Santa Rosa Junior College

HAZARD COMMUNICATION PROGRAM

What This Document Covers:

I. Introduction and Policy
II. Responsibility
III. Site Specific Hazard Communication
IV. List of Hazardous Chemicals
V. Material Safety Data Sheets (MSDS)
VI. Labels and other Forms of Warning
VII. Training and Information
VIII. Contractor Employers
IX. Non-Routine Tasks and Work in Laboratories
X. Additional Information

For specific questions or concerns regarding the SRJC Hazard Communication Program, contact the Environmental Health & Safety (EH&S) Department at 527-4803.

I. Introduction and Policy

The Hazard Communication Standard (California Code of Regulations, Title 8, Section 5194) establishes uniform requirements to ensure that all chemicals used in California workplaces are evaluated to determine their hazards. This information must be provided to employers and to their affected employees. Chemical manufacturers must perform the evaluations and convey the hazard information obtained to users by means of labels on containers and material safety data sheets (MSDSs). Employers must educate their employees to understand the hazards associated with the hazardous materials they work with, and ensure that resources such as MSDSs and container labels for the materials are maintained and accessible.

The purpose of this written Hazard Communication Program is:

To establish guidelines and policies to ensure that all members of the SRJC community are apprised of the chemical hazards to which they may be exposed.
To provide a foundation of knowledge to permit employees to make informed decisions about these materials.

The safe conduct of work with potentially hazardous chemicals is dependent on the value the institution places on protecting health and the environment, and on the motivation and good judgement the individual chemical user exercises. Therefore, it is the responsibility of departments, supervisors, college staff, and students to adhere to the specifics and the intent of the Hazard Communication Program in order to reduce risk to the college community as a whole and promote safety as a value in the SRJC culture.

The provisions of the Hazard Communication Program (HCP) apply to any hazardous substance that is known to be present in the workplace, with the exception of specific teaching activities in laboratories. The Chemical Hygiene Plan applies to most activities performed by teaching laboratory workers. The full scope of the HCP does apply to all teaching uses of chemicals conducted in laboratories.

Consumer products packaged for and used by the general public in a manner that will not result in significantly greater exposure than that of the general consumer, are excluded from the program.

II. Responsibility

The SRJC program establishes responsibility for the implementation of the Hazard Communication Program.
The College President is responsible for ensuring that the applicable operations of the College are conducted in accordance with these provisions.

Environment Health & Safety (EH&S) is responsible for overall program development, serves as a central repository for hard copy MSDSs, provides general hazard communication training, and assists users of chemicals with local program implementation.

Individual departments and/or shops are responsible for designating a person in charge of implementing the Hazard Communication Program for their area. This designee will be the liaison with EH&S for all Hazard Communication Program issues. This includes the development and maintenance of an inventory of hazardous materials as well as procurement and maintenance of a MSDS file for these hazardous materials. The designee will also ensure that chemical containers are adequately labeled and that employees receive specific training for the materials they use. Training must also include details of their specific Hazard Communication Program (such as location of the MSDS file and any in-house procedures). The written Hazard Communication Program and MSDS file must be accessible to employees during their normal working hours.

Chemical users are responsible for maintaining familiarity with the materials they use, using them in a safe and responsible manner, and seeking supervisory support before using new materials or using materials in unusual situations.

III. Site Specific Hazard Communication Information

(Fill in the blanks)

The SRJC program applies to all faculty, staff, students, visitors, and volunteers.

Michael Ceser of Environmental Health & Safety is the overall coordinator of the SRJC program.

The area/unit covered by this specific plan is ____________________________________.
____________________________ is the local designated person in charge responsible for the Hazard Communication Program in this facility/shop.

MSDSs are maintained and accessible at _______________________________________.

An inventory of all hazardous chemicals used and stored by ________________________ will be maintained and updated as necessary.

The Hazard Communication person in charge or _________________________________ will monitor and maintain records of employee training.

Training Records will be maintained in ________________________________________.

In general, each employee in the facility will be informed of the substance of the Hazard Communication Program, the hazardous properties of chemicals they work with, and measures to protect themselves from these chemicals.

Other site-specific Hazard Communication information:

IV. List of Hazardous Chemicals

The hazardous chemical list will be updated on receipt or removal of hazardous chemicals from the site. Many materials such as cleaning agents, adhesives, copying supplies, art materials, paints, strippers, solder and welding supplies, fertilizers, pesticides, and compressed gases contain hazardous materials and must be included on the inventory. Materials used in a similar quantity and fashion as a household consumer are excluded from this standard. The list of materials for the area under the local hazard communication designee is attached (Appendix A). A compiled inventory of materials stored on the main SRJC campus is maintained by the Environmental Health & Safety Department.

V. Material Safety Data Sheets (MSDS)

The objective of a Material Safety Data Sheet (MSDS) is to concisely inform you of the hazards of the materials you work with or may be exposed to so you can protect yourself and respond to emergency situations. EH&S will maintain a MSDS for every substance on the list of hazardous chemicals at SRJC. The MSDS will consist of a fully completed OSHA Form 174 or equivalent. Each department or shop will maintain a MSDS library on every substance on their list of hazardous chemicals. The Hazard Communication Coordinator will secure and maintain a MSDS for each hazardous material used in their area.

MSDSs must be readily accessible to employees working in remote or field locations. Appropriate MSDSs will be maintained in a binder in each vehicle, on each job site, or immediately accessible by phone and fax.

Alternatively, MSDSs may be accessed electronically (i.e., via computer locally or via Internet). If electronic access is used, the procedure to access those sheets will be attached and employees will be trained in the access procedure.

A variety of MSDS databases and Chemical Fact Sheets may be accessed from the SRJC EH&S web site.

MSDSs must be readily available to all employees, EH&S, and Cal/OSHA on request.

MSDSs must be received at the facility either prior to or at the time of receipt of the first shipment of any potentially hazardous chemical purchased from a vendor. If materials are received for which no MSDS is available in the area of use, the local Hazard Communication designee shall contact EH&S at ext 4803 to secure the needed MSDS.

VI. Labels and Other Forms of Warning

The local Hazard Communication designee provides oversight to ensure that hazardous chemicals in his/her area are properly labeled. However, if a label is falling off or deteriorating, it is everyone's responsibility to take action so that the identity of a material is not lost. Labels on incoming containers should not be defaced while they contain the indicated material. Labels on these primary containers should list the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer, or other responsible party.

Secondary containers (those containers into which material is transferred) must be labeled with the name of the material as it appears on the MSDS, and an appropriate hazard warning. A placard containing the chemical or product name, an appropriate hazard warning, and a key to link it to an abbreviation or a code displayed on the secondary container may be used (see Table 1 below for a sample of commonly used chemical abbreviations). Chemical users must be trained in the recognition and purpose of the placard if one is used in the area. Placards are frequently used in laboratories on small containers and squeeze bottles. Common immediate use containers (those in which the hazardous substance will be under the control and used only by the person who transfers it from a labeled container and within that workshift) do not require labeling.

Table 1 - A Sample Abbreviation Placard Often Used in Laboratories

CHEMICAL ABBREVIATIONS AND ANNOTATIONS USED ON SECONDARY CONTAINERS IN THIS LABORATORY

ACIDS - Corrosive to skin, eyes and respiratory tract

HCL - hydrochloric acid
HF - hydrofluoric acid
TCA - trichloroacetic acid
H2SO4 - sulfuric acid

BASES - Corrosive to skin, eyes and respiratory tract

KOH - potassium hydroxide
NH3OH - ammonium hydroxide
NaOH - sodium hydroxide

FLAMMABLE LIQUIDS - Fire Hazard, Toxic by ingestion, irritant

EtOH - ethyl alcohol
MeOH - methanol
IPA - isopropyl alcohol

TOXIC - Harmful by Ingestion or skin absorption

DEPC - Diethyl pyrocarbonate
DMSO - Dimethyl sulfoxide (carries hazardous materials through the skin)

LOW HAZARD

SDS - Sodium Dodecyl Sulfate, detergent
TAE - Tris acetic acid + Ethylenediaminetetra acetic acid
TBE - Tris boric acid + Ethylenediaminetetra acetic acid
PBS - Phosphate buffered saline, buffer
SSC - Sodium chloride sodium citric acid
TE - Tris Ethylenediaminetetraacetic acid
SSPE - Sodium chloride sodium phosphate + Ethylenediaminetetraacetic acid
STET - Sodium chloride ethylenediaminetetraacetic acid tris triton X-100
TNT - Tris sodium chloride Tween-20
TPE - Tris phosphoric ethylenediaminetetraacetic acid

The area supervisor will check frequently to ensure that containers in the facility are labeled and that the labels are up-to-date.

VII. Training and Information

Each employee who works with or is potentially exposed to hazardous chemicals will receive initial training on the Hazard Communication Standard and the safe use of those hazardous chemicals. EH&S will perform general Hazard Communication training as part of formal Injury and Illness Prevention Plan training during New Employee Safety Orientation. Hazardous chemical training is conducted by the supervisor or their designate. Additional training will be provided for employees whenever a new hazard is introduced to their work areas. The training will emphasize these elements:

A summary of the standard and this written program.
Hazardous chemical properties and methods that can be used to detect the presence or release of hazardous chemicals, including visual appearance and odor.
Physical and health hazards associated with potential exposure to workplace chemicals.
Procedures to protect against hazards; e.g., personal protective equipment, work practices, and emergency procedures.
Hazardous chemical spill and leak procedures.
Where MSDSs are located, how to understand their content, and how employees may obtain and use appropriate hazard information. This includes computer-based access when appropriate.
The procedures for conducting non-routine tasks involving hazardous materials.
Accurate records on all safety training must be maintained by supervisory personnel. Records should include: the employee name, date of training, topic covered, employee signature, and name of instructor. Records should also include a copy of any test or quiz (see Appendix B-Hazard Communication Initial Training Exam) used to evaluate level of knowledge and effectiveness of training.
Environmental Health & Safety will provide assistance with the development of departmental programs upon request.

VIII. Contractor Employers

The project manager will advise outside contractors of any chemical hazards that may be encountered in the normal course of their work at SRJC facilities.

IX. Non-Routine Tasks and Work in Laboratories

Periodically, employees may be required to perform hazardous non-routine tasks. Any employee contemplating a non-routine task involving possible chemical hazards (e.g., chlorine line repair) will contact their supervisor or manager. The supervisor will ensure that employees are informed of:

1) The specific hazards associated with the performance of these tasks.

2) Protective measures that must be used.

3) Measures the department has taken to lessen these hazards such as ventilation, personal protective equipment, or the presence of another employee.

4) Specific emergency procedures to be used in the event of an accident or injury.
All work in laboratories may involve potential hazards from chemicals used and stored. All work should be coordinated with the laboratory staff to identify and minimize potential hazards in the work area. No work should be conducted that requires entering the fume hood body or moving laboratory equipment or stored chemicals without the permission of the supervisor.

X. Additional Information

Further information on this written program, the Hazard Communication Standard, and applicable MSDSs is available from the Environmental Health & Safety Department. The MSDS Master file is located at Community Services, Bldg. 26, 1990 Armory Drive, Santa Rosa, (707) 527-4803.

APPENDIX A

List of Hazardous Materials Covered By this Plan (insert here)

APPENDIX B

Hazard Communication Initial Training Exam (fill in the blanks)

Hazard Communication Training Date:

Department:

Name:

Title:

1) What does MSDS stand for?

2) Where are MSDSs located in your area?

3) Is there a written Hazard Communication Program for your department at SRJC?

4) Other than the paper copy MSDS file, are MSDSs available through other means?

Describe:

5) What should you do when faced with a non-routine situation involving hazardous chemicals?

6) What information should appear on the label of hazardous materials?

7) Name four sections that appear on MSDS sheets:

8) What information must appear on a secondary container label?