Hazard Communication Program Policy

Policy Number: #400

Responsible Executive(s):

• Senior Vice President and CFO

Responsible Office(s):

• Physical Plant

Date Adopted: 02-01-2017

Date Revised: 01-22-2021

A. Purpose

The Regis University (Regis) Hazard Communication Program (HAZCOM) has been developed to comply with the Occupational Safety and Health Administration (OSHA), 29CFR 1910.1200 Hazard Communication Standard. Regis’ program requires that all University personnel have the right-to-know information about the properties and the right-to-understand potential physical and health hazards of chemicals that they may be potentially exposed to in the course of their employment or study.

Individuals engaged in laboratory use of hazards chemicals in a laboratory should also refer to their Chemical Hygiene Plan.

B. Scope

Individuals engaged in laboratory use of hazardous chemicals in a laboratory should also refer to their Chemical Hygiene Plan.

The principles behind the Hazard Communication Program are that all employees have the right-to-know the hazards of the chemicals they use or that are present in their work area the right-to-understand how to protect themselves. Complying with the requirements of Hazard Communication ad ensuring employees are informed about the hazards of the chemicals involves three basic steps:

• Identifying, inventorying, and labeling all hazardous chemicals used
• Obtaining and providing access to Safety Data Sheets (SDS)
• Training employees about the hazards of the chemicals they use or are exposed to

The following departments and personnel shall be responsible for implementing this program and its policies.

1. Environmental Health & Safety Department

The Environmental Health & Safety (EHS) Department shall act as the “program administrator” and shall be responsible for the following elements of the program:

• Develop, maintain, periodically review, update and manage the written Hazard Communication Program (HAZCOM).
• Provide guidance and technical assistance to departments regarding the program.
• Provide results of hazard analysis and monitoring reports upon request to affected employees.

2. Human Resources Department

The Human Resources (HR) Department shall assist and coordinate the following:

• Assist EHS in the coordination and administration of personnel that fall within the limits of the Hazard Communication Program.
• Coordinate and schedule hazardous chemical exposure examinations of personnel covered by the Hazard Communication Program as needed.
• Manage and/or maintain medical exposure records.
• Provide affected personnel with follow-up medical examinations in accordance with the requirements of this program.

3. Deans, Directors, or Department Heads

Deans, Directors and Department Heads are responsible for:

• Hazard Communication Program compliance within their departments.
• Analyzing each job description relevant to identifying potential hazardous chemical exposure.

4. Supervisors and Faculty (Hazardous Communication Coordinators - each Department)

It is the responsibility of the supervisor or faculty member (department) of the work area that uses hazardous chemicals to:

• Assess the potential hazard(s) posed to their workers.
• Ensure all workers who use hazardous materials are properly trained.
• Train the employees regarding these hazards and guidelines.
• Supply the proper Personal Protective Equipment (PPE).
• Turn in appropriate records to the Human Resources department.
• Ensure that a system is established to make Safety Data Sheets (SDS) readily available to employees.
• Assign a Hazardous Communications Coordinator.

Department lab coordinators or assigned individuals as Hazardous Communications

Coordinators shall ensure the following:

• Ensure an inventory (Chemical or Biological) list is maintained and updated periodically.
• Identify all hazardous, chemical and biological products used, acquired or maintained by staff.
• Maintain SDS files.
• Ensure hazardous chemicals are labeled.
• Ensure that a system is established for accessing SDS’s during emergencies.
• Conduct appropriate training.

5. Regis Employees

Regis Employees shall comply with the following information:

• Become familiar with the requirements of the Hazard Communication Program prior to performing activities covered by the program.
• Abide by the requirements established by the program and apply safety and health precautions specified by the University.
• Report any issues of concern which could compromise health and safety to their immediate supervisor.
• Utilize proper personal protective equipment (PPE).
• Attend annual basic safety training and area-specific training as required under the Regis Hazard Communication Program and any department-specific training.

6. Contractors

Regis employees who oversee outside services personnel (i.e. contractors) are responsible for ensuring that the contractor is provided with the following information:

• Provide the contractor with information about the University Hazard Communication Program.
• Provide information about any known hazardous chemicals or materials they may encounter.
• Provide information, i.e. (SDS), on any precautions for their employees to follow.

Regis employees who oversee outside servicing personnel (i.e. contractors) are responsible for ensuring that the contractor provides the University with the following information:

• The contractor shall provide an SDS and any other potential hazardous information regarding hazardous chemicals that will be used in a University building and provide a specific location for SDS’s of hazardous materials to be used on campus.
• The contractor SDS’s must be accessible to occupants and Regis staff.
• The contractor is responsible for training his/her employees in all aspects of the Regis Hazard Communication Program (or comparable program) including all hazardous chemicals and materials that they may be exposed to while working at the University.
• Outside services must follow all labeling procedures (See Section IV).

Hazard Identification and Evaluation

The Hazard Communication Program requirements are applicable to chemicals and materials utilized in the work area if they present a physical or health hazard. All chemicals utilized in the work area must be evaluated to determine whether they present a physical or health hazard.

The manufacturer issued Safety Data Sheet (SDS), is the proper document to consult when evaluating a chemical’s properties. EHS is available to assist the proper document to consult when evaluating a chemical’s properties. EHS is available to assist with questions regarding the hazards of chemicals.

A chemical with a physical hazard means that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, unstable (reactive), water reactive or other physical hazards. A chemical with a health hazard means a chemical in which statistically significant evidence indicates acute or chronic health effects may occur in exposed employees.

1. Chemical Inventory

The University and regulatory standards require that a list of chemicals in the workplace be maintained as part of this program. The list serves as an inventory of Safety Data Sheets that must be maintained. Each department shall establish a procedure or process for ensuring that new chemicals are promptly and accurately added to the chemical inventory list.

2. Safety Data Sheets

Safety Data Sheets (SDS) are the most convenient and widely accepted method for communicating the hazards of a chemical to an employee. An SDS is a printed 16 section formatted description of the chemical’s properties, precautionary steps and first aid measures; produced by the manufacturer of the chemical. These documents provide the supervisor and employees with the necessary information to use chemicals safely and to respond to with chemical spills and releases. Format for the SDS must contain the following data.

1. Product Identification
2. Hazard Identifications
3. Composition
4. First Aid Measures
5. Fire Fighting Measures
6. Accidental Release Measures
7. Handling and Storage
8. Exposure Control, PPE and Exposure Limits
9. Chemical and Physical Properties
10. Stability and Reactivity
11. Toxicology Information
12. Ecological Information
13. Disposal Considerations
14. Transportation
15. Regulatory Information
16. Other

Each department must maintain a file of SDS for chemicals used within their area. The supervisor must ensure that the SDS file is accessible to all employees during work hours.

• For products currently in use, SDS must be obtained immediately.
• For new products the SDS must be obtained, and appropriate training provided prior to the use of the product by any employee. It is the supervisor’s responsibility to ensure this training is conducted.

It is essential that work areas establish procedures for acquiring the SDS as well as training the employee(s) in the hazards of a new product prior to its use. Each department must have procedures in place to control the selection and purchase of materials, and the acquisition and distribution of the SDS’s prior to employee usage of the product.

Labeling

All hazardous chemicals and materials used in the workplace must be labeled properly. Hazardous chemicals and materials that are shipped in and used in their original container are often labeled by the manufacturer or distributor.

Hazardous materials and chemicals which are placed into secondary containers for distribution and use around the workplace must meet various labeling requirements. Specifically, the label on all of the secondary containers must state:

• The identity of the product or the ingredients of a mixture that will allow SDSs to be obtained when needed
• Information regarding the hazards of the chemical or material that includes: Health hazard; Reactivity hazard; Fire hazard; and, Required Personal Protective Equipment (PPE)
• Any other necessary physical or health hazards not covered above

The Hazardous Material Information System (HMIS) label shall be used for all secondary containers. It is presented below. Other labeling systems, such as NFPA, may be used provided that employees are properly trained in their use.

HMIS Label

NFPA Chemical Hazard Label

Each of the colored areas has a box in which the degree of hazard can be written. The degree of hazard is given by these numbers:

4—Extreme

3—Serious

2—Moderate

1—Slight

0—Minimal

A definition of each degree of hazard category is listed below:

The NFPA Chemical Hazard label white diamond provides special symbols that may include:

....Water Reactive                                                        Ox  ....Oxidizing Agent

...Radioactive                                                                    ...Poison 

The HMIS label, Protective Equipment (white section), may include the following: HMIS Letter,   Required Protective Equipment

A - Safety Glasses

B - Safety Glasses, Gloves

C - Safety Glasses, Gloves, Protective Apron

D - Face Shield, Gloves, Protective Apron

E - Safety Glasses, Gloves, Dust Respirator

F - Safety Glasses, Gloves, Protective Apron, Dust Respirator

G - Safety Glasses, Gloves, Vapor Respirator

H - Splash Goggles, Gloves, Protective Apron, Vapor Respirator

I - Safety Glases, Gloves, Dust and Vapor Respirator

J - Splash Goggles, Gloves, Protective Apron, Dust and Vapor Respirator

K - Air Line Mask or Hood, Gloves, Full Suit, Boots

L - Site specific label. Ask supervisor for handling instructions

Global Harmonization

The new implementation was devised to provide labeling elements called “pictograms,” that would be universal for all employees worldwide. These classification pictures will now be on all primary labels of chemicals coming from a manufacturer. These pictograms can be used singular or in unison with one another.

HCS Pictograms and Hazards

 Food or Beverage Where Chemicals are Used

Hazardous chemicals shall be separated from eating and drinking areas, in order to prevent possible ingestion of chemicals. No employee, student or visitor shall be allowed to consume or store food or beverages in any area exposed to hazardous chemicals.

Additionally, no food or beverage will be stored in a refrigerator or freezer where chemicals, biohazards, radioactive or other hazardous processes are stored. Food or beverages must not be placed in a microwave oven or other heating device that is used to conduct hazardous processes.

Refrigerators, freezers and microwaves used for the storage of processing of hazardous, toxic, biohazard or radioactive products shall be labeled with wording that positively identifies that the equipment’s use is restricted. Words such as “CHEMICAL STORAGE ONLY” or “CHEMICAL PROCESSING ONLY,” are appropriate. Food containers are not appropriate for the storage of hazardous materials or chemicals.

Employee Awareness, Training, Releases and Recordkeeping

1. Employee Awareness

Each work area will train their employees on the specific hazardous materials or chemicals in their departmental work area. Refresher training shall be conducted annually. Training records must be maintained. EHS can assist with training needs and requirements for departments. The training requirements for the Hazard Communication Program include the following:

• At the time of initial assignment or when new tasks are assigned for which training has not been received.
• When a new hazardous chemical is introduced into the workplace.

2. Training Requirements

Training is expected to include, but may not be limited to:

• Information and training may be designed to cover categories of hazards (i.e. flammability, toxicity, carcinogenicity) or specific chemicals.
• Describe the location and availability of the chemical inventory list (within the department), location of SDS, and the location of the University’s Hazard Communication Program.
• Explain the purpose and contents of Safety Data Sheets. An employee must be able to understand an SDS and obtain hazard, handling, and exposure control information from an SDS.
• Explain the labeling system utilized by the department and how employees can obtain and use appropriate information.
• Review the methods and observations that can be used to detect the presence of hazardous chemicals, such as odor, appearance and monitoring/instrumentation.
• Assess the hazards of the chemicals or materials used and review the assessment with employees. This review must include describing protective measures for minimizing exposure such as appropriate work practices, personal protective equipment, and emergency procedures.
• Review handling, storage and spill procedures.
• Review emergency response procedures. 

3. Non-Routine Tasks, Spills or Releases

Tasks may periodically be performed which may potentially expose employees to hazardous chemicals not normally used in their regular work duties. Examples of non-routine tasks performed may include: repairs, spill cleanup, and servicing of equipment. Prior to starting work on such projects, affected personnel shall be presented information by their supervisor about hazards to which they may be exposed during the task.

This training must include the same level of detail and information necessary for routinely used hazardous chemicals. The training must emphasize that the potential hazard of working with unfamiliar material can be greater than with those that are handled routinely. 

4. Recordkeeping

Employee training records will be retained within each department. The Hazard Communication Training form may be used for training and recordkeeping. Training records shall be retained for minimum of seven years.

The medical exposure record for each employee must be maintained in the Human Resources department and must be retained for thirty years.

Hazardous Waste Disposal

Chemicals or materials that are outdated, expired, or no longer used must be evaluated prior to disposal to determine if it is considered a hazardous waste. EHS can assist in the determination if a material is a hazardous waste.

Chemicals and materials that are a hazardous waste must be disposed of properly. For guidance on the proper procedure to follow, refer to the University’s Hazardous Materials Management Plan.

Emergency Information

In case of a spill or release immediately contact Campus Safety at 303.458.4122 or Physical Plant 303.458.4944. These departments will then determine the next steps to take.