HAZARD COMMUNICATION PROGRAM INTRODUCTION HAZARD COMMUNICATION PROGRAM
Introduction
This manual constitutes the development of an institutional document for the Hazard Communication Program for the Department of Research laboratories, located in the Hawkins Building.
This manual is organized and contains six (6) important sections. The sections are as follows: a) Purpose of the Hazard Communication Standard b) Summary of the Standard c) Written Program d) Hazard Determination e) Labels f) MSDS Documents g) Education and Training
Each section attempts to fulfill a specific requirement of the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.
This document also provides the following information: 1) An inventory of hazardous chemicals found in each work area. 2) Information to laboratory and other staff about the chemical hazards associated with non- routine tasks. 3) Information to all laboratory and “associated staff” about the hazards of chemicals contained in the pipes. 4) Information supplied to “contracted vendors” or consultants about chemical hazards to which the employee(s) of the vendor or consultant may become or may be exposed to while performing work at the company facilities.
Accessibility
This document is available to all Charles Drew University Research laboratory staff or their associated staff upon request.
This document is also available to the Assistant Secretary for Occupational Safety and Health, and the Director of the National Institute for Occupational Safety and Health (NIOSH).
Employee Responsibility
It is the objective of Charles R. Drew University of Medicine and Science to ensure that all employees who handle hazardous chemicals be fully informed of the hazards involved and that they be trained to perform their jobs safely.
However, to accomplish this objective, the active participation of each laboratory employee and the associated staff is required and is essential to make the Hazard Communication Program a success.
PURPOSE OF THE HAZARD COMMUNICATION PROGRAM
It is the aim of the Charles R. Drew University of Medicine and Science to inform all laboratory staff about the hazardous substances they may encounter in the laboratories or associated workplace.
It is the intent of this institution that all laboratory staff shall recognize, familiarize, and learn the appropriate protective measures for working safely with potentially hazardous chemical substances.
This Hazard Communication document is intended to comply with the requirements of the OSHA Hazard Communication Standard 29 CFR 1910.1200. OSHA HAZARD COMMUNICATION STANDARD
This section contains a summary of the OSHA Hazard Communication Standard. This summary was prepared by OSHA and is entitled “Chemical Hazard Communication Standard”.
The purpose of including this section is to enable laboratory and other “associated staff” to develop a better understanding and to be more informed of the various requirements of the standard.
HAZARD COMMUNICATION STANDARD
Charles R. Drew University of Medicine and Science shall protect all laboratory and administrative staff from the dangers of hazardous chemicals.
This institution shall develop management systems which shall address chemical safety, chemical hazardous communication, emergency controls, occupational health and medical surveillance processes to ensure the safety of the research staff.
This institution affirms the fact that research staff has the “right to know” the specific name and type of chemicals that are stored and utilized in their respective laboratories, and the protective mechanism that shall be instituted to limit chemical exposure.
Laboratory Hazard Communication-Responsibility of Chemical Manufacturers
Chemical manufacturers shall provide this institution with the specific information which notifies investigators of the physical and health hazards of each chemical acquired or ordered. MSDS sheets shall be submitted by the manufacturers wit all ordered chemicals.
All chemical containers acquired for research purposes shall be appropriately labeled and inspected on its initial acquisition.
Responsibility of Charles R. Drew University
The Hazard Communication Program developed by this institution shall explain the implementation of this program to all laboratory staff.
This institution shall develop and utilize a central repository where all MSDS and pertinent chemical information shall be located and used as a source for recognizing, understanding, and research gathering on chemical safety.
It is the institution’s responsibility to develop safe chemical procedures when using and storing hazardous substances. The final responsibility of this institution is to provide chemical safety training on all hazardous chemicals.
Responsibility of Investigators and other Research Staff
It is the responsibility of the investigators and laboratory staff to recognize and read chemical labels and Material Safety Data Sheets (MSDS) to minimize the risk and exposure levels of chemical hazard.
CHEMICAL INFORMATION ON CONTAINERS
Policy
Chemicals ordered by laboratory investigators must be “shipped” in chemical containers with the specific labels, symbols and information that properly identifies the chemical. The container must have the specific chemical name of the substance on the container. The name, address, and emergency telephone number of the company that manufactured the chemical must be specifically stated on the container or on the MSDS.
The physical hazards of the chemical must be clearly stated. This shall include the reactivity, and the flammability of the chemical.
The health hazards shall also be noted on the container with specific information on its toxicity and its characteristic as an irritant.
Important storing, handling instructions, the personal protective equipment and procedures when working with this chemical should also be included.
All labels on chemical containers must be read before moving, handling, or opening any chemical container. In situations where labels are not on containers. DO NOT OPEN THE CONTAINER.
THE MSDS INFORMATION
Policy
The MSDS information concerning chemicals shall provide information of chemical and physical characteristics of the chemical, the safety procedures for handling and storage, and the emergency response process.
Each chemical ordered shall have a specific Material Safety Data Sheet. The Material Safety Date Sheets shall be divided into several sections including but not limited to: a. Identity b. Hazardous composition c. Physical and chemical characteristics d. Physical hazards e. Reactivity f. Health hazards g. Procedures and precautions for safe handling and use h. Control measures
Identity of Chemicals
The acquisition of any chemicals for laboratory research shall have the chemical name, the name and address and telephone number of the company that produces the chemical, and the MSDS date of issue.
The name of the chemical on the MSDS must be exactly as it is on the container.
Composition and Hazardous Ingredients
This lists the product’s individual hazardous chemicals and their relative percentages. The chemical abstract service number must also be listed and all hazardous components, chemical ID and common names. Worker exposure limits to the chemical, such as PEL and TLV limits shall also be included.
Physical and Chemical Characteristics
This information shall provide the physical and chemical characteristics of the chemical which shall include but not be limited to the boiling point, vapor pressure, vapor density, melting point, evaporation rate, water solubility and physical appearance under normal conditions. Physical Hazards
The physical hazards of the chemical are to be identified. It indicates the flammability, flash point and exposure. It identifies ways to handle these hazards which include fire equipment and other procedures.
Reactivity
Reactivity denotes the stability of the substance and provides information on the relative reactivity of the chemical substance. Implicit in this information is the level of compatibility of this chemical to other chemicals and is therefore indicative of how reactive this chemical is with other chemicals and the level of separation that must be employed in accordance with physiochemical principles to prevent a chemical reaction.
Health Hazards
The utilization of chemicals in the laboratories presents the potential for “overexposure”. There are several toutes of chemicals to the body. This fact is based on acute, subchronic and chronic studies.
The routes of exposure include but is not limited to inhalation, ingestion, skin, eye, and intraperitoneal. Included in the information is the LD50 levels which is used to establish the degree of hazard to humans.
Information, in the interest of laboratory staff, concerning the chemical carcinogenicity, tetratogenicity, neurotoxicity, mutagenicity and reproductive effects must be available.
Signs and symptoms of exposure to the chemical provides vital information in the event of “overexposure”. In the event of an emergency or accidents, first aid measures are also provided.
Procedures and Precaution for Safe Handling and Use of Chemicals
The precautionary measures that shall be utilized by laboratory staff to handle the chemical in the appropriate and safe way is prominently emphasized. The storage requirement and disposition procedures are also provided.
The precautionary measures, equipment and procedures employed to handle accidental release, chemical spills or leaks is also provided.
Exposure Control Measures
The exposure control measures employ engineering control measures to prevent statis electricity and sparks around chemicals used in the laboratory.
Ventilation systems that maintain and limit airborne levels or chemicals in the laboratory environment is provided.
Managerial controls which attempts to conduct periodic medical surveillance on exposed workers with emphasis on the skin, kidneys and respiratory system is provided.
The utilization of personal protective equipment (PPE) by laboratory staff to prevent or limit exposure to chemicals must be worn. The PPE used includes but is not limited to respirators, gloves, eye protection, and laboratory coats or jackets.
Disposition, Transportation and Regulatory Information
This provides disposition of chemicals used in the laboratories, and the transportation information required to be in compliance with DOT transportation requirements.
EPA regulations, RCRA and CERCLA regulations shall be followed in accordance with the guidelines so stipulated. Training
This institution shall provide the training in the Hazard Communication Program. This training shall enumerate the list of hazardous chemicals in each laboratory and the associated MSDS documents.
The labels and symbols of chemicals shall be emphasized as well as the procedures and equipment to handle hazardous substances safely.
Procedures to be Followed by all Laboratory Staff
1. All laboratory staff shall identify hazards before they commence a job. 2. Respect and take precautions at all times. 3. Any laboratory staff in doubt of a procedure should ask their respective supervisor. 4. Acquaint or familiarize yourself with all procedures prior to commencing any research protocol. 5. Identify staff members with whom you can communicate in the event of an emergency or in the event you need help. 6. Read all labels on chemical containers and Material Safety Date Sheets. 7. Familiarize yourself with procedure and where to find information about chemicals in your laboratory. 8. Follow all warning and instructions. 9. Use personal protective equipment when handling hazardous substances. 10. Learn and follow all emergency procedures. 11. Practice sensible, safe work habits at all times.
POLICIES AND REQUIREMENTS
Purpose
The purpose of this Hazard Communication Program is to develop, implement and maintain for the laboratories and “associated offices” a written communication program which describes the managerial systems and processes by which the hazard communication standard shall be implemented.
Policy A
This institution shall plan, develop and implement a labeling and warning system for all hazardous chemicals in the laboratories. This office shall develop a management system for managing the Material Safety Data Sheets (MSDS) and provide the employee an information and training system to ensure compliance with statutory requirements.
LABORATORY INVENTORY OF HAZARDOUS CHEMICALS
Policy B
This institution shall develop an inventory of all laboratory hazardous chemicals by utilizing an identification or classification system as specified in the Material Safety Data Sheets.
NON-ROUTINE TASKS/UNLABELED PIPES
Policy C
This institution shall also develop and implement managerial safety processes by which laboratory staff shall be informed of the hazards of non-routine tasks and the hazards associated with chemicals in unlabeled pipes in their respective laboratories. CONTRACT VENDOR EMPLOYEES OR CONSULTANT
Policy D
This institution shall provide and make available to all contract vendor employees or consultant(s) all pertinent MSDS documents.
This institution shall develop methods or make MSDS documents available at a central location in the Office of Research. These MSDS documents shall include but is not limited to the hazardous chemicals the contracted vendor employee(s) may be exposed to while working in the Drew University laboratories.
PRECAUTIONARY MEASURES
POLICY E
This institution shall develop managerial processes to inform the employee(s) of a contracted vendor of and precautionary measures that need to be exercised in order to protect employee(s) during the workplace’s normal operating conditions and in the event of any foreseeable emergencies.
LABELING INFORMATION
POLICY F
Charles R. Drew University of Medicine and Science shall utilize management systems to inform the employees of a contracted vendor of the labeling system used in the laboratories and the associated offices.
AVAILABILITY POLICY G
Charles R. Drew University of Medicine and Science shall make the written Hazard Communication Program available upon request to all laboratory staff and their designated representatives, the Assistant Secretary, and the Director, in accordance with the requirements of 29 CFR 1910.20 (E).
GOVERNANCE
The institutional Biohazard and Safety Committee shall have managerial independent oversight over the Hazard Communication Program.
The committee, in addition to this specific function, shall oversee the operational policies, procedures and the processes emanating from the Laboratory Operations Office, whose predominant function pertains to occupational health and biohazard safety. Accordingly, the Biohazard and Safety Committee shall view, oversee, review, modify, amend and recommend implementation of the operational processes pertaining to and emanating from the Occupational Health and Biohazard Program. ASSIGNED RESPONSIBILITIES ASSOCIATED WITH GENERAL INSTITUTIONAL POLICIES
The Right to Know: Research Biosafety Manager
Charles R. Drew University of Medicine and Science shall appoint and assign a “Research Right to Know Biosafety Manager” who shall be responsible for managing and coordination all activities pertaining to this program.
“The Right to Know” Biosafety Manager for the Research Office is:
______NAME DEPARTMENT
Labels, MSDS and Employee Training
Charles R. Drew University of Medicine and Science, Office of Research Programs for hazard determination, labels, MSDS and employee training are described in separate and subsequent sections of this manual under the respective subject headings.
The Right to Know: Research Biohazard Technician II
Charles R. Drew University of Medicine and Science shall appoint a staff who shall be responsible for evaluating MSDS and for developing a list of hazardous substances acquired and utilized within the research laboratories.
The staff person(s) responsible for this function (s) is:
Biohazard Technician II
______NAME
OR
Research Laboratory Safety Representative
______NAME
OR
Research Operations Department
______NAME
OR
Research Laboratory Investigator
______NAME The Right to Know: Hazards of Non-Routine Tasks and Unlabeled Pipes
The non-routine tasks involving the use of hazardous chemicals include the following: a. b. c. d. e. f.
Prior to performing non-routine tasks in the research laboratories, all research laboratory staff shall review with their respective supervisor the potential hazards of the task and the proper safety and handling procedures established by Charles R. Drew University research laboratories.
The Material Safety Data Sheets for each hazardous material used shall always be consulted, read, and understood prior to performing the task(s).
The employee’s supervisor shall be responsible for informing all staff on the hazards of materials used in non-routine tasks prior to performing the task(s).
Pipes Containing Hazardous Substances
All pipes containing hazardous substances shall be labeled. In addition, tags specifying the identity of the hazardous substance shall be affixed to exit points of the pipeline system.
The person responsible for labeling the pipes and exit valves is:
______NAME DEPARTMENT
A list of materials contained in the piping systems shall be developed by:
______NAME DEPARTMENT
Material Safety Date Sheets for those materials will be maintained in the work area and will be readily accessible to all research staff. Furthermore, during the education and training of research staff, hazardous materials contained in pipes shall be addressed.
CONTRACTED VENDOR INFORMATION
Policy
A contracted vendor shall provide Material Safety Data Sheets on all hazardous materials brought into Charles R. Drew University Office of Research laboratories during the performance oaf any contracted work. This information shall be provided to the Office of Laboratory Operations.
The contracted vendor shall inform Charles R. Drew University Office of Research about any precautionary measures that must be undertaken by Charles R. Drew University of Medicine and Science research staff during the performance of any contractual work on these premises. The contracted vendor shall be informed by Charles R. Drew University of Medicine and Science (PI of lab) about the hazards of materials in the labs where the contractor’s employee(s) will work.
The vendor shall be informed of the availability of this written Hazard Communication Program and the location of the MSDS documents in laboratories where the vendor employee(s) will be located.
All vendors shall acknowledge in writing the receipt of this information and his/her intent to disseminate the information to his/her employees.
Assigned Responsibility
The person responsible for implementing the outside contractor policies is:
______NAME DEPARTMENT
LABELING
Purpose
The purpose of labeling chemical containers in the research laboratories as well as chemical containers being shipped to other workplaces within the research building is to evaluate and transmit warning information concerning the use of hazardous chemicals in the laboratories.
Requirements of the Standard
Chemical Manufacturers
Policy A
Chemical manufacturers or distributors of hazardous chemicals shall ensure that each container of hazardous chemical that is ordered or purchased by the research laboratories is labeled or have the appropriate warning signs and symbols which is not in conflict with the Hazardous Materials Transporting Act.
The manufacturer shall provide the following information:
a. The identity of the hazards chemicals. b. The specific hazard warning. c. The name and address of the chemical manufacturers.
For specific OSHA regulated chemicals, the manufacturer and Charles R. Drew University of Medicine and Science shall ensure that the labels and warning symbols are in accordance with the OSHA Specific Standard.
No container will be accepted unless it is properly labeled with the required information. If a container is received without the required information, the manufacturer shall be notified to provide properly labeled containers. Charles R. Drew University
Policy B
Charles R. Drew University of Medicine and Science shall ensure that each container of hazardous chemicals in the laboratories are labeled with the following information:
1. The identity of the hazardous chemical in the container.
2. Hazard warning, signs, symbols or combination thereof which shall provide all laboratory staff and employees with information of the physical and health hazards associated with that specific hazardous chemical.
3. Placards and other written materials may be used on stationary to process containers instead of labels as long as this alternative method conveys the same warning information regarding the hazardous chemical. This written information, if applicable, shall be made available to all employees upon request.
Immediate Use Containers or Lab Transfer Containers
Policy C
All transfer containers used within company facilities shall be labeled with the following: a) Identity of the chemical and hazard warnings. Then if the contents of a transfer container are to be sued immediately by the same person who performed the transfer the container need not be labeled. However, transfer containers used between work shifts and/or by different workers must be labeled with the required information.
Existing Labels on Incoming Containers
Policy D
Charles R. Drew University of Medicine and Science shall not remove or destroy existing labels on incoming containers of hazardous chemicals unless the container is immediately marked with the required information.
English Labels
Policy E
This employer shall ensure that labels or other forms of warning are 1) legible, 2) written in English, 3) prominently displayed on the container, and 4) readily available in the laboratory area. Employees who speak other languages may add the label information in their language as long as the information is presented in English as well.
Existing Labels Policy F
Charles R. Drew University and the manufacturers are not required to affix new labels to comply with the labeling regulation if existing labels already convey the required information. Label Revisions
Policy G
Chemical manufacturers and/or Charles R. Drew University of Medicine and Science shall revise the labels for hazardous chemicals within three (3) months of becoming aware of new and significant information regarding the hazard of the chemical.
Labels on containers of hazardous chemicals shipped after that time shall contain the new information. In the event that the chemical is not currently produced or imported, the manufacturer and the employer shall add the information to the label before the chemical is shipped or introduced into the laboratory again.
Drugs
Policy H
Drugs which are dispensed or utilized in any research laboratory for direct administration to a patient or subject are exempted from this labeling.
LABELING
Goals
1. To ensure all acquired chemicals from manufacturers or vendors are labeled. 2. To identify each hazardous chemical(s) in the laboratories. 3. To develop a process by which hazard warning symbols remain affixed to all chemical containers. 4. To compile a list of the chemical manufacturers of all purchased chemicals for the research laboratories.
Objectives
1. To develop, monitor and implement on a monthly basis a labeling system for the acquisition of all laboratory chemicals. 2. To develop, and maintain on a monthly basis an information data base of all chemical manufacturers from whom chemicals are ordered. 3. To develop monitor and maintain an inventory list of all acquired laboratory chemicals.
Scope
This policy applies to all laboratory research staff, research administration, manufacturers of vendors of hazardous chemicals and all other research associated staff.
Procedures
1. Submit all purchase requisitions for ordered hazardous chemicals to the Procurement Office in the Research Department. 2. The Procurement Office shall submit an inventory form for approval by the Occupational Health and Safety Office (shall be processed within 30 minutes). 3. The approved order is then processed and submitted to the manufacturer by the Procurement Office. 4. The manufacturer shall ship the hazardous chemical directly to the laboratory. 5. On receipt of the hazardous chemical, the Biohazard Technician II (hazardous-chemical and radiation technician) shall be notified. 6. The Biohazard Technician II shall complete a chemical log receipt inventory form. 7. The Biohazard Technician II shall examine the outer and inner contents of the box to verify that there is no contamination or broken glass container. 8. The identity of the hazardous chemical shall be verified by the Biohazard Technician II. 9. The Biohazard Technician shall check and verify the presence on the container of all warning signs and symbols. 10. Labels shall be legibly written in English if there is another language beside it. 11. All labels shall be conspicuously placed on the container. 12. This technician shall obtain the MSDS package from the shipping documents and shall verify the absence or presence of the MSDS documents. 13. In the event that there are no MSDS documents, the technician shall notify the manufacturers and duly note the log accordingly. 14. Once the MSDS documents are available, the technician shall notify all laboratory staff of the physical and health hazards associated with the use of that hazardous chemical. 15. A copy of the MSDS document shall be placed in the institutional research MSDS centralized inventory. A copy shall be placed in the MSFS binder of the specific laboratory. 16. Existing labels on incoming hazardous containers shall be checked to verify that the labels have not been destroyed. 17. Revise and change all labels on chemical containers if new and significant information is obtained about a specific hazardous chemical. 18. All “drugs” ordered for use in the laboratories or vivarium must have appropriate labels with the specific signs and symbols. 19. Maintain an informational data base of manufacturers and hazardous chemicals.
RESPONSIBILITY
Charles R. Drew University
Charles R. Drew University of Medicine and Science is responsible for the following:
1. Advocating and implementing hazard communication policies and procedures. 2. Ensuring that the identity or name of all hazardous chemicals are affixed to the container. 3. Ensuring warning labels, signs and symbols are placed on all hazardous containers. 4. Providing centralized MSDS documents for all laboratory staff. 5. Revising and amending any new and significant changes regarding hazardous chemicals.
Principal Investigator and Laboratory Staff
It is the responsibility of all Principal Investigators and laboratory staff to follow the institutional and statutory guidelines as outlined in this section.
Principal Investigators and laboratory staff shall be responsible for the submission of all purchase requisitions for the acquisition of all hazardous chemicals. They are also responsible for storing and maintaining in a binder all MSDS documents pertaining to hazardous chemicals.
Chemical Manufacturers
The chemical manufacturer is responsible for the following:
1. Shipping hazardous chemicals that are labeled. 2. Ensuring that warning signs and symbols are affixed to the hazardous chemical containers. 3. Ensuring that the identity or name of the chemical is affixed to the container. 4. Providing the name and address of the chemical manufacturing division. 5. Providing warning signs that are legible, conspicuous and written in English. 6. Revising and submitting to this institution any new and significant information regarding any ordered or previously ordered hazardous chemical. Responsibility
The Biohazard Technician II shall be responsible for the following:
1. Complete the chemical log receipt inventory form. 2. Examine and report any contamination of the outer and inner contents of the “shipped” chemical container. 3. Identify the name of the hazardous chemicals and verify that appropriate warning symbols and signs are placed on a conspicuous part of the container. 4. Verify the presence of MSDS documents. 5. Notify all laboratory staff of the physical and health hazards associated with the use of the hazardous chemical. 6. Compile an inventory of all hazardous chemicals in each specific laboratory. 7. Revise and change all labels on chemical containers if new and significant information regarding a specific chemical is made available to the institution. 8. Maintain an informational data base regarding several aspects of hazardous chemicals utilized in the laboratories.
Responsibility for Labeling
The department and the name of the person responsible for ensuring that incoming containers are labeled with the required information is:
The Biohazard Technician II
______NAME
OR
The Safety Department
______NAME
OR
The Purchasing Department
______NAME
OR
Shipping and Receiving
______NAME
OR
Other Department
______NAME Responsibility
The person to notify if improperly labeled containers is:
______NAME DEPARTMENT
Responsibility
The person responsibility for ensuring that labels are affixed to transfer containers and other laboratory containers is:
The Biohazard Technician II
______NAME
OR
Principal Investigator
______NAME
OR
The Safety Department
______NAME
OR
Other
______NAME
Responsibility
The person responsible for providing the information to be noted on the laboratory labels is:
The Biohazard Technician II
______NAME
OR
Principal Investigator
______NAME
OR The Safety Department
______NAME
OR
Other
______NAME
The manufacturer shall be relied upon to provide the hazard ratings for each hazardous product or any new information to be included on the labels.
LABELING SYSTEM
The labeling system to be used on in-house containers throughout the Charles R. Drew University research laboratories is:
______HMIS
______CHIT
______NFPA
______Manufacturer supplied label
______Other (specify)
A description of this system is found at the end of this section.