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Introduction to the Hazard Communication Program

Policy

Cornell University 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. Environmental Health and Safety provides 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 Occupational Safety and Health Administration 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 Cornell University.



Summary of Hazard Communication Requirements

The purpose of this program is to ensure that:

  • All employees are aware of our Hazard Communication Program and that it is available to all employees, their designated representatives, and OSHA.
  • All hazards of chemicals are evaluated.
  • All hazardous chemicals used in the work place are labeled, and that a list of chemicals is available.
  • Material Safety Data Sheets (MSDSs) are available for all hazardous chemicals.
  • 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.
  • All persons involved in non-routine work tasks are informed of the hazards of such tasks.
  • Contractors and their employees will be informed of chemical hazards before performing work in our facility; and that sub-contractors will inform us of any hazardous materials brought into our facility.

Employees Covered 

The Hazard Communication Program will apply to employees who are exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Employees who encounter hazardous chemicals only in non-routine, isolated instances are not covered.

Chemicals Covered 

Hazardous chemicals are defined as those materials that possess either a physical and/or health hazard.

Major Requirements 

  • Chemical inventory must be prepared according to work area and available to employees.
  • Material Safety Data Sheet collections must be prepared according to work area and available to employees. Environmental Health and Safety maintain a complete set.
  • Employees must be provided with information and training.
  • Coordination of information with other employers on multi-employer work places.

Special Exemptions and Provisions 

The law has special provisions for certain specific situations:

  1. Laboratories - for laboratory operations, the following aspects of the Hazard Communication Program will apply:
  • Labels on incoming containers are not to be removed or defaced.
  • Material safety data sheets that are received with the products must be maintained and will be available to laboratory personnel. 
  • Employees will be apprised of the hazards of the chemicals through an appropriate information and training program.
  1. Sealed Containers - In operations such as warehousing, retail sales, or materials management, where employees handle only containers that are sealed, the following aspects of the Hazard Communication Program will apply:
  • Labels on incoming containers are not to be removed or defaced.
  • Material Safety Data Sheets that are received with incoming containers must be kept and maintained.
  • If requested by employees, Material Safety Data Sheets must be obtained.
  • Material Safety Data Sheets must be accessible to employees.
  • Cornell University will provide an information and training program that is sufficient to protect employees from hazards presented by the contents of sealed containers should they spill or leak.
  1. Non-routine Tasks - This section applies to jobs that are not performed on a routine basis and that may involve contact with a hazardous chemical (e.g. cleaning out a chemical holding tank, cleaning out a boiler, working on unlabeled pipes).
  • Supervisors will determine what chemical hazards are present or may be created by the task. The supervisor is responsible for communicating information to employees. Employees will be informed of the hazards presented by the non-routine task.
  1. Retail Operations - Retail operations, which sell hazardous chemicals to commercial customers, will provide a Material Safety Data Sheet to those customers if requested. 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 does not open the sealed containers on their premises.

 


Location of Written Hazard Communication Program

The Hazard Communication Program for Cornell University is in written form and is available to employees at the following locations:

  • The red Toxic Substances Notebook, located in many department offices.
  • Environmental Health and Safety, 125 Humphreys Service Building, Ithaca, New York 14853, phone (607) 255-8200.
  • Cornell Police, G-2 Barton Hall, where it is accessible on a 24-hour basis.

 

 

Chemical Inventory Lists

  • A list of the hazardous chemicals used by each department is available in each department for employee information. This list is commonly found in the Toxic Substances Notebook, which also contains the Material Safety Data Sheet collection.
  • The department supervisor is responsible for keeping the Hazardous Chemical List for his section up-to-date. Anyone who orders chemicals shall notify the appropriate supervisor that a new chemical has been purchased. It is the responsibility of the supervisor to obtain the MSDS for such chemicals.

 

 

Material Safety Data Sheets (MSDS)

A Material Safety Data Sheet file and computer database with information on thousands of chemicals used at the university are kept and maintained by Environmental Health and Safety (EH&S).

Additional copies of MSDSs are available in each department, based on the chemicals used in the department. Notebooks containing MSDSs are located in each department and are updated by the department supervisor. Employees are encouraged to review these Material Safety Data Sheets.

Internal Distribution of MSDSs

  • When a new or revised MSDS is received by the department supervisor, copies will be placed in the appropriate MSDS notebooks. The old MSDS shall not be removed or discarded until all supplies of current inventory are used.
  • When an MSDS is received by EH&S, it is retained in the files and referred to when responding to information requests.
  • When an MSDS is received by any other office at the university, it will be forwarded to EH&S.

Obtaining MSDSs

In the event that a chemical shipment is not preceded or accompanied by an MSDS, the department supervisor will notify Environmental Health and Safety (EH&S). EH&S will locate the MSDS and forward it to the department supervisor. It is the responsibility of the supervisor to place the MSDS in the Toxic Substances Notebook.


Employee Requests for MSDSs

  • Employees can obtain copies of MSDSs by referring to the department Toxic Substances Notebook or by calling or writing EH&S. Chemical information request forms are included in the Toxic Substances Notebook for the convenience of employees. A copy of the MSDS will be provided to the employee and assistance in interpretation will be given if requested.
  • In the event that the MSDS is not available immediately, EH&S will notify the employee and send the MSDS as soon as it is obtained from the manufacturer or distributor.

 

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.
  • 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 the supervisor to determine which information provided on the Material Safety Data Sheets and labels of the incoming containers is to be transferred to the in-house labels.

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).

Stationary Containers - For processes using in-house stationary containers, such as dip tanks and plating 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. However, 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. The supervisors will provide this training.

Updating Labels - The 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 the chemicals that 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 Material Safety Data Sheets for their hazardous chemicals. It is our policy to rely on the Material Safety Data Sheets 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
(Source: OSHA Hazard Communication Standard)

The following substances are exempt from the Hazard Communication Standard and, therefore, no hazard determination will be performed upon the following products:

  1. Hazardous waste - subject to regulations issued by the Environmental Protection Agency
  2. Tobacco or tobacco products
  3. Wood or wood products
  4. Articles which would not emit a hazardous substance if worked upon
  5. Foods, drugs, cosmetics or alcoholic beverages packaged for consumers
  6. Food, drugs, or cosmetics for personal consumption
  7. Consumer or hazardous substances used in the same manner, frequency and duration as does a normal consumer. 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.
  8. 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 and Material Safety Data Sheets 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: the immediate supervisor gives initial training, and further training is given by Environmental Health and Safety. The initial training given by immediate supervisors follows the training checklist given on page 8. Environmental Health and Safety later offers a more comprehensive chemical safety-training program, which is summarized on page 8-9. A training log is maintained; 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:

  • A new employee starts work.
  • An employee is transferred to a department that uses different hazardous materials.
  • A new chemical hazard is introduced into the work place.
  • 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

  1. Discuss the summary of the Hazard Communication Standard.
  2. Inform employees of the location of the red Toxic Substances Notebook, which includes the chemical inventory list and Material Safety Data Sheets, and the written Hazard Communication Program.
  3. Inform employees of the location of the written Hazard Communication Program for Cornell University: in the red Toxic Substances Notebook located in many department offices; Environmental Health and Safety, 125 Humphreys Service Building; and at the Cornell Police, G-2 Barton Hall, where it is accessible on a 24-hour basis. 
  4. Explain how to interpret a Material Safety Data Sheet for a chemical used in your work area, using "Reading Material Safety Data Sheets" as a guide.
  5. Inform the employee about any labeling systems in use in the work area.
  6. Inform the employee about any hazardous chemicals used in the work area. You may refer to the chemical inventory list and Material Safety Data Sheets. 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
  1. Discuss methods of notification about hazards in non-routine tasks and hazards associated with chemicals contained in unlabeled pipes.
  2. Inform the employee of the requirement for attendance at the new employee-training program on chemical safety given by Environmental Health and Safety.
  3. Complete the Hazard Communication Initial Training Log.

 

Hazard Communication Training Program
Environmental Health and Safety

The staff of Environmental Health and Safety presents this program 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 Material Safety Data Sheets

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
  • Meds, discussed section by section
  • Control measures - elimination, substitution, ventilation, personal protective equipment
  • Federal Hazard Communication Standard

Material Safety Data Sheets

Section-by-section discussion of information on MSDSs; this includes a written exercise on interpretation of an MSDS.

Labels

Information provided on labels - colors, codes, symbols, hazard information

Chemicals In Use

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 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, EH&S will coordinate the distribution of information between Cornell University 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 Cornell University. Contractors are also asked to make available Material Safety Data Sheets on request. 

 

 

 

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  For more information about the contents of this page  
  contact : Nathan Hunter 
  Last Updated : 12.10.03