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  Written Hazard Communication Program

Steve Lawton, OSHA Coordinator
Richard Hall, Associate Dean

August 12, 2002



Table of Contents
 
 

Section 1.0 Scope
Section 2.0 University Policy
Section 3.0 Responsibilities
Section 3.1 Office of Environmental Health and Safety
Section 3.2 The Administrative Unit
Section 3.3 Employees
Section 4.0 Hazard Determination
Section 5.0 Hazardous Chemical Inventory
Section 6.0 Labels and Other Forms of Warnings
Section 7.0 Material Safety Data Sheets (MSDS's)
Section 8.0 Training Requirements
Section 9.0 Method to Inform Employees of the Hazards  (Non-Routine Tasks)
Section 10.0 Contractors
Section 11.0 Written Program Availability and Review
 
 
Appendix A Hazard Communication Standard Appendix A
Appendix B Health and Safety Policy and Procedure Appendix B
Appendix C HAZCOM Inventory of Hazardous Products Appendix C
Appendix D Hazard Communication Labeling Systems Appendix D
Appendix E Hazard Communication Training Requirements Appendix E
Appendix F Hazard Communication Glossary Appendix F
Appendix G Abbreviations Index Appendix G
Appendix H Toxic Substances, CFR Part 1910, Subpart Z Appendix H
Appendix I Hazard Communication Program Review Statement Appendix  I

 




 
 

1.0  Scope

In order to comply with the Public Employment Risk Reduction Program (PERRP) (Ohio House Bill 308 - An Act) and the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard [29 CFR 1910.1200 (Appendix A)], the following written Hazard Communication Program has been developed by the Office of Environmental Health and Safety and modified for the College of Biological Sciences.  These laws are designed to protect University and contractor employees from the dangers associated with hazardous chemicals to which they maybe exposed at The Ohio State University.  This written program includes information on labeling, availability of Material Safety Data Sheets (MSDS's), employer and employee responsibilities and employee training.
 
 
 

2.0  University Policy

It is The Ohio State University policy (Appendix B) that all faculty, staff, student employees and contractor employees, who may come in contact with hazardous chemicals in the workplace, receive information concerning the particular hazards which the chemicals pose and methods by which they may deal with such chemicals in a safe manner.  In accordance with PERRP, The Ohio State University establishes a hazard communication program for all employees.
 
 
 

3.0  Responsibilities

This section discusses the responsibilities of the Office of Environmental Health and Safety, the administrative units, and employees.  The relevant sections of this program shall be reviewed by supervisors, employees and other individuals having responsibility for the non-laboratory use of hazardous chemicals.  Specific Hazard Communication Program responsibilities for the various groups include the following:
 

3.1  Office of Environmental Health and Safety
 

  • Provide a model written Hazard Communication Program for modification and adoption by administrative units.
  • Provide technical assistance to supervisors, workers and contractors concerning the appropriate storage, handling and disposal of hazardous substances.
  • Conduct internal audits for compliance with the Hazard Communication Standard.
  • Establish and maintain an MSDS system for use by University personnel.
  • Develop a generic Hazard Communication training program and work with administrative units concerning the program delivery.
3.2  The Administrative Unit
  • Maintain an administrative unit specific written Hazard Communication Program.
  • Maintain an inventory of the hazardous chemicals known to be present in the workplace.
  • Provide job specific training for employees and maintain training records.
  • Request assistance from the Office of Environmental Health and Safety as needed.
  • Ensure that all materials deemed hazardous under this Standard are labeled in accordance with this Standard.
  • Provide and maintain MSDS's for all hazardous chemicals within the operation.
3.3  Employees
  • Follow all health and safety standards, rules and policies.
  • Report all hazardous conditions to their supervisor.
  • Wear or use prescribed personal protective equipment.
  • Report any job-related injuries or illnesses to their supervisor and seek treatment immediately.
  • Refrain from the operation of any equipment or instrumentation without proper instruction or authorization.
  • Understand the dangers associated with hazardous substances in the workplace, as well as their safe and proper use.
  • Request information when unsure about handling procedures for a hazardous substance.
4.0  Hazard Determination

The University will primarily rely upon the safety and health related information found on labels and within the Material Safety Data Sheets (MSDS's) which are provided by manufacturers or suppliers of chemicals and chemical containing products.  The University will also use other information sources or references for determining the hazard potential of chemicals such as those references listed in the Hazard Communication  Standard (Appendix A).
 

5.0  Hazardous Chemical Inventory

A list of all hazardous chemicals or products containing hazardous chemicals known to be present in the work area will be maintained by the College of Biological Sciences. The instructions for completing the inventory list of hazardous chemicals or products are described in Appendix C.  The list of hazardous chemicals should be routinely reviewed to determine if the information is current.  Additions or deletions to the list shall be communicated by the administrative unit to all  affected employees and contractors.

The list of all hazardous chemicals will be kept in the following places:
 

  •  Safety Coordinator's Office  119 Biological Sciences
  •  College Administrative Office  103 Biological Sciences
  •  Department of Biochemistry  776 Biological Sciences
  •  Department of Entomology  103 Botany and Zoology
  •  Department of Microbiology  376 Biological Sciences
  •  Department of Molecular Genetics 984 Biological Sciences
  •  Department of Plant Biology  108 Botany and Zoology
  •  Department of EEOB   104 Botany and Zoology
  •  General Biology    104 General Biology Annex
  •  Museum of Biological Diversity 1100-1315 Kinnear Road
  •  Biological Sciences Woodshop  116 Biological Sciences
  •  Biological Sciences Greenhouse  704 Biosci Greenhouse
  • THE COLLEGE SAFETY WEB PAGE : FinalMSDSPage.htm

 
 
 
 
 

A copy of the hazardous chemical inventory will be conspicuously present in each location  inside The Right to Know Safety Book and will accessible to any employee or visitor at all times.

The following persons will be responsible to maintaining and updating the hazardous chemical inventory:
 

  •  Safety Coordinator's Office  Steve Lawton, OSHA Coordinator
  •  College Administrative Office  Nancy Tomei, Assistant to Dean
  •  Department of Biochemistry  Anita Rimmer, Administative Assistant
  •  Department of Entomology  Chris Edbrooke, Administative Assistant
  •  Department of Microbiology  Peggy Milliman-Wing, Administative Assistant
  •  Department of Molecular Genetics  Jessie Siegman, Administative Assistant
  •  Department of Plant Biology  Jill Hartman, Administative Assistant
  •  Department of EEOB   Cathy Drake, Administative Assistant
  •  General Biology    Jaynie Holt, Administative Assistant
  •  Museum  of Biological Diversity    Kathy Royer, Office Assistant
  •  Biological Sciences Woodshop  Dan Bland, Supervisor
  •  Biological Sciences Greenhouse  Joan Leonard, Supervisor

 
 
 

6.0  Labels and Other Forms of Warning

The Hazard Communication Standard requires that product containers inform employees about the physical and health hazards of the product.  The labels must also inform employees of appropriate protective equipment and body organs affected by over exposure. The description of acceptable hazardous chemical labeling systems is provided in Appendix D.  The College of Biological Sciences  will ensure the following:
 

  •  Labels for incoming chemical containers are not to be removed or defaced.
  • Hazardous chemicals transferred to another container for storage must be appropriately labeled (Appendix D).
  • Chemicals transferred to new containers must have the new container labeled as discussed previously.   Labeling is not required for portable containers into which hazardous chemicals have been transferred as long as the chemical transfer is intended for immediate use by the employee who performs the transfer.
Note:  Some chemicals may be exempted from the Hazard Communication Standard.  See Appendix A Section f.

No additional labeling system will be implemented.

The following persons will be responsible for ensuring proper and correct labeling in the College Academic Subuits:
 

  •  Safety Coordinator's Office  Steve Lawton, OSHA Coordinator
  •  College Administrative Office  Nancy Tomei, Assistant to Dean
  •  Department of Biochemistry  Anita Rimmer, Administative Assistant
  •  Department of Entomology  Chris Edbrooke, Administative Assistant
  •  Department of Microbiology  Peggy Milliman-Wing, Administative Assistant
  •  Department of Molecular Genetics Jessie Siegman, Administative Assistant
  •  Department of Plant Biology  Jill Williams, Administative Assistant
  •  Department of EEOB   Cathy Drake, Administative Assistant
  •  General Biology    Jaynie Holt, Administative Assistant
  •  Museum  of Biological Diversity    Kathy Royer, Office Assistant
  •  Biological Sciences Woodshop  Dan Bland, Supervisor
  •  Biological Sciences Greenhouse  Joan Leonard, Supervisor

 

7.0  Material Safety Data Sheets (MSDS's)

Material Safety Data Sheets (MSDS's) are written documents which are provided by manufacturers for each hazardous chemical or product that they produce, sell or distribute.  Chemical manufacturers and suppliers are mandated by law to provide the MSDS's along with their product to the customer or user.  The MSDS contains valuable information about the characteristics, safety and health hazards, protective measures and emergency response procedures for the hazardous chemical or product.  The College of Biological Sciences must maintain a current file of MSDS's for all products containing hazardous chemicals as listed in the inventory.  The MSDS's shall be readily accessible to University employees and University contractors.  The Office of Environmental Health and Safety will provide assistance to the departments in obtaining MSDS's.  MSDS's must be completed by the individual(s), who synthesize chemicals that are transferred outside the group or unit.

The list of MSDS's will be kept in the following places:
 

  •  Safety Coordinator's Office  119 Biological Sciences
  •  College Administrative Office  103 Biological Sciences
  •  Department of Biochemistry  776 Biological Sciences
  •  Department of Entomology  103 Botany and Zoology
  •  Department of Microbiology  376 Biological Sciences
  •  Department of Molecular Genetics 984 Biological Sciences
  •  Department of Plant Biology  108 Botany and Zoology
  •  Department of EEOB   104 Botany and Zoology
  •  General Biology    104 General Biology Annex
  •  Museum of Biological Diversity 1100-1315 Kinnear Road
  •  Biological Sciences Woodshop  116 Biological Sciences
  •  Biological Sciences Greenhouse  704 Biosci Greenhouse
  •  THE COLLEGE SAFETY WEB PAGE : FinalMSDSPage.htm

 
 
 
 

A copy of all MSDS's will be conspicuously present in each location  inside The Right to Know Safety Book and will accessible to any employee or visitor at all times.

The following persons will be responsible to maintaining and updating the MSDS  inventory:
 

  •  Safety Coordinator's Office  Steve Lawton, OSHA Coordinator
  •  College Administrative Office  Nancy Tomei, Assistant to Dean
  •  Department of Biochemistry  Anita Rimmer, Administative Assistant
  •  Department of Entomology  Chris Edbrooke, Administative Assistant
  •  Department of Microbiology  Peggy Milliman-Wing, Administative Assistant
  •  Department of Molecular Genetics Jessie Siegman, Administative Assistant
  •  Department of Plant Biology  Jill Williams, Administative Assistant
  •  Department of EEOB   Cathy Drake, Administative Assistant
  •  General Biology    Jaynie Holt, Administative Assistant
  •  Ohio Biological Survey   Barbara Fate, Administative Assistant
  •  Biological Sciences Woodshop  Dan Bland, Supervisor
  •  Biological Sciences Greenhouse  Joan Leonard, Supervisor
If there are individual(s) in the administrative unit who synthesize chemicals that are transferred outside the administrative, a MSDS must be completed.  A copy of a blank MSDS and instructions can be obtained from The Office of Environmental Health and Safety.
 
 
 

8.0  Training Requirements

The College of Biological Sciences will be responsible for informing and training their employees about hazardous chemicals used in the workplace.  This information and training must be provided to employees at the time of the initial assignment to the work area.  Additional instruction will be provided whenever a new chemical hazard is introduced to the work area.  Appendix E outlines the information that must be included in the generic and specific Hazard Communication training.
 

  • Generic Hazard Communication instruction and training includes the following:
  • A discussion of the Hazard Communication Standard and its key elements.  This includes an explanation of: definitions (Appendix F), and abbreviations of key terms (Appendix G), and permissible exposure limit (PEL) information (Appendix H).
  • An explanation of the information within MSDS’s.
  • A description of the health and physical hazards posed by chemicals.
  • Safe operating procedures and personal protective equipment to be used for  various chemical hazard classes.
  • The methods for detecting and identifying the presence of a hazardous chemical in the work area.
  • The emergency procedures to be followed in case of chemical spills, fires and other incidents.
  • The measures (i.e., safe work practices, emergency procedures, and spill control) that employees can take to protect themselves from work place hazards.
The College of Biological Sciences OSHA Coordinator will be responsible for OSHA generic training for all employees.
 
 

Specific Hazard Communication instruction and training includes:

  • The location and availability of the department administrative unit's written Hazard Communication Program.
  • The location and accessibility of MSDS's for the hazardous chemicals known to be present in the work area.
  • The specific physical and health hazards of the chemicals known to be present in the work area.  This would include a discussion of the physical and chemical characteristics of these substances, as well as target organ systems.
  • Any operations where hazardous chemicals are present.
  • The location and availability of the inventory of hazardous chemicals  known to be present  in the work place.
The College of Biological Sciences OSHA Coordinator, Steve Lawton, will be responsible for OSHA specific training for all employees.

The College of Biological Sciences OSHA Coordinator, Steve Lawton, is responsible  for  ensuring that new, transferred or employees returning from long leaves receive training on both generic and job specific Hazard Communication information.

The College of Biological Sciences OSHA Coordinator, Steve Lawton, is responsible  for training affected employees when a change of hazard(s) or information occurs in their work area.

Employees are to be informed of any new information concerning potential hazards as it becomes available.  The College of Biological Sciences is responsible for documenting all generic, specific and follow-up training.  The documentation will include the date, time, location, subject material, attendance lists of all participants and names of instructors.

The College of Biological Sciences OSHA Coordinator will maintain, review and update the records of generic and specific Hazard Communication training and those logs will be available in Room 119 Biological Sciences.
 
 

9.0  Employee Hazard Awareness - Non-Routine Tasks

It is the responsibility of the College of Biological Sciences and the immediate supervisor to ensure that their employees are informed about the hazards of non-routine tasks, as well as the protective measures that should be followed to reduce exposure.  Special written operating procedures are to be developed for internal use when necessary.
 

10.0  Contractors

It is the responsibility of the University through the College of Biological Sciences to inform contractors about potentially hazardous chemicals or operations that may threaten the health and safety of contract employees.  Furthermore, it is the responsibility of project captains, administrators, supervisors or research investigators that have authority for controlling the work area or operation to inform the contractors of these hazards.  A list of known chemicals, precautions and procedures to be followed must be communicated to the contractor.  Administrative Unit MSDS's must be available to contractors.

The College of Biological Sciences OSHA Coordinator and the administrator of the academic subunit involved are responsible for ensuring that information about hazardous materials utilized in the administrative unit will be communicated to contractors.

The contractor must maintain MSDS's for hazardous chemicals utilized during the course of their work.  They must have them readily available upon request to the contractor employees, University Employees, or government officials.  The project captains or persons responsible for the construction or renovation work are responsible for forwarding the name and phone number of the contact employee responsible for maintaining contractor MSDS's to the Office of Environmental Health and Safety.

11.0  Hazard Communication Program Availability and Review

The written Hazard Communication Program, which includes the hazardous chemical inventory and MSDS's is to be made available to employees, employee designated representative(s), contractors, and regulatory officials upon request.  The written Hazard Communication Program should be reviewed and updated at least annually using the review document included in Appendix I.

Copies of The College of Biological Sciences Written Hazard Communication Plan will be kept in the following places:
 

  •  Safety Coordinator's Office  119 Biological Sciences
  •  College Administrative Office  103 Biological Sciences
  •  Department of Biochemistry  776 Biological Sciences
  •  Department of Entomology  103 Botany and Zoology
  •  Department of Microbiology  376 Biological Sciences
  •  Department of Molecular Genetics 984 Biological Sciences
  •  Department of Plant Biology  108 Botany and Zoology
  •  Department of EEOB   104 Botany and Zoology
  •  General Biology    104 General Biology Annex
  •  Museum of Biological Diversity 1100-1315 Kinnear Road
  •  Biological Sciences Woodshop  116 Biological Sciences
  •  Biological Sciences Greenhouse  704 Biosci Greenhouse
  • THE COLLEGE SAFETY WEB PAGE : safety/OfficeSafety.htm
A copy of the Written Hazard Communication Plan will be conspicuously present in each location inside The Right to Know Safety Book and will accessible to any employee or visitor at all times.

The College OSHA Coordinator, Steve Lawton, will be responsible for maintaining and updating the Written Hazard Communication Plan on an annual basis, to be reviewed by Richard W. Hall, Associate Dean.