Hazard Communication Policy

Purpose

The purpose of the policy is to inform employees of the potential hazards of the chemicals/chemical-containing products in use or storage at Calvin. The communication of hazards is to be accomplished through appropriate container labeling, safety data sheets, education and training.

Definitions

ACUTE: Effects that occur rapidly as a result of short-term exposures, and are of short duration.

CHRONIC: Effects that are long-lasting and recurring

COMBUSTIBLE LIQUID: Any liquid having a flashpoint at or above 100ºF (37.8º C), but below 200ºF (93.3ºC), except any mixture having components with flashpoints of 200ºF (93.3ºC), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.

FLAMMABLE: A chemical that gives off vapors which readily ignite under normal working conditions.

FLASHPOINT: The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite.

GLOBAL HARMONIZATION SYSTEM: The GHS is a system for standardizing and harmonizing the classification and labelling of chemicals. It is a logical and comprehensive approach to:

• Defining health, physical and environmental hazards of chemicals;
• Creating classification processes that use available data on chemicals for comparison with the defined hazard criteria; and
• Communicating hazard information, as well as protective measures, on labels and Safety Data Sheets (SDS).

OSHA has adopted new hazardous chemical labeling requirements as a part of its recent revision of the Hazard Communication Standard, 29 CFR 1910.1200 (HCS), bringing it into alignment with the United Nations’ Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

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. The term “health hazard” refers to chemicals that may have one or more of the following effects:skin corrosion or irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, irritants, specific target organ toxicity, or aspiration hazard.

SAFETY DATA SHEET (SDS): A Safety Data Sheet is a technical bulletin detailing health and safety information about hazardous substances. A SDS tells employees about the hazards of substances used in their work locations and the safety precautions that should be taken when handling them.

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.

PHYSICAL HAZARD: A chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, and organic peroxide, an oxidizer, pyrophoric, reactive, or water reactive.

PICTOGRAM: a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical or product. Eight mandatory and one nonmandatory pictograms (shown below) are designated under the MIOSHA standard.

REACTIVE (UNSTABLE): A chemical which 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.

SIGNAL WORD: a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard. The signal words used are “Danger” or “Warning” – danger is used for the more severe hazard, while warning is used for the less severe.

Responsibilities

• Environmental Health & Occupational Safety
  • Ensure initial training at time of hire
  • Conduct refresher training as needed
  • Review the policy and procedure annually
  • Assure that signs are posted throughout campus notifying employees of SDS location in accordance with Act No. 80 of the Public Acts 1986
  • Ensure posters identifying the person responsible for maintaining SDSs and where the SDSs are located are posted within each department.
  • Ensure that new or revised SDS are posted on the MIOSHA “New or Revised SDS” signs
  • Maintain a list of hazardous chemicals and ensure availability to all employees
• Department Representatives
  • Ensure containers entering the department are properly labeled (identity, hazard rating, pictograms, signal word, hazard statement)
  • Maintain SDS binders and ensure accessibility; or ensure that your department’s data sheets have been uploaded to Calvin’s online system, msdsonline.com
  • For a detailed listing of Department Representatives, see Appendix A
• All Employees
  • Follow the policy and procedure
  • Any employee who orders a chemical shall request a SDS be sent with the order from the supplier
  • Forward a copy of the SDS to EHS for review
  • Ensure portable containers used in the work area are labeled with the appropriate identity and hazard warning
  • Do no remove or deface labels on containers unless immediately marked prominently and legibly with the appropriate information

Procedure

• Requesting a SDS
  SDSs will be available for review to all employees during each work shift. Copies will be available upon request to the Environmental Health and Safety Office (EH&S). Many departments have their sds’ available online at msdsonline. Employees are welcome to search for data sheets on this website anytime.
• If a required SDS is not received, the responsible person of the department shall contact the supplier, in writing, to request the SDS. If an SDS is not received after two such requests, the Environmental Health and Occupational Safety Office shall contact the MIOSHA Occupational Health Division (OHD) at (517) 322-1608, or General Industry Safety Division (GISD) at (517) 322-1831, for assistance in obtaining the SDS.
• New Products and Archiving SDS – See Appendix B
• Multi-Employer Worksites
  • If Calvin University exposes any employee of another employer to any hazardous chemicals that we use or store, the following information will be supplied to that employer:
    • The hazardous chemicals they may encounter.
    • Measures their employees can take to control or eliminate exposure to the hazardous chemicals.
    • The container and pipe labeling system used on-site.
    • Where applicable SDSs can be reviewed or obtained.
  • Periodically, our employees may potentially be exposed to hazardous chemicals brought on our site by another employer. When this occurs, we will obtain from that employer information pertaining to the types of chemicals brought on-site, and measures that should be taken to control or eliminate exposure to the chemicals. The contractor will also indicate the area(s) that are intended for chemical use and the location(s) and method(s) of storage for the chemicals. The contractor is responsible for the removal of all unused portions of the chemicals and their waste products.
  • It is the responsibility of EH&S to ensure that such information is provided and/or obtained prior to any services being performed by the off-site employer. To ensure that this is done the following mechanism will be followed:
    1. Chemical Notification All chemical materials to be used on Calvin University property must first be approved by the Director of Physical Plant and/or Environmental Health and Safety Officer.
    2. Labeling All containers of hazardous materials brought onto Calvin University property by the Contractor shall be properly labeled. Similarly, where such hazardous materials are then transferred to a secondary container, a label shall be so affixed to the receiving container. All such labels shall include information that identifies the product, health and physical hazard warnings and provides safe handling instructions.
    3. Safety Data Sheets (SDS) Safety Data Sheets containing required information on any and all hazardous materials used or produced by the Contractor on Calvin University property shall be in the possession of the Contractor at all times while on site, and made available upon request to affected Calvin University employees for their examination. Safety Data Sheets shall disclose information about the hazards, possible health effects and protective measures associated with the use of the hazardous material.
  • In accordance with the requirements of the MIOSHA Hazard Communication Standard, Calvin University maintains files of Safety Data Sheets (SDS) on chemical substances in the facility. If a Contractor or its employees should have a question regarding any chemical they may come in contact with, a SDS on that chemical should be reviewed. SDS’s can be obtained from the Environmental Health and Occupational Safety Officer upon request.
• Hazardous Non-Routine Tasks
  • Occasionally, employees are required to perform non-routine tasks (i.e. enter confined spaces, etc.). Prior to starting work in such areas, each employee will be given information about the hazards of the area or procedure. This information will include:
    • Specific chemical hazards.
    • Protection/safety measures the employee can take to lessen risks of performing the task.
    • Measures the company has taken to eliminate or control the hazard, including:
      • air monitoring,
      • ventilation requirements,
      • use of respirators,
      • use of attendants to observe procedures, and
      • emergency procedures
    • It is the policy of Calvin that no employee will begin performance of a non-routine task without first receiving appropriate safety & health training.
    • It is the responsibility of the supervisor to ensure that the employee receives the necessary training prior to beginning the task. Assistance in evaluating hazards of non-routine tasks and determining the appropriate precautions and protective measures is available through EH&S.
• Pipes and Piping Systems
  • Information on the hazardous contents of pipes and piping systems will be identified by label, sign, placard or written operating instructions.
  • Natural gas, steam and compressed air lines (with pressures exceeding 25 psig) will be identified in accordance with ANSI A13.1-198.
    • ANSI recommends the following colorations: blue for low-medium pressure oxygen and compressed air lines, yellow for variable-high pressure oxygen and compressed air lines, and yellow for acetylene and natural gas lines.
  • Calvin University will label pipes according to this ANSI standard in new construction and as buildings are remodeled. As work load permits existing pipes will be labeled accordingly.

Training

• EHS shall coordinate and maintain records of employee hazard communication training, including attendance rosters (when applicable).
• Before their initial work assignment, each new employee will complete a New Employee Phase 2 training module, which includes training on hazard communication. After each new employee completes the module he will meet with his supervisor and receive job specific hazard communication training. The combination of these two training resources will cover:
  • The requirements of the MIOSHA Hazard Communication Standard
  • All operations in the work area where hazardous chemicals are present
  • Location and availability of the written hazard communication program, the list of hazardous chemicals, and the SDS
  • Methods and observations that can be used to detect the presence or release of hazardous chemicals in the work area
  • Physical and health hazards of the hazardous chemicals
  • Measures the employee should take to protect themselves from these hazards
  • Details of the hazard communication program including explanation of labeling system and SDSs and how employees can obtain and use hazard information
• Before any new physical or health hazard is introduced into the workplace, each employee who may be exposed to the substance will be given information on the measures necessary to protect themselves from these hazards.