or health hazard during routine or non-routine operations or during emergency conditions at any phase of the chemicals' "life-cycle" including receipt/issue, use or disposal.

This document applies to all personnel who work with or supervise operations involving work with materials of concern at the Indiana University-Purdue University at Indianapolis (IUPUI) campus.

Exception: This program does not apply to research laboratories. These facilities are subject to Laboratory Chemical Safety Plan requirements under the OSHA Laboratory Standard, 29CFR1910.1450.

This applies to laboratories only as follows:

Employers shall ensure that labels on incoming containers of hazardous chemicals are not removed or defaced;

Employers shall maintain all Material Safety Data Sheets (MSDS) for incoming containers of hazardous chemicals and ensure that they are readily accessible to employees;

Employers shall ensure that employees are provided information and training on the associated hazards of chemicals in their workplace; and

Laboratory employers that ship hazardous chemicals are considered to be either a chemical manufacturer or a distributor under this rule, and thus must ensure that any containers leaving the laboratory are labeled in accordance with the labeling requirements of this document and that a material safety data sheet is provided to distributors and other employers.

For more information, contact the Manager of Laboratory Safety at 278-6450. Refer to the IUPUI’s Chemical Hygiene Plan for specific requirements affecting laboratory employees.

Authority and Responsibility

Environmental Health and Safety has the primary responsibility and authority for the implementation and enforcement of the Hazard Communication Program and is responsible for:

Reviewing and revising the Hazard Communication Program annually to ensure compliance;

Providing general information and training relating to hazard communication for affected University employees;

Maintaining and updating the MSDS Program;

Identification of appropriate personal protective equipment (PPE);

Assisting supervisors in identifying hazardous substances present in the work area and evaluating potential hazards of operations; and

Recommending appropriate engineering controls, administrative controls and personal protective equipment.

Department Supervisors in support and administrative areas are responsible for providing the necessary direction and support to ensure the effective implementation of the hazard communication program for their work locations. The supervisor is responsible for providing the information and training specific to the employees' specific needs and work environment are responsible for:

Notifying all employees of the purpose and intent of the Hazard Communication Program;

Ensuring that affected employees are trained in general hazard communication;

Providing department specific information and training relating to hazard communication for affected University employees;

Identifying hazardous chemicals in their work area that may pose a potential health or physical risk to employees;

Maintaining a list of hazardous chemicals and updating the list on an annual basis;

Ensuring Material Safety Data Sheets (MSDS) for all hazardous materials in their work area are readily available for employees;

Ensuring that all containers of hazardous materials are properly labeled with the chemical or trade name; and
Providing personal protective equipment.

Affected Employees are responsible for:

Complying with the Hazard Communication Program procedures;

Participating in the University's general Hazard Communication training session and department specific training sessions;

Understanding how to read chemical labels and material safety data sheets;

Know the location and use the information provided on the MSDS;

Understanding and taking necessary precautions when handling hazardous chemicals;

Ensuring proper labeling of hazardous chemicals; and

Using personal protective equipment.

Information and Training

Employees shall receive information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. General training will be may take the form of individual instruction, group seminars, audiovisual presentations, handout material, or any combination of the above.

Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical specific information shall always be available through labels and material safety data sheets. Environmental Health and Safety shall provide all general hazard communication training. This general training program shall provide an introduction to the following:

The requirements of the standard;

Any operations in their work area where hazardous chemicals are present;

The location and availability of the written Hazard Communication Program;

The details of the Hazard Communication Program including an explanation of the labeling system and the material safety data sheet and how employees can obtain and use the appropriate hazard information;

Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area;

The physical and health hazards of the chemicals in the work area; and

The measures employees can take to protect themselves from these hazards, including work practice controls, emergency procedures and personal protective equipment.

Department specific training shall be conducted upon employment, and whenever a new hazard (e.g., new class of chemical hazards, a change in assignment or a new process which may be hazardous) is introduced into an employee's work area. Department specific hazard communication training shall include information on:

Specific chemical hazard classes found in the work area;

Location of the University's Hazard Communication Program within the department;

Specific location and availability of the department's Material Safety Data Sheets (MSDS);

A review of what a MSDS is and how to read the MSDS (i.e. what each section contains and where to look for specific information), where the MSDSs are kept in each work area, and how to obtain copies of MSDSs as required;

The HMIS labeling system to ensure that all containers of hazardous chemicals are labeled with the product name and/or chemical name(s) and hazard warnings;

Available personal protective equipment and appropriate emergency procedures for chemicals found within the work area as outlined by the Material Safety Data Sheets; and

Location and availability of appropriate chemical labels.

Departmental Supervisors shall be responsible for providing department specific training to covered employees. Supervisors providing this training will need to be trained by Environmental Health and Safety. Records of departmental training shall be kept by the department and provided to EHS.

Chemical Inventory List

Supervisors shall compile a workplace chemical list that contains the following information for each hazardous chemical normally present in the workplace or temporary workplace.

a. The identify of the chemical as specified on the container label or MSDS for that chemical;
b. The location (room number) that the chemical is stored; and
c. The quantity of the chemical generally kept at the location.

Supervisors shall update the workplace chemical list as necessary but at least by December 31 of each year. Each workplace chemical list shall be dated and signed by the person responsible for compiling the information.

The workplace chemical list may be prepared for the workplace or for each work area or temporary workplace and must be readily available to employees and Environmental Health and Safety. All employees shall be made aware of the workplace chemical list before working with or in a work area containing hazardous chemicals.

Material Safety Data Sheets

Material safety data sheets are the primary data source intended to outline the special precautions and controls necessary for handling specific hazardous chemicals. IUPUI shall rely on material safety data sheet information provided by the chemical manufacturer in determining chemical hazards.

Material safety data sheets are typically provided by the chemical manufacturer or chemical supplier and usually divided into several different sections, approximately 8 to 10 sections. The different sections of an MSDS may vary slightly from manufacturer to manufacturer (e.g., section titles and section order), but each MSDS shall contain the following information:

Chemical identification;

Physical and chemical characteristics;

Physical hazards;

Health hazards;

Primary routes of entry;

Occupational Safety and Health Administrations (OSHA's) permissible exposure limit (PEL);

Carcinogenicity;

Generally applicable precautions for safe handling and use;

Generally applicable control measures;

Emergency and first aid procedures;

Date of preparation;

Name, address and telephone number of the chemical manufacturer; and

Disposal procedures.

Obtaining MSDSs Material safety data sheets are readily available upon request 24 hours a day and shall be accessible by one of the following methods:

Accessing www.ehs.iupui.edu, programs, MSDS Hazard Communications, Search for MSDS for links to various materials safety data sheet websites;

Accessing www.toxnet.nlm.nih.gov;

Contacting the chemical manufacturer; or

Contacting Environmental Health and Safety at 278-2005 (information provided within 24 hours of the request).

Labeling

To ensure that appropriate information concerning the hazards of a chemical are accessible to employees, all containers of hazardous chemicals shall be labeled. Labels shall be legible, in English (additional languages may be included as necessary), and prominently displayed on the container. Chemical manufacturers, importers, and distributors shall ensure that every container of hazardous chemicals entering the workplace is appropriately labeled with the identity of the hazardous chemical(s) (common and/or chemical name), appropriate hazard warnings; and the name and address of the chemical manufacturer, importer or other responsible party.

If a chemical label in the workplace becomes damaged, illegible, or is inadvertently removed from a container, it shall be replaced immediately by the supervisor or designee.

Replacement labels shall include, at a minimum, the identity of the hazardous chemical(s) (common and/or chemical name), appropriate hazard warnings or alternatively, words, pictures, symbols or combination thereof, which provide at least the general information regarding the hazards of the chemicals.

Chemicals which are transferred from the original container into a secondary container shall be identified by a label on the secondary container.

To comply with labeling requirements, the University has adopted the HMIS (Hazardous Materials Information System) labeling system or the NFPA (National Fire Protection Association) warning information when factory labeled.

The following colors are used to represent the hazards on the HMIS label:

Red represents the fire hazard;

Blue represents the health hazard;

Yellow represents the reactivity hazard; and

White represents personal protective equipment to be used (HMIS).
White represents specific hazards such as corrosive or water reactive (NFPA).

Alternatives and allowable exceptions to the above labeling requirements are:

For stationary process containers (i.e. 55-gallon drums, 33-gallon drums, 5-gallon carboy), alternate identification methods may be used if the hazards of the chemical (as specified in 29CFR1910.1200(f)(4)) are effectively conveyed to the employee.

Alternate methods of labeling are:

Signs, placards, batch tickets (tags). A numbering or lettering system may be an acceptable form of identification on the above types of labels. However, all employees must be taught and understand this method of identification and know where to find the MSDSs in their work areas during each shift.

Containers that are used for carrying daily use and/or storing chemicals (i.e. safety cans, plastic bottles, etc.) will be labeled with the trade and/or chemical name. Hazard warnings do not have to be included if the primary container or MSDS is located in the same area as the carrying, storing, or daily use containers, and if the primary container is identified with the appropriate hazard warnings (health, reactivity, flammability, PPE).

Pipes at IUPUI are labeled in the hospital and academic areas only if they contain a hazardous gas or chemical. Pipes that are unlabeled and insulated contain either steam, condensate, or water.

Shipping

Any employee offering or accepting international, interstate or intrastate transportation of hazardous materials shall be in accordance with the Department of Transportation 49 CFR 172.101.

Contractors on Campus

Contractors are required to provide IUPUI with a list of the hazardous chemicals they will bring to the job site. It is the responsibility of the University Architect's Office, Purchasing Department, or Campus Facilities Services shall be responsible for the following;

Requiring that information (including MSDSs) be provided to IUPUI on all chemicals to be utilized by the contractor in performance of his duties;

Providing EHS with the information on all chemicals to be utilized by the contractor;

Ensuring that contract work involving the use of hazardous chemicals in conducted in a manner to minimize potential exposure to IUPUI employees, students, or visitors;

No chemical shall be used by a contractor without prior approval of EHS.

Definitions

Chemical: Any element, chemical compound or mixture of elements obtained by a chemical process or used for producing a chemical effect.

Chemical Name: The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation.

Container: Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical.

Employee: A worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers who encounter hazardous chemicals only in non-routine, isolated instances are not included.

Foreseeable Emergency: Any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.

Hazardous Chemical: Any chemical which is a physical or health hazard.

Health Hazard: A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins (liver damage), nephrotoxins (kidney damage), neurotoxins (nervous system damage), agents which act on the hematopoietic system (decreases hemoglobin function), and agents which damage the lungs, skin, eyes, or mucous membranes.

Material Safety Data Sheet (MSDS): Written or printed material concerning a hazardous chemical which is prepared in accordance with 29 CFR 1910.1200 (g).

Permissible Exposure Limit (PEL): An exposure limit established and enforced by the Occupational Safety and Health Administration (OSHA) which may be expressed as a time-weighted average (TWA) limit, short term exposure limit (STEL), or ceiling exposure limit.

Physical Hazard: A chemical for which there is scientifically valid evidence that it is a combustible liquid, compressed gas, explosive, flammable, organic peroxide, oxidizer, pyrophoric, unstable (reactive), or water-reactive.

Work Area: A room or defined space in a workplace where hazardous chemicals are produced or used and where employees are present.