2: Hazard Communication Program Summary

Introduction

The Hazard Communication Program was designed to alert workers about hazardous chemicals by giving them greater access to information on the physical and health hazards of chemicals, safe handling precautions, and emergency and first aid procedures; and to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.

Departments are required to establish Hazard Communication Programs to convey information on the hazards of chemicals used by individuals in their department by labeling containers, ensuring material safety data sheets (MSDSs) are available, and providing training.

The Hazard Communication Program applies to all chemicals used at Princeton University, except laboratory areas. Chemical use in laboratories is covered by the Laboratory Standard (see Section 3). In accordance with the OSHA Hazard Communication Standard, certain chemicals are exempt from the standard, including hazardous wastes, food, wood, tobacco, and potentially hazardous substances such as drugs and cosmetics brought to the University for personal consumption.

Under the Hazard Communication Program, individuals who work with hazardous chemicals have the right to know:

• what chemical substances are present in the products they handle
• what health effects these chemicals are capable of causing in the event of over exposure
• what precautions are necessary to protect from exposure
• what physical hazards (e.g., fire, explosion) are possible if the product is not handled properly
• how to properly handle the product in order to avoid hazards

The Hazard Communication Program consists of six major elements: hazard evaluation, labeling, material safety data sheets, a written program, contractor requirements and training.

Hazard Evaluation

Manufacturers, importers, or distributors of chemicals are required to assess the physical and health hazards of their products. This information must be recorded on the product label and included in a material safety data sheet (MSDS).

Labeling

The manufacturer must label containers with the chemical name(s), hazard warnings, and the manufacturer’s name and address.

The manufacturer’s label must not be removed or defaced. If the product is transferred from one container to another, the new container must be labeled with the product name, the names of all hazardous chemicals and/or the five most predominant chemical constituents, the Chemical Abstract Service (CAS) number for each chemical, and appropriate hazard warnings.

If the chemical is transferred from a labeled container into a process container, that is, if the person performing the transfer will use the transferred material within the workday, the container does not need to be labeled as described above. However, it is always the best practice to label.

Material Safety Data Sheets (MSDS)

Each department must obtain and maintain an MSDS for each hazardous material in the workplace. These MSDSs must be accessible to individuals working with the products during all work hours. If an MSDS is not received with a chemical shipment, the department must obtain the MSDS within a reasonable amount of time. See Section 5 for an explanation of interpreting MSDSs.

Written Hazard Communication Program

Each department must develop a written Hazard Communication Program which details how the department will comply with the provisions of the OSHA Standard. The program must include an inventory of hazardous materials used or stored by the department; handling of MSDSs, including where they will be maintained, how they will be obtained, and how to access them; labeling requirements; training requirements; contractor requirements; and provisions for non-routine tasks.

The written program must be accessible to individuals during all work hours, and must be reviewed and updated at least annually. A model written program is available through the EHS.

Contractors

Departments must inform outside contractors of the potential hazards which may be encountered during their work at the University. This includes giving contractors access to the written Hazard Communication Program, the hazardous chemical inventory, and the MSDSs for these chemicals.

Similarly, the contractor is expected to inform and provide departments with a chemical inventory and MSDSs for the materials that will be introduced into the work area in the course of their work at Princeton University. The contractor must also provide information regarding the location of chemical use and storage.

Training

All individuals who work with hazardous materials must receive training. General training is provided by EHS, and covers the provisions of the federal OSHA Hazard Communication Standard, methods to recognize hazards, hazard evaluation, interpreting MSDSs, common methods to prevent and control chemical exposure, the use and function of personal protective equipment, and general procedures for spill clean-up and hazardous waste.

Specific information about hazardous materials used in the workplace is provided by the individual department. Each department is responsible for informing workers of:

• the location and availability of the written Hazard Communication Program, the chemical inventory, and MSDSs
• the nature and potential health and safety risk of specific hazardous substances to which individuals may be exposed in the course of their work
• the proper handling, under all circumstances, of hazardous materials in the workplace
• the appropriate emergency treatment for exposures
• procedures for clean-up of leaks and spills
• the location of hazardous materials in the workplace

The Department is responsible for assuring that workers attend training and for keeping attendance records of this training.

Special hazards which workers may encounter when performing non-routine duties in the course of their work must be discussed with the worker before the job begins. It is the responsibility of the supervisor to ensure that workers receive specialized training, as needed. EHS may provide assistance in evaluating the hazards and determining the appropriate precautions.

Summary

Individuals who work with chemicals have the right and responsibility to know about the hazards of the chemicals they use and how to work with them in a safe manner which minimizes exposure to chemicals.

In order to accomplish this, each worker must:

• Attend training.
• Maintain proper labeling of chemical containers.
• Review MSDSs for hazardous chemicals before working with them.
• Follow instructions and recommendations when using chemicals.
• Use appropriate personal protective equipment, as necessary.
• Report potentially hazardous conditions to supervisors.

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