HAZARD COMMUNICATION PROGRAM
New York State
Agricultural Experiment Station
Environmental Health & Safety
G-18 Food Science Research Laboratory
Geneva, New York 14456
Telephone (315) 787 - 2466
April 5, 1999
HAZARD COMMUNICATION PROGRAM
INTRODUCTION TO THE HAZARD COMMUNICATION PROGRAM
Policy
NYS Agricultural Experiment Station Employees have a right to know about the hazardous chemicals that they work with or could be exposed to, and what they can do to avoid injury or illness when working with these chemicals. Department of Environmental Health & Safety provide information and training in order to reduce the possibility of accidental exposure and to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.
Purpose
The OSHA Hazard Communication Standard (29CFR 1910.1200) requires that all Employers develop and implement a written hazard communication program. This program describes how the OSHA Hazard Communication Standard requirements are met at the Station.
The purpose of this program is to ensure that:2) All chemical hazards are evaluated.
3) All hazardous chemicals used in the work place are labeled, and a list of chemicals is available.
4) Material Safety Data Sheets (MSDSs) are available for all hazardous chemicals.
5) Employees receive information and training so that they are informed of the requirements of the standard and are trained about chemical hazards in their work place.
6) All persons involved in non-routine work tasks are informed of the hazards of such tasks.
7) Contractors and their Employees will be informed of chemical hazards before performing work in our facility; and sub-contractors will inform us of any hazardous materials brought into our facility.
SUMMARY OF HAZARD COMMUNICATION REQUIREMENTS
Employees Covered
The hazard communication program applies to Employees who are exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. A review of all Employee positions at the Geneva Station has been conducted to determine which departments and Employees have occupational exposure to hazardous materials during the performance of their duties. This program does not apply to laboratory settings except as listed under Special Exemptions and Provisions on page 5.
Listed below are some examples of Department/Units and working titles that may have potential exposure to hazardous chemicals.
DEPARTMENT/UNIT |
WORKING TITLE |
Buildings & Properties |
|
Communication Services |
|
Entomology |
|
Field Research Unit |
|
Food Science Technology |
|
Horticultural Science |
|
Plant Pathology |
|
Chemicals Covered
Hazardous chemicals are defined as those materials which possess either a physical and/or health hazard.
Major Requirements
- Chemical inventory - prepared according to work area and available to Employees.
- MSDS collections - prepared according to work area and available to Employees. A complete set is maintained by Geneva Environmental Health and Safety (EH&S).
- Provide Employees with information and training.
- Coordination of information exchanges with other employers in multi-employer workplaces.
Special Exemptions and Provisions
The law has special provisions for certain specific situations. These special situations are:
1. Laboratories
Although laboratories Employees are covered by the OSHA Occupational Exposure to Hazardous Work in Laboratories the following aspects of the Hazard Communication Program will apply:
a. Labels on incoming containers are not to be removed or defaced.
b. Material safety data sheets that are received with products must be maintained and are available to laboratory personnel.
c. Employees will be apprised of the hazards of the chemicals through an appropriate information and training program.
2. Sealed Containers
Operations such as warehousing or materials management, where Employees handle only sealed containers are exempt. However the following aspects of the Hazard Communication Program will apply:
a. Labels on incoming containers are not to be removed or defaced.
b. MSDSs that are received with incoming containers must be kept and maintained.
c. If requested by Employees, MSDSs must be obtained.
d. MSDSs must be accessible to Employees.
e. NYS Agricultural Experiment Station will provide an information and training program sufficient to protect Employees from hazards presented by the contents of sealed containers should they spill or leak.
3. Non-routine Tasks
This section applies to jobs that are not performed on a routine basis and may involve contact with a hazardous chemical (example: cleaning out a chemical holding tank, cleaning out a boiler, working on unlabeled pipes).
Project Leader, Shop Foreman and/or Supervisor will determine what chemical hazards are present or may be created by the task. The Project Leader, Shop Foremen and/or Supervisors are responsible for communicating information to Employees. Employees will be informed of the hazards presented by the non-routine task.
HAZARD COMMUNICATION PROGRAM
Components
There are three major components of the NYS Agricultural Experiment Station's Hazard Communication program:
- This written document
- Hazardous Chemical Inventory Lists
- Material Safety Data Sheets
Each department affected by the Hazard Communication Standard develops and maintains their own customized chemical inventory list and collection of MSDSs based on their particular needs. These documents are incorporated in a binder, labeled Hazard Communication Program.
Location
The Hazard Communication Program binder is available to Employees at the following locations:
- Department or section office
- Geneva Environmental Health & Safety, G-18 Food Science Research Laboratory
- Station's Heating Plant, where it is accessible on a 24-hour basis
HAZARDOUS CHEMICAL INVENTORY LISTS
The department Project Leader, Shop Foreman and/or Supervisors will keep their department or section's Hazardous Chemical List up-to-date. Anyone who orders chemicals shall immediately notify the appropriate Project Leader, Shop Foreman and/or Supervisors that a new chemical has been purchased.
MATERIAL SAFETY DATA SHEETS
The Project Leader, Shop Foreman and/or Supervisors will obtain the MSDS for every chemical listed on their Hazardous Chemical List.
Obtaining MSDSs
Most often a chemical shipment is preceded or accompanied by an MSDS. If not, MSDSs can be obtained from:
1. The following World Wide Web sites,
2. Directly requested from the manufacturer
[Note: chemical manufacturers, importers and distributors do not need to provide material safety data sheets to retail operations which have informed them that the retail distributor does not sell the product to commercial customers, or it does not open the sealed containers on their premises.]
3. Geneva Environmental Health & Safety. G-18 Food Science Research Laboratory, extension 466.
Distribution of MSDSs
When a new or revised MSDS is received by the department Project Leader, Shop Foreman and/or Supervisors, copies will be placed in their Hazard Communication Program binder. The old MSDS shall not be removed or discarded until all supplies of current inventory are used.
A copy of every MSDS, especially new or revised, must be forwarded to EH&S, G-18 Food Science Research Laboratory. If an MSDS is first received by Geneva EH&S, copies will be made for their files and the original sent to the user's Project Leader, Shop Foreman and/or Supervisors for filing in their Hazard Communication Program Binder.
Employee Requests for MSDSs
Employees are strongly encouraged to review these Material Safety Data Sheets.
Additional copies of any MSDS must be readily available to any Employee upon their request. Any Employee, at any time, may request an MSDS from Station Heating Plant, extension 499.
LABELS AND OTHER FORMS OF WARNING
General Requirements
Chemical manufacturers, importers, and distributors are required to label all containers of hazardous chemicals. The labels, tags, or markings must include:
1. Identity of the hazardous chemical
2. Name and address of the manufacturer, importer, or other responsible party
3. Appropriate hazard warnings including: health hazards, physical hazards, target organs and effects, and personal protective equipment required
All hazardous material containers delivered to the work place must have appropriate labels. If a container is not labeled, then a request will be sent to the manufacturer for a proper label by the Supervisor, project leader and/or shop foreman.
Labels on incoming containers of hazardous materials shall not be removed or defaced.
Solid Metal
Suppliers of solid metal materials that may emit hazardous substances when worked upon are required to supply labels with the first shipment of that material.
In-house Labeling System
When materials are transferred from a labeled container to another container, the receiving container must be labeled. Any labels developed in-house will derive their information from the labels of the incoming containers and the Material Safety Data Sheets. It will be the responsibility of transferor to determine which information provided on the material safety data sheets and labels of the incoming containers is to be transferred to in-house labels (see Labels and Other Forms of Warning, General Requirements).
Labeling of Portable Containers
Portable containers into which hazardous chemicals have been transferred need not be labeled if that container is used immediately (within one day and used by the Employee who performed the transfer). In the interest of safety, labeling the container(s) with the chemical name of the contents may prevent accident, injury and/or illness.
Stationary Containers
For processes using in-house stationary containers, such as above ground gas tanks, signs or placards may be used in lieu of labels as long as the signs and placards meet the labeling requirements. Operating procedures, process sheets, batch tickets, and other written materials can be used as substitutes for individual container labels on stationary process equipment. These written materials must contain the same information as required on the labels and must be readily accessible to the Employees. Pipes and piping systems do not have to be labeled; however, hazard information must be on file in the MSDS central file.
Training Requirements
All Employees are to receive training on any in-house labeling system so that they can interpret and understand the labels and information provided. This training will be provided by the Project Leader, Shop Foreman and/or Supervisors.
Updating Labels
The Project Leader, Shop Foremen, and/or Supervisor is responsible for reviewing and updating label information when new and significant information is found. This information can be extracted from revised MSDSs provided for incoming hazardous materials.
HAZARD DETERMINATION POLICY
Chemical manufacturers and importers are required to evaluate the hazards of chemicals which they manufacture. These health hazard determinations are to be based upon scientific evidence. The evidence must be statistically significant and must be based on at least one positive study conducted in accordance with established scientific principles. This health hazard information will appear on the material safety data sheet. The Hazard Communication Standard requires that chemical manufacturers, importers, and distributors provide MSDS for their hazardous chemicals. It is our policy to rely on the MSDSs we receive for information concerning the hazardous chemicals we work with.
If hazard determination is needed, because we generate a chemical for which we have no MSDS, Environmental Health and Safety will evaluate the hazard by identifying and considering the available scientific evidence concerning such hazards. For health hazards, evidence that is statistically significant and that is based on at least one positive study conducted in accordance with established scientific principles is considered to be sufficient to establish a hazardous effect if the results of the study meet the definitions of health hazards as defined in the law.
Environmental Health and Safety will use the following sources for establishing that the chemicals listed in them are hazardous: 29CFR Part 1910, Subpart Z, Toxic and Hazardous Substances, (OSHA); or Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment (ACGIH).
Environmental Health and Safety will use the following sources in establishing that a chemical is a carcinogen or potential carcinogen for hazard communication purposes: National Toxicology Program (NTP) Annual Report on Carcinogens; International Agency for Research on Cancer Monographs; or 29CFR Part 1910, Subpart Z, Toxic and Hazardous Substances, OSHA.
For determination of the hazards of mixtures of chemicals, if a mixture has not been tested as a whole to determine whether the mixture is a health hazard, the mixture shall be assumed to present the same health hazards as do the components which comprise one percent (by weight or volume) or greater of the mixture. If the mixture has not been tested as a whole to determine whether the mixture is a physical hazard, the available scientifically valid data will be used to evaluate the physical hazard potential of the mixture.
HAZARDOUS CHEMICAL EXEMPTIONS
The following substances are exempt from the Hazard Communication Standard and, therefore, no hazard determination will be performed upon the following products:
a. Hazardous waste - subject to regulations issued by the Environmental Protection Agency
b. Tobacco or tobacco products
c. Wood or wood products
d. Articles which would not emit a hazardous substance if worked upon
e. Foods, drugs, cosmetics or alcoholic beverages packaged for consumers
f. Food, drugs, or cosmetics for personal consumption
g. Consumer or hazardous substances used in the same manner, frequency and duration as does a general public. Environmental Health and Safety will determine if the frequency and duration of a chemical’s use is comparable to that of consumer use. Environmental Health and Safety will obtain a material safety data sheet where it is determined that these products are used more frequently than they would be by a normal consumer.
h. Solid drugs such as tablets, capsules, and pills
EMPLOYEE INFORMATION AND TRAINING POLICY
A combination of audiovisual and written materials is used for informing and training Employees. Employees are informed of the location of the written Hazard Communication Program, Hazardous Chemical Inventory List and MSDSs and how they can obtain a copy of an MSDS. They are also informed of the hazards of the chemicals they work with and how they can protect themselves from exposure.
Our training program consists of two parts: initial training is given by the immediate Supervisor, and further training is given by Environmental Health and Safety. The initial training given by immediate Project Leader, Shop Foreman, Supervisors follows the training checklist given on page 13. Environmental Health and Safety later offers a more comprehensive chemical safety training program which is summarized on page 14. A training log is maintained at Geneva Environmental Health & Safety Office; it includes the subject of training, the date of training, the instructor's name, the Employee's department, and the Employee's signature.
Employees Requiring Training
The determination of which Employees will be selected to receive Hazard Communication Training will be based upon their exposure. Those Employees who have potential as well as actual exposure to hazardous chemicals will receive training. It is our intent to insure that Employees receive information about all chemicals they use in their work areas, and that they are prepared to deal with any unexpected releases or emergency situations, as well as exposures during the normal course of employment. Employees who do not work with hazardous chemicals will not be required to attend Hazard Communication Training. For example, office workers in general would not be likely to experience exposure that will require Hazard Communication training.
The Hazard Communication Standard has special training provisions for personnel who handle sealed containers of hazardous chemicals and for laboratory personnel.
When Training is Given
Training is provided to Employees when:
1. A new Employee starts work.
2. An Employee is transferred to a department that uses different hazardous materials.
3. A new chemical hazard is introduced into the work place.
4. New information becomes available for a substance already in use.
HAZARD COMMUNICATION INITIAL TRAINING CHECKLIST
1. Distribute to the Employee:
- New Employee Hazard Communication Training Materials
- Summary of the Hazard Communication Standard
- Reading Material Safety Data Sheets
2. Discuss the summary of the Hazard Communication Standard.
3. Inform Employees of the location of the Hazard Communication Program Binder, which includes the chemical inventory list and Material Safety Data Sheets, and the written Hazard Communication Program.
4. Inform Employees of the location of the written Hazard Communication Program for NYSAES - Geneva Station.
5. Explain how to interpret a MSDS for a chemical used in your work area, using "Reading MSDS" as a guide.
6. Inform the Employee about any labeling systems in use in the work area.
7. Inform the Employee about any hazardous chemicals used in the work area. You may refer to the Chemical Inventory List and MSDS. Include in this discussion at least the following:
- Methods used to determine the chemical's presence or release in the work area
- Any physical or health hazards associated with the chemicals
- Any personal protective equipment required and any emergency procedures
8. Discuss methods of notification about hazards in non-routine tasks and hazards associated with chemicals contained in unlabeled pipes.
9. Inform the Employee of the requirement for attendance at the new Employee training program on chemical safety given by Environmental Health and Safety.
10. Complete the Hazard Communication Initial Training Log.
HAZARD COMMUNICATION TRAINING PROGRAM
This program is presented by the staff of Environmental Health and Safety to new Employees who may be exposed to hazardous chemicals in their work area.
Requirements of the Hazard Communication Standard
- Inform Employees of their rights under the law
- Review the requirements of the standard
- Inform Employees of the location of the written Hazard Communication Program, the Chemical Inventory List, and the department's MSDSs.
Audiovisual Program: Telling Employees About Chemical Hazards
- Chemical hazard classes: corrosive, reactive, toxic
- Routes of entry: absorption, ingestion, inhalation
- Concept of dose or exposure
- Threshold limit value - TLV and PEL
- Health effects: acute and chronic
- Carcinogens
- How to detect presence of chemicals - odor, sight, burning of eyes or respiratory tract, air sampling, monitoring devices
- Reading labels
- MSDSs, discussed section by section
- Control measures - elimination, substitution, ventilation, personal protective equipment
- Federal Hazard Communication Standard
Section-by-section discussion of information on MSDSs. Includes a written exercise on interpretation of an MSDS.
Information provided on labels - colors, codes, symbols, hazard information
Discussion of physical and health hazards of chemicals in use. Emphasis on safe handling procedures and use of protective equipment.
Question and Answer Period
MULTIPLE EMPLOYER COORDINATION POLICY
Occasionally it will be required that an outside employer or a contractor perform operations at our facility. These outside agencies who produce, use, or store hazardous chemicals at our facility may expose our Employees to the chemicals they bring on site. The reverse condition may occur where these outside agencies may have their Employees exposed to chemicals that we keep on our premises. It is our position that all persons on our premises are entitled to information regarding the chemicals to which they are exposed in their work areas.
To this end, Geneva EH&S in conjunction with Building & Properties will coordinate the distribution of information between NYSAES - Geneva Station and any outside employers or contractors. This exchange of information is limited to those situations where an outside employer's Employees may be exposed to chemicals.
Contractors are requested to have available a list of the chemicals used by the contractor while at NYSAES - Geneva Station. Contractors are also asked to make MSDSs available on request.