Hazardous Material Management Policy

April 2022

Scope

This policy is prepared in accordance with Amherst College Plans, Policies and Standard Operating Guidelines, and the Amherst College Environmental Health and Safety Committee.

Purpose

Amherst College is committed to provide a safe environment for faculty, staff, students, outside contractors, and visitors of the College who to work with or around hazardous materials and to those areas of the Campus which may be affected by presence of such materials. The management of hazardous materials through their acquisition, utilization, and storage stages is critical. This policy is written to provide the overall requirements for the management of hazardous materials in all laboratories, work spaces, facilities, and other property of Amherst College.

Applicability:

All departments, faculty, staff, students, outside contractors, and visitors at Amherst College.

Definitions:

Hazardous Material: A product, waste or combination of substances which because of its quantity, concentration, physical, chemical, toxic, radioactive, or infectious characteristics may reasonably pose a significant, actual, or potential hazard to human health, safety, welfare, or the environment when improperly treated, stored, transported, used, disposed of, or otherwise managed. Hazardous materials include - without limitation - synthetic organic chemicals, petroleum products, heavy metals, radioactive or infectious materials, and all substances defines as "toxic" or "hazardous" under MGL Chapters 21C and 21 E using the Massachusetts Oil and Hazardous Material List in 310 CMR 40.

Procurement of Hazardous Materials

A. General requirements
  1. Only authorized faculty and staff may order hazardous materials or acutely hazardous materials.
  2. Before ordering hazardous materials, ensure that suitable materials are not available (declared excess by another researcher or department) for use by utilizing the Amherst College Chemical Inventory System.
  3. Procure hazardous materials in the smallest quantities available which meet the maximum usage requirements for a reasonable time period.
B. Purchase Orders
  1. Purchase orders (PO) can be used for ordering any hazardous materials.
  2. For purposes of maintaining an accurate inventory, it is important that the IUPAC or common names for the materials ordered be used on the PO.
  3. In the event that POs are placed by telephone, the originator of the PO shall identify the responsible Faculty Member or Staff Member as the person to whom the material is to be shipped.
  4. The originator of the purchase order shall ensure that the responsible person's name is noted on the PO.
  5. The procuring department shall enter the purchase order information into the Amherst College Chemical Inventory System (CIS) and print a barcode label for that material to be used when it is received.
C. Hazardous Material Receipt

When the hazardous material is received, the container, bottle, etc., shall have the bar code label affixed to the container by the department ordering the hazardous material. The bar code label must include the expiration date of the material.

The material shall be stored, if not used immediately, in accordance with the manufacturer's SDS or label warnings, or the appropriate sections of the Chemical Hygiene Plan.

Handling and Use of Hazardous Material

A. Storage

All hazardous material must be stored in appropriate cabinets, flammable material storage cabinets etc. until use and returned for safekeeping after use. Containers of hazardous materials should not be left on bench tops when not in use.

B. MSDS Information
  1. It is important that anyone using hazardous material read the Safety Data Sheet (SDS) associated with the hazardous material before its use.
  2. Anyone handling or using hazardous material shall use personal protective equipment as noted in the SDS or as indicated in the Amherst College Chemical Hygiene Plan.
C. Disposal of Empty Hazardous Material Containers
  1. If the entire contents of a hazardous material container are consumed, the empty container shall be wanded to read the bar code to decrement the quantity in the CIS.
  2. Empty containers may be discarded into a "Glass Only" box or a wastebasket as appropriate. A container is considered empty if the contents have been removed by the normal procedure for that hazardous material, pouring, scooping, etc.
D. Hazardous Material on hand without Future Use

Any hazardous material which is deemed unacceptable for future use or is identified as excess material without future need, will be declared hazardous waste by attachment of the appropriate hazardous waste label and managed in accordance with the Amherst College Hazardous Waste Management Policy.

Training

A. Responsibility
  1. It is the responsibility of the Environmental Heath and Safety Manager and Chemical Hygiene Officer to schedule and provide training for all persons on Campus who require hazardous material and safety training as a part of their normal job functions.
  2. Any person who has need to handle or use hazardous materials and has not had the required training shall notify the Environmental Heath and Safety Manager x8189 or Chemical Hygiene Officer at x2736 for training.
B. Applicability

Amherst College is now a Large Quantity Generator, LQG, 40 CFR (EPA) effective April 2006. Hazardous waste training at the point of generation is strongly recommended. 29 CFR (OSHA) does require training for all persons involved with hazardous waste in the normal course of their work

  1. No person at Amherst College may handle or use hazardous material without the training noted below.
  2. Research undergraduate students and teaching assistants (TA) who work at the hazardous waste point of generation, i.e. Satellite Accumulation Areas (SAA) will receive modified hazardous material and safety training to conform with the requirements of 40 CFR (EPA) and 29 CFR (OSHA).
  3. Research faculty, post-doctoral persons, laboratory supervisors, any employee who work at the hazardous waste point of generation, i.e. Satellite Accumulation Areas (SAA) who must handle hazardous material as part of normal duties, graduate students from any program associated with Amherst College, e.g. Molecular and Cellular Biology (MCB) students and visitors who are on Campus for time periods exceeding one month will receive annual hazardous material and safety training to conform with the requirements of 40 CFR (EPA) and 29 CFR (OSHA).
  4. Any employee who is involved with Main Accumulation Areas (MAA) must receive annual formal training to cover the requirements of 49 CFR (DOT), 40 CFR (EPA) and 29 CFR (OSHA)
C. Record Keeping
  1. Records of training will be maintained for each person trained. Information in the record will include the course, date attended, and next training date where applicable.
  2. Records will be maintained by the Environmental Heath and Safety Manager for three years.