Hazard Communication Program

Northwestern University Hazard Communication Program ! Office of Research Safety Office of the Vice President for Research ____________________________________________ TABLE OF CONTENTS 1.0 Introduction 1.1 Occupational Safety and Health Administration Hazard Communication Standard 1.2 EPA Superfund Amendments and Reauthorization Act, Title III Responsibilities 2.1 Department Heads 2.2 Principal Investigators and Other Supervisory Personnel 2.3 Department Safety Representative 2.4 Office of Risk Management 2.5 University Police 2.6 Office of Research Safety 2.7 Facilities Management 2.8 Employees 2.9 Students Hazardous Chemical Definition 3.1 Health Hazard 3.2 Physical Hazard 3.3 Additional Hazardous Chemicals Training and Information 4.1 Departmental Training 4.2 Human Resources 4.3 Office of Research Safety Material Safety Data Sheets 5.1 Departmental Responsibilities 5.2 Manufacturers’ and Importers’ Responsibilities 5.3 Information Contained on MSDSs Labeling and Other Warnings 6.1 Departmental Labeling Requirements 6.2 Exemptions to Labeling 6.3 Labeling Requirements for Manufacturers, Importers, and Distributors Workplace Hazardous Chemical List Hazards of Nonroutine Tasks Hazardous Materials Information for Contractors 9.1 Departmental Responsibilities 9.2 Reducing Employee and Community Risk to Chemical Exposure 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 Laboratory Requirements 11.0 Annual Chemical Inventory 12.0 Safety Desk Book Appendix A – Glossary of Terms, Abbreviations, and Acronyms Appendix B – Hazard Communication Program, Record of Required Training Appendix C – Departmental Training Checklist Appendix D – Hazard Communication Program for Outside Contractors Rev. 5-99 ____________________________________________ 1.0 INTRODUCTION The Northwestern University Hazard Communication Program ensures compliance with federal, state, and local laws governing the use and storage of hazardous chemicals. The program at Northwestern covers all departments in the University. It is designed to provide information and instruction to faculty, staff, and students on the hazards associated with the chemicals in their workplace so that they may make informed judgments regarding the precautions necessary to protect themselves. The senior vice president for business and finance and the vice president for research have assigned direct responsibility for compliance with the Hazard Communication Program to unit heads (department chairs, center directors, facility directors or their designees). The Office of Research Safety (ORS) has been assigned to coordinate the University’s overall compliance effort. The Hazard Communication Program is based on the Occupational Safety and Health Administration Hazard Communication Standard (OSHA HCS) and the Superfund Amendments and Reauthorization Act, Title III (SARA Title III). These are generally referred to as “right-to-know” laws. The OSHA HCS applies to employers and employees. The University program additionally requires that the same chemical safety information be given to students who may come into contact with hazardous chemicals in the course of their academic work. Full text of the OSHA HCS is on file in ORS and will be made available upon request. A glossary of terms, abbreviations, and acronyms is provided in Appendix A of this document. 1.1 Occupational Safety and Health Administration Hazard Communication Standard The OSHA HCS, Title 29 Code of Federal Regulations 1910.1200, is designed to ensure that the hazards of all chemicals produced in or imported to the United States are evaluated and that information concerning their hazards is transmitted to employers and employees. The OSHA HCS covers chemicals in all physical forms—liquids, solids, gases, vapors, fumes, and mists—whether they are contained or not. The OSHA HCS achieves its purpose by requiring chemical manufacturers and importers to evaluate the chemicals they produce or import to determine if they are hazardous. Chemicals determined to be hazardous must have a comprehensive Material Safety Data Sheet (MSDS) and warning labels for chemical containers. The MSDS and labels shall be prepared by the chemical manufacturer or importer. The MSDS and labels must accompany a hazardous chemical shipped from the manufacturer or importer. The OSHA HCS requires the employer to develop a written hazard communication program and provide information and training to employees about the hazardous chemicals in the workplace. This document serves as the University’s written hazard communication program. The OSHA HCS establishes three important informational requirements: labels, MSDSs, and employee training. Labels provide a brief statement of the hazards associated with the chemical. MSDSs provide more comprehensive technical information on the hazardous chemical. They serve as reference documents for exposed employees as well as health professionals providing services to these employees. Employee training ensures that employees understand the information provided by labels and MSDSs, know where and how to obtain this information, and are aware of the proper protective measures and emergency procedures to follow. 1.2 EPA Superfund Amendments and Reauthorization Act, Title III The essential purpose of SARA Title III is to assure that information regarding hazardous chemicals is made available to emergency response agencies and the general public. See Section 11.0 for more information. ____________________________________________ 2.0 RESPONSIBILITIES Northwestern University is committed to providing a safe and healthful environment for the pursuit of teaching, research, and public service. The University is further committed to complying with federal, state, and local regulations relating to employee health and safety and to protection of the environment. This policy and related regulations and guidelines apply equally to all faculty, staff, students, and visitors. p. 1 Rev. 5-99 2.1 Department Heads The term department head will be used in this text to include academic and administrative directors. The department head is responsible for providing a safe workplace for faculty, staff, and students within the department’s facilities. The department head is responsible for ensuring training of departmental faculty, staff, and students in the proper procedures necessary to maintain the general safety of the day-to-day operations. The department head may delegate safety and health-related responsibilities to a department safety representative or to principal investigators and other supervisors, but it is the department head’s responsibility to see that the requirements are met. 2.1.1 Training. Department heads must provide safety training to faculty, staff, and students whose work potentially exposes them to hazardous chemicals during normal operations or in foreseeable emergencies. Additional training must be provided whenever a new health or physical hazard not covered in previous training is introduced into their work area. The department must maintain a training record and forward a copy to the Evanston ORS office. Contact ORS for training materials, guidelines, and advice on training. See Section 4.0 for detailed training information. 2.1.2 Material Safety Data Sheets. Department heads must ensure that an MSDS is obtained for each chemical used or stored in the workplace and made readily accessible to faculty, staff, students, and emergency response personnel. See Section 5.0 for more information on MSDSs. 2.1.3 Container Labeling and Other Forms of Warning. Department heads are responsible for ensuring that all chemical containers in their workplace bear labels with the appropriate chemical identity and hazard warnings. See Section 6.0 for complete information on labeling and hazard warnings. 2.1.4 Workplace Hazardous Chemical List. Department heads are required to compile a list of hazardous chemicals used in their department and make it available to faculty, staff, and students. See Section 7.0 for complete information regarding a list of hazardous chemicals. 2.1.5 Hazards of Nonroutine Tasks. Department heads are required to inform faculty, staff, and students of the hazards of nonroutine tasks and of the hazards associated with chemicals contained in unlabeled pipes in the workplace. See Section 8.0 for information on the hazards of nonroutine tasks and the hazards of chemicals contained in unlabeled pipes. 2.1.6 Hazardous Materials Information for Contractors. Department heads must ensure that information regarding chemical hazards present in their workplace is shared with contractors. For more information on this subject, see Section 9.0 and Appendix D. 2.1.7 Laboratory Requirements. Department heads must be aware of and implement the special requirements under the Hazard Communication Program that apply to laboratories. For more information on laboratory requirements, see Section 10.0. 2.1.8 Annual Inventory. Department heads are responsible for compiling the annual inventory of hazardous chemicals as required under SARA Title III. See Section 11.0 for more information on the annual inventory. 2.1.9 Safety Desk Book. Department heads are responsible for assembling a Safety Desk Book. See Section 12.0 for a list of the documents and other information required. 2.2 Principal Investigators and Other Supervisory Personnel Principal investigators and other supervisory personnel are responsible to the department head for implementing the departmental safety programs, policies, and procedures. The principal investigator and other supervisory personnel shall be familiar with and understand the University safety policies and procedures pertaining to the workplace. These encompass but are not limited to employee training, record keeping, MSDS maintenance, labeling of chemicals, posting of warnings, medical surveillance, inventory reporting, engineering controls, safe work practices, and provision of personal protective clothing and equipment. Principal investigators and other supervisory personnel may not delegate their responsibilities. p. 2 Rev. 5-99 2.3 Department Safety Representative Department heads may appoint a department safety representative to perform designated safety functions. The department safety representative • contacts University safety personnel on safety-related problems • corresponds with other department safety representatives in the building • knows the emergency procedures for the department and the University • coordinates the department’s program of accident prevention, safety training, annual inventory of hazardous chemicals, and emergency response. 2.4 Office of Risk Management Risk Management protects the University with a comprehensive insurance program and provides health insurance to students, athletes, and visiting scholars. University property and automobile insurance are coordinated through Risk Management. They also administer the Workers’ Compensation program to provide assistance to employees who sustain work-related, on-the-job injuries. Risk Management implements fire prevention and protection programs throughout the University. They inspect University buildings for safety and building code requirements. Risk Management investigates accidents and will provide general safety training to employees. 2.5 University Police (UP) UP responds to alarms and emergency calls to provide assistance and control the site of the emergency. The communications officer summons the fire department or ambulance when needed. The responding UP officer may provide emergency first aid and arrange for transportation to the emergency room in cases where paramedics are not required. 2.6 Office of Research Safety (ORS) ORS is responsible for coordinating the University’s overall compliance with the Hazard Communication Program. ORS responsibilities, as they relate to the Hazard Communication Program, include • maintaining the central repository for MSDSs • compiling the annual inventory of hazardous chemical information and submitting reports to federal, state, and local agencies • surveying laboratory facilities and offering recommendations for improved work practices • coordinating the Safety Plan program • training and advising personnel in safe work practices, personal protective clothing and equipment, engineering controls, and regulatory requirements • conducting or arranging for environmental monitoring • inspecting laboratory equipment such as chemical fume hoods • recommending policies and procedures for the safe conduct of work with chemicals. ORS representatives are authorized to enter University facilities within their jurisdiction at any time to observe working conditions, monitor equipment, and sample for contaminants. The ORS director and the designated chemical hygiene and biohazards safety officers are authorized to close a facility or stop a process or procedure that poses an imminent danger to life or property. 2.7 Facilities Management Facilities Management maintains the basic infrastructure of building facilities. These include fire extinguishers, fire hoses, building fire alarm systems, ventilation systems, and building electrical and piping systems. Facilities Management personnel respond to emergencies to help as needed in evacuation and handling building services and equipment. 2.8 Employees Safety requirements are well documented and available for most basic work procedures. Employees must accept the responsibility for knowing the safety requirements and putting them into practice in the workplace. Safety considerations should always be included in the planning and performing of work, which includes learning in advance about the properties, p. 3 Rev. 5-99 hazards, and safety measures pertinent to the materials and equipment to be used. Employees must know the established emergency procedures and the location and proper use of emergency equipment and supplies. 2.9 Students Although the OSHA standards apply only to employers and employees (including student employees), it is the policy of Northwestern University to ensure that all students who might be exposed to hazardous materials in the course of their academic activities are adequately protected and trained. Students shall receive instruction in the appropriate safety precautions for their specific research/teaching labs and will be expected to follow the given rules. ____________________________________________ 3.0 HAZARDOUS CHEMICAL DEFINITION A hazardous chemical is defined by OSHA as any chemical that is a health hazard or a physical hazard. 3.1 Health Hazard OSHA defines a health hazard as a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. Chemicals covered by this definition include carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents that act on the hematopoietic system, and agents that damage the lungs, skin, eyes, or mucous membranes. 3.2 Physical Hazard OSHA defines a physical hazard as a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or waterreactive. 3.3 Additional Hazardous Chemicals The broad definition OSHA uses to define hazardous chemicals includes not only generic chemicals but also paints, cleaning compounds, inks, dyes, and many other common substances. Chemical manufacturers and importers are required to determine if the chemicals they produce or repackage meet the definition of a hazardous chemical. A chemical mixture may be considered as a whole or by its ingredients to determine its hazards. It may be considered as a whole if it has been tested as a whole and an MSDS has been issued accordingly. Otherwise the mixture must be evaluated by its components. If the mixture contains 1.0% or more of a hazardous chemical or 0.1% of an ingredient listed as a carcinogen or suspected carcinogen, the whole mixture is assumed to have the same health and/or carcinogenic hazards as its components. ____________________________________________ 4.0 TRAINING AND INFORMATION Employers must provide information and training to employees regarding the hazardous chemicals in their work area at the time of the employees’ first work assignment and again whenever a new health or physical hazard is introduced into the work area. Inform employees of the following: • requirements of the Hazard Communication Program and the OSHA Hazard Communication Standard • any operations in their work areas where hazardous chemicals are present • location and availability of the written Hazard Communication Program, including workplace hazardous chemical lists and MSDSs. Train employees in the following: methods of observing and detecting the release of hazardous chemicals into the work area physical and health hazards of chemicals in the work area measures employees may take to protect themselves from these hazards, including the specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals • explanations of MSDSs, labels, and how employees can obtain and use appropriate hazard information. • • • The regulations require that employers teach their employees what they need to know to work safely and protect their health when working with hazardous chemicals. Employers may design their employee training format as desired so long as all of p. 4 Rev. 5-99 the training requirements are included. A key concept in the training is understanding. Employees must walk away from the training understanding the hazards in their work area and how to protect themselves. Giving employees an instruction sheet or MSDS to read or a video to watch does not satisfy the intent of the laws. The training must include an opportunity for employees to ask questions to ensure that they understand the information presented to them. 4.1 Departmental Training Department heads are responsible for training and disseminating information to their faculty, staff, and students as discussed in Section 4.0. They may delegate the actual training and dissemination of information to department safety representatives, supervisors, or principal investigators. Supervisors and principal investigators may not delegate the responsibility. Department heads must keep a record of the dates and topics of training sessions, the individual conducting the training, and the names of those in attendance (Appendix B). Copies of the training records must be sent to Evanston ORS for that department’s compliance file. Department heads may use the “Departmental Training Checklist” (Appendix C) to evaluate the effectiveness and completeness of their hazard communication training. 4.2 Human Resources The Department of Human Resources distributes the Employee Safety Handbook to all new employees at each newemployee orientation session. This reference booklet summarizes the Hazard Communication Program. In addition, the booklet provides information on important phone numbers, emergency procedures, medical treatment procedures, and safety inspections. Specific hazard training must be conducted in the new employee’s department by supervisory personnel. 4.3 Office of Research Safety ORS, on request, will provide orientation for department supervisory personnel on the general requirements of the Hazard Communication Program. With the materials given to them and otherwise available through ORS, the supervisory personnel must then develop training programs tailored to their respective departments. ____________________________________________ 5.0 MATERIAL SAFETY DATA SHEETS MSDSs are the most basic source of hazardous chemical information. An employer shall have an MSDS for each hazardous chemical used in the workplace. The MSDS summarizes the chemical’s properties, the health and physical hazards, and related safety information. 5.1 Departmental Responsibilities Departments must maintain copies of the required MSDS for each hazardous chemical in the workplace and must ensure that these copies are readily available to faculty, staff, and students during each work shift when they are in their work areas and to emergency response personnel. The term readily available means quickly and easily accessible at any time for information and emergency use. Alternate means of keeping MSDSs, such as electronic access, microfiche, and CD-ROM, are permitted as long as no barriers to immediate employee access are created by their use. MSDS databases on the Internet are not an acceptable alternative for keeping workplace MSDSs. A department receiving an MSDS with an order shall keep a copy and send the original to ORS for the central repository. A department that does not receive an MSDS within a few days after an order arrives should check if the MSDS was sent to ORS. MSDSs received at ORS rarely include any information on who placed the order. If the MSDS identifies the individual placing the order, ORS will send a copy of the MSDS to that individual. ORS will assist a department in obtaining MSDSs. Obsolete MSDSs, which must be kept on file for 30 years, should be sent to ORS. The central repository in the ORS office serves as a long-term, hard-copy file as well as a backup source of information to University departments. 5.2 Manufacturers’ and Importers’ Responsibilities The OSHA HCS requires chemical manufacturers and importers to assess the physical and health hazards associated with the chemicals they produce or repackage. This information must be supplied to employers by means of labels and MSDSs. Manufacturers, importers, and distributors must supply an MSDS with the first shipment of any hazardous chemical. They must revise an MSDS within three months after receiving any “significant new information” and supply an updated MSDS whenever changes are made. 5.3 Information Contained on MSDSs p. 5 Rev. 5-99 OSHA requires that each MSDS be in English (although the employer may maintain copies in other languages as well) and contain at least the following information. 5.3.1 Identity. The chemical identity, as used on the container label, shall appear on the MSDS. 5.3.2 Physical and Chemical Characteristics. The physical and chemical characteristics of the hazardous chemical shall appear on the MSDS. Examples include vapor pressure, appearance, odor, and flash point. 5.3.3 Health Hazards. The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions that are generally recognized as being aggravated by exposure to the chemical shall be listed on the MSDS. See Section 3.1 for the definition of health hazard. 5.3.4 Physical Hazards. The physical hazards of the hazardous chemical shall be listed on the MSDS. See Section 3.2 for the definition of physical hazard. 5.3.5 Exposure Route(s). The hazardous chemical’s primary route(s) of entry shall be listed on the MSDS. Chemicals may enter the body through the following routes: inhalation, ingestion, injection, and skin or eye contact. 5.3.6 Exposure Limits. The chemical manufacturer, importer, distributor, or employer preparing the MSDS shall include the OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the individual(s) preparing the MSDS. 5.3.7 Carcinogens. The chemical manufacturer, importer, distributor, or employer preparing the MSDS shall provide information that identifies carcinogens. OSHA cites the following three sources that list known or suspected carcinogens: • National Toxicology Program (NTP) Annual Report on Carcinogens • International Agency for Research on Cancer (IARC) Monographs • OSHA list of cancer suspect agents. 5.3.8 Safe Handling and Use. The chemical manufacturer, importer, distributor, or employer preparing the MSDS shall include precautions for safe handling and use of the hazardous chemical. The MSDS shall provide information on proper protective clothing and respiratory protection. Spill control and clean-up procedures shall also be provided on the MSDS. 5.3.9 Control Measures. The MSDS shall list applicable exposure control measures for the hazardous chemical. Exposure control measures may include the use of engineering controls (e.g., localized ventilation), safe working procedures, or personal protective equipment (e.g., respirators). 5.3.10 Emergency and First Aid Procedures. The MSDS shall provide emergency and first aid information. 5.3.11 Pertinent Dates. The MSDS shall provide the date of preparation or the date it was last revised. 5.3.12 Responsible Party. The MSDS shall have the name, address and telephone number of the chemical manufacturer, importer, distributor, employer, or other responsible party who prepared it. The individual who prepared the MSDS may then be contacted, if necessary, to provide additional information on the hazardous chemical or appropriate emergency procedures. Currently there are no OSHA regulations that standardize the format and quality of the information presented on an MSDS. ____________________________________________ 6.0 LABELING AND OTHER WARNINGS 6.1 Departmental Labeling Requirements Supervisors and principal investigators are responsible for ensuring that all containers of hazardous chemicals brought into their respective work areas are properly labeled and that containers and apparatuses filled in the work area are labeled as p. 6 Rev. 5-99 required. Each container and/or apparatus of hazardous chemical in the work area shall be labeled with the following information: • identity of the hazardous chemical(s), which may be a trade name, generic chemical name, or manufacturer’s code number of the product • hazard warnings in words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemical(s). The information contained on the label, in conjunction with MSDSs and a workplace hazardous chemical list, will provide employees with the specific information they need to work safely regarding the physical and health hazards of the hazardous chemical. Supervisors and principal investigators must ensure that labels on incoming containers of hazardous chemicals are not removed or defaced, unless the container is immediately marked with the required information. The department head supervising any person who is to vacate a laboratory or other work area must, prior to that person’s departure, ensure the proper disposition of all hazardous materials and the identification, containerization, and labeling of all substances before releasing or assigning the area to the next occupant. 6.2 Exemptions to Labeling A portable chemical container filled from a labeled container by an employee who uses it immediately or during his or her work shift does not have to be labeled. However, if any of the material is left at the end of the work shift, it must be labeled or returned to a labeled container. OSHA provides alternatives for hard-to-label chemical containers and for air emissions, such as in a welding area. Signs, placards, process sheets, batch tickets, or other such written material are suitable substitutes for labels on individual stationary process containers, where labels may be lost or difficult to read. The alternative label information must identify which container it refers to and be available to employees in the work area at all times. Pipes or piping systems do not have to be labeled. 6.3 Labeling Requirements for Manufacturers, Importers, and Distributors Chemical manufacturers, importers, and distributors must ensure that each container of hazardous chemicals leaving their workplace is labeled with the following information: • identity of the hazardous chemical(s), which may be a trade name, generic chemical name, or manufacturer’s code number of the product • appropriate hazard warnings in words, pictures, or symbols that adequately convey the health and physical hazards of the chemical ♦ If known, the specific target organ affected should be named in the hazard warning. ♦ If the substance attacks the brain, lungs, skin, or other organ, this must be indicated in the hazard warning. ♦ A warning of carcinogenicity is required for those chemicals known to be carcinogenic and those that may reasonably be anticipated to be carcinogenic by the National Toxicological Program and the International Agency for Research on Cancer. ♦ OSHA-regulated carcinogenic chemicals must be labeled according to the substance-specific standards. • name and address of the manufacturer, importer, or other responsible party. Any label that conveys the required information listed above, clearly and in English, is acceptable. Labels may also include other information, such as antidotes, first aid, advice to physicians, and storage and handling information. ____________________________________________ 7.0 WORKPLACE HAZARDOUS CHEMICAL LIST Department heads are required to ensure that a list of hazardous chemicals used in their departments is compiled and maintained. The list may be compiled for the department as a whole or for local work areas. The University’s Safety Plan requires laboratories (research and teaching) to compile a list of hazardous chemicals used in laboratories. The list of hazardous chemicals shall reference the hazardous chemical in the same manner as on the corresponding MSDS. The list shall be updated as necessary and be maintained in the designated work area’s Safety Desk Book. Faculty, staff, and students shall know the location and availability of the hazardous chemical list for their work areas. p. 7 Rev. 5-99 ____________________________________________ 8.0 HAZARDS OF NONROUTINE TASKS Department heads are required to ensure that faculty, staff, and students are aware of the hazards of nonroutine tasks (e.g., cleaning of reactor vessels, entering confined spaces). A special training session may be necessary to inform faculty, staff, and students of the hazardous chemicals to which they may be exposed and the proper precautions to take to reduce or avoid exposure. Department heads also must ensure that faculty, staff, and students are informed of the hazards associated with chemicals contained in unlabeled pipes in their work areas. ____________________________________________ 9.0 HAZARDOUS MATERIALS INFORMATION FOR CONTRACTORS The OSHA HCS requires Northwestern University to inform contractors about the Hazard Communication Program. The term contractor means any employer and his/her personnel working on a contractual basis with the University. Any work that contractors perform at the University must follow all applicable OSHA regulations. Department heads must supply contractors with a copy of the form Hazard Communication Program for Outside Contractors (Appendix D). 9.1 Departmental Responsibilities Department heads must inform contractors about the hazardous chemicals used or stored in their workplace to which the contractor’s employees may be exposed. Department heads must provide the following information to contractors: • on-site access to an MSDS for each hazardous chemical to which the contractor’s employees may be exposed while working in the department • any precautionary measures that need to be taken to protect the contractor’s employees during the department’s normal operating conditions and in foreseeable emergencies • labeling systems used in the department. 9.2 Reducing Employee and Community Risk to Chemical Exposure If the department head or ORS determines that the contracted work places the University or the community at risk from exposure to hazardous chemicals, contractors must adequately reduce that risk. The contractor must use the following measures to reduce faculty, staff, student, and community exposures to hazardous materials: • use break-resistant containers to transport, store, and use chemicals • label all chemical containers with the chemical identity and hazard warnings • provide ORS and client department access to MSDSs for all chemicals used at the work site • properly dispose of all hazardous waste created at the work site • contact the client department for safety information specific to the work site. ____________________________________________ 10.0 LABORATORY REQUIREMENTS The Hazard Communication Program has four requirements for laboratories. • • • Ensure that labels on incoming containers of hazardous chemicals are neither removed nor defaced. Maintain any MSDSs that are received with hazardous chemicals, and ensure that MSDSs for all hazardous chemicals in the work area are readily accessible to laboratory employees during the times they work in the laboratory and to emergency response personnel. Provide information and training to employees regarding the hazardous chemicals in their work area at the time of their first work assignment and again whenever a new health or physical hazard is introduced into their work area. Laboratory employees are to receive the same training as discussed in Section 4.0. Additionally, laboratory employees must understand and follow the standard operating procedures for the correct handling of hazardous chemicals as covered in Chemical and Biological Safety in Laboratories and their laboratory-specific Safety Plan. p. 8 Rev. 5-99 • Laboratories that produce a chemical and ship the chemical to another user outside of the laboratory must provide an MSDS and labels for chemical containers. If a new chemical is produced in the laboratory for which no MSDS and label is available, then there is no MSDS and label to provide. See Chemical and Biological Safety in Laboratories for further information regarding the hazards of chemicals used in laboratories. ____________________________________________ 11.0 ANNUAL CHEMICAL INVENTORY SARA Title III requires the University to submit annual chemical inventories to state and local agencies. Chemicals used in research laboratories are exempt from SARA Title III, but chemicals in teaching laboratories and common storerooms for research laboratories are covered by the standard. ORS will send a notification letter and an inventory form to unit heads on or around November 1 of each year. Each department must complete the supplied inventory form and return it to ORS no later than December 31. A separate inventory form should be used for each building, room, or outside location where hazardous chemicals are present. All inventory information requested on the form must be shown for each chemical, so that it can be easily incorporated into the combined University inventory. Inventory forms with incomplete information will be returned to the department for completion. ORS will compile the inventories, classify the chemicals, and submit the inventory report on or before March 1 to the Illinois Emergency Management Agency, the Evanston and Chicago emergency planning and notification committees, and the Evanston and Chicago fire departments. ____________________________________________ 12.0 SAFETY DESK BOOK As a means of organizing the information required to be available in the department, each department head is required to assemble a Safety Desk Book. The desk book must be readily available at all times to all faculty, staff, and students working in the department. Depending on the physical arrangement of the department, it may be appropriate to place copies of the Safety Desk Book at various locations. A Safety Desk Book is required in all research laboratories and teaching laboratories. A complete Safety Desk Book contains the following documents and information: • Bloodborne Pathogens Program • Chemical and Biological Safety in Laboratories • department evacuation procedures • First Aid Kit Policy and Guideline for Laboratories • Hazard Communication Program • Radiation Safety Handbook • Recombinant DNA Safety Program • Respiratory Protection Program • safety equipment inspection records • Safety Plan and Annual Reviews • Workplace Hazardous Chemical List and Material Safety Data Sheets • The Chemical Fume Hood Handbook • Training Records Safety Desk Books are distributed on request by ORS, at no cost. p. 9 Appendix A, Rev. 5-99 ____________________________________________ GLOSSARY OF TERMS, ABBREVIATIONS, AND ACRONYMS ACGIH: American Conference of Governmental Industrial Hygienists. Acute Effect: A health effect that occurs soon after a brief exposure to the offending agent. Carcinogen: A chemical that is capable of causing cancer. Under the HCS a carcinogen is any chemical that has been found to be a carcinogen or potential carcinogen by the International Agency for Research on Cancer, is listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program, or is regulated by OSHA as a carcinogen. Chemical and Biological Safety in Laboratories: The University’s general chemical hygiene plan, as required by the OSHA Laboratory Standard. Chronic Effect: A health effect that occurs over a long period of time as a result of continued or periodic exposure to the offending agent. Combustible Liquid: Any liquid having a flash point at or above 100° F (37.8° C), but below 200° F (93.3° C). Compressed Gas: (A.) a gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70° F (21° C); or (B.) a gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130° F (54.4° C) regardless of the pressure at 70° F; or (C.) a liquid having a vapor pressure exceeding 40 psi at 100° F (37.8° C) as determined by ASTM D-323-72. Corrosive: A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. Employee: An individual receiving a paycheck from the University. EPA: U.S. Environmental Protection Agency. Explosive: A chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature. Flammable: A chemical that catches on fire easily and burns readily. Hazardous Chemical: Defined by OSHA as any chemical that is a health hazard or a physical hazard. Hazard Warning: Any words, pictures, symbols, or combination thereof appearing on a label that convey the hazards of the chemical(s) in the container. Health Hazard: A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. Chemicals covered by this definition include carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, that which act on the hematopoietic system, and agents that damage the lungs, skin, eyes, or mucous membranes. Hematopoietic System: The body’s blood system, including the production and circulation of blood and the blood itself. Hepatotoxins: Chemicals that cause liver damage. HSC: Hazard Communication Standard (OSHA: Title 29 Code of Federal Regulations 1910.1200). Importer: The first business with employees working with the Customs Territory of the United States that receives hazardous chemicals produced in other countries for the purpose of supplying them to distributors or employers within the United States. Irritant: A chemical that is not corrosive but causes a reversible inflammatory effect on living tissue by chemical action at the site of contact. Label: Any written, printed, or graphic material displayed on or affixed to containers of hazardous chemicals. Material Safety Data Sheet (MSDS): Written or printed material concerning a hazardous chemical that includes information on the chemical’s identity; physical and chemical characteristics; physical and health hazards; primary routes of entry; exposure limits; whether the chemical is a carcinogen; precautions for safe handling and use; control measures; emergency and first aid procedures; the date of preparation of the MSDS or the last change to it; and the name, address, and telephone number of the manufacturer, importer, or employer distributing the MSDS. Mixture: A heterogeneous association of substances where the various individual substances retain their identities and can usually be separated by mechanical means. Includes solutions or compounds but does not include alloys or amalgams. MSDS: Material Safety Data Sheet. Nephrotoxins: Chemicals that cause kidney damage. Neurotoxins: Chemicals that produce their primary toxic effects on the nervous system. Organic peroxide: An organic compound that contains the bivalent -O-O-structure and may be considered to be a structural derivative of hydrogen peroxide where one or both of the hydrogen atoms has been replaced by an organic radical. p. 11 Rev. 5-99 OSHA: Occupational Safety and Health Administration. Oxidizer: A chemical other than a blasting agent or explosive that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases. Permissible Exposure Limit (PEL): An exposure limit that is published and enforced by OSHA as a legal standard. Physical Hazard: A chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water-reactive. Pyrophoric: A chemical that will ignite spontaneously in air at a temperature of 130° F (54.4° C) or below. Readily Available: To be quickly and easily accessible at any time for information and emergency use. Reproductive Toxins: Chemicals that affect the reproductive capabilities including chromosomal damage (mutations) or effects on fetuses (teratogenesis). Responsible Party: Someone who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary. Safety Desk Book: A central safety resource for the laboratory, shop, and department safety documents. Safety Plan: A laboratory-specific chemical hygiene plan required by the OSHA Laboratory Standard for research labs, teaching labs, and common facilities (those shared by more than one researcher). SARA Title III: Title III of the Superfund Amendments and Reauthorization Act, it is also known as the Emergency Planning and Community Right-To-Know Act (EPCRA). Sensitizer: A chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical. Threshold Limit Value (TLV): A time-weighted average concentration under which most people can work consistently for eight hours a day, day after day, with no harmful effects. The values are published in a table annually by the American Conference of Governmental Industrial Hygienists. Toxic: Causing acute or chronic injury to the human body or suspected of being able to cause disease or injury under some conditions. The HCS defines “toxic” and “highly toxic” specifically by the chemical’s median lethal dose and median lethal concentration for laboratory animals. Unstable (reactive): A chemical that in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shocks, pressure, or temperature. Water-reactive: A chemical that reacts with water to release a gas that either is flammable or presents a health hazard. Work area: A room or defined space in a workplace where hazardous chemicals are produced or used and where employees are present. Workplace: An establishment, job site, or project at one geographical location containing one or more work areas. p. 12 Appendix B, Rev. 5-99 ____________________________________________ HAZARD COMMUNICATION PROGRAM, RECORD OF REQUIRED TRAINING The OSHA Hazard Communication Standard requires employers to provide information and training to employees regarding the hazardous chemicals in their work area at the time of the employees’ first work assignment and again whenever a new health or physical hazard is introduced into the work area. The University’s Hazard Communication Program also requires that students be given the same information and training. Departments must keep records of the dates and subject matter of training sessions and names of those in attendance. This form is to be used for that purpose. Training records must be kept in the department and copies sent to Evanston ORS. Below is a list of required training topics to be included in departmental safety training. When appropriate insert the topic number(s) below on the reverse side to indicate the topic(s) covered in the training session. Initial Required Training For All Employees 1. Inform employees of the specific information and training requirements of the Hazard Communication Program. 2. Inform employees of the OSHA Hazard Communication Standard and their rights under the standard. 3. Inform employees of the University’s written hazard communication program, department Safety Desk Books, department evacuation plans, and emergency procedures. 4. Inform employees of any operations in their work areas where hazardous chemicals are present. 5. Train employees in the health and physical hazards of chemicals in the work area and the proper use and handling of them. 6. Inform employees of the hazards associated with performing any nonroutine tasks. 7. Train employees in the methods and observations that may be used to detect the presence or release of hazardous chemicals in the work area. 8. Train employees in proper work practices, personal protective equipment, and other controls to reduce or eliminate their exposure to hazardous chemicals. 9. Train employees in emergency procedures and signs and symptoms of overexposure to hazardous chemicals in the workplace. 10. Instruct employees on the use of a Material Safety Data Sheet (MSDS). 11. Inform employees of the location and availability of the MSDSs and the workplace hazardous chemical list. 12. Train employees to know when and how to update the workplace hazardous chemical list. 13. Explain labels and their hazard warnings and the requirements for proper labeling of containers holding hazardous chemicals. Additional Required Training 14. Inform employees of new hazards associated with the chemicals already in use in the workplace. 15. Inform employees of new health and physical hazards before introducing new hazardous chemicals into the workplace. p. 13 Appendix B, Rev. 5-99 ____________________________________________ RECORD OF REQUIRED TRAINING Dept./Ctr. Trainer (Name and Title) See instructions on reverse. Date Phone List code number(s) of topic(s) covered or identities of specific hazardous materials covered in the training: Signature Name Campus address Campus phone p. 14 Appendix C, Rev. 5-99 ____________________________________________ Complete Incomplete DEPARTMENTAL TRAINING CHECKLIST 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. Informed faculty, staff, and students of the specific information and training requirements of the University’s Hazard Communication Program. Informed faculty, staff, and students of the requirements of the OSHA Hazard Communication Standard and their rights under the law. Informed faculty, staff, and students of your department’s Safety Desk Book, Safety Plans, and evacuation procedures. Informed faculty, staff, and students of the different types of chemicals present in the workplace and the hazards associated with them. Established a thorough training program. Identified faculty, staff, and students who need training. Trained all new faculty, staff, and students before their first work assignment. Informed faculty, staff, and students of the specific hazards and proper use and handling of the chemicals and processes they work with. Ensured that faculty, staff, and students know how to detect the presence or release of hazardous chemicals in the workplace. Trained faculty, staff, and students in proper work practices, personal protective equipment, and other controls to reduce or eliminate their exposure to hazardous chemicals. Trained faculty, staff, and students in emergency procedures and signs and symptoms of overexposure to hazardous chemicals in the workplace. Developed procedures to identify and inform faculty, staff, and students of new health and physical hazards before they are introduced into the workplace. Established a system to identify and inform faculty, staff, and students of new hazards associated with the chemicals presently in use at the workplace. Established a system to inform faculty, staff, and students of the hazards associated with nonroutine tasks. " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " " 15. Developed a method for evaluating the effectiveness of the training program and for tracking attendees. 16. Kept training records of the dates and topics of training sessions, individual conducting the training, and names of those in attendance and sent copies to Evanston ORS. 17. Obtained MSDSs for each hazardous chemical in your workplace. 18. Listed all the hazardous chemicals in your workplace in a workplace hazardous chemical list. 19. Ensured that faculty, staff, and students know when and how to update the workplace hazardous chemical list. 20. Informed faculty, staff, and students of the location and availability of the workplace hazardous chemical list and MSDSs. 21. Instructed faculty, staff, and students on how to use an MSDS. 22. Explained labels and their hazard warnings to faculty, staff, and students. 23. Developed a system to ensure that all incoming containers of hazardous chemicals are properly labeled. p. 15 Appendix D, Rev. 5-99 ____________________________________________ HAZARD COMMUNICATION PROGRAM FOR OUTSIDE CONTRACTORS The Occupational Safety and Health Administration (OSHA) requires Northwestern University to inform contractors about the University’s Hazard Communication Program. This chemical safety program is concerned with the safety of University personnel and your employees. Any work that you perform at Northwestern University must follow all applicable OSHA regulations and the guidelines listed below. 1. It is the University’s policy to protect and support your employees from exposure to hazardous materials while they are working at the University. The department head or director is responsible for informing you of potential hazards and to remove or lower the risk of exposure to these hazards. Special care must be exercised by those working within a laboratory or servicing laboratory equipment. You and your employees must contact the department head or laboratory supervisor prior to working in a laboratory. If you feel that your University work site is unsafe because of hazardous chemicals, contact the department that hired you or the Office of Research Safety at (847) 491-5581 on the Evanston campus or (312) 503-8300 on the Chicago campus. To obtain Material Safety Data Sheets (MSDSs) for chemicals used at Northwestern University and to which you may be potentially exposed at a University work site, contact the department head or director who hired you or the Office of Research Safety. 2. If the department head or the Office of Research Safety determines that the contracted work might be hazardous to the University community, you must take appropriate measures to adequately reduce the risks. All hazardous chemicals that you may use at Northwestern University must be in “break-resistant” containers and labeled with the chemical identity and hazard warnings. You must provide access by University personnel to MSDSs for the hazardous chemicals used at the work site. You are responsible for properly disposing of any hazardous waste that is created by the contracted work whether or not such disposal is specified in the contract. Contact the department that hired you for more detailed information. Emergency Information for life-threatening Injury, Fire, Hazardous Chemical Spill or Release: • EVACUATE the area immediately in case of fire, explosion, or spill. • PULL FIRE ALARM, if available in immediate area, in case of fire or explosion. • CALL 911 (456 for non-emergencies). • WAIT for emergency personnel. • ASSIST emergency personnel. 3. Further information can be obtained by telephoning the Office of Research Safety at (847) 491-5581 in Evanston or (312) 503-8300 in Chicago. p. 17