ENVIRONMENT, HEALTH & SAFETY€¦ · Maintain documentation of the program and training records as...

ENVIRONMENT, HEALTH & SAFETY

GUIDELINE

Subject: Hazard Communication Program Date: 09-20-2018 Revision: 02 Page: 1 of 14

This guideline is created and issued by the Environment Health and Safety Department (EHS) to provide guidance and consistency in management of chemical containing products that are used by University of Michigan-Flint faculty, staff and students.

TABLE OF CONTENTS

SUMMARY

The purpose of this Guideline is to assure that all University of Michigan employees who use chemical-containing products in their work activities are instructed to work with them in a safe manner as required by Federal Regulation 29CFR 1910.1200 along with Michigan Regulation Part 42, 92, and 430 Hazard Communication Standard (HazCom). This program is modeled after the UM AA OSEH Hazard Communication Program https://ehs.umich.edu/working-safely/hazard-communication-hazcom/ . A Hazard Communication (HazCom) Program is necessary for communicating workplace chemical hazards to employees. This Guideline identifies departmental responsibilities and the necessary administrative oversight for managing the HazCom Program. A Model Hazard Communication Program has been attached in Appendix G to assist departments in writing a HazCom Program specific for their needs.

Section Page Summary 1 Scope 1 Reference Regulations 2 Definitions 2 Responsibility 4

Deans, Directors, Department Heads 4 Instructors and Principle Investigators 4 Employees 5 EHS 5 Departments Preparing Specification for Contractors

6

Program Components 6 Training 7 Hazardous Material Information 8 Related Documents 8 Appendix A: SDS Location Poster 9 Appendix B: New/Revised SDS Notification 10 Appendix C: Sample GHS Label 11 Appendix D: Sample Secondary Chemical GHS 12 Appendix E: Pictograms 13 Appendix F: Compatibility Chart 14

https://ehs.umich.edu/working-safely/hazard-communication-hazcom/

https://ehs.umich.edu/working-safely/hazard-communication-hazcom/

Subject: Hazard Communication Date: 09-20-2018 Revision: 02 of 20

SCOPE

This guideline applies to all University employees that utilize any hazardous chemicals as defined under the OSHA and MIOSHA Hazard Communication Standard. Laboratory workers are covered under the Laboratory Safety Standard Chemical Hygiene Program, which has similar requirements. Labs address Hazard Communication issues in their respective Chemical Hygiene Plans (CHP) and therefore are not required to have a written Hazard Communication program for their departments. Departments operating under the Lab Safety Standard should ensure operations are consistent with OH Part 431 Hazardous Work In Laboratories and Occupational Safety and Health Administration (OSHA) Laboratory standard (29 CFR 1910.1450) REFERENCE REGULATIONS:

State of Michigan Right To Know Law Act No. 80 Amendments to Act 154 Michigan Occupational Safety and Health Act (MIOSHA):

Construction Safety Standard Part 42 Hazard Communication

MIOSHA General Industry Safety Standard Part 92 Hazard Communication

MIOSHA Occupational Health Standard Part 430 Hazard Communication DEFINITIONS Chemical: Any element, chemical compound, or mixture of elements and/or compounds. Exposure to chemicals can be in a variety of forms such as; solids, liquids, gases, dusts, mists, or fumes. Chemical Hygiene Plan (CHP): The intent of a CHP is to protect employees from hazardous chemicals and promote a healthy and safe work environment. The CHP includes information to ensure that employees have working knowledge about the hazardous chemicals they use. The CHP is also intended to provide information on best practices in laboratory health and safety Exposure (or Exposed): means that an employee is subjected in the course of employment to a chemical that is a physical or health hazard and includes potential e.g. accidental or possible exposure. “Subjected” in terms of health hazards include any route of entry e.g. inhalation, ingestion, skin contact or absorption. Hazard Category: The division on criteria within each hazard class, e.g. oral acute toxicity, and flammable liquids include four categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally. Hazard Class: The nature of the physical or health hazards, e.g. flammable solid, carcinogen, oral acute toxicity. Hazard Not Otherwise Classified (HNOC): An adverse physical or health effect identified through evaluation of scientific evidence during the classification process that does not meet the specified criteria for the physical and health classes.

http://www.michigan.gov/documents/CIS_WSH_part_42__47164_7.pdf




Hazard Statements: Hazard statements are standardized and assigned phrases that describe the hazard(s) as determined by hazard classification. An appropriate statement for each GHS hazard should be included on the label for products possessing more than one hazard.

Hazard Chemical-any chemical which is classified as a physical hazard, or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified (HNOC). For example, compressed gas is considered a physical hazard and wood dust is considered a health hazard. Health Hazard: A chemical for which there is statistically significant evidence that acute or chronic health effects may occur. The term “health hazard” applies to chemicals which are:

Carcinogens

Toxic or highly toxic agents

Reproductive toxins

Irritants, corrosives

Sensitizers

Hepatotoxins (affects liver)

Nephrotoxins (affects kidneys)

Neurotoxins (affects nervous system)

Agents which act on the hematopoietic (blood-forming) system,

Agents who damage the lungs, skin, eyes, or mucous membranes. Label: An appropriate group of written, printed, or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or on the outside of packaging. Mixture: A combination or solution composed of two or more substances in which they do not react. Personal Protection Equipment (PPE): Devices worn by worker to protect against hazards in the environment. UM Flint refers to UM AA EHS Guideline-Personal Protective Equipment.

Eye Protection (goggles, safety glasses)

Lab Coats

Apron

Hand Protection (latex, nitrile gloves etc.)

Foot Protection (shoe covers, “booties”) Physical Hazard: A chemical that is classified as a posing on of the following hazardous effects:

Explosive

Flammable (gases, aerosols, liquids, or solids)

Oxidizer (liquids, solids, or gas)

Self-reactive

Pyrophoric (liquid or solid)

Self-heating

Organic peroxide

Corrosive to metal


Gas under pressure

In contact with water emits flammable gases Pictograms: A composition that may include symbols 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. Eight mandatory pictograms and one non-mandatory pictogram that are designated under the MIOSHA standard for application to a particular hazard category (see appendix E). Precautionary Statement: A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from the exposure to a hazardous chemical or improper storage or handling. Pyrophoric Gas: A chemical in a gaseous state that will ignite spontaneously in air at a temperature of 130oF (54.4oC) or below. Safety Data Sheet (SDS): Formerly known as Material Safety Data Sheet (MSDS). The SDS is a written or printed material concerning a hazardous chemical that serves as an informational tool developed by chemical manufactures containing the following information for a hazardous chemical:

Product Identification

Use Restrictions

Hazard Identification

Chemical Ingredients

First-aid Measures

Fire-fighting measures

Accidental Release Measures

Handling and Storage Information

Physical and Chemical Properties

Stability and Reactivity Information

Toxicological Information SDS are in a standardized, 16 section format and can be obtained from the chemical suppliers and many internet sites. Signal Words: The signal word indicates the relative degree of severity a hazard. The signal words used in the GHS are

"Danger" for the more severe hazards.

"Warning" for the less severe hazards. Signal words are standardized and assigned to the hazard categories within endpoints. Some lower level hazard categories do not use signal words. Only one signal word corresponding to the class of the most severe hazard should be used on a label. Simple Asphyxiant: A substance or mixture that displaces oxygen in the ambient atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to unconsciousness and death.

Substance: Chemical elements and their compounds in the natural state or obtained by any production process, including any additive necessary to preserve the stability of the product and any impurities


deriving from the process used, but excluding any solvent which may be separated without affecting the stability of the substance or changing its composition. Trade Secrets: Any confidential formula, pattern, process, device, information or compilation of information that is used in an employer’s business and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it. Use: To package, handle, react, emit, extract, generate as a byproduct or transfer. RESPONSIBILITIES:

This program applies to employees, faculty, including student’s workers, temporary, graduate assistants and contract employees under the direct supervision of department employees, who may come into contact with or be exposed to hazardous materials at the workplace while performing their normal duties or during emergency conditions. It also applies to those who are involved in the purchase, transportation, or storage of hazardous materials.

Deans, Directors and Department Heads:

Designate and empower supervisors who will be responsible for the preparation and implementation of the Hazard Communication Program within each work unit.

Actively support this program within individual units.

Ensure an environment where all staff, student employees, and faculty are encouraged to follow this program.

Supervisors:

Implement procedures in accordance to this Guideline.

Ensure that employees are aware of this Guideline, instructed on the details of implementation and provided by supervisors and/or EHS regarding Hazard Communication.

Ensure that employees are instructed on the details of implementation and provided equipment and methods of control.

Maintain documentation of the program and training records as required.

Contact EHS to request initial training, technical assistance, and to evaluate health and safety concerns with their unit.

Employees and Student Workers (as defined above):

Familiarize themselves and comply with hazard warnings, hazard labels, and SDS’s so they can use this information where needed.

Comply with this program and any further safety recommendations provided by supervisors and/or EHS regarding Hazard Communication.

Conduct assigned tasks in a safe manner.

Wear appropriate personal protective equipment (PPE).

Obtain training and/or information prior to using unfamiliar chemicals.


Environment, Health and Safety:

Document and administer the Hazard Communication Program

Provide training to supervisors and employees upon request, and maintain records of EHS provided training.

Assist departments in the selection of PPE for routine or non-routine activities, when requested.

Assist UM-Flint Departments in providing vendors and contractors with information about hazardous chemicals that their employees may be exposed to on the job site, and suggested precautions.

Assist in obtaining information about hazardous chemicals used by UM-Flint employees and students which contractors might be exposed to.

Maintain a comprehensive file of SDS for hazardous chemicals provided to EHS by individual departments for products used and stored at the university.

Serve as a university liaison for local, county, state and federal agencies regarding safety issues.

Review and revise the Hazard Communication Program as necessary to comply with government regulations.

Departments Preparing Specifications for Contractors: (Facilities & Operations, ITS, Procurement, etc.)

Inform contractors of any hazardous chemicals located in the contracted work area and the precautionary measurements to be taken to protect employees during normal operations and foreseeable emergencies.

Inform contractors they must provide SDS for all hazardous materials they propose to bring, use or store on campus, prior to beginning work.

Inform contractors that they are required to maintain SDS on site for all hazardous materials brought onto university property.

Inform contractors that they must comply with all other University of Michigan contractor safety requirements.

PROCEDURES: The written Hazard Communication Program is necessary to describe the chemical hazards present in the workplace and how these hazards will be communicated to the employees. A Model Hazard Communication Program is included with this Guideline in Appendix G to provide assistance in preparing individualized documents. The components of this written program must include:

1. A list of all hazardous chemicals located in the workplace. 2. Methods to ensure containers of hazardous chemicals are clearly labeled with the identity of the

material, as well as the appropriate hazard warnings. 3. Methods to be utilized for acquiring and maintaining SDS for each listed hazardous chemical.

The MIOSHA SDS Locator sign (Appendix A) identifying the location and the responsible person for obtaining the SDS must be posted in the workplace. The Michigan Safety and Health Protection on the Job Poster must also be posted. At UM-Flint, these are posted outside the

http://www.michigan.gov/documents/dleg/wsh_cet2010_273203_7.pdf



University Human Resources Department in 213 University Pavilion. The MIOSHA SDS Locator Poster may also be posted in individual departments where chemicals are used or stored.

4. Notifications of new and revised SDS must be posted in the workplace 5 days after receipt and remain in place for 10 days. The MIOSHA New or Revised SDS Poster (Appendix B) can be utilized for this purpose.

5. SDS are considered to be a source of employee exposure records, and must be maintained for at least 30 years, unless records of the chemical name, where and how it was used are maintained for at least 30 years.

6. The SDS must comply with government regulations and be available for employee use. Methods for obtaining SDS include contacting the manufacturer or supplier of the chemical or utilizing various SDS resources provided on the EHS website such as the ChemGold III (CG3) SDS Database & Search Engine and repository program : https://ehs.umich.edu/research-clinical/chemical/safety-data-sheets/

7. Hazardous chemical information and training must be readily available to employees and student workers at the time of the initial assignment and whenever new hazardous chemicals are introduced to the work area. The hazardous associated to the use of chemicals used in a non-routine manner (a manner other than what they were originally intended for) and the hazards associated with performing non routine or emergency tasks associated to an operation e.g. cleaning reactor vessel, entering confined spaces, etc. must be included as well. EHS can provide technical assistance, information, and training materials to assist departments with compliance.

8. Contractors must be informed of the presence of hazardous chemicals that they may encounter while at the university and contractors must provide the university with SDS for products they intend to use during the university projects that contain hazardous chemicals.

9. Pipes and piping systems containing a hazardous chemical must be identified by a label, sign, placard, or written operating procedures.

TRAINING Initial Training Training can be presented in a formal classroom setting using videotapes and lecture methods or it can be an informal on-the-job discussion of the required training information. With either method, the training must be documented and records maintained for not less than 30 years. For employees, faculty or student workers whose duties require them to work with or around hazardous materials, initial training shall be provided by department or EHS before they begin their work assignment. This training will cover at a minimum the following topics:

1. Overview of Hazard Communication regulations, including employees' rights under the regulations.

2. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area. Examples include air monitoring devices, visual appearance, or odor.

3. The physical and health hazards of the chemicals typically found in work areas. 4. How to read warning labels and identify the presence or release of hazardous materials. 5. The measures employees can take to protect themselves from the hazards. Examples include

appropriate work practices, emergency procedures and personal protective equipment.

https://www.michigan.gov/documents/dleg/wsh_cet2105_219990_7.pdf



https://ehs.umich.edu/research-clinical/chemical/safety-data-sheets/



6. Emergency procedures for spills/accidents, including fire hazards, first aid, clean-up, and disposal, protecting storm drains.

7. Location and availability of this Hazard Communication Program, including hazardous materials lists and SDS’s.

8. How to read an SDS and use it to identify (at a minimum) a. Physical and Health Hazards b. First Aid Procedures c. Protective Measures d. Storage and Handling Procedures e. Spill Response Procedures

9. Details of the HazCom Program include identifying operations where hazardous chemicals are present, the location and availability of the written program with the list of hazardous chemicals present and the SDS, an explanation of the labeling system, and how employees can use the hazard information.

Training videos and other training materials are available from the EHS office at 810-766-6763. When contacted, the EHS will coordinate/schedule hazard communication training for employees, students and others. Site-Specific Training Site specific training shall also be provided on an as-needed basis by the department or supervisor as new hazards are introduced into the workplace and for hazards that are newly discovered (For example, if a new solvent is brought into the workplace, and it has hazards similar to existing chemical for which training has already been conducted, no new training is required). It is responsibility of the supervisor to coordinate this training. Training for Non-Routine Tasks Periodically, employees, and student workers are required to perform non-routine tasks which may involve hazardous materials. Before starting work on such projects, affected employees shall be given information by their supervisor or PI about the hazards to which they may be exposed. If hazardous non-routine tasks need to be performed by employees, site specific training will be held. HAZARDOUS MATERIAL INFORMATION

A. All purchases of hazardous materials must include the SDS with delivery. B. A list of workplace hazardous materials can be found in departmental SDS binders and or files

and when forwarded to EHS entered into the campus chemical inventory data base. C. Safety Data Sheets can also be obtained online at the following web site:

https://ehs.umich.edu/research-clinical/chemical/safety-data-sheets/ D. Departments must maintain hard copy of SDS and also forward copy to the EHS department.

Postings Signs must be posted in the workplace to notify employees of the following: (See Appendix A and B)

The location of the SDS and the name of the person from whom to obtain the sheets.

The employer is prohibited from discharging or discriminating against an employee who exercises the rights regarding information about hazardous chemicals in the workplace.



The MIOSHA SDS locator poster and the MIOSHA New or Revised SDS Poster that notifies employees of new or revised SDS are posted at various locations across the university campus. (See Appendix A and B)

In the event of an emergency call: UM-Flint Department of Public Safety 9-1-1 from any campus telephone or (810)-762-3333

Contact EHS at (810)-766-6763 WARNINGS & LABELING All containers of hazardous materials are to be labeled with the following information:

Product Identifier

Signal word

Hazard Statement(s)

Pictograms(s)

Precautionary statement(s)

Name, address, and telephone number of chemical manufacture, importer, or other responsible party.

Emergency Contact Information If a secondary container is used, it must be labeled with either a copy of the original label or with appropriate generic labels, as long as all required information is transferred to the blank generic label. Required information for secondary/portable containers:

1. Product Identifier- use the common chemical name. Abbreviations not acceptable. 2. Health/Physical Hazards – use general hazard word (e.g. carcinogenic; flammable; corrosive etc.) 3. Optional Items-include GHS pictograms, other graphics, symbols. (e.g. use a flame symbol for

flammable, combustible does not necessarily GHS flame pictogram.) 4. For small containers, where it would be difficult to attach a legible label a tag may be utilized or

labeling a rack or other container of smaller containers may be used. All warnings and labels must be legible, in English, and prominently displayed on containers, or readily available in the work area throughout each work shift. For example of labeling requirements see Appendix C

RELATED DOCUMENTS:

Hazardous Work in Laboratories; Chemical Hygiene Plan (CHP) Personal Protective Equipment, General Guideline UM-Flint Emergency Response Plan Appendix A: SDS Location Poster

Appendix B: New or Revised SDS Poster – to be posted in areas where chemical products are used.

Appendix C: Sample GHS Label

Appendix D: Sample GHS Labels for Secondary/Portable Containers

Appendix E: Reference Pictogram Labels Appendix F: Reference Chemical Compatibility Chart

Appendix G: Hazard Communication Program- Model Program for Department’s Use




Appendix A: MIOSHA SDS Locator Poster – to be posted in common areas where chemical products

are used or stored.


Appendix B: New or Revised SDS Poster – to be posted in areas where chemical products are used or

stored.


Appendix C: Sample GHS Label


Appendix D: Sample GHS Label for Secondary/Portable Containers

Print your own GHS compliant labels in different sizes using the Chemgold System available UM-Flint EHS website: http://jr.chemwatch.net/chemgold3/?X. Click on Label button on left side of screen, enter chemical name and manufacturer.

http://jr.chemwatch.net/chemgold3/?X


Appendix E: Pictogram Labels


Appendix F: Compatibility Chart


Appendix G: Hazard Communication Program – Model Plan (Customize the red, italicized portions within each particular section of this Model Plan)

Purpose

Designated Responsibilities

Written Hazard Communication Program

1. Hazardous Chemical List

2. Labels and Hazard Warnings

3. Safety Data Sheets (SDS)

4. Non-Routine Tasks and Unlabeled Piping

5. Departments Preparing Specifications for Contracted Work or Hiring Contractors

6. Postings

7. Employee Information and Training

HazCom Review/Revision Sheet

SDS Access Sites

Glossary of Common SDS Terms

PURPOSE The purpose of this Hazard Communication (“HazCom”) Program is to inform employees working for the

Name of Department of the chemical hazards present in their work environment and ways to protect

themselves during normal operations and during foreseeable emergencies. The program identifies

departmental responsibilities for ensuring a safe and healthful work environment for all employees

located in Building Name(s) or Area.

DESIGNATED RESPONSIBILITIES The person responsible for the implementation of the Hazard Communication Program for Department

Name is Responsible Individual. Responsibilities include compliance with the components of this

document, including completion, review and maintenance of the specific written HazCom program.

Other responsibilities that need to be addressed include; general employee training, specific task

training, obtaining and maintaining Safety Data Sheets (SDS), assuring proper labeling of chemical

products. This can be written out in text or table format.

WRITTEN HAZARD COMMUNICATION PROGRAM All of the following items must be included in the written program:

1. Hazardous Chemical List

A list of hazardous chemicals used in the workplace and location(s) in building(s) where they are

present.

State how this list will be maintained and updated, who is responsible, providing it to EHS, and

how it will be made available. Example: Updating the UM-Flint Chemical Inventory for your

department and maintaining a list in the department for employees to view at a specific

location. Arrangement of the list could be alphabetically by product or manufacturer or both.

2. Labels and Hazard Warnings

Proper labeling of hazardous chemical containers must be assured at the time of receipt and

periodically thereafter. Proper labeling will include the identity of the chemical,

pictograms/pictures and the hazard warnings appropriate for employee protection. Portable,

secondary or in-house workplace containers must be labeled with the same label that would be on

http://www.oseh.umich.edu/hazcomappb.pdf


shipped containers for the chemical or with a product identifier and words, pictures, symbols, or

combination thereof, which provide at least general information regarding the physical & health

hazards of the chemicals.

Alternative labeling systems such as the National Fire Protection Association (NFPA) 704 Hazard

Rating and the Hazardous Material Information System (HMIS) are permitted for workplace

containers. However, the information supplied on these labels must be consistent with the revised

HCS, e.g., no conflicting hazard warnings or pictograms.

State who will be responsible for this, what type of system will assure that this procedure is

followed at the time of receipt and periodically thereafter.

The labels must be legible, in English, and prominently displayed. All pipes and piping that

contain hazardous contents must be labeled according to the U-M Design Guidelines developed

and maintained by Architecture, Engineering and Construction (AEC). Information can be found

in AEC’s Design Guideline, Section 15190: Mechanical Identification and Painting. On the

UM-Flint campus, Facilities & Operations would be responsible for labeling of pipes.

3. Safety Data Sheets (SDS)

SDS must be obtained for all hazardous chemicals that are brought into the facility. SDS must be

maintained for employee access. SDS for new chemicals must be posted no later than five (5)

days after receipt and remain in place for ten (10) days. SDS are considered to be a part of

employee medical records and therefore must be maintained for at least 30 years. SDS for

materials no longer used or stored should be kept in an “archived” section of each facility’s SDS

binder.

Methods for obtaining SDS include contacting the manufacturer or supplier of the chemical

directly or utilizing various SDS databases noted on EHS’s Safety Data Sheet webpage. Refer to

the instructions for accessing these SDS databases on EHS webpage.

In lieu of maintaining hard copies of SDS, electronic versions of a Department’s SDS can also be

obtained within ChemWatch’s ChemGold III (CG3) SDS repository program. Instructions for

using this program as well as for creating Departmental SDS folders can also be found in EHS’

Safety Data Sheet webpage.

Users of the MI Safety Portal Chemical Inventory system can also associate (link-to) on-line SDS

location information for the chemicals they are tracking with this system. Refer to the

information provided within EHS’s Chemical Inventory webpage, UM Ann Arbor EHS webpage,

or contact EHS for more information 810-766-6763.

Describe specifically who will be responsible for collecting and maintaining the SDS, the

location of the SDS, and how employees can access them.

4. Non-Routine Tasks and Unlabeled Piping (Delete this Section if not applicable.)

Whenever hazardous chemicals are to be used in a non-routine manner (a manner other than what

it was intended) or when performing non-routine tasks associated to the operation, e.g., cleaning

reactor vessels, entering confined spaces, etc., knowledgeable Departmental staff should be

consulted for overall safety considerations prior to performing the operation(s).

https://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html


https://www.umflint.edu/ehs/chemical-inventory-system


The hazards associated with these non-routine tasks must be reviewed with the employee prior to

beginning the task. EHS staff is available to evaluate non-routine tasks and provide hazard

information to the department and employee.

Non-routine hazard information to provide employees will include (as applicable):

Specific chemical hazards.

Personal protection and safety measures the employee can take to lessen risks of performing

the task.

Measures that have been taken to eliminate or control the hazard, including, but not limited

to:

o air monitoring,

o ventilation requirements,

o use of respirators,

o use of attendants to observe procedures, and

o emergency procedures.

Additional details regarding confined spaces can be found on EHS’s webpage.

Employees working in areas that contain hazardous chemicals in piping must be informed of the

contents and provided with appropriate hazard information.

State how the above items will be addressed.

5. Departments Preparing Specifications for Contracted Work or Hiring Contractors

When contractors are working for the University, they must be informed of any hazardous

chemical they may come into contact within the project area. The contractor, in turn, must inform

the University of any hazardous chemicals they intend to use while on University property and

provide the appropriate SDS. Both parties must be aware of the necessary measures to be taken

during normal operations and foreseeable emergencies. The university’s purchasing department

includes this requirement in their contract and PO documents with the Contractor

State the procedures that will be followed to assure that contractors are informed of the

presence of hazardous chemicals in their work areas and the necessary measures to be taken

during normal operations and forseeable emergencies. State what mechanisms will be utilized

to assure that the University is informed of any hazardous chemicals the contractor brings on-

site and that the SDS(s) are available.

6. Postings

Signs must be posted in the workplace to notify employees of the following:

a) The location of the SDS and the name of the person from whom to obtain the sheets.

b) The employer is prohibited from discharging or discriminating against an employee who

exercises the rights regarding information about hazardous chemicals in the workplace.

c) The Michigan Occupational Safety and Health Administration (MIOSHA), part of Michigan’s

Department of Licensing and Regulatory Affairs, can be contacted for assistance in obtaining

SDS.

http://www.michigan.gov/dleg/0,1607,7-154-11407---,00.html


The SDS locator poster and the poster that notifies employees of new or revised SDS are posted

at Note the location(s) of these posters.

The blank MIOSHA SDS locator posters can be downloaded from the MIOSHA website:

https://www.michigan.gov/lara/0,4601,7-154-11407_30453-174563--,00.html

7. Employee Information and Training

Consider what methods of information and training would be best suited for the needs of the

department, who will be responsible for and conduct the training, how will this be implemented

and maintained for new hires and/or new chemical usage, and who will be responsible for

maintaining documentation of the process. Options of online training, classroom training and

a combination are available.

The contents of the Hazard Communication training must be documented in the written

program and contain at a minimum the following information:

a. Methods and observations that may be used to detect the presence or release of a hazardous

chemical in the work area. Examples include, air monitoring devices, visual appearance or

odor.

b. Physical and health hazards of the chemicals present in the work area.

c. Measures employees can take to protect themselves from these hazards. Examples include,

appropriate work practices, emergency procedures, and personal protective equipment (PPE).

d. Details of the HazCom Program, including identifying operations where hazardous chemicals

are present, the location and availability of the written program with the list of hazardous

chemicals present and the SDS, an explanation of the labeling system, and how employees can

use the hazard information.

For additional compliance assistance, a guidance document is available on the MIOSHA website: Right

to Know (RTK) Hazard Communication Compliance Guideline (SP #22).

A HazCom review/revision sheet is also included below that can be used to document the regular, i.e.,

annual, reviews of the written program.

https://www.michigan.gov/lara/0,4601,7-154-11407_30453-174563--,00.html

http://www.oseh.umich.edu/pdf/guideline/ppe_guideline.pdf

http://www.michigan.gov/documents/lara/lara_miosha_cetsp22_379146_7.doc

http://www.michigan.gov/documents/lara/lara_miosha_cetsp22_379146_7.doc


HazCom Review / Revision

(Complete this page, after each HazCom review or revision.)

Name (print) Signature Date

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

________________________ _________________________ ______________________

ENVIRONMENT, HEALTH & SAFETY€¦ · Maintain documentation of the program and training records as...

Documents

Transcript of ENVIRONMENT, HEALTH & SAFETY€¦ · Maintain documentation of the program and training records as...