OSU's Written Hazard Communication Program
Page Updated October 2008
OSU's official written Hazard Communication Program is Oklahoma State University Policy and Procedures letter 3-0535, as seen below.
HAZARD COMMUNICATION PROGRAM |
3-0535
Business
& Finance
April, 1994 |
INTRODUCTION AND GENERAL STATEMENT
1.01 Almost every workplace contains some substances which could pose potential
health problems to employees if exposed to them in concentrations or in a manner not
prescribed. Oklahoma State University recognizes that its employees have the right and
need to know the properties and potential safety and health problems of substances to
which they may be exposed. With this policy, Oklahoma State University intends to ensure
the transmission of necessary information to employees regarding substances in the
workplace, pursuant to Title 40, Oklahoma Statues, Section 401-424 and the Federal
Occupational Safety and Health Act Hazard Communication Standard, 29 Code of Federal
Regulations 1910.1200.
1.02 A hazardous substance is defined as any substance that is a physical hazard
or a health hazard, i.e. compressed gases, explosives, flammables, oxidizers, carcinogens,
toxins, irritants, or corrosives. Hazardous substances generally have a Material Safety
Data Sheet (MSDS) provided by the manufacturer.
1.03 This policy is established to:
- a. Ensure compliance with the applicable state and federal standard.
- b. Safeguard the health and safety of employees of Oklahoma State University.
- c. Create guidelines to follow for implementation and maintenance of a hazard
communication program.
1.04 The Hazard Communication Program for Oklahoma State University shall be
administered by the Manager of Environmental Health & Safety Services, whose line of
administrative authority is through the Director of Physical Plant Services. The Hazard
Communication Coordinator has been designated as the Master Record Keeper.
1.05 The OSU Branch Campuses will be responsible for developing and maintaining
their own internal procedures.
CHEMICAL INVENTORY AND MATERIAL SAFETY DATA SHEETS
2.01 Annual updates of the Chemical Information Lists (CIL) beginning with the
fiscal year July 1, 1990, are required. Individual department supervisors shall complete
and mail Chemical Information Lists (CIL) to the Master Record Keeper no later than August
1 of each year. CIL's must be submitted in alphabetical order and shall be verified for
completeness by the appropriate department head. Each CIL is subject to audit by the
Master Record Keeper. The Master Record Keeper will provide copies of the CIL to the Local
Fire Department and the Local Emergency Planning Committee.
2.02 A master CIL shall be created and maintained by the Master Record Keeper in
a manner that will allow a listing of hazardous substances by building, room, department,
and manufacturer.
2.03 Each building on campus shall have a CIL. The CIL shall include a listing
of all hazardous substances present. The Master Record Keeper will develop an overall
Building CIL by combining the individual lists supplied by each department/area in the
building.
2.04 Each time a department receives a new hazardous substance, the substance
must be added to the departmental CIL within 30 days. A copy of the CIL, along with the
original copy of the Material Safety Data Sheet (MSDS) for the new substance, must be sent
to the Master Record Keeper.
2.05 Material Safety Data Sheets (MSDS's) provide detailed information on a
hazardous substance. The sheets include information such as product name (hazardous
substance), chemical abstract service number(s), ingredients, physical data, fire and
explosion hazard data, environmental and disposal information, health hazard data,
first-aid instructions, and handling precautions.
2.06 Department Heads must assure that MSDS's for all hazardous substances in
the work place are obtained. A copy of the MSDS's must be kept in the department and be readily
accessible to employees who work with the hazardous substances. The original copies of
MSDS's must be sent to the Master Record Keeper to be placed in the master file. Copies of
the MSDS's should be placed in a filing cabinet, notebook, etc., and marked with an MSDS
label available from the Master Record Keeper.
2.07 Purchase Orders for any hazardous substance, regardless of the quantity
ordered, shall require that an MSDS be obtained. It is the responsibility of the ordering
department (Department Head) to make every effort to obtain an MSDS from the manufacturer.
If difficulties are encountered, the Master Record Keeper can assist.
2.08 Areas that store hazardous substances for distribution to other departments
must obtain MSDS's for these substances and prepare a CIL. When the storeroom sells or
transfers a hazardous substance to another department, the storeroom supervisor must
assure that the receiving department or individual receives a copy of the MSDS. Likewise,
if the storeroom prepares a substance by any process for distribution to another
department or individual, then the storeroom has assumed the role of the manufacturer and
must prepare an MSDS for the substance. The Department Head over the storeroom areas shall
assure that the above steps have been completed.
2.09 Should the supervisor of an area dealing with hazardous substances become
aware of any information that is significant in regard to the health hazard of a substance
(that does not already appear on the MSDS), he/she must add the information to the MSDS
within a period not to exceed 30 days. The supervisor must also report this information to
the Master Record Keeper. The information will be added to the master file and reported in
writing to the appropriate state agency for follow-up investigation with the chemical
manufacturer.
SIGNS AND LABELS
3.01 All existing labels on containers of hazardous substances must remain
intact. The labels must be legible and written in English. Where labels are not present or
are not legible, a Hazardous Material Information System (HMIS) label will be affixed to
those containers holding the hazardous substance.
3.02 It is the responsibility of the Department Heads to assure that each
container of a hazardous substance in the workplace is marked, labeled or tagged with
the...
- a. Common/trade name of the substance.
- b. Appropriate hazard warnings: Health, flammability, reactivity, and personal
protective equipment.
- c. Chemical abstract service number (CAS).
HMIS labels are available from the Master Record Keeper for this purpose.
3.03 Portable containers filled with hazardous chemicals transferred from a
labeled storage container must be labeled if:
- a. The material is not used within the work shift of the employee making the transfer.
- b. The employee that made the transfer leaves the work area.
- c. The container is moved to another work area and is no longer in possession of the
employee who filled the container.
Labels on portable containers are not required if the employee who made the transfer
uses all of the contents during the work shift.
3.04 Storage tanks must be labeled with the identity of the substances that it
contains. The label must show the health, flammability, reactivity, and physical hazards
associated with the substance. The National Fire Protection Association (NFPA) rating
system must be used to show these ratings.
3.05 Containers used by outside service contractors shall be properly labeled
with either a manufacturer's label or an HMIS label prior to the use of the hazardous
substance on A & M Colleges' property.
3.06 Employees that work in the storeroom areas, where sealed containers of
hazardous substances are received for distribution to other departments, must assure that
the manufacturer's labels are not defaced or removed. If the labels are removed or
defaced, follow the procedure outlined in 3.02 for replacement of the labels. In addition,
if a spill or leak occurs in a container of hazardous substance, the employees should
leave the area, go to a place of safety, and call the Environmental Health and Safety
Department for assistance. MSDS's for all substances in the storeroom must be obtained and
be readily accessible to employees for these substances.
3.07 In addition to the labeling requirement for containers of hazardous
substances, the area where the hazardous substance is used or stored must be properly
marked. In order to accomplish this requirement, the Master Record Keeper has obtained the
Uniform Laboratory Hazard Signage (ULHS) system. The signs identify the areas where
hazardous substances are used or stored through pictograph symbols. The signs will warn
employees and visitors that proper precautions should be observed when entering the area.
The ULHS signs are available from the Master Record Keeper.
EXCLUSIONS
4.01 These regulations do not apply to any substances which are foods, drugs,
cosmetics, or tobacco products intended for personal consumption by the employees while in
the workplace. Additionally, these regulations do not apply to any consumer products and
food stuffs packaged for distribution to (and intended for use by) the general public.
Consumer products are packaged and used as a normal consumer would use the product as
defined in the Consumer Product Safety Act and Federal Hazardous Substances Act.
4.02 The term "laboratory" is intended to mean a workplace where
relatively small quantities of hazardous chemicals are used on a nonproduction basis. All
research laboratories may be excluded from the standard except for the following
requirements:
- a. Complete a CIL and submit a copy to the Master Record Keeper.
- b. Conduct a training and education program that shall be designed to inform employees
of appropriate work practices, protective measures, and emergency measures regarding
hazardous materials in the workplace.
- c. Supply employees with the chemical names of all hazardous substances.
- d. Maintain MSDS's and make them readily accessible to employees.
- e. Ensure that containers of hazardous substances bear a legible manufacturer's label or
an HMIS label.
- f. Develop and implement a written chemical hygiene plan and provide a copy to the
Master Record Keeper. Use the OSU Laboratory Safety Manual as a guide to develop the
Chemical Hygiene Plan. CFR 29 1910.1450.
EXPOSURE
5.01 Exposure or exposed means that an employee is subjected to a hazardous
chemical in the course of employment through any route of entry (inhalation, ingestion,
skin contact or absorption, etc.), and includes potential (e.g. accidental or possible)
exposure as referenced by the MSDS. When the employer discovers that an employee has
received a potentially hazardous exposure to any substance or agent, the employer must
immediately notify the employee and take such steps that may be necessary to provide
medical evaluation, monitoring, or treatment. Likewise, an employee that has received a
potentially hazardous exposure to a substance or agent must immediately notify the
employer of such exposure.
5.02 After the appropriate safety and health precautions have been taken, it is
the responsibility of the employee's supervisor to fill out an Employee Exposure Report
(EER). EER forms are available from the Master Record Keeper. The completed EER should be
submitted to the Master Record Keeper (original copy), with a copy retained at the
department and a copy provided to the employee.
5.03 The Master Record Keeper will retain the original EER and send a copy to
the Personnel Services Office. The Personnel Services Office will place the EER in the
employee's permanent personnel file to be retained for the length of employment plus 40
years.
5.04 An affected employee (or designated representative) may make a request to
the Master Record Keeper or employing department for access to copies of the appropriate
CIL and MSDS's. Access to the appropriate CIL and MSDS's shall be granted within a
reasonable time, place, and manner, but never later than one working day after the request
for access is made. In addition, whenever an affected employee or designated
representative requests a copy of the CIL and/or MSDS's, the Master Record Keeper shall,
within 15 days, assure that either a copy or a mechanical means to copy is provided.
5.05 An employee that has requested information as stated in section 5.04, and
has not received the requested information within the specified time period, may refuse to
work with the substances or refuse to work at the location for which the request was made.
An employer may not discharge or initiate any adverse personnel action against any
employee because the employee has exercised his/her right to the requested information.
Furthermore, an employer may not request or require an employee to waive any rights under
this policy. Any such waiver executed shall be null, void, and unenforceable.
5.06 Employees working in areas where exposure(s) to hazardous substances exist
shall be required to perform their jobs in accordance with precautions communicated to
them during training and education programs. A supervisor may take the appropriate
disciplinary action when an employee does not comply with the precautionary measure this
policy indicates.
5.07 The Department Head or designee shall be responsible for providing the
following in all departmental areas having contact with hazardous substances:
- a. Chemical name of each hazardous substance.
- b. Correct labeling of each hazardous substance.
- c. Availability of any MSDS for each hazardous substance present in the immediate work
area.
- d. Training and education of employees on work practices, protective measures, and
emergency measures in the work place.
5.08 Periodic checks for program integrity will be made by means of an audit
team comprised of personnel from the Environmental Health and Safety Office.
TRAINING
6.01 The Master Record Keeper will present a Train-the-Trainer Program for
supervisors of campus departments. The supervisors of campus departments will be
responsible for the training of their employees on the Hazard Communication Program.
6.02 All employees of Oklahoma State University must receive Hazard
Communication training. All employees will include temporary, work-study, part-time,
graduate assistants, teaching assistants, and full-time personnel. New employees will
receive a general information brochure on Hazard Communication from Personnel Services at
the start of employment.
6.03 Department supervisors shall inform their employees of the requirements of
the Hazard Communication Standard (cover the four stages of the program), any operations
in their department where hazardous substances are used, the location and availability of
the MSDS's and CIL, and a review of the department Contingency Checklist. In addition, the
training must cover the methods used to detect the presence of a substance released and
the steps to take after the release is detected, the physical and health hazards in the
department, the measures and equipment used for personal protection, and the details of
the written plan. The training must occur within 30 days of employment for new employees.
Any time a new hazard is introduced into the workplace, employees must be trained on the
hazard; and an annual retraining session is required for all employees.
6.04 Training and education provided to employees and others must be documented
with detailed records of training maintained by the department. The training records must
be kept for the length of employment plus 40 years. A copy of all training records must be
sent to the Master Record Keeper.
FIRE SAFETY
7.01 The Master Record Keeper will create a building CIL package consisting of
floor maps and rooms. The building CIL packages will be submitted to the Local Fire
Department. The building CIL packages will be updated annually by the Master Record
Keeper.
7.02 In addition to the annual update requirement for the CIL, each
department/area on campus is required to complete and submit a Contingency Checklist. The
Contingency Checklist should be completed and sent to the Master Record Keeper at the same
time the annual CIL is sent. The Contingency Checklist is needed to prepare and update the
Campus/County-wide Contingency Plan. The Contingency Checklist forms are available from
the Master Record Keeper.
OUTSIDE CONTRACTOR'S RESPONSIBILITIES
8.01 Any time an outside contractor brings a hazardous substance(s) into the
workplace, a CIL and MSDS(s) for the substance(s) must be received. Similarly, a CIL and
MSDS(s) for all hazardous substances in the area that the contractor will be working must
be provided to the contractor. This exchange will be coordinated by whomever is granting
the contract. A contractor safety form must be signed stating the contractor agrees to
this provision.
8.02 Service contractors whose work or materials pose a health hazard to
employees shall be responsible for the training and education requirements outlined under
the training section of this policy.
8.03 The above cross-training must be documented and the records must be
retained in the department where the work is performed. Copies of the cross-training
records must also be sent to the Master Record Keeper.
8.04 Outside contractors must comply with all the provisions of the Hazard
Communication Standard while serving on the OSU Stillwater campus. Periodic audits from
the Master Record Keeper will be performed to assure compliance.
ASBESTOS NOTICE AND LABELING
9.01 Pipes, boilers, storage vessels, structural members, or equipment with
insulating material that might be removed, penetrated, damaged or otherwise disturbed by
repair, remodeling, renovation, maintenance or other activity, shall be labeled with
cautionary labels. Such caution labels shall be printed in letters of sufficient size and
contrast as to be readily visible and legible. Each room or area where the conditions
require that labels exist shall have a minimum of one such label, and additional labels as
is necessary, to insure ready visibility and legibility. Equipment with
asbestos-containing material shall bear the following label:
DANGER
Contains Asbestos Fibers
Avoid Creating Dust
Cancer and Lung Disease Hazard
9.02 Areas with asbestos-containing material used as acoustical material on
ceilings or walls shall post the following notice:
NOTICE TO EMPLOYEES
This facility has been inspected
for the presence of
Asbestos-containing material.
Asbestos-containing material is present in this facility.
Asbestos-containing material may cause health problems.
Revised: October 1990
April 1994
OSU-SPECIFIC POLICIES & PROCEDURES
The purpose of the Contingency Check List
is to assist in the preparation of a Campus/County-wide contingency plan in cooperation
with the Payne County Local Emergency Planning Committee.
One of the most important items of information requested on the
contingency check list is the contact personnel (who to contact in the event of an actual
emergency).
It is important that the form is completed in its entirety, i.e.,
nearest fire hydrant, storm drains, or drain inside the building, etc.
Even though no hazardous substances are used or stored in the
department, show the evacuation route to be used for other emergency situations. If no
chemicals are used in the department, such as offices, some questions will not apply;
enter N/A.
The Employee Exposure Report (EER) was developed to comply with the
law and to assure the safety and protection of all employees at Oklahoma State University.
It is important to answer all questions on the EER after an exposure
or potential exposure has occurred. It is the responsibility of the employee's supervisor
or department head to complete the form, not the affected employee. Once the form is
completed, it should be sent to the Environmental Health and Safety Department. The
Employee Exposure Report will be kept on file for a period of forty years after the
employee has left employment at Oklahoma State University.
The completion of the Employee Exposure Report is to protect all
employees and is not an admission of liability.
The following items are available from the Environmental Health and
Safety Department, at no charge to departments. Please call x47241 to place an order for
the needed supplies.
- HAZARDOUS MATERIALS IDENTIFICATION SYSTEM
(HMIS) LABELS
- MATERIAL SAFETY DATA SHEET (MSDS) LABELS
- UNIFORM LABORATORY HAZARD SIGNAGE (ULHS)
LABELS
- HAZARD COMMUNICATION BROCHURES
 Outline of Right-to-Know Program < BACK NEXT > Chemical Inventory List
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