Safety / Hazard Communication Plan

Hazard Communication Plan

 

Table of Contents

  • Appendix A Hazard Communication Standard - CFR Part 1910
  • Appendix B Health and Safety Policy and Procedure
  • Appendix C Hazard Communication Inventory of Hazardous Chemicals and Products - Instructions
  • Appendix D Hazard Communication Labeling Systems
  • Appendix E Hazard Communication Training Requirements (generic and specific)
  • Appendix F Hazard Communication Glossary
  • Appendix G Abbreviations Index
  • Appendix H Toxic and Hazardous Substances, CFR Part 1910, Subpart Z
  • Appendix I Hazard Communication Program Review Statement

 

1.0 Scope

This Hazard Communication Program is part of a program to ensure a safe working environment for all employees of the College of Pharmacy at The Ohio State Unversity. The document has been prepared 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)]. These laws are designed to protect University and contractor employees from the dangers associated with physical hazards and hazardous chemicals to which they may be exposed at The Ohio State University. Employee rights described in these laws include:

  • To have the physical and health hazards of the workplace evaluated by the employer.
  • To be informed of the hazardous chemicals to which one could be exposed, either during the normal course of work or in the event of a foreseeable emergency.
  • To be informed of hazards or hazardous chemicals when initially assigned into a work area or whenever new physical or health hazards are introduced.
  • To be informed as to procedures which are available to protect one from workplace hazards.
  • To have a written hazardous communication program.
  • To be trained on the details of working in a safe environment.

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 College of Pharmacy

  • Maintain an written Hazard Communication Program specific for the College of Pharmacy.
  • 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 Pharmacy. 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 hazardous chemicals or products containing hazardous chemicals known to be present in the College of Pharmacy is located in the Office of the OSHA Coordinator (217A Parks) and on the College of Pharmacy Web Site. All employees of the College of Pharmacy may access the list from any of these locations.

The list of hazardous chemicals is reviewed annually to verify its accuracy. It is also be updated anytime a new chemical or product containing hazardous chemicals is introduced into the workplace. The review and updates are done under the direction of the OSHA Coordinator, Lane Wallace.

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 Pharmacy 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 labeling systems other than those provided by the manufacturer will be implemented in non-laboratory areas of the College of Pharmacy. The OSHA Coordinator, Lane Wallace, will be responsible for ensuring that correct labeling methods are utilized.

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 Pharmacy 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.

Material Safety Data Sheets are located in the Office of the OSHA Coordinator (217A Parks) and at the EOHS Web Site.

The OSHA Coordinator, Lane Wallace is responsible for ensuring that MSDS's are obtained, maintained and updated for all chemicals on the inventory.

8.0 Training Requirements

The College of Pharmacy will be responsible for informing and training its 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 OSHA Coordinator, Lane Wallace is responsible for training employees on the generic Hazard Communication information.

 

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 area.

The OSHA Coordinator, Lane Wallace, is responsible for training employees on job specific Hazard Communication information.

The OSHA Coordinator, Lane Wallace, 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 OSHA Coordinator, Lane Wallace, 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 Pharmacy 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 assistant OSHA Coordinator, David Brigham, is responsible for maintaining, reviewing, and updating the records of generic and specific Hazard Communication training.

9.0 Employee Hazard Awareness - Non-Routine Tasks

It is the responsibility of the College of Pharmacy 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 Pharmacy 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 OSHA Coordinator, Lane Wallace, is 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 written Hazard Communication Plan are located in the Office of the OSHA Coordinator (217A Parks) and on the College of Pharmacy Web Site. All employees of the College of Pharmacy may access the plan from any of these locations.

The Hazard Communication Plan is reviewed annually to verify its accuracy. The review and any necessary updates are done under the direction of the OSHA Coordinator, Lane Wallace.

 

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