SECTION C2: Hazard Communication

(Chemical Use in Non-Laboratory Areas)

• Introduction
• Scope and Application
• Program Description
• Roles and Responsibilities
• For More information

Introduction

The Hazard Communication Program is designed to inform workers about hazardous chemicals. This is achieved by providing access to information on the physical and health hazards of chemicals, safe handling precautions, and emergency and first aid procedures. This program is also designed to and to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.

Departments are required to establish Hazard Communication Programs to transmit 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.

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Scope and Application

The Hazard Communication Program applies to all chemical use at Princeton University, except laboratory areas. Chemical use in laboratories is covered by the Laboratory Standard (see Section C3). 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.

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Program Description

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 overexposure
• 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 transferred material will be used within the workday by the person performing the transfer, the container does not need to be labeled as described above.

Material Safety Data Sheets (MSDS)

Each department must obtain and maintain an MSDS for each hazardous material in their 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.

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 Office of Environmental Health and Safety (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 where chemicals will be used and stored.

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.

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Roles and Responsibilities

Department

• Develop and maintain a written Hazard Communication Program, to be reviewed at least annually.
• Maintain an inventory of hazardous chemicals in the workplace.
• Obtain and maintain MSDSs for all hazardous materials in the workplace.
• Ensure the written program, chemical inventory, personal protective equipment and MSDSs are accessible to workers during all work hours.
• Provide specific training on working with the hazardous substances in the workplace.
• Keep records of training.
• Provide additional training for non-routine tasks, as needed.
• Inform contractors of potential hazards in their work area.
• Ensure contractors inform department representatives of potential hazards they bring into the workplace

Supervisors

• Ensure workers receive general and specific training.
• Ensure containers are properly labeled.
• Recognize potential hazards in the workplace.
• Ensure workers wear personal protective equipment, when necessary, and properly handle hazardous materials.
• Ensure workers receive specialized training for non-routine tasks.

EHS

• Provide general training.
• Assist in evaluating hazards and determining appropriate precautions.
• Audit departmental program periodically.

Individual

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

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For More Information

Contact an EHS Industrial Hygienist at 258-5294.

A copy of the OSHA Hazard Communication Standard (28 CFR 1910.1200) is available through EHS or the web page at http://www.princeton.edu/~ehs/services.htm#HazCom.

A model written Hazard Communication Program is available through EHS.

EHS has several thousand MSDSs available on CD-ROM. A guide to interpreting MSDSs is available through EHS or the EHS web page at http://www.princeton.edu/~ehs/index.html#MSDS.

Additional information on contractor requirements may be found in Construction and Renovation, Section B11, of the Health and Safety Guide.

The Chemical Use in Non-Laboratory Areas Self-Audit Checklist is available through EHS or may be downloaded either as a PDF or a customizable Word document. .

Links to other chemical safety-related web sites are available here. The following additional references are available through EHS and the University Library:

• Bretherick, I., Handbook of Reactive Chemical Hazards, 4th edition, CRC Press, 1990
• Clayton, George and F. Clayton, Patty’s Industrial Hygiene and Toxicology, Wiley Interscience, 1991
• Gosselin, et al, Clinical Toxicology of Commercial Products, 5th edition, Williams and Wilkins, 1984
• Hawley, Gessner G., Condensed Chemical Dictionary, 11th edition, VanNostrand Reinhold Company, 1987
• Lewis, Richard J., Dangerous Properties of Industrial Materials, 8th edition, Prentice-Hall, Inc., 1977
• National Institute of Occupational Safety and Health, Registry of Toxic Effects of Chemical Substances, published annually
• National Institute of Occupational Safety and Health, Pocket Guide to Chemical Hazards, published annually
• Windholz, et al, editors, The Merck Index, Merck and Company, published annually

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