Hazardous Communication Program

What Every Employer Nees to Know About HazCom and GHS (PDF)
GHS and SDS Training (PowerPoint)

Fort Lewis College is complying with the requirements of OSHA's Hazard Communication Standard by:

  • Identifying hazardous materials
  • Compiling a list of hazardous chemicals
  • Using Safety Data Sheets (SDS)
  • Ensuring that containers are properly labeled
  • Training our workers

In addition, we will provide this information to subcontractors involved in a specific project so they may provide it and train their employees.

This program applies to all work operations on campus and the Hesperus campus. Faculty, students, and staff may be exposed to hazardous substances under normal working conditions or during an emergency. The Environmental Health & Safety (EH&S) manager is the program coordinator and is responsible for the program. The EH&S department will regularly review and update the program annually or more often.

Copies of the written program may be obtained from the Environmental Health & Safety office, Education Business Hall, Room 181. All employees and students can get further information on this written program, the Hazard Communication Standard, and applicable SDS from the EH&S office.

Under this program, our employees will be informed of the contents of the Hazard Communication Standard, the hazardous properties of chemicals with which they work, safe handling procedures, and measures to take to protect themselves from these chemicals. Our employees will also be informed of the hazards associated with non-routine tasks.

After reading this program, if you find improvements that can be made, please contact the EH&S department. We encourage all suggestions because we are committed to the success of our written hazard communication program. We strive for clear understanding, safe behavior, positive reinforcement, and involvement in the program from every level of Fort Lewis College.

Hazard Evaluation Procedures

Our chemical inventory is a list of hazardous chemicals known to be present on campus. Anyone who comes in contact with the hazardous chemicals on the list needs to know what those chemicals are and how to protect themselves. That is why it is so vital that we identify hazardous chemicals, whether they are found in a container or generated in work operations (for example, welding fumes, dust, and exhaust fumes). The hazardous chemicals on the list can cover a variety of physical forms, including liquids, solids, gases, vapors, fumes, and mists.

Sometimes hazardous chemicals can be identified using purchase orders. Identification of others requires an actual inventory of the facility. The EH&S manager updates the inventory as necessary and keeps the chemical inventory list, and any related work practices followed on campus. The list of chemicals can be found in the Education Business Hall, Room 181, where it is accessible during work hours.

Fort Lewis College relies on the manufacturer or importer to identify the hazardous material in the products it purchases and uses on campus.

Safety Data Sheets (SDS)

The SDS we use are fact sheets for chemicals that pose a physical or health hazard in the workplace. SDS provide our employees with specific information about the chemicals they use. The EH&S manager and department representatives are responsible for obtaining/maintaining the SDS at our College. The EH&S manager will contact the chemical manufacturer or vendor if additional research is necessary.

Some SDS are kept in paper form by each department that uses hazardous chemicals. The preferred method is to access the SDS online from the manufacturer. Online access for SDS must be available immediately and without password-protected computer workstations. This is an OSHA requirement. If possible, laboratories should have a dedicated computer strictly for SDS access. Employees can also obtain access to them by submitting a written request to EH&S for paper copies or downloading them.

The procedures followed if the SDS is not received at the time of the first shipment is for the department ordering the material to follow up with the supplier and forward this information to the EH&S department. No chemicals should be introduced to Fort Lewis College without evaluating the SDS and ensuring appropriate safeguards are in place. The EH&S department will assist the departments if the need arises.

Labels and Other Forms of Warning

Labels will follow the Hazard Communication Standard 2012 and the Global Harmonization Standard for labeling of chemicals, which requires the name, address, and phone number of the manufacturer, distributor, or other responsible parties, the product identifier, and signal word (Danger or Warning), hazard statement(s), precautionary statements, and pictograms.

This labeling requirement is different for EPA-registered chemicals, many of which are used by campus custodians. Labeling is still required on secondary containers, but labels must follow EPA guidelines. With assistance from the EH&S manager, the individual departments are responsible for ensuring that all hazardous chemicals in secondary containers are appropriately labeled and updated as necessary. This same process applies to newly purchased materials. Each department is responsible for ensuring the proper labeling of any shipped containers. Employees will refer to the corresponding SDS in verifying label information.

Informational handouts are available to inform employees about the hazard communication standard, the Hazardous Materials Identification System (HMIS), and the National Fire Protection Association (NFPA) labeling systems used on campus and shipped containers. Copies are available in the EH&S office.

If employees transfer chemicals from a labeled container to a portable container intended only for their IMMEDIATE use, no labels are required on the portable container. A label is required if the container is used during the following shift or class. Labels must be replaced if worn, damaged, or missing by the person responsible for maintaining the container. Departments should inspect containers on an ongoing basis.

Training

Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training and any necessary retraining on the Hazard Communication Standard. The safe use of those hazardous chemicals by either department trainers or EH&S.  Exposure 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) and includes potential exposure. Additional training is required whenever a new hazard or an old one changes.

Information and training are critical parts of the hazard communication program.

We train our employees to read and understand the information on labels and

SDS, to determine how the information can be obtained and used in their work areas and to understand the risks of exposure to the chemicals in their work areas as well as the ways to protect themselves both on and off the job.

Our goal is to ensure employee comprehension and understanding, including being aware that they are exposed to hazardous chemicals, knowing how to read and use labels and SDS, and appropriately following our established protective measures. We ask our employees to ask their immediate supervisor questions with support offered by the EH&S department. As part of the training program assessment, employees will be asked about the training they have received and their suggestions for improving it. In this way, we hope to reduce any incidence of chemical source illnesses and injuries.

Training Content

Training content emphasizes the following elements:

  • Summary of the standard and this written program, including what hazardous chemicals are present, the labeling system used, and access to SDS information and what it means.
  • Chemical and physical properties of hazardous materials (e.g., flash point,               reactivity) and methods that detect the presence or release of chemicals (including chemicals in unlabeled pipes).
  • Physical hazards of chemicals (e.g., the potential for fire, explosion, etc.).
  • Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
  • Procedures to protect against hazards (e.g., engineering controls; work practices or methods to assure proper use and handling of chemicals; personal protective equipment required and its proper use and maintenance; and procedures for reporting chemical emergencies).

The individual departments will train new employees at the time of their initial assignment. The introduction of new hazards requires training specific to the new hazards. Immediate on-the-spot training will be conducted by supervisory personnel for any employee or student worker who requests additional information or appears to lack understanding of a specific chemical hazard. Training will be documented and will be kept by EH&S.

Responsibilities

Environmental Health & Safety

  • Ensures that the overall program is functioning correctly through periodic inspections and review
  • Request additional information from chemical manufacturers or suppliers when needed to support departments or thoroughly review SDS
  • Provide consultation and training to the campus community

Department Chairs, Directors, or Designates

  • Ensures the program is functioning correctly within the area(s) of responsibility
  • Ensure chemicals are correctly used, stored, and labeled
  • Coordinates and communicates HazCom activities with Department personnel
  • Ensures Department inventory and SDS lists are updated when new hazardous materials are received
  • Review SDS with new or transferred employees and identifies the location of the SDS and chemical inventory list
  • Document training of employees, indicating the date, time, location, and brief description of the type of training received
  • Ensure only the minimum amount necessary is kept at teaching or workstations
  • Ensures that employees adhere to the above and this program.

Employees

  • Comply with the chemical safety requirements of this program
  • Report any problems with storage or use of chemicals
  • Use only those chemicals for which you have been trained
  • Use chemicals only for specific assigned tasks in the proper manner

Hazards of Nonroutine Tasks

When employees are required to perform nonroutine tasks that could expose them to hazardous chemicals, the immediate supervisor will inform their workers of the potential hazards.

Hazards of Unlabeled Pipes

We inform employees of the hazards of chemicals in unlabeled pipes in their work areas by having the immediate supervisor identify the hazards or another knowledgeable individual qualified by experience or education.

Multi-Employer Facility

When contractors or any other employers' workers (i.e., painters, electricians, or plumbers) will be working at this workplace, the EH&S director will:

  • Provide the other employer(s) with SDS for any of our chemicals to which their employees may be exposed during initial or subsequent project review meetings
  • Relay necessary labels and emergency precautionary information similarly to the other employer(s).

Each contractor bringing chemicals on-site must provide the EH&S director with the appropriate hazard information on these substances, including the SDS, the labels used, and the precautionary measures to be taken in working with these chemicals.

Additional Information

All employees and students can obtain further information on this written program, the Hazard Communication Standard, applicable SDS, and chemical information lists from the EH&S manager at the Education Business Hall, Room 181, extension 6926.