Industrial Maintenance and Construction/Support Services Safety Manual - Hazard Communication Program

Title

Industrial Maintenance and Construction/Support Services Safety Manual - Hazard Communication Program

(OSHA 1910.1200)

Legal Requirements

The provisions of the NC OSHA Hazard Communication Program were revised and became law in March 2012 to encompass global harmonization. The HAZCOM 2012 Standard requires employers to provide employees with information concerning the hazards associated with the chemicals in their workplace. This standard requires a written hazard communication program, container labels, inventory of chemicals, area warning signs, safety data sheets, and chemical safety training and information sessions.

Responsibilities

For Facilities Services shops, instrument shops, chemical storerooms, and other department functions that use or store hazardous chemicals, the Department Head or his/her designee has responsibility to ensure that labels are proper, that safety data sheets are obtained and maintained, that chemical safety training is provided, and that the inventory of the hazardous chemicals used or stored in the work area is readily available to employees.

The Department of Environment, Health and Safety will coordinate implementation of the Hazard Communication Program and will assist Departments in obtaining safety data sheets and in conducting general safety training and workplace hazard communication inspections.

Chemical Hazard Communication Program

This document shall serve as the written Chemical Hazard Communication Program for the University. It is to be readily available to employees upon request.

Definition of Hazardous Chemicals

The requirements of the Chemical Hazard Communication Program apply to chemicals with one or more of the following hazardous properties:

1. Physical Hazards: Create dangerous situations, and have been proven to be combustible liquid, compressed gas, explosive, flammable, organic peroxide, oxidizer, pyrophoric, and unstable, or water-reactive chemicals.
2. Health Hazards: Chemicals that can produce negative health affects in exposed employees. These can be chemicals that are toxic, carcinogenic, corrosive, irritant, or sensitizing.
3. A chemical is considered to be carcinogenic if:
   1. it has been evaluated by the International Agency for Research on Cancer (IRAC), and found to be a carcinogen or potential carcinogen; or
   2. it is listed as carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP); or
   3. it is regulated by OSHA as a carcinogen.
4. Health hazards can cause either acute or chronic effects. Acute health effects are the negative effects from a substance that occur after one or multiple exposures in a short period of time. (Ex. Spilling Hydrochloric Acid on your hand.) Chronic health effects are the negative effects from a substance that occur over a longer period of time, usually from repeated exposure of low doses. Sometimes delayed for years. (Ex. Being exposed to Asbestos fibers.)

Labels

Chemical manufacturers, importers, or distributors are required to ensure that each container for hazardous chemicals is labeled with the identity of the hazardous chemicals(s); a harmonized product identifier, pictogram, signal word, and hazard statement for each class and category. University departments are to ensure that chemicals they receive are labeled with the required labels that have identity of the hazardous chemicals(s) and appropriate pictograms and product identifiers. This includes chemicals received from the UNC Scientific Supply or other campus storerooms. If a chemical is placed into a container without a label, that container must also be labeled with the requirements stated above. If a label is removed, it should be replaced immediately.

Pictograms are required on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard(s), such as health, physical, and environmental. The pictogram on the label is determined by the chemical hazard classification. There are nine pictograms with only the environmental pictogram being optional.

Signal Word is used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are:

• “Danger” – used for the more severe hazards
• “Warning” – used for less severe hazards.

Hazard Statement describes the nature of the hazard(s) of a chemical, including where appropriate the degree of hazard. All of the applicable hazard statements must appear on the label.

Precautionary statement is a statement that describes recommended measures that should be taken to minimize or prevent adverse effects.

Other Forms of Warnings

Warning signs are to be displayed in areas where there may be airborne hazardous chemicals. This would include areas such as welding; operations of internal combustion engines, indoor application of paint, or adhesives; grinding and sanding operations; and removal of asbestos containing materials. The employee responsible for producing the above potentially hazardous environments is responsible for posting the area warnings signs. All pipes containing hazardous chemicals are to be labeled.

Chemical Inventory

A current inventory of all hazardous chemicals present in the workplace is to be maintained. The inventory should be kept with the SDS file as a quick reference for chemicals that are being stored in the area. The Chemical Inventory List should also be updated annually, or as new chemicals are brought in and old chemicals are properly disposed of.

Safety Data Sheets (SDS) - formerly known as MSDS

Chemical manufacturers are required to send a Safety Data Sheet (SDS) with the initial shipment of a chemical. The SDS contains a specified 16 section standardized format about physical and chemical properties of the chemical, the physical and health hazards, safe handling precautions, spill clean-up procedures, emergency and first aid procedures. The standardized 16 sections is broken down as follows:

1. Identification of the substance or mixture
2. Hazards identification of the substance
3. Composition/information or ingredients/Mixture
4. First aid measures
5. Firefighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical properties
10. Stability and reactivity
11. Toxicological
12. Ecological information (non-mandatory)
13. Disposal considerations (non-mandatory)
14. Transport information (non-mandatory)
15. Regulatory information (non-mandatory)
16. Other information including information on preparation and revision of the SDS

University departments are to maintain all SDS received and to make them readily available to their employees in a file or notebook, or an accessible computer file. If an SDS for a chemical is not received, the chemical manufacturer or distributor should be contacted to obtain the SDS. Efforts to obtain the SDS are to be documented by either a telephone log, computer database or with copies of correspondence. Assistance in obtaining SDSs is available from Department of Environment, Health and Safety.

Information and Training

The Department of Environment, Health and Safety provides general hazard communication training for all University employees. In addition to general chemical safety training, it is the responsibility of the supervisor to provide training for the specific chemicals used or stored in the work area and whenever a new hazard is introduced.

Hazardous chemical safety training is to include the following essential information:

• Interpreting information on labels and SDSs
• Location of hazardous materials in the workplace
• Location and availability of material safety data sheets
• Acute and chronic effects of chemicals
• Safe handling procedures
• Personal protective equipment
• Methods used to detect leaks and releases
• First Aid
• Spill clean-up and emergency procedures
• Waste disposal

The Department of Environment, Health and Safety has developed training programs including slide programs explaining the Chemical Hazard Communication Program, the toxic effects of chemicals, and the safe handling of hazardous chemicals in the workplace. The Department of Environment, Health and Safety should be contacted to schedule these programs.

In addition to general chemical safety training it is the responsibility of the supervisor to provide training for the specific chemicals used or stored in the work area and whenever a new hazard is introduced. Training should be documented by keeping records, such as job briefings and Job Safety Analysis (JSA). The documentation shall include when training sessions were held, who attended, and the contents/outline of the training.

Routes of Exposure

There are 4 routes of exposure to chemical substances (Inhalation, ingestion, absorption, and injection). The most likely target depends upon the characteristics of the chemical being used.

1. Inhalation is the primary route of entry which includes airborne contaminants such as gases, vapors, and particulate matter that enters the body.
2. Absorption can occur very quickly through cuts or abrasions on the skin, and may also occur even when skin is intact. Mucous membranes and eye tissue are particularly vulnerable to absorption.
3. Ingestion can occur by the direct tasting of chemicals, and by ingesting contaminated food or putting personal items such as make-up on one’s face. This is the reason that food, drinks, cosmetics, and other items are banned from laboratory areas. Labeling containers and practicing good housekeeping are ways of controlling the possibility of ingesting a chemical. If you work in a lab or perform maintenance in a lab, always make sure you wash your hands before leaving.
4. Injection can occur from needle sticks, broken glass, broken capillary tubes, or broken pipettes. Make sure that carefully planned procedures are in place when handling broken materials. Needle blocks should be in place to prevent accidental needle sticks.

Non-Routine Tasks

All jobs or projects involving hazardous chemicals that are being done for the first time or done periodically, shall be considered a non-routine task. Prior to performing the task, the supervisor shall conduct a job briefing (see attached file) to inform the employees of the hazards associated with the task, such as but not limited to chemicals, special precautions, and required PPE. A JSA should be developed for all non-routine tasks that occur at some regular interval (e.g. once a year, every three years, etc.).

Contractors

Contractor employees are to be informed of hazardous chemicals that they may encounter at their work location on campus and provided with the name of the University person(s) from whom chemicals safety information is available. Contractors who use hazardous chemicals are to maintain a list of the chemicals and the SDSs at the work location on campus.

Trade Secrets

In some cases, the chemical manufacturer may withhold the complete chemical identity from the SDS if it is a trade secret. However, the chemical and physical properties must be disclosed on the SDSs. Trade secret information will be available to health professionals for medical treatment of exposed personnel, assessment of hazards and employee exposures, and selection of appropriate safety precautions.

Appendices

• Appendix A: Hazard Communication Training Certificate (see attached file)
• Appendix B: Job Briefing Checklist (see attached file)

Contact Information

Policy Contact

Environment, Health and Safety
1120 Estes Drive
Campus Box #1650
Chapel Hill, NC 27599-1650
Phone: 919-962-5507