Hazard Communications Plan - Safety and Security Policy - 70210

1. Purpose

  1. To establish guidelines and policies to make Germanna Community College employees aware of chemical hazards to which they may be exposed and methods to help protect them while handling and using chemicals.
  2. To establish procedures to be used by employees and students when responding to an event, whether it is a chemical spill or injury.
  3. The Hazard Communication Plan is a living document designed to educate employees and students on the procedures to follow if there is an accident in the lab.

2. Policy

  1. This plan implements work practices to ensure employees are properly trained to deal with chemical hazards, outlines the responsibilities of those involved in ensuring a workplace free of chemical hazards, and outlines the proper handling, storage, and labeling of chemicals. This document applies to all employees at Germanna Community College and should be used in conjunction with the Chemical Hygiene Plan.

3. Definitions

  1. Chemical: means any substance, or mixture of substances.
  2. Container: means any bag, barrel, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical.
  3. Exposure or exposed: means that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, and includes potential (e.g. accidental or possible) exposure. “Subjected” in terms of health hazards includes any route of entry (e.g. inhalation, ingestion, skin contact or absorption.)
  4. Hazardous chemical: means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
  5. Health hazard: a chemical for which there is 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 persons. The term includes chemicals that are carcinogenic, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, or agents that damage the lungs, skin, eyes, mucous membranes, liver, kidneys or other target organs.
  6. Mixture: means a combination or a solution composed of two or more substances in which they do not react.
  7. Physical hazard: a chemical for which there is scientifically valid evidence that it is a corrosive, an oxidizer, a combustible liquid, a compressed gas, an explosive, a flammable, an organic peroxide, and unstable (reactive) or water reactive. This hazard information is available from labels and SDS.
  8. Safety Data Sheet (SDS): means written or printed material concerning a hazardous chemical.

4. Responsibilities

  1. College administration
    1. Responsible for supporting those actions necessary to meet and maintain compliance with regulations governing hazardous chemicals.
  2. Safety and Security Manager (Chief of Police)
    1. Receive updated chemical inventories from all applicable departments.
    2. Distribute chemical inventories to outside first responders.
    3. Coordinate with outside first response in the event of a chemical hazard emergency.
  3. Laboratory managers and technicians
    1. Ensure that written chemical inventories are updated and accessible in every area where hazardous chemicals are used.
    2. Supply updated versions of the chemical inventory to the Safety and Security Manager (Chief of Police) every year.
    3. Supply all student workers with the Chemical Hygiene Plan and Hazard Communication Plan to review and ensure they have received adequate training for handling hazardous chemicals.
    4. For every hazardous chemical that is ordered, an updated SDS sheet must be available.  SDS sheets must be kept up to date and be accessible to all who use the applicable hazardous chemical.
    5. Ensure that all chemical containers are labeled according to the OSHA Hazard Communication Standard (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200) and properly stored.
    6. Update the College’s Hazard Communication Plan and notify the appropriate parties that this has been done.
  4. Instructional faculty, students, and all other employees using hazardous chemicals
    1. The right to receive information on OSHA hazard communication training and to receive that training if desired.
    2. Know the location of the Chemical Hygiene Plan and Hazard Communication Plan and be familiar with these materials.
    3. Know the location of the Safety Data Sheets for all hazardous chemicals that may be used.
    4. Follow correct procedures for use and handling of hazardous chemicals.

5. Procedures

  1. Hazardous Materials Inventory
    1. All hazardous chemicals must be listed in the inventory to include: pipes, storage tanks, bottles, boxes, and other individual containers.
    2. The inventory must follow a consistent format, to include: the chemical’s name, CAS# (where available), amount of chemical typically present, location of chemical (building and room number), and the responsible department or work unit.
    3. The inventory must be typed, accessible to all employees or students who will be working with the chemicals, updated regularly, and submitted to the Chief of Police at a minimum of once per year.
    4. The following departments should maintain inventories if hazardous materials are present: Facilities management, art department, science department, nursing and dental hygiene labs, automotive repair workshops and labs, carpentry workshops and labs.
  2. Containers
    1. All containers arriving at a facility must be labeled with: chemical or common name, all appropriate hazard warnings, name and address of chemical manufacturer/supplier.
    2. Any chemicals removed from the original container must be placed in a container that is labeled with the chemical name and any hazard warnings.
    3. Chemicals that are being actively used by an employee may be transferred to unlabeled containers for short periods of time, but at no point are the containers to be left unattended and unlabeled.
    4. Update all labels as necessary to reflect changing hazardous characteristics.
  3. Non-routine tasks
    1. Employees may occasionally be asked to perform hazardous non-routine tasks.  Before beginning the task the employee should educate themselves on the risks and hazards associated with the task.  They should think about any protective and safety measures that should be implemented.

6. Chemicals

  1. Any food products, drug or cosmetic materials, alcoholic beverages, tobacco products, wood or wood products, any commercially purchased products, any product that does not result in the release or exposure of a hazardous chemical, and any products brought to campus by employees for personal consumption are exempt from the Hazard Communication Standard.
  2. All chemicals must have an up to date Safety Data Sheet (SDS) that is accessible to anyone who might come in contact with the chemical.
  3. If an employee or student is exposed to a hazardous chemical, exposure records, incident report, and SDS records must be retained for 30 years past the duration of the exposed employee’s employment or exposed student’s graduation date.

7. Training

  1. All employees are required to receive chemical hazard training.
    1. Follow the procedure for chemical hazard training as outlined in the Chemical Hygiene Plan.
  2. All employees should be made aware of the Chemical Hygiene Plan and Hazard Communication Plan and should read both plans.
  3. Employees should familiarize themselves with the OSHA Hazard Communication Standard.
  4. Container labeling, use and interpretation of SDS, and methods to detect and respond to the presence of a hazardous material in the workplace are all subjects that should be included in the initial training and reviewed regularly.
  5. All employees should keep records of training and any certification certificates they receive.

8. Non-college personnel

  1. Responsibilities of the college
    1. To make available all information regarding any hazardous substances that the non-college personnel may be exposed to and the precautions they can take to protect themselves.
    2. To notify the Chief of Police when non-college personnel will be on campus.
    3. To notify the Facilities Manager when non-college personnel will be on campus and the services they will be performing.
  2. Contractors
    1. Contractors must be made aware of:
      1. Potentially hazardous substances to which the contractor(s) may be exposed.
      2. Precautions the contractor(s) should take to lessen the possibility of exposure.
      3. The college personnel that should be contacted in the event of an accident.
    2. Responsibilities
      1. To notify the Chief of Police, Facilities Manager, and any other involved party of any hazardous chemical that they are bringing onto college property.
      2. To remove all hazardous chemicals brought onto college property or generated on college property by the contractor.
  3. Renting a lab room
    1. Anyone wishing to rent a lab room must follow the rules outlined in the Lab Room Rental Guidelines.

9. References

  1. OSHA 29 CFR 1910.1200 Hazard Communication
  2. Carnegie Mellon University Hazard Communication Program, November 2021

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