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Injury Illness and Prevention Program: Hazard Communication Program Policy

Policy Statement

It is the policy of the University of California Santa Cruz that all staff who may come into contact with hazardous chemicals in the work place receive information concerning the hazards which may be posed, and the methods by which they may deal with such materials in a safe and healthful manner. To implement this policy, all non-laboratory facilities using or storing hazardous materials must develop and use a Hazard Communication Program (Haz Com) to provide required information to employees. This policy identifies roles, responsibilities and required elements of the Hazard Communication Program. Laboratories are covered separately under the Chemical Hygiene Program.

References: Title 8 California Code of Regulations Section 5194, 29 CFR. 1910.120. 29

Definition:

Hazardous Materials: chemical substances which are physical or health hazards. Typical examples are: flammable liquids, corrosives, explosives, radioactive materials, compressed gasses, poisons, oxidizers and materials on the following lists:

  1. Director's list of hazardous substances, 8 CCR 339.
  2. Toxic and Hazardous Substances List, 29 CFR 1920, Subpart Z.
  3. Threshold Limit Values for Chemical Substance in the Work Environment, American Conference of Governmental Industrial Hygienists, 1984.
  4. Third Annual Report on Carcinogens, National Toxicology Program, 1984.
  5. Monographs, International Agency for Research on Cancer, Volumes 1-34
  6. Any other chemical with recognized hazardous properties.

Safety Data Sheets (SDS) are information sheets provided by the manufacturer or distributor of products containing hazardous materials. These sheets contain information about the physical and chemical properties of the hazardous ingredients as well as important health information.

Laboratory:

Note: If you need assistance to determine if you meet the legal definition of a laboratory, contact EH&S.

Responsibilities:

IIPP coordinator

The Injury and Illness Prevention Coordinator (IIPP) is charged with making reasonable efforts to institute the IIPP in their departments. The Haz Com Program is a part of the IIPP. The IIPP coordinator, in consultation with the department supervisor, may elect to implement the Haz Com program or to assign all or part of it to suitably qualified staff in their department. The IIPP coordinator does retain responsibility for monitoring implementation of the Haz Com Program. The ultimate responsibility for ensuring implementation of health and safety programs in their department is the department head.

Supervisors 

The supervisor has the ultimate responsibility for ensuring safe work practices are followed in areas under their supervision. Implementation of the hazard communication program is a critical part of that responsibility.

Hazard communication Implementation designee(s)

  1. Ensure implementation of the program.
  2. Develop and post a list of all chemicals containing hazardous substances within their department.
  3. Ensure all employees are trained to work safely with chemicals.
  4. Monitor employees to ensure compliance with safe work practices.
  5. Identify those work areas and employees, which involve the potential use of or exposure to hazardous substances.
  6. Collect and make available all MSDSs for hazardous substances used in the work place.
  7. If an MSDS is not available, contact EH&S.
  8. Review incoming MSDSs for completeness and any new or revised information.
  9. Ensure that all chemical containers are properly labeled.

Employees

  1. Follow all safe work practices, including use of appropriate PPE.
  2. Read and understand the MSDS on chemicals they will use.
  3. Notify the supervisor if material safety data sheets are not available for chemicals in the work place or if they do not understand information on the MSDS.
  4. Ensure all chemicals transferred to containers, by them, are labeled to identify contents and hazards of the material.
EH&S

EH&S will assess each department's program and provide assistance, on request, in the development of departmental Haz Com Programs. EH&S can also provide assistance training employees on chemical safety, and help in obtaining MSDSs and interpreting technical information.

Hazard Warnings

Safety Data Sheets

Work sites with multiple locations may keep SDSs at a central location, which is visited daily by employees. MSDSs may also be kept on computer. Whenever a new or revised material safety data sheet is received, the information shall be given to affected employees in a timely manner but no more than thirty days after the information is received. If the information indicates a previously unknown, serious hazard, the employee shall be notified immediately. All new chemicals used in the work place must be accompanied by an SDS.

Containers

Each container of a hazardous substance must be labeled or tagged. Labels must identify the hazardous chemical present, appropriate hazard warnings and the name and address of the manufacturer, importer or other responsible party. If a chemical is transferred into another container, the container must be labeled with the name of the chemical and an appropriate hazard warning.

Piping

Pipes carrying hazardous materials must be labeled to clearly identify the contents. Labeling must be at an interval which is frequent enough so labels are clearly visible to any person working on the piping system.

Non-routine tasks

Employees are occasionally asked to perform non-routine tasks using chemicals. Each department shall identify the means they will use to inform employees of chemical hazards presented by non-routine activities. The supervisor will ensure that employees are informed of:

  1. The specific hazards of the task.
  2. Protective measures that must be used.
  3. Steps the department has taken to lessen the hazard.
  4. Specific emergency procedures to be used in the event of an emergency.

Training

Employees must be trained on hazardous substances in their work area at the time of their initial assignment and when a new hazard is introduced into the work area. Training must be in a language and at a level of comprehension suited to the employee. Employees must demonstrate their understanding of the information by passing a written or verbal examination. Documentation of all employee training and any test results must be maintained in departmental or individual training records for at least three years after the employee leaves service. Note: Training must be pro-active. It is insufficient to inform the employee of the availability of information and leave it to the employee's discretion to seek out the information.

Training shall consist of:

  1. Requirements of the hazard communication standard.
  2. Operations in their work area where hazardous substances are present.
  3. Methods that may be used to detect a leak of a hazardous substance.
  4. Physical and health hazards of substances in the work area.
  5. Methods to prevent exposure including selection and use of Personal Protective Equipment (PPE).
  6. Location of material safety data sheets.
  7. Any special procedures the department has implemented to eliminate or reduce exposure to a hazardous chemical.

Contractors

To ensure the safety of outside contractors working on UCSC property, it is the responsibility of the UCSC project manager or their designee to provide contractors with the following information before they begin work:

  1. Hazardous substances used by UCSC, to which they may be exposed while on the job.
  2. Precautions and protective measures that can be taken to lessen the possibility of exposure.
  3. List of University contacts should an exposure occur.Contractors shall provide MSDSs to the University representative supervising the project, for all substances covered by this policy and used in university workplaces by the contractor or any subcontractors engaged by the principle contractor.

Hazard Communication Program

Introduction

UCSC has developed the hazard communication program in order to provide safe working conditions for all University employees and meet regulatory obligations. This Program will provide information about chemical hazards in order to control or minimize those hazards through mandatory and comprehensive employee training, distribution and accessibility of Material Safety Data Sheets (MSDSs), and through container labeling.

This document will serve as the written policy for:

Department/Unit Name: _________________

IIPP Coordinator: _________________

Department Supervisor: _________________

Hazard Communication Program Coordinator: _________________

Extension: _________________

Fax: _________________

Chemical Inventory

Each facility shall maintain an accurate, up-to-date inventory of chemicals in the work place. This inventory along with appropriate MSDSs must be posted or be kept in a readily available area for employee review and must be maintained in an organized manner.

Location Product Name Hazardous Ingredient(s)_________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ __________________________________ _________________ _________________Date of Inventory Collector's Signature

Hazard Communication Implementation Check List

  • Identify the Hazard Communication Coordinator and send a copy of the designation form to EH&S.
  • Conduct an initial chemical inventory and fill out the inventory sheet. Post the inventory in a prominent location.
  • Collect and organize material safety data sheets and make them readily accessible to all employees.
  • Train employees on chemical hazards in the work place.
  • Document employee training using appendix H in the IIPP binder.
  • Train employees on any new chemicals in the work place and ensure all new chemicals are accompanied by an MSDS.
  • Check chemical inventory annually to ensure all chemicals are listed.
  • Review all new material safety data sheets for changes.
  • Update employees on any new information as needed.