HAZARD COMMUNICATION TRAINING, OSHA 1910.1200 SPECIFIC INFORMATION FOR MESSIAH COLLEGE The Occupational Safety and Health Administration (OSHA) enacted a standard (29 CFR 1910.1200 – Hazard Communication) for hazardous chemicals in the workplace. The intent is to insure that the hazards of these chemicals are identified by the manufacture, and communicated to the employees who use them through chemical labeling, Safety Data Sheets (SDSs), workplace procedures and training. The employer is to document the workplace programs for compliance in a written hazard communication program. As a minimum, the hazard communication program should describe how the requirements of this standard will be met. Messiah College’s Hazard Communication Program: Chemical Safety Manual is available on the College’s MC-Square portal under the Environmental, Health & Safety (EHS) channel. The EHS channel is on both the Employee and the Student tabs. On the Employee tab it will appear at the center, top of the screen; on the Student tab is will appear on the left side of the screen, directly under “Need-to-Know.” On this channel is a link to various EHS documents, including the Hazard Communication Program: Chemical Safety Manual. It contains information on everything contained in this document and more...labels…Safety Data Sheets … Inventory Lists… chemical spill procedure…general safety practices to follow when using chemicals…contractor’s chemicals…etc. (See the Table of Contents, Attachment 1). WHAT IS A CHEMICAL OR CHEMICAL SUBSTANCE? Under this OSHA standard, a chemical is anything that during use can emit dusts, vapors, gases, mists or particulates. Therefore, a piece of wood that is being sanded where dust is generated is a chemical under this standard. A piece of metal that is being polished where dust is emitted is a chemical under this standard. This makes sense because both wood dust and metal dusts can be hazardous to your health. CHEMICAL LABELING All chemical containers must be labeled by the manufacturer. It is illegal to deface, remove, cover up or in any way destroy these labels unless the container is empty. The new Globally Harmonized System (GHS) labeling system is to be used by manufacturers. (For awhile you may see a combination of old-style and new GHS labels on chemical containers.) Secondary containers also require labels. A secondary container is any container in which you place the chemical substance that is not the manufacturer’s container. Page 1 At Messiah College, there are two approved methods for secondary labeling: 1. Copy/photocopy of the manufacturer’s original label applied to the secondary container; 2. The Messiah College secondary label. HEALTH Hazards PHYSICAL Hazards The name of the chemical substance traceable to the SDS The name of the manufacturer Both Health Hazard & Physical Hazard information should be included on the label by placing an “X” in the box above the appropriate hazard. This hazard information can be obtained from the manufacturer’s original label or the SDS for the substance. Health Hazard information is noted in the blue area. Check all hazards that apply. If the substance contains 0.1% or more of a carcinogen, the box above Carcinogenic Toxin should be checked. The box above Reproductive Toxin should be checked if the substance contains 0.1% or more of a reproductive toxin. The box above Acutely Toxic should be checked if the substance is acutely toxic; this is often denoted by a “Skull and Crossbones” on the manufacturer’s label. The box above Harmful to Health should be checked if the substance is an irritant or sensitizer (via skin contact, inhalation) or is harmful (but not acutely toxic) if ingested. These health effects are often denoted by an Exclamation Mark on a manufacturers’ label. However, even if no health hazards are checked, treat the chemical as if it is hazardous as future testing may result in one of these classifications. Always handle chemicals with respect! Page 2 Physical Hazard information is noted in the red area. Check all hazards that apply. If the substance is flammable, then the box above Flammable should be checked; this is often denoted by flame symbol on a manufacturer’s label. The box above Oxidizer should be checked if the substance is an oxidizer; this is often denoted by the symbol with the flame over an O on manufacturers’ labels. The box above Explosive should be checked if the chemical substance is explosive or self-reactive or an organic peroxide. This is often noted by the Exploding Bomb symbol on a manufacturer’s label. The box above Corrosive should be checked if the substance is a corrosive; this is often denoted by the corrosive symbol on manufacturers’ labels. NOTE: Secondary containers of water or other non-hazardous chemicals should be labeled for identification purposes to avoid confusion. Containers in office areas are not included in this requirement. There are some exceptions to the requirement for secondary labels: Pipes and pipelines – however, always consult facilities maintenance if potential exposure to the contents of plumbing exists Portable, intermediary containers – intended only for the use of the employee who performs the transfer and only during the work shift it is transferred Solid materials, storage areas, workshops – may display signs to notify employees of the potential hazards of exposure Substances that are subject to labeling requirements by other federal agencies (ex., hazardous waste that is governed by EPA) Tobacco and tobacco products Food or alcoholic beverages Drugs as defined by the Food, Drug and Cosmetic Act Cosmetics intended for personal use Articles Wood and wood products that will NOT be processed Ionizing and nonionizing radiation Biological hazards Any consumer product or hazardous substance where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the Page 3 product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended Example, White Out used in an office with normal exposure would be exempt; Windex used by campus events would not be exempt as exposure would be expected to be greater than normal use in a home. For more information about chemical labeling and pictograms, see the OSHA QuickCards (Attachment 2, Attachment 3). SAFETY DATA SHEET ACCESS AND AREA INVENTORY LISTS 3E ONLINE SYSTEM SAFETY DATA SHEETS A Safety Data Sheet (SDS) (previously referred to as a Material Safety Data Sheet) is a document which contains information (health and physical hazards) about a chemical substance, manufacturer’s contact information, physical properties, and more. The SDS is a standard format that is internationally recognized. It has 16 sections of information which must appear in a specific order. See Attachment 4, OSHA’s QuickCard on Safety Data Sheets, for a description of each section. Employers are required to maintain copies of Safety Data Sheets (SDSs) for all chemical substances found in their workplace and to have them available for employees during their workshifts. At Messiah College, we utilize an outside vendor to maintain a database of our SDSs. Safety Data Sheets (SDSs) for chemicals used at Messiah College are found in the 3E Online System. A link to the 3E Online System is available from the Environmental, Health & Safety channel on MCSquare (on both the Employee and Student tabs). You can access SDSs 24-7…view them on a computer, print them or email them to yourself. SDSs are also available via phone. Campus phones should display a sticker with the phone number to call. This should be primarily for emergency situations when the online system is not available. However, if for any reason you have difficulty using the online system, this also serves at the backup. AREA INVENTORY LISTS OSHA requires a chemical inventory be maintained for all workplaces. The chemical inventories for areas/departments at Messiah College are maintained electronically on the same 3E Online System. Page 4 REMEMBER… Detailed instructions on how to use the 3E Online System and additional information about topics covered in this training can be found in the written Hazard Communication Program: Chemical Safety Manual. If you have any questions about the safe use of chemicals in your area, contact your area leadership. If you still have questions, please feel free to contact the Compliance Coordinator, Donna Fink, at ext. 5038 or [email protected]. Please complete the documentation page (Attachment 5) and send it to Donna Fink, suite 3015 or give it to your leadership to have him/her send it. OSHA doesn’t recognize training that isn’t documented! Page 5 Attachment 1 Table of Contents for the Hazard Communication Program: Chemical Safety Manual Section 1 – Introduction Section 2 – Definitions Section 3 – Labels & Other Forms of Warning Section 4 – Safety Data Sheets (SDSs) Section 5 – Methods to Inform Employees of Hazards of Chemicals Section 6 – Chemical Hazards Section 7 – Measures to Protect Against Chemical Exposures and General Worksite Safety Practices Section 8 – Spill Procedure Section 9 – Employee Information and Training Section 10 – Inventory Lists of Hazardous Chemicals Section 11 – Contractors Section 12 – NFPA Codes Page 6 Attachment 2 The required GHS label elements include: Product Identifier(s) Supplier/Manufacturer Identification and Contact Information Precautionary Statements Hazard Pictograms (for both health and physical hazards) Hazard Statements Supplemental Information Page 7 Attachment 3 Page 8 Attachment 4, Side 1 Page 9 Attachment 4, Side 2 Page 10 Attachment 5 Documentation Form for HAZARD COMMUNICATION TRAINING This training included information on the Messiah College Hazard Communication Program: Chemical Safety Manual and how to access it, Safety Data Sheets and the 3E System, and chemical labeling including the GHS labels and the Messiah College secondary label system. Name (Print): Signature: Job Position: Date of Training: Name (Print): Signature: Job Position: Date of Training: Name (Print): Signature: Job Position: Date of Training: Name (Print): Signature: Job Position: Date of Training: Employees - please send completed form to Donna Fink, Suite 3015, for record retention. Student Employees – please send completed form to Belinda Conrad, Suite 3010 for record retention. Page 11
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