10.02 / Hazard Communication Program

Policy

It is the policy of Wichita State University to promote safety and prevent employee health problems associated with exposure to and use¹ of hazardous materials including chemicals, radioactive material, and biological agents in the workplace. The University will use the "Hazard Communication Standard," 29 CFR Part 1910.1200, from the Occupational Safety and Health Administration (OSHA) as the guide to assure every effort is made to reduce the incidence of illness and/or injury caused by hazardous materials. A copy of the OSHA standard is available in the Environmental Health and Safety Office. The WSU Hazardous Communication Program is to inform employees of the hazards and identifies of chemical, radioactive, and biological materials to which they may be exposed in the workplace and of the protective measures available.

¹ Use is defined as "to package, handle, react, or transfer."

Components

The program contains detailed policy on container labeling, chemical inventory, and material safety data sheet (MSDS) information. Also included are provisions for employee hazard communication training, hazards of nonroutine tasks, hazards of chemicals in unlabeled pipes, and communication of hazards to outside contractors.

Employees Affected

It is recognized that many physical plant operations, research laboratories, and other essential work areas frequently require the use of materials which have potentially hazardous properties. When using these substances, it is important that all employees who use or may be exposed to them are aware of the identity and toxicity or other hazardous properties of the material.

Availability

The Hazard Communication Program is available to all Wichita State University employees, their designated representatives, the Assistant Secretary of Labor for Occupational Safety and Health Administration (OSHA), and the Director of the National Institute for Occupational Safety and Health (NIOSH).

Hazard Communication Program

1. Hazard Determination

   1. Any substance listed in 29 CFR 1910, Subpart Z, Toxic and Hazardous Substances; the Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment published by the American Conference of Governmental Industrial Hygienist (ACGIH), the Annual Report on Carcinogens published by the National Toxicology Program (NTP); or Monographs published by the International Agency for Research on Cancer (IARC) will be considered hazardous.

   2. Any human epidemiological study, individual case report, or toxicological testing which indicated that a material presents a health hazard will be considered hazardous provided that the study indicated an adverse health effect that is likely occur, that the results are statistically significant, and that the study was conducted in accordance with scientific principles.

2. Labeling System for Hazardous Materials

   1. Container labels must be legible. Labels that are illegible, defaced, or missing shall be replaced immediately.

   2. Each container of a hazardous material in the workplace shall be prominently labeled in English and must include:

      1. Name of the substance as corresponds to its material safety data sheet;
      2. Identity of the chemical contained within;
      3. Identity of primary hazard associated with the material;
      4. Appropriate hazard warnings.

   3. No employee shall remove any label unless specifically directed to do so by a supervisor. Any container without a label should be reported immediately to the work area supervisor.

   4. In situations involving individual stationary process containers, the label may be replaced by a sign, placard, process sheet, batch ticket, or other means to convey the warnings.

   5. Containers designated for washing or rinsing of hazardous material must be appropriately labeled.

   6. If the hazardous chemical is regulated by OSHA as a substance-specific health hazard, the label used will be in accordance with the requirements of that standard.

   7. Labels are not needed for:

      1. Portable containers of hazardous materials intended for immediate use by the employee who performs that transfer.
      2. Pipes or piping systems.

3. Material Safety Data Sheets (MSDS's)

   1. Wichita State University does not commercially produce or generate hazardous chemicals; therefore, MSDS's for hazardous materials on campus are furnished solely by outside vendors.

   2. The most current MSDS supplied by the chemical manufacturer, importer, or distributor for each hazardous chemical known to be present at Wichita State University is maintained by the Environmental Health and Safety Office. MSDS's are accessible to all employees, their designated representatives, the Assistant Secretary of Labor for Occupational Safety and Health, and the Director of the National Institute for Occupational Safety and Health (NIOSH).

   3. MSDS stations containing MSDS's for particular work areas are maintained by departments with assistance from the Environmental Health and Safety Office. These stations are accessible during each work shift to employees who frequently use or are exposed to chemicals.

   4. If new and significant information comes to light about any hazardous material used on campus, a revised material safety data sheet will be obtained and the employees who use the material notified.

   5. No hazardous material will be used in the workplaces unless a MSDS has been obtained and is on file in the work area. A waiver to this requirement may be granted by the Environmental Health and Safety Office if a MSDS for a similar material is on file and readily accessible to the department using the chemical.

   6. In a work area where it is more appropriate to address the hazards of the process rather than individual hazardous chemicals, material safety data sheets may be kept in the form of operating procedures and may be designed to cover groups of hazardous chemicals.

   7. When ordering new hazardous chemicals, the purchaser must ensure that the words "Hazardous: MSDS Required" are included in bold letters in the description block of the purchase request.

4. Employee Information and Training

   1. Employee information and training are primarily provided by the Environmental Health and Safety Office and employee supervisors.

   2. Training will be renewed annually, at minimum, for all employees who use or are exposed to hazardous materials.

   3. Initial hazard communication training is required for all employees during new employee orientation sessions. This training includes:

      1. Introduction to the Hazard Communication Program and Chemical Hygiene Plan and their requirements.
      2. Presence of hazardous materials on campus
      3. Types of hazards
      4. Potential exposure and risks
      5. Labeling and warning systems on packages and containers
      6. Locations and availability of Material Safety Data Sheets
      7. Safety controls
      8. Emergency and safety resources

   4. Additional training for employees who are frequently exposed to hazardous materials is required. Current training programs available from the Environmental Health and Safety Office provide for:

      1. Understanding material safety data sheets
      2. Trade secret provisions
      3. Handling hazardous chemicals
      4. Detecting the presence or release of hazardous chemicals
      5. Physical and health hazards of materials
      6. Symptoms of exposure to hazardous materials
      7. Personal protective equipment and its use
      8. Proper action in case of a chemical splash, spill, or other emergency
      9. Engineering controls
      10. Use of radioactive material
      11. Laboratory safety
      12. Chemical fume hood and biological safety cabinet use

   5. On-the-job training is provided for employees who frequently use or are exposed to hazardous materials by department supervisors. This training includes:

      1. Standard safety procedures and personal protective equipment needed for each assigned task.
      2. Procedures to be used during nonroutine operations.
      3. Potential for exposure to chemicals present in the work area including chemicals in unlabeled pipes.
      4. The location and availability of the written Hazard Communication program, list of hazardous chemicals, and MSDS station.
      5. Emergency procedures

   6. New training programs are developed to meet the needs of employee groups as needed.

5. Outside Contractors

   1. As part of any contractual arrangement between an outside contractor and Wichita State University, the contractor must list all hazardous chemicals that are to be used by his employees in the course of their work on WSU property.

   2. Prior to beginning work on WSU property, all contractors will be given a copy of the University's Hazard Communication Program. The particular hazards associated with the work area(s) will be identified. Material safety data sheets for relevant hazardous chemicals will be provided to the contractor.

6. Responsibilities

   1. Administration

      1. Supports and implements policy to protect the health and safety of Wichita State University employees.
      2. Ensures compliance with current federal, state, local, and institutional regulations.

   2. University Safety Committee

      1. Monitors institutional compliance with Hazard Communication Program requirements.
      2. Receives and investigates complaints related to safety issues and prepares recommendations for complaint resolution.
      3. Serves as a campus resource for information promoting safety in the workplace.
      4. Assists in employee training sessions as needed.
      5. Identifies and supports methods to achieve more effective worker protection and reduce the occurrence of illnesses, injuries, and fatalities due to chemical mishandling and exposure.

   3. Environmental Health and Safety

      1. Monitors federal, state, and local regulations concerning hazardous materials and recommends action.
      2. Monitors institutional compliance with Hazard Communication Program requirements.
      3. Maintains material safety data sheets for every hazardous chemical known to be used on campus.
      4. Trains employees and maintains records of training.
      5. Receives and investigates complaints relating to hazardous materials.
      6. Assists departments in all aspects of Hazard Communication Program implementation.
      7. Identifies work areas in need of more effective worker protection including engineering controls, monitoring, personal protective equipment, etc., and prepares recommendations for improvement.
      8. Maintains and provides safety information on all hazardous materials including chemicals, biological agents, and radioactive material.
      9. Recommends safe alternatives for hazardous materials.

   4. Office of Purchasing

      1. Provides outside contractors with copies of the Wichita State University Hazard Communication Program and relevant material safety data sheets with assistance of the Environmental Health and Safety Office.
      2. Reviews purchase requests for hazardous materials.
      3. Identifies means to reduce the amount of hazardous materials purchased by the institution.
      4. Prepares bids and contracts which comply with all federal, state, local, and institutional regulations concerning hazardous material testing, monitoring, removal, etc.

   5. Department Supervisors and Chairs

      1. Effectively implement all aspects of the Hazard Communication Program in the work area.
      2. Ensure all hazardous chemicals in the work area have material safety data sheets and are available during all work periods to employees who frequently use or are exposed to these materials.
      3. Provide appropriate on-the-job training.
      4. Identify work areas in need of more effective worker protection and prepare recommendations for improvement.

   6. Employee

      1. Is alert to and understands the potential hazards of materials in the work areas.
      2. Consults material safety data sheets and other relevant sources or information concerning hazardous materials with which he or she works.
      3. Follows appropriate work practices.
      4. Identifies work areas in need of more effective worker protection and brings to supervisor's attention.