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Hazard Communication Policy
In accordance with the Amherst College Environmental Health & Safety Policy, the following Hazard Communication guidelines have been designed to provide the appropriate health and safety requirements that are to be incorporated for the transmittal of information regarding the labeling, storage, use and warnings of hazardous or potentially hazardous substances at Amherst College. The guidelines have been established in order to comply with all local, state and federal regulations, including that of the Occupational Health & Safety Administration (OSHA), 29 CFR 1910.120, the Massachusetts Right To Know Law and all applicable nationally recognized standards.
To establish guidelines and performance objectives for the health and safety of Amherst College employees and outside contractors that are or will be working with hazardous or potentially hazardous substances as outlined here-in. Amherst College Facilities shall provide the necessary assistance and training to all employees regarding the potential hazards of chemicals, communicating information concerning those hazards through labels, SDSs, signage and warnings, and the appropriate protective measures that need to be taken to properly protect the contractors, faculty, staff, students and visitors at Amherst College.
The Amherst College Hazardous Communications Guidelines and other applicable requirements found here-in shall at least comply with if not exceed local, state and federal requirements. It is the responsibility of all companies and personnel working at or for Amherst College to adhere to this Hazard Communication Guideline, unless the use of a more stringent policy or program is exercised. The guidelines shall apply to any and all hazardous or potentially hazardous substances, including cleaning materials and chemical waste which are known or suspected to be present at Amherst College. The above applies to all applicable materials that are to be handled, stored and used by employees of the college under normal conditions or during a foreseeable emergency.
ACGIH -American Conference of Governmental Industrial Hygienists. The ACGIH develops and publishes recommended occupational exposure limits for hundreds of chemical substances and physical agents.
Asbestos - a hydrated magnesium silicate in fibrous form
Biohazard - “Biological Hazard”. Organisms or products of organisms that present a risk to humans
Chemical - any element, chemical compound, or mixture of elements and / or compounds
Chemical Name - Scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) or a name that will clearly identify the chemical for the purpose of conducting a hazard evaluation.
Container - Any bag, barrel, drum, bottle, box, can, cylinder, reaction vessel, storage tank, or similar that contains a hazardous chemical.
GHS (Global Harmonization Standard) - In 2003, the United Nations (UN) adopted the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The GHS includes criteria for the classification of health, physical and environmental hazards, as well as specifying what information should be included on labels of hazardous chemicals as well as safety data sheets.
Hazardous Material - Any substance or compound that has the capability of producing adverse effects on the health and safety of humans or that poses a risk to the environment.
Safety Data Sheets (SDS) - Written or printed material concerning a hazardous chemical that is prepared in accordance with paragraph (g) of the Hazard Communication Standard, 29 CFR 1910.1200. SDS's are the revised standardized version of the MSDS (Material Safety Data Sheets) to comply with the new format of Global Harmonization, see the new standard on the OSHA Website.
Personal Protective Equipment - Devices worn by employees to protect against hazards in the workplace.
Pesticides - General term for the group of chemicals used to control or kill such pests as rats, insects, fungi, bacteria, weeds, etc., that prey on humans and agricultural products. These include fumigants, fungicides, herbicides, insecticides, rodenticides
Both Amherst College Academic and Facilities must communicate chemical hazard information to employees who might normally or during emergencies, be exposed to hazardous or potentially hazardous substances in the workplace, and must provide employee training guidelines and requirements. Also, Amherst College and Facilities Departments shall develop, implement and maintain a written hazard communication program that includes;
- Labeling and warning sign procedures
- SDS collection, storage, use and review
- A list of the hazardous or potentially hazardous chemicals that are either known or believed to be in the workplace. These chemicals include both material we currently use and those that may have been used previously that may still be on campus.
- The intended communication procedure for getting information out to all affected employees, regarding hazardous substances.
- The identification and labeling of undesignated piping that may contain hazardous substances
- Personal Protective Equipment selection, maintenance, storage, use and disposal.
Amherst College must make SDS’s available to any employee involved in workplace activities they may involve hazardous substances and waste, regardless of time. This shall include weekend and after hour acquisition of the SDS, if necessary. It must also provide engineering controls, if applicable:
- The method used to provide outside employees or contractors with a copy of all our applicable SDS’s for a particular site.
- The methods used to inform outside employees or contractors of the labeling and warning sign system used at the college and how they will incorporate same into any similar work.
Employees of Amherst College Facilities must follow manufacturer's specifications when it comes to proper mixing, storage, use and application of hazardous chemicals, including those used for cleaning. They shall attend training classes to gain knowledge of:
- Safety Data Sheets
- Label, signage and warning requirements
- Chemical hazards and warnings applicable to the workplace, including possible entry and work in biological, chemical and radioactive laboratories
- Product substitution when appropriate
- Engineering controls when appropriate
- Proper selection, maintenance, storage, use and disposal of Personal Protective Equipment
- Environmental Protection Agency (EPA) and Dept. of Environmental Protection (D.E.P), Occupational Safety and Health Administration (OSHA) requirements, citations and financial impact.
- What to do in the event of a Hazardous Material Incident such as a fire, leak, rupture or spill
- Acquiring of SDS’s from either the Facilities Service Desk, Environmental Health & Safety or the Distributor / Manufacturer of the product being used.
Distributor, Importers and Manufacturer Requirements
Chemical manufacturers and importers must provide distributors and Amherst College with the appropriate SDS at the time of initial shipment and with the first shipment after the SDS has been updated. Distributors must provide Amherst College with the SDS and all appropriate updated information. Unless specifically exempt, manufacturers and distributors are required to ensure that each container of hazardous chemicals they ship must be labeled, tagged or marked with the following information:
- Identity of the hazardous chemical
- Appropriate warning signage
- The name and address of the manufacturer, importer or other responsible party.
Label, Signage and Warning Requirements
The colors, font, size and information on the labels, signage and warnings shall meet the requirements dictated by applicable regulations.
Examples: · Size of letters is dependent on container size;
Size of Container Label Letter Size
Amherst College must provide the appropriate labels, signage and other warnings for all hazardous substances and waste regulated under this guideline:
- Sign design and configuration shall comply with all nationally recognized standards including color contrast
- All labels must be prominently located on the container in the upright position for use
- The labels and other required signage must be affixed to (2) separate and distinct sides of the container.
- The labels and other required signage must at all times be visible for inspection. Containers or bottles can not be placed in such positions that they could not be read without container relocation.
- Labels must be completed in English, but should also have any other appropriate language specific to the workplace and their employees.
- Labels shall be suitable for the environment and weather-proof if necessary.
- Labels and other appropriate signage must be affixed to all barrels, bottles, containers, cylinders, drums, pipes, tanks and valves that contain or allow passage of hazardous substances.
- Labels, signage and other warnings can not be removed from any container received by Amherst College, unless
- The container is completely empty
- The container has been completely cleaned out in accordance with regulatory requirements, if applicable
- The container is suitable for the new product it will receive.
- Gasoline in an approved flammable liquid container, not in a spray bottle or cup.
- The bottle has been re-labeled with the new contents of the container. The label must indicate the actual name of the product and the hazard it presents.
NFPA 704 Diamond Label
The NFPA 704 diamond Label system uses 3 main categories to identify flammability, health and reactivity hazards of chemicals and other hazardous substances. The label is color coded red, blue, yellow and white to highlight the different hazards, making it easier to identify the specific risks
Red - Flammability
Blue - Health Hazard
Yellow - Reactivity
White - Special Information such as “ W “ or Water Reactive
The NFPA 704 system also uses a numerical value of between “0” and “4” to indicate the level of hazard for that particular chemical
0 = Material will not burn
1 = Material must be heated before ignition occurs
2 = Exposed to high heat before ignition occurs
3 = Liquids or solids will ignite under ambient temperature
4 = Vaporizes and burns at normal pressure and temperature
0 = No hazard
1 = Minor irritation
2 = Intense or chronic exposure may cause temporary incapacitation
3 = Short exposure could cause serious injury
4 = Short exposure could cause death
0 = Not reactive
1 = Normally stable but can become unstable with heat
2 = Violent reaction when exposed to heat or with water
3 = May detonate with initiating source
4 = May detonate at normal temperature and pressure
The Hazardous Material Identification System (HMIS) label system incorporates a label and four color bars and a space at the top of the label for chemical identification The colored bars, like the NFiPA 704 diamond indicates health, flammability and reactivity hazards as well as the appropriate personal protective equipment that should be incorporated. The HMIS label also uses the “0” to “4” numbering scale that indicates level of hazard.
0 = Essentially No Hazard 4 = Extreme Danger
The HMIS system now includes a second box on the blue (health hazard) bar. If the box contains an “*”, then the health hazard associated with the material is a chronic (long term) effect.
SDS - Safety Data Sheets
Safety Data Sheets, more commonly referred to as SDS’s are one of the best sources of information on hazardous chemicals, materials and substances. Employees should be able to access all relevant SDS’s for materials that they may use or store on or around their place of employment. Employees must also be trained in their use and access. Employers are responsible for requesting updates from manufacturers and importers.
The SDS sheets must be in English and shall provide at least the following information;
- Chemical identity / name, including any trade secrets
- Physical hazards (flammability / reactivity)
- Health Hazards
- Primary routes of entry into the body (inhalation, ingestion, absorption and injection)
- The OSHA or other recognized agencies Permissible Exposure Limits (PEL), Threshold Limit Values (TLV), Lower Explosive/Flammable Limit (LEL or LFL) or Time Weighted Average (TWA).
- If the chemical is listed in the National Toxicology Program (NTP) “Annual Report on Carcinogens” or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) or by OSHA or the ACGIH.
- Any general precautions for safe handling and use of the chemical as stipulated by the manufacturer, importer or employer preparing the SDS.
- Any applicable control measures known to the chemical manufacturer, importer or employer preparing the SDS.
- Emergency and First Aid Procedures
- The SDS date of preparation or latest date of change
- The name, address, and telephone number of the manufacturer, importer or employer of the chemical or other agency that may distribute the SDS.
Hazard Communications Requirement Exemptions
The following is a list of those items that are not required to meet the provisions of 29 CFR 1910.1200.
- Any hazardous waste subject to the EPA Resource Recovery Act (RCRA)
- Tobacco and tobacco products
- Wood or wood products, except those that are in the pressure treated or wood dust related form.
- Food, drug, cosmetics or alcoholic beverages in retail for consumer purchase
- Any consumer product or hazardous substance that an employer can demonstrate is used in the workplace in the same manner as it would be used in the home.
The list below are those materials that are exempt from the requirements of labeling, but not the other conditions of the Hazard Communication Guidelines. Labeling for these items must however meet the criteria stipulated in Federal Insecticide Fungicide and Rodenticide Act (FIFRA) and the EPA
- Food or food additive
- Color additives
- Medical and veterinary devices
- Nuisance particulate
- Ionizing and non-ionizing radiation
- Biological issues
Environmental Health & Safety Committee Responsibilities
The Environmental Health and Safety Committee shall require the acquisition of SDS forms for new hazardous chemicals, before the alternate material is purchased. The Committee, when appropriate shall review any new product and SDS for reasons of health & safety. Material that does not meet the needs of Amherst College, or for which substitution of a less hazardous material is possible will not be used or accepted. With the assistance of the Environmental Health & Safety Manager, the EH&S Committee will examine new personal protective equipment, engineering controls and the possible substitution of less hazardous materials for the health and well-being of our employees.
Environmental Health & Safety Manager Responsibilities
The EH&S Manager in cooperation with the EH&S Committee shall assume the responsibility of the Amherst College Facilities Right To Know Coordinator. With the assistance of Facilities staff and supervisors, the EH&S manager will maintain, to the best of their ability a comprehensive list of a hazardous substances currently ordered, stored and used. This list shall include those substances which are no longer ordered, but may still be present on campus. EH&S duties include:
- The EH&S Manager shall assemble a complete list of hazardous chemicals used by the Amherst College Physical Plant. The inventory should be kept current and old, unused chemicals should be properly disposed of as necessary.
- The EH&S Manager will assist any Facilities employee with SDS interpretation or acquisition, if the necessary SDS form is not on file.
- The EH&S Manager will provide initial and refresher Right To Know Training annually, as required by law.
- The Project Manager / Shop Supervisor shall verify that all contractors working at or for Amherst College have their own Hazard Communication Program. He or she shall ensure that the contractor is aware of hazardous chemicals at Amherst College that may be located or used in close proximity to the job being performed by the contractor.
- EH&S shall maintain all appropriate training records including attendance lists, dates of instruction and the names of the personnel that obtained the information
Amherst College Facilities must provide employees with effective information and training on hazardous chemicals, materials and waste in the workplace. The information and training shall incorporate the hazards associated with specific chemicals, how to use and understand the SDS, how to react during a chemical emergency and the storage, use, maintenance and disposal of personal protective equipment. The employee must be given the following information;
- The location of hazardous chemicals in the employee's work area.
- The location and availability of the Hazard Communications Guidelines and SDS’s.
- The list of known hazardous chemicals being utilized
- How to react to a fire, spill or other accidental release of a hazardous chemical in the work area.
- How to acquire, use and dispose of the appropriate Personal Protective Equipment that may be required for a certain task.
- How to label, placard or provide signage or other warnings on containers that have or will contain hazardous chemicals
- The dangers of exposure or over-exposure to hazardous chemicals that are currently used or stored on campus
- How to respond to hazardous locations such as biological, chemical and radioactivity laboratories if maintenance or service is required.
- How to best protect themselves in areas where hazardous chemicals, materials or waste may be stored, used or disposed of.
The training shall include;
- Hands on classroom sessions
- How to interpret a SDS
- Actual examples and use of PPE
- Placement and proper labeling, placard and signage techniques for a variety of containers
- Engineering controls available
- An orientation tour of the workplace, when applicable
- A short quiz to ensure that the material was conveyed and understood by the audience. Training for new Amherst College Facilities employees should take place as soon as possible, after hiring. Supervisors must ensure that each new employee is properly oriented regarding work requirements, safety procedures and emergency measures before being assigned to his or her own work area.
In order to verify that the Hazard Communication Guidelines exist and that training is being provided on an annual basis, OSHA inspectors (if on site) may spot quiz an employee about the Haz-Com program and some of the requirements.
SDS (Safety Data Sheets) Location
Currently the SDS sheets for Amherst College are located at the Service Building for fast and easy access and availability. The SDS forms shall be maintained by the EH&S Manager and the Service Center Staff until another more suitable method of acquisition is discovered. A CD-ROM or similar technology will be obtained for the Police Department for informational purposes, after hours.
Personal Injury involving Hazardous Chemicals
The established guidelines for dealing with injury involving Hazardous Chemicals:
- Ensure your own safety, first.
- Have someone else call 2111 for the Amherst Ambulance
- Request the response of the EH&S Manager
- Request or otherwise obtain a copy of the SDS form for transportation to the closest medical facility, by ambulance
- Adequately flush the patient (if appropriate) with copious amounts of water (15 minutes) or until relieved by the Amherst Fire Department. Make sure appropriate levels and stages of PPE are being utilized for reasons of health and safety
- Do Not (unless absolutely necessary) leave the patient by themselves, while waiting for an ambulance. Stay with the patient and provide the appropriate emotional support until EMS arrives.