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MIT Hazard Communication Program
1. Purpose / Background
This document serves as MIT’s written hazard communication program, required by OSHA
29CFR1910.1200, Hazard Communication. A summary of the content of this program is provided in
paragraph 3 below.
This document has been updated to incorporate information about the 2012 changes to the OSHA Hazard
Communication regulation. These changes were to adopt the Global Harmonization System (GHS) for
classification and labeling of chemicals. During the years 2013 through 2016, employers will be
transitioning from the previous regulatory requirements to the new requirements. By July 1, 2016, MIT
will need to have replaced MSDSs with SDSs, and assure that other aspects of the HAZCOM program fully
incorporate the changes. The first critical requirement is to assure all HAZCOM employees are trained
about the new label elements and the new SDS format by December 1, 2013.
2. Scope
The MIT HAZCOM program is applicable to employees (referred to as HAZCOM employees) who work in
non-laboratory work areas or operations (referred to as HAZCOM areas)) where hazardous chemicals are
used or stored, except as noted in the next sentence. This program does not apply to non-laboratory work
areas or operations in a DLC covered by a Chemical Hygiene Plan (CHP), provided that the DLC CHP
contains special hazard communication provisions for the non-laboratory areas within that DLC, as
detailed in the Chemical Hygiene Plan Template. Such areas may include kitchens for cleaning glassware
and preparing media, or small machine shops for making parts or specialized equipment for researchers,
or for maintaining such equipment.
3. Requirements
As required by OSHA, all employees who may be potentially exposed to hazardous chemicals as part of
their job are informed of the hazards of those chemicals and the protective measures established for
handling the chemicals. This program describes procedures for:
Listing the hazardous chemicals, by the Department, the building and room where they are used or
stored
Collecting, maintaining and providing ready access to an MSDS or SDS
Assuring that materials are properly labeled
Assuring that measures are established for the safe use of the hazardous materials
Providing information to employees about this program and OSHA requirements.
Providing training to employees on the hazards of chemicals they work with and the protective
measures established. Training is to be provided upon employment and when changes in the
workplace or operations result in new chemical hazards and new protective measures.
Assessing hazards of non-routine jobs involving potential exposure to hazardous materials, and
informing employees about those hazards and the protective measures established.
Assuring contract employees are informed of chemical hazards to which they may be exposed
when working at MIT.
Informing MIT employees of hazards that contractors may introduce, and safeguards to minimize
potential for exposures.
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4. Program Details.
4.1.
Written MIT HAZCOM Program availability:
A copy of this MIT HAZCOM Program is available on the EHS Office Web Site at:
http://ehs.mit.edu/site/content/mit-hazard-communication-program. A copy should be
maintained in the MSDS or SDS Notebooks maintained at worksites. New employees should be
informed about the written program and its location. A print copy will be provided to HAZCOM
employees upon request.
4.2.
MIT Work Area HAZCOM Summary Sheet:
The Work Area HAZCOM Summary Sheet, (see Appendix A, also linked at
http://ehs.mit.edu/site/content/mit-hazard-communication-program ), contains work area
specific information regarding:
(1) The location and/or procedures for obtaining an MSDS or SDS,
(2) Procedures for labeling portable containers, and
(3) Procedures established in the department for providing HAZCOM training.
This form shall be completed and posted in the work area by the Supervisor, and a copy shall be
sent to the EHS Coordinator who will maintain it on file for the Department/Center.
4.3.
Chemical Lists:
4.3.1.
The Manager/Supervisor shall compile a list of hazardous chemicals for each HAZCOM work
area, and put this list in a notebook with the MIT HAZCOM written Program and the MSDSs or
SDSs for the work area. The EHS Office is available to provide assistance with compiling this
list.
4.3.2.
The list shall include the name of the chemical or chemical product, as given on the original
container label and MSDS or SDS, the manufacturer, and the use and/or storage location(s) of
the chemical. The list must include materials such as wood, welding rods, solder wire, plastics,
metals, etc., when the use of these materials may involve exposures to hazardous particles or
fumes due to machining or heating.
4.3.3.
The EHS Office has posted a spreadsheet that can be used for compiling the inventory on the
HAZCOM website at: http://ehs.mit.edu/site/content/mit-hazard-communication-program.
An inventory program is available called ChemTracker and this can also be used to compile the
inventory. EHS can provide initial instructions for use of this program upon request at 2-3477.
Other inventory systems are acceptable, provided a list of chemicals, by location, can be
generated by the program.
4.3.4.
The list should be updated at least annually, adding new chemicals and deleting chemicals no
longer in use for the area. A copy of the initial list and the annual update must be furnished to
the DLC EHS Coordinator. Note: If the ChemTracker system is used, the EHS Office can run
reports on what is in the Chemtracker system on an annual basis.
4.3.5.
When new hazardous chemicals are ordered, they shall be promptly added to the chemical list.
The process is simple if ChemTracker is used. Before purchasing a new chemical product, asses
the hazards and protective measures required, and make sure the product can be handled
safely. Plan the amount of product needed for the work area and do not order excessive
quantities of chemicals. EHS can be consulted for assistance with an assessment.
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4.4.
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The EHS Coordinator shall forward the EHS office dated copies of the chemical lists on an
annual basis, unless ChemTracker or equivalent system that EHS staff have access to is used for
the inventory. The EHS office will assure these lists are maintained on file for 30 years. These
lists are considered a record of exposure, and so must be maintained for this time period.
Material Safety Data Sheet (MSDS) or Safety Data Sheet (SDS):
The MSDS or
SDS is a document generated by a chemical manufacturer, importer or distributor for each
hazardous chemical they produce or distribute that contains specified information. As part of
HACOM 2012, MSDSs are to be replaced with SDSs. The SDS will have a standard format that
must be used, which is not the case with an MSDS. On the SDS, specific content will need to be in a
given section of the SDS. Appendix F taken from OSHA website contains information on the
different sections of an SDS and the content that is to be included. The information on an MSDS or
SDS includes information on contents of chemical, hazards of chemical and protective measures.
HAZCOM employees must be provided ready access to an MSDS or an SDS for each chemical on
the chemical list and for any new hazardous chemical received and/or used in the work area.
4.4.1.
The Supervisor shall be responsible for assuring MSDSs or SDSs are obtained and made
available for each hazardous chemical in the workplace they supervise. Whenever a new
hazardous material is obtained for the workplace, an MSDS or SDS should be obtained for that
material. Hazardous materials include things such as wood products or metal that will be
machined or heated, and that can produce a toxic dust or hazardous fume. The supervisor may
designate someone to assist with this responsibility.
4.4.2.
MSDSs and/or SDSs shall be kept in a manner to ensure that they are readily accessible to
employees using the products. Readily accessible notebooks in specific work areas may be used
for ensuring that MSDSs/SDSs are available. Electronic data sheet storage, such as a CD-ROM
or the Internet, is acceptable provided that a hard copy of the MSDS or SDS can be provided to
emergency responders immediately in the event of an emergency, and provided that a back-up
system is available in the event of a power failure or on-line access delays. When data sheets
are available through means other than a notebook, employees must be able to obtain the MSDS
or SDS without assistance, e.g. this must be able to use the computers and access the data
sheets.
4.4.3.
All employees shall be informed of the location of MSDSs /SDSs by their supervisor, and the
process, e.g. procedure for computer use, for obtaining an MSDS or SDS.
4.4.4.
MSDS/SDS collections must be updated whenever a new material is introduced to the work
area and must be reviewed annually to assure they correlate with the chemical list. By July 1,
2016, all MSDSs must be replaced with SDSs. At the time of the annual update, MSDSs/SDSs
for products no longer being used in the work area may be deleted or discarded.
4.5.
Labels and Other Forms of Warning:
Labels on hazardous chemicals contain name of product, information about the hazard of the
chemical and precautions for safe use of the chemical. Labels updated to meet GHS requirements
will also contain red bordered pictograms to indicate hazard, and a signal word, either “Danger” or
“Warning”. The labels will have standardized language about hazards and precautions, and will
include a phone number for contacting manufacturer or distributor, and for emergency
information. All containers at MIT should be labeled to indicate the contents of the container.
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When the chemical is hazardous, the containers must be labeled as indicated below. No labels on
original containers should be defaced unless container is empty.
4.5.1.
The receiving employee shall inspect all newly received containers of hazardous chemicals to
ensure the labels are intact and not defaced. If there is a problem with the label and the
container is otherwise undamaged, a new label should be obtained from the seller. If the
container is damaged, the product should be returned to the seller.
4.5.2.
For materials obtained in bulk and transferred to smaller, portable container for use by
employees, these smaller or “portable” containers shall be labeled with the common name for
the product, as given on the MSDS, and pictograms or words which provide information
regarding the hazards of the chemical. Contact the EHS Office for additional information on
labels for portable containers.
4.5.3.
Alternate forms of labeling portable containers from that describe in 4.5.2 are not permitted in
HAZCOM areas at MIT unless approved by the EHS Office (617-452-3477). Blank labels can be
ordered to assist with portable container labeling. Chemical suppliers may also provide
portable container labels. Employees shall be informed of any special procedures developed in
their work area for labeling portable containers.
4.5.4.
If a material is produced at MIT, for example as part of a research project, and is transferred or
shipped outside the generator’s immediate lab, it must be properly labeled. Contact the EHS
Office for guidance regarding labeling and shipping requirements for all such materials.
4.6.
Training:
4.6.1.
HAZCOM Training. The types of HAZCOM training provided at MIT are listed below. In
order to assure that HAZCOM training is specific to the workplace, supervisors play a key role
in providing the training for their work areas. The EHS Office provides training for supervisors
and general training for employees. The EHS Office also assists supervisors with development
of training for their areas and development of training materials, when requested.
4.6.1.1. General Hazard Communication (HAZCOM) Training. (Web Based or Classroom)
This training provides an overview of chemical safety and the MIT HAZCOM program
and covers topics outlined in Appendix C. This training will be required for most
HAZCOM Employees, unless they work in an area where it has been determined by an
Industrial Hygiene Program (IHP) review that the chemicals used are limited and that the
Work Area Specific Hazard Communication Training is sufficient. The IHP review
exempting employees in an area from general HAZCOM training will be documented in
writing. As of December 1, 2013, Classroom General HAZCOM training will include
training on the Global Harmonization Changes and information on labels and pictograms.
4.6.1.2. Work Area Specific Hazard Communication Training
This training will be provided by supervisors or designated department personnel to all
new HAZCOM employees before they use the chemicals of concern in their work area.
This training consists of information on hazardous chemicals used in a specific work area
or for a specific task, and the measures established for safe use of the chemicals. This
training also includes information on where the MSDS’s are located in the work area and
who to contact with concerns about any chemical hazards. This training will be updated
when products presenting a new chemical hazard are introduced to the work area.
Personnel providing this training will need to take the Hazard Communication Training
for Supervisors.
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4.6.1.3. Hazard Communication Training for Supervisors
This training is required for supervisors and any other personnel who will be giving Work
Area Specific HAZCOM training and will consist of the materials covered in the “General
HAZCOM Training” described in 4.6.1.1 above, in addition to topics and materials to assist
supervisors with developing job specific HAZCOM training for their organization.
4.6.1.4. HAZCOM Awareness Information
This information will be available as an information booklet and on the web page and will
be a summary of the requirements of the HAZCOM standard and of the HAZCOM
program at MIT. EHS Coordinators can use this information to inform upper level
management such as department heads, directors, chiefs, for HAZCOM areas regarding
the HAZCOM program.
4.6.1.5. Global Harmonization System Training update
By December 1, 2013, all HAZCOM employees at MIT shall be informed of new GHS label
elements and the new format of safety data sheets. A separate course number has been
established to document this training for those employees who have not received such
training as part of General HAZCOM training.
4.6.2.
4.6.2.1.
Employees receive Work Area Specific Training from their supervisor or a designated
DLC employee prior to work with hazardous chemicals.
4.6.2.2.
Employees attend a classroom session of General HAZCOM Training or complete on-line
General HAZCOM training as soon as possible after beginning work at MIT unless they
work in a group specifically exempted from General HAZCOM training, as noted in
4.6.1.1 above.
4.6.3.
4.7.
Summary of Training Requirements for HAZCOM Employees
Training must be provided at the time of the employees’ initial assignment and whenever a new
physical or health hazard is introduced about which employees have not had previous training.
Employees must be trained as follows:
Training Documentation
All training shall be documented using the EHS Office Training Database. Training obtained
on-line will be documented automatically when the employee completes the training. General
HAZCOM Training in the classroom will be documented by EHS unless other arrangements are
made with the DLC EHS Coordinator. The DLC EHS Coordinator must assure that work area
specific HAZCOM training is documented. The supervisor must use the EHS Training Roster
Template or equivalent, and forward a copy of this form to their EHS Coordinator to document
all work area specific training.
Program Review
The EHS-MS Level II inspection program has incorporated questions specific to requirements of the
HAZCOM program for those areas that are defined as HAZCOM areas, and inspection data and
training records shall be reviewed annually as part of program review. When inspection data and
training records indicate there may be some lapses with program compliance, the EHS Office will
conduct a comprehensive audit of the HAZCOM program.
4.8.
Non-Routine Operations or Tasks Involving Hazardous Materials
4.8.1.
Whenever hazardous materials are involved in a non-routine task or operation, the supervisor
shall assure the hazardous materials involved are identified, material safety data sheets are
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collected for the hazardous materials to be used, and procedures are established to protect
employees from the hazards. An optional template form to document the hazard assessment is
in Appendix D.
4.8.2.
The supervisor will inform all employees involved in the operation or task of the hazards
identified and the measures established to protect the employee.
4.8.3.
The EHS Office (617-452-3477) is available to provide assistance with evaluation of non-routine
operations or tasks to include obtaining information on the hazards, making recommendations
for control measures, and providing training.
4.9.
Outside Contractors and Service Employees
4.9.1.
Whenever possible, work involving outside contractors or service personnel should be arranged
to minimize potential for contractor exposures to hazardous chemicals or substances associated
with MIT operations or facilities. When exposure to hazardous chemicals or substances
associated with MIT operations or facilities cannot be eliminated, contractors and service
employees who may be potentially exposed when performing their work shall be provided
information, as indicated below, on those hazardous chemicals. This information shall be
provided to contractors by Facilities Department when they are working under Facilities
jurisdiction. The Department/Center EHS Coordinator shall serve as a resource for information
required by Facilities Department representatives. For service personnel arranged by the DLC,
the DLC EHS Coordinator shall provide the information. The EHS Office can assist, as needed.
4.9.1.1.
A list of chemicals or substances such as lead, asbestos, or PCB, to which they may be
exposed.
4.9.1.2.
Information on the specific hazards of each chemical, and signs and symptoms of
overexposure.
4.9.1.3.
Procedures and equipment to be used for safe work in the area.
4.9.1.4.
Information about what to do in the event of a chemical emergency at MIT.
4.9.1.5.
Sources of information for hazardous chemicals, including the label and the MSDS or SDS,
and guidance for obtaining additional specific chemical information when working at
MIT.
4.9.2.
When the work being done by contractors hired by Facilities Department involves the use of
hazardous chemicals to which MIT employees may be exposed, the Facilities Department
project manager is responsible for obtaining and maintaining MSDSs for those materials for the
duration of the project, and for ensuring the project is conducted in a manner which minimizes
exposure to MIT personnel. In no case shall MIT personnel be exposed in excess of established
exposure limits for chemicals being used as part of a contract project. EHS Coordinators and
the EHS Office shall be informed of such work in advance by way of the form letter provided in
Appendix B, or by email with information similar to that requested on the form. Information on
specific chemicals being used by outside contractors shall be made available to the EHS Office
and to MIT personnel upon request. MIT employees can contact their EHS Coordinator or the
EHS Office to obtain this information.
4.9.3.
For outside contract or service personnel reporting to a DLC instead of being hired through the
Facilities Department, the DLC EHS Coordinator shall be responsible for obtaining MSDSs or
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SDSs from these contract/service personnel when such personnel use hazardous chemicals to
which the DLC employees may be exposed. It is advised that this information be maintained
with department chemical lists. DLC EHS Coordinators shall ensure contract/service work is
done in a manner which minimizes potential for exposure to MIT personnel, and shall make
MSDSs available to MIT employees upon request. In no case shall MIT personnel be exposed in
excess of established exposure limits due to work performed by outside service personnel.
5. Responsibilities
5.1.
Upper Level Management (Department Heads, Directors, Chiefs, etc.) Shall:
5.1.1.
Assure necessary resources are provided to implement and support the HAZCOM program for
their organization.
5.1.2.
Support the EHS coordinator, as needed, for implementation and maintenance of the HAZCOM
program within their organization.
5.1.3.
Be familiar with HAZCOM Awareness Information, as described in section 4.6.
5.2.
EHS Coordinators Shall:
5.2.1. Be familiar with the MIT HAZCOM program and their responsibilities in support of the
program. Note: These responsibilities depend on the organization(s) they support.
5.2.2.
Ensure that chemical lists, as described in Section 4.3, are compiled and maintained for all
HAZCOM areas in the department/center. Forward a copy of the chemical lists to EHS on an
annual basis for archiving. (Optional Format for Compiling Chemical List).
5.2.3.
Ensure that MSDS’s for hazardous chemicals used in HAZCOM areas are available as described
in Section 4.4.
5.2.4.
Ensure that HAZCOM training is provided to HAZCOM employees according to one of the
options described in Section 4.6.
5.2.5.
Assure records of employee training are maintained in accordance with Section 4.6.3.
5.2.6.
Provide assistance to supervisors/managers/PIs as needed, for accomplishing their
responsibilities under this program.
5.2.7.
When necessary, provide outside service and contract employees with information on
hazardous chemicals to which they may be exposed in the vicinity of the work to be performed,
in accordance with Section 4.9. This may involve communicating with Facilities Department
personnel who are overseeing contract work in the area (refer to Section 4.9).
5.3.
Supervisors/Managers/Principal Investigators of HAZCOM Areas or
Operations Shall:
5.3.1.
Complete HAZCOM Training for Supervisors in accordance with Section 4.6.
5.3.2.
Compile or ensure the compilation of a list of hazardous chemicals, as described in Section 4.3,
for each HAZCOM area under their jurisdiction, and furnish a copy to the EHS Coordinator.
These chemical lists shall be updated routinely, but at least annually.
5.3.3.
Obtain or ensure that an MSDS is readily accessible, as described in Section 4.4, for each
chemical on the chemical list.
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5.3.4.
Ensure hazardous chemicals in HAZCOM areas are properly labeled in accordance with Section
4.5.
5.3.5.
Complete a Work Area HAZCOM Summary Sheet (see Appendix A) to provide specific work
area information to employees for compliance with the HAZCOM Program, as described in
Section 4.2.
5.3.6.
Provide or assure employees are provided Work Area Specific HAZCOM training in
accordance with section 4.6, and document this training. Ensure that new employees receive
work area specific training prior to use of hazardous chemicals, and that the training is
documented as required in section 4.6.3.
5.3.7.
Ensure that appropriate procedures and controls have been established for safe work with
hazardous chemicals. (Contact the EHS Office as necessary for assistance with determining
what controls and procedures are appropriate.)
5.3.8.
Ensure employees are provided with and use protective clothing and equipment required for
safe use of a given chemical. (For assistance with determining protective clothing and
equipment requirements, refer to the label, the MSDS, and/or contact the EHS Office.
Additional information on Personal Protective Equipment Program can be found on the EHS
web page at http://ehs.mit.edu/site/content/personal-protective-equipment-ppe .
5.3.9.
Ensure for non-routine operations or tasks involving work with hazardous materials, a hazard
assessment is conducted and the employees are informed of those hazards and the protective
measures established.
5.3.10. Promptly investigate chemical accidents, incidents or exposures reported by employees and
complete a first report of injury form, when required. Notify the EHS Office of all accidents or
near misses involving chemicals. The link for completing a first report of injury is as follows:
http://web.mit.edu/hr/benefits/work_comp.html .
5.3.11. Support the EHS coordinator for the organization, as needed or requested, to address
HAZCOM program requirements.
5.4.
Employees Shall:
5.4.1.
Receive Work Area specific HAZCOM training, in accordance with Section 4.6, from their
supervisor or a designated representative from the department.
5.4.2.
Complete General HAZCOM Training in accordance with Section 4.6, unless
such training as noted in section 4.6.
5.4.3.
Be familiar with the hazards of chemicals they are using, and with the signs and symptoms of
overexposure to those chemicals.
5.4.4.
Know how to obtain an MSDS or SDS for chemicals they use in their work area.
5.4.5.
Use hazardous chemicals properly, follow procedures and precautions specified and use
protective clothing specified by the label, the MSDS or SDS and/or the supervisor or the EHS
Office.
5.4.6.
Properly label portable containers of hazardous chemicals in accordance with Section 4.5.
5.4.7.
Promptly report chemical exposures, accidents, incidents, and near misses to their supervisor.
5.5.
The Environment, Health, And Safety Office Shall:
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exempt from
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5.5.1.
Provide classroom General HAZCOM training, as needed, in accordance with Section 4.6.
5.5.2.
Develop and oversee web-based General HAZCOM training.
5.5.3.
Provide HAZCOM Training for Supervisors in accordance with Section 4.6.
5.5.4.
Develop and provide HAZCOM training materials, upon request, to the department for
departmental training.
5.5.5.
Provide technical support for reading and interpreting labels, MSDSs or SDSs.
5.5.6.
Assist with implementation and maintenance of the HAZCOM Program and address requests
of DLCs, EHS Coordinators, and supervisors for assistance.
5.5.7.
Provide a mechanism for compiling and maintaining chemical lists.
5.5.8.
Provide and maintain a central system for employee training records as noted in section 4.6.3.
5.5.9.
Audit to ensure DLCs implement the HAZCOM Program, where necessary, in accordance with
Section 4.7.
5.6.
All Those Who Hire Contractors Shall:
5.6.1.
Provide contractors under their jurisdiction information, as described in Section 4.9, concerning
hazardous chemicals associated with MIT operations when there is potential for contract
employee exposure to these materials.
5.6.2.
Ensure contract work involving the use of hazardous materials is conducted in a manner to
minimize exposure to MIT personnel.
5.6.3.
Obtain MSDSs for hazardous materials to be used by contractors and maintain them for the
duration of the project. Ensure that MIT employees are provided information concerning
hazardous materials upon request.
5.6.4.
Prior to initiation of work, notify EHS Coordinators of contract work in their area requiring the
use of hazardous materials. Notification will be done using form letter in Appendix B, or other
communication means such as email.
6. References / Related EHS Guides:
6.1. OSHA Standards 29CFR1910.1200, Hazard Communication.
6.2.
MIT Policies and Procedures, A Guide for Faculty and Staff, Chapter 9.2.
6.3.
MIT EHS Policy
7. Definitions
Note: Many of these definitions are taken from OSHA 29CFR.1200-Hazard Communication. Others are
pertinent to the organization at MIT. OSHA definitions are in italics.
7.1.
Article means a manufactured item other than a fluid or particle: (i) which is formed to a specific shape or
design during manufacture; (ii) which has end use functions(s) dependent in whole or in part upon its shape
or design during end use; and (iii) which under normal conditions of used does not release more than very
small quantities, e.g., minute or trace amounts of a hazardous chemical, and does not pose a physical hazard
or health risk to employees.
7.2.
Chemical means any substance or mixture of substances.
An official hardcopy of this document exists in the EHS Office or on the EHS website.
See Legal Disclaimer at: http://ehs.mit.edu/site/content/legal-disclaimer
Environment, Health &
Safety Office
Page #:
SOP Owner:
10 of 20
Emily Ranken
SOP #:
Revision #:
Implementation Date:
EHS-0016
2.0
5/14/05
Last Reviewed/Update Date:
Approval:
5/29/2013
EHS: Lou DiBerardinis; IHP: Pam
Greenley
7.3.
Chemical name means the scientific designation of a chemical in accordance with the nomenclature systems
developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts
Service (CAS) rules of nomenclature, or a name that will clearly identify the chemical for the purpose of
conducting a hazard classification.
7.4.
Classification means to identify the relevant data regarding the hazards of a chemical; review those data to
ascertain the hazards associated with the chemical; and decide whether the chemical will be classified as
hazardous according to the definition of hazardous chemical in this section. In addition, classification for
health and physical hazards includes the determination for the degree of hazard, where appropriate, by
comparing the data with the criteria for health and physical hazards.
7.5.
Common name means any designation or identification such as code name, code number, trade name, brand
name or generic name used to identify a chemical other than by its chemical name.
7.6.
Container means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like
that contains a hazardous chemical. For purposes of this OSHA definition, pipes or piping systems, and
engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers.
7.7.
Distributor means a business, other than a chemical manufacturer or importer, which supplies hazardous
chemicals to other distributors or to employers.
7.8.
DLC means Department, Lab, or Center.
7.9.
EHS Coordinator means an employee designated to coordinate Environmental Health and Safety programs
for a DLC.
7.10.
Employer means a person engaged in a business where chemicals are either used, distributed, or are produced
for use or distribution, including a contractor or subcontractor.
7.11.
Exposure or exposed means that an employee is subjected in the course of employment to a chemical that is a
physical or health hazard, and includes potential (e.g., accidental or possible) exposure. "Subjected" in terms
of health hazards includes any route of entry (e.g., inhalation, ingestion, skin contact, or absorption).
7.12.
Foreseeable emergency means any potential occurrence such as, but not limited to, equipment failure,
rupture of containers, or failure of control equipment which could result in an uncontrolled release of a
hazardous chemical into the workplace.
7.13.
Hazard category means the division of criteria within each hazard class, e.g., oral acute toxicity and
flammable liquids include four hazard categories. These categories compare hazard severity within a hazard
class and should not be taken as a comparison of hazard categories more generally.
7.14.
Hazard class means the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute
toxicity.
7.15.
Hazard not otherwise classified (HNOC) means an adverse physical or health effect identified through
evaluation of scientific evidence during the classification process that does not meet the specified criteria for
the physical and health hazard classes addressed in this section. This does not extend coverage to adverse
physical and health effects for which there is a hazard class addressed in this section, but the effect either falls
below the cut-off value/concentration limit of the hazard class or is under a GHS hazard category that has not
been adopted by OSHA (e.g. acute toxicity Category 5).
7.16.
Hazard statement means a statement assigned to a hazard class and category that describes the nature of
the hazard(s) of a chemical, including, where appropriate the degree of hazard.
An official hardcopy of this document exists in the EHS Office or on the EHS website.
See Legal Disclaimer at: http://ehs.mit.edu/site/content/legal-disclaimer
Environment, Health &
Safety Office
Page #:
SOP Owner:
11 of 20
Emily Ranken
SOP #:
Revision #:
Implementation Date:
EHS-0016
2.0
5/14/05
Last Reviewed/Update Date:
Approval:
5/29/2013
EHS: Lou DiBerardinis; IHP: Pam
Greenley
7.17.
Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a
simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
7.18.
HAZCOM Area means a work space at MIT that is not considered a research laboratory where hazardous
chemicals are used or stored. Examples include machine shops, maintenance shops, and arts and crafts shops.
7.19.
HAZCOM Employee refers to non-laboratory personnel at MIT who may be exposed to hazardous chemicals
under normal operating conditions or in foreseeable emergencies. Workers such as office workers who
encounter hazardous chemicals only in non-routine, isolated instances are not covered by the OSHA
HAZCOM regulation.
7.20.
HAZCOM Operation means a non-laboratory operation or process where hazardous chemicals or
substances are used, e.g. waste water treatment, parts cleaning, painting.
7.21.
Health hazard means a chemical which is classified as posing one of the following hazardous effects: acute
toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory
or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ
toxicity (single or repeated exposure); or respiration hazard. The criteria for determining whether a chemical
is classified as a health hazard are detailed in Appendix A to 29 CFR 1910.1200 – Health Hazard Criteria. A
link is provided at http://ehs.mit.edu/site/content/mit-hazard-communication-programLabel means an
appropriate group of written, printed or graphic information elements concerning a hazardous chemical that
is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside
packaging.
7.22.
Label elements means the specified pictogram, hazard statement, signal word and precautionary statement
of each hazard class and category.
7.23.
Material safety data sheet (MSDS) means written or printed material concerning a hazardous chemical
which is prepared in accordance with requirements of OSHA 29 CFR 1910.1200 - Hazard
Communication, paragraph g prior to adopting GHS system. MSDSs are to be replaced with SDSs by
July 1, 2016.
7.24.
Mixture means a combination or a solution composed of two or more substances in which they do not react.
7.25.
Physical hazard means a chemical that is classified as posing one of the following hazardous effects;
explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive;
pyrophoric (liquids, or solids); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in
contact with water emits flammable gas. See Appendix B to 29CFR1910.1200 – Physical Hazard Criteria,
linked at http://ehs.mit.edu/site/content/mit-hazard-communication-program.
7.26.
Pictogram means a composition that may include a symbol plus other graphic elements, such as a border,
background pattern, or color, that is intended to convey specific information about the hazards of a chemical.
Eight pictograms are designated under this standard for application to a hazard category.
7.27.
Precautionary statement means a phrase that describes recommended measures that should be taken to
minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or
handling.
7.28.
Product identifier means the name or number used for a hazardous chemical on a label or in the SDS. It
provides a unique means by which the user can identify the chemical. The product identifier used shall permit
cross-references to be made among the list of hazardous chemicals required in the written hazard
communication program, the label, and the SDS.
An official hardcopy of this document exists in the EHS Office or on the EHS website.
See Legal Disclaimer at: http://ehs.mit.edu/site/content/legal-disclaimer
Environment, Health &
Safety Office
Page #:
SOP Owner:
12 of 20
Emily Ranken
SOP #:
Revision #:
Implementation Date:
EHS-0016
2.0
5/14/05
Last Reviewed/Update Date:
Approval:
5/29/2013
EHS: Lou DiBerardinis; IHP: Pam
Greenley
7.29.
Produce means to manufacture, process, formulate, blend, extract, generate, emit, or repackage.
7.30.
Pyrophoric gas means a chemical in a gaseous state that will ignite spontaneously in air at a temperature of
130 degrees F (54.4 degrees C0 or below.
7.31.
Readily accessible means can be accessed by or be made available to an employee during their
immediate work-shift.
7.32.
Safety data sheet (SDS) means written or printed materials concerning a hazardous chemical that is
prepared in accordance with paragraph (g) of OSHA 29CFR1910.1200.
7.33.
Signal word means a word 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 in this section are “danger” and “warning.” “Danger”
is used for the more severe hazards, while “warning”: is used for the less severe.
7.34.
Simple asphyxiant means a substance or mixture that displaces oxygen in the ambient atmosphere and can
thus cause oxygen deprivation in those who are exposed, leading to unconsciousness and death.
7.35.
Specific chemical identify means the chemical name, Chemical Abstracts Serve (CAS) Registry Number, or
any other information that reveals the precise chemical designation of the substance.
7.36.
Substance means chemical elements and their compounds in the natural state or obtained by any production
process, including any additive necessary to preserve the stability of th product and any impurities deriving
from the process used, but excluding any solvent which may be separated without affecting the stability of the
substance or changing its composition.
7.37.
Use means to package, handle, react, emit, extract, generate as a byproduct, or transfer.
8. Appendices
8.1.
Appendix A: MIT Work Area HAZCOM Summary Sheet
8.2.
Appendix B: Contractor Chemical Use Information Form
8.3.
Appendix C: General HAZCOM Training Outline
8.4.
Appendix D: Non-Routine Operation/Task Hazard Assessment Form
8.5.
Appendix E: GHS Pictograms Handout
8.6.
Appendix F: GHS SDS Format Information
An official hardcopy of this document exists in the EHS Office or on the EHS website.
See Legal Disclaimer at: http://ehs.mit.edu/site/content/legal-disclaimer
Appendix A
MIT WORK AREA HAZCOM SUMMARY SHEET
(To be posted in the work area)
Date Posted:
MIT WORK AREA HAZCOM SUMMARY SHEET
(To be posted in the work area)
This form serves as a supplement to the MIT HAZCOM Program &summarizes hazard
communication information for the work area below. The MIT HAZCOM Program is at
http://ehs.mit.edu/site/content/mit-hazard-communication-program
Organization
Location (Room and Building)
Supervisor and Phone
EHS Coordinator and Phone
Employees have a right to information concerning the potentially hazardous chemicals they use
or are routinely exposed to as part of their job. It is the policy at MIT to ensure that chemical
hazards are identified within each work area and that chemical hazard information is available to
all employees potentially exposed. This summary sheet is applicable to employees in nonlaboratory areas who may be exposed to potentially hazardous chemicals as a normal part of
their work. Laboratory employees are covered by the requirements of the Chemical Hygiene
Plan for their area.
EMPLOYEE TRAINING. Prior to work with or around hazardous chemicals, employees are to
receive training concerning those chemicals and their potential hazards, signs and symptoms of
overexposure, precautions and equipment for safe use of the chemical, what to do in the event
of a chemical emergency, and sources for information on the hazardous chemical to include
labels and material safety data sheets.
General Hazard Communication (HAZCOM) Training is available through EHS. It
may or may not be required for your area, as noted below. For details on the training,
contact the EHS Coordinator listed above or the EHS Office.
Work Area Specific HAZARD Communication is required for all employees handling
potentially hazardous chemicals and is provided by your DLC as indicated below. If you
have not received training, speak with your supervisor or contact EHS at 2-EHSS (617452-3477 off campus).
General HAZCOM Training Required
(Yes or No)
Work Area Specific Training Provided by
CHEMICAL LISTS, MATERIAL SAFETY DATA SHEETS or SAFETY DATA SHEETS are to
be compiled by the Supervisor in your work area. The MSDS or SDS is a source of information
on hazardous chemicals you handle as part of your work. You have a right to access the list and
the MSDSs or SDSs for hazardous chemicals in your area. Below is access information.
Chemical List and MSDS or SDS Location Information
CHEMICAL LABELING. All hazardous chemicals must be properly labeled. The label provides
information on the hazards of a chemical and instructions for safe use of the chemical. If a
material is not labeled, the label is damaged, or if you have any questions concerning the
information on the label, contact your supervisor. Do not use a chemical product that is not
clearly labeled. If you transfer bulk chemicals to a second smaller container, properly label that
smaller container. Ask your supervisor for information on work area procedures for labeling
portable containers.
Appendix B
MIT HAZCOM PROGRAM
CONTRACTOR CHEMICAL USE INFORMATION
MIT HAZCOM PROGRAM
CONTRACTOR CHEMICAL USE INFORMATION
From: Facilities Department
To:
(EHS Coordinator and Organization)
This letter is being sent to inform you that the contract detailed below will
involve the use of hazardous chemicals. Arrangements have been made to
minimize potential for exposure to University employees. However, should there
be any questions or concerns about exposures during this project, or to obtain a
Material Safety Data Sheet for chemicals listed, please contact the project contact
listed below. It is advised that this information be maintained on file with
department chemical lists.
Project name:
Project contact and phone:
Project number:
Project description:
Hazardous chemicals to be used:
APPENDIX C
HAZCOM Training Topics
General and Web based HAZCOM Training: EHS, MIT will oversee the MIT Web
Based and Classroom HAZCOM Training. The following topics will be covered in this
training:
Information about the HAZCOM standard and the HAZCOM Program at MIT.
Details on sources of information for handling hazardous chemicals, including
the label and the MSDS, and guidance for interpreting this information.
The concept of exposure limits for chemicals.
Routes of exposure for chemicals.
Common chemical hazards and how to recognize them.
SDSs and how to read them.
Labels and how to read them.
GHS Pictograms and what they mean.
General emergency response procedures.
Work Area Specific HAZCOM training: The following topics should be covered in job
specific HAZCOM training:
Information on specific chemicals the employee is required to use, to include the
hazard(s) of the chemical, the exposure limits, if any, for the chemical, and
methods and observations that may be used to detect the presence or release of
the hazardous chemical in the specific work area.
The availability and location in your work area of the notebook with the written
MIT HAZCOM Program, chemical lists and MSDSs for the specific work area.
Measures established in the specific work areas for employee protection from the
hazardous chemicals, including specific procedures established for the routine
use of the chemicals and specific procedures for response to emergencies
involving that chemical.
For chemical handling operations where personal protective equipment (PPE) is
required, the employees must receive training on the use of the PPE, the
limitations of the PPE, and the maintenance requirements for the PPE. (Link to
PPE and Respiratory Protective Equipment (RPE) programs when established.)
Supplemental Training and Training Materials: The EHS Office shall develop and
make available information for use by supervisors to assist them in providing work area
specific HAZCOM training to their employees. The EHS Office shall offer Supplemental
HAZCOM Training to EHS Coordinators, EHS Representatives, and supervisors
designated to provide HAZCOM training by the department. The supplemental training
shall include the following information:
The HAZCOM program requirements.
Methods for compilation of chemical lists.
Methods for determining chemical hazards and grouping chemicals by
hazard.
Methods for determining and establishing procedures for safe work with
chemicals.
Forms for use in developing Job Specific Chemical Safety training.
Procedure for documentation of job specific training.
Supplementary materials on commonly hazardous chemicals in HAZCOM
areas at MIT.
APPENDIX D
Non-Routine Operation or Task Hazard Assessment Form
(MIT EHS Office rev 8/10)
This form is to document an assessment of a non-routine operation or task involving use or
potential exposure to hazardous chemicals that your employees do not normally use or work
around. Use this form to identify the hazards, and the control measures needed to protect the
employees, and then to train your employees about the hazards and procedures they need to
follow. Attach an MSDS or SDS for each hazardous chemical or product listed.
DLC:
Location(s) of operation:
Assessment Conducted by:
PI/Supervisor:
Signature:
Date signed:
Describe the non-routine operation or task. (A step by step description may be useful
for a complicated task)
Chemical or product
and ingredients.
Summary of
Hazard(s)
Personal Protective
Equipment Needed
Other controls such as
blowers, isolation, etc.
APPENDIX E
Taken from OSHA website at:
http://www.osha.gov/Publications/HazComm_QuickCard_Pictogram.html
HCS Pictograms and Hazards
As of June 1, 2015, the Hazard Communication Standard (HCS) will require pictograms 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). The
pictogram on the label is determined by the chemical hazard classification.
Health Hazard






Carcinogen
Mutagenicity
Reproductive Toxicity
Respiratory Sensitizer
Target Organ Toxicity
Aspiration Toxicity
Flame






Flammables
Pyrophorics
Self-Heating
Emits Flammable Gas
Self-Reactives
Organic Peroxides
Exclamation Mark






Gas Cylinder

Gases Under Pressure
Corrosion



Flame Over Circle
Skin Corrosion/Burns
Eye Damage
Corrosive to Metals
Exploding Bomb



Environment
Oxidizers

Explosives
Self-Reactives
Organic Peroxides
Skull and
Crossbones
(Non-Mandatory)

Irritant (skin and
eye)
Skin Sensitizer
Acute Toxicity
Narcotic Effects
Respiratory Tract
Irritant
Hazardous to Ozone
Layer (NonMandatory)
Aquatic Toxicity

Acute Toxicity (fatal
or toxic)
APPENDIX F
Taken from OSHA website at:
http://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html
Hazard Communication Safety Data Sheets – New Format
The Hazard Communication Standard (HCS) requires chemical manufacturers, distributors, or importers
to provide Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to
communicate the hazards of hazardous chemical products. As of June 1, 2015, the HCS will require
new SDSs to be in a uniform format, and include the section numbers, the headings, and associated
information under the headings below:
Section 1, Identification includes product identifier; manufacturer or distributor name,
address, phone number; emergency phone number; recommended use; restrictions on use.
Section 2, Hazard(s) identification includes all hazards regarding the chemical; required
label elements.
Section 3, Composition/information on ingredients includes information on chemical
ingredients; trade secret claims.
Section 4, First-aid measures includes important symptoms/ effects, acute, delayed;
required treatment.
Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment;
chemical hazards from fire.
Section 6, Accidental release measures lists emergency procedures; protective equipment;
proper methods of containment and cleanup.
Section 7, Handling and storage lists precautions for safe handling and storage, including
incompatibilities.
Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits
(PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective
equipment (PPE).
Section 9, Physical and chemical properties lists the chemical's characteristics.
Section 10, Stability and reactivity lists chemical stability and possibility of hazardous
reactions.
Section 11, Toxicological information includes routes of exposure; related symptoms, acute
and chronic effects; numerical measures of toxicity.
Section 12, Ecological information*
Section 13, Disposal considerations*
Section 14, Transport information*
Section 15, Regulatory information*
Section 16, Other information, includes the date of preparation or last revision.
*Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through
15(29 CFR 1910.1200(g)(2)).
This is the new standard format for what will now be called Safety Data Sheets, not
Material
Safety
Data
Sheets.
More
details
about
content
are
at
http://www.osha.gov/dsg/hazcom/index.html. Some chemical suppliers are already
using this format. If you have questions about information or interpretation, contact the
MIT EHS Office at 617-452-3477 or [email protected].