Hazard Communication Program

Policy

It is the policy of Sonoma State University to develop, implement, and maintain at the workplace a written hazard communication program for its employees. The written Hazard Communication Program describes the criteria for labels and other forms of warnings, material safety data sheets (MSDS), and employee information and training.

Purpose

To protect employee safety by providing information and training about hazards that may exist in the workplace.

Definitions

Article
A manufactured item:
  • Formed to a specific shape or design during manufacture;
  • Has end use function(s) dependent in whole or in part upon its shape or design during end use;
  • Does not release, or otherwise result in exposure to, a hazardous chemical, under normal conditions of use.
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) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation.
Combustible Liquid
Liquid having a flashpoint at or above 100 degrees F (37.8 degrees C), but below 200 degrees F (93.3 degrees C), except any mixture having components with flashpoints of 200 degrees F (93.3 degrees C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.
Container
Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers.
Distributor
A business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers.
Employee
A worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered.
Explosive
A chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.
Exposure / Exposed
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.
Flammable
A chemical that falls into one of the following categories:
  • aerosol
  • gas
  • liquid
  • solid
Flashpoint
The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite in the presence of an ignition source.
Foreseeable Emergency
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.
Hazardous Chemical
means any chemical which may present is a physical hazard or a health hazard if used improperly.
Hazard Warning
Any words, pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the hazard(s) of the chemical(s) in the container(s).
Health Hazard
A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term 'health hazard' includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.
Immediate Use
The hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.
Label
Any written, printed, or graphic material, displayed on or affixed to containers of hazardous chemicals.
Material Safety Data Sheet (MSDS)
Written or printed material concerning a hazardous chemical which is prepared in accordance with OSHA specifications.
Mixture
Any combination of two or more chemicals if the combination is not, in whole or in part, the result of a chemical reaction.
Organic Peroxide
An organic compound that contains the bivalent oxygen to oxygen structure with organic subtituents on one or both ends.
Oxidizer
A chemical other than a blasting agent or explosive as defined in Sec. 1910.109(a), that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.
Physical Hazard
A chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.
Pyrophoric
A chemical that will ignite spontaneously in air at a temperature of 130 (degree)F (54.4 (degree)C) or below.
Unstable (Reactive)
A chemical which in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shocks, pressure or temperature.
Water-Reactive
A chemical that reacts with water to release a gas that is either flammable or presents a health hazard.
Work Area
A room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present.

Responsibilities

Vice Presidents, Deans, Directors, Department Heads, Supervisors, Managers

  • Provide employees information and training on hazardous substances in their work area at the time of their initial assignment, and whenever a new hazard is introduced into their work area.
  • Comply with the hazard communication requirements of section 5194, Title 8 California Code of Regulations (see Appendix D).
  • Ensure that all requirements of the Hazard Communication Program have been met before employees are potentially exposed to hazardous substances, including unlabeled pipes, during normal conditions or in a foreseeable emergency.
  • Develop and maintain an inventory of hazardous substances present in all work areas within the department.
  • When ordering suspected hazardous substances, request an MSDS on the requisition form.
  • Maintain a file of current MSDS in a location readily accessible to department employees.
  • Ensure all outside contractors have provided EH&S with MSDS for materials they will bring on campus.
  • Ensure that all employees that share the same work area are informed of the
  • Report the use of any regulated carcinogens to EH&S.

Environmental Health and Safety

  • Develop, implement, and monitor the Hazard Communication Program.
  • Assist departments in complying with program requirements.
  • Assist departments with use, storage and transport of hazardous substances and maintaining an MSDS file.
  • Maintain contract for MSDS database in the EH&S Office.
  • Assist departments in notifying outside contractors of the hazards which they may be exposed.
  • Maintain employee training, exposure, and medical records.
  • Report the use of any regulated carcinogens to Cal/OSHA and/or the EPA.
  • Provide general hazard communication training.

Instructional Support Technicians

  • Provide updated inventory biannually to EH&S.
  • Ensure an MSDS is available for all hazardous materials.

Employee

Each employee assigned to work with a hazardous substance, this includes unlabeled pipes, shall read and comply with all hazard communication procedures, whether written or oral, while performing assigned duties. Although no single set of safety procedures can guarantee accident-free employment or place of employment, the minimum safety standards are listed in Section 5.0 and Section 6.0.

All non-routine safety tasks, potential hazards, and appropriate protective measures shall be addressed during department safety meetings.

Specific Requirements

Labeling

Each department shall ensure that each container of hazardous substances in the workplace is labeled, tagged or marked in English with the following information:

  • Identify the hazardous substance(s) contained therein.
  • Appropriate hazard warnings.
  • Name and address of the manufacturer, importer, or other responsible party.

Employees shall not remove or deface existing labels on incoming containers of hazardous substances.

The labeling requirements of this program do not apply to any Federally regulated:

  • pesticide.
  • insecticide.
  • fungicide
  • rodenticide
  • food
  • food additive
  • color additive
  • drug
  • cosmetic
  • distilled spirits
  • wine
  • malt beverage intended for nonindustrial use.
  • any consumer product or hazardous substance regulated by the Consumer Product Safety Act.

Materials that are not adequately labeled within ten (10) days after the material is discovered are considered waste.

Material Safety Data Sheets (MSDS)

  • Departments shall request an MSDS on the purchase requisition form for all suspected hazardous substances which they use where one is not currently present in the department or available from the Facilities Services/EH&S Office.
  • Each MSDS shall be in English and shall contain specific information (see Appendix D for a sample MSDS form, Appendix F for Required information on MSDS, and Appendix G for sample MSDS explanation.)
  • Facilities Services/EH&S shall maintain an inventory of hazardous substances on campus. Facilities Services/EH&S shall also maintain the contract for the MSDS database available at MSDS On-Line.
  • Departments shall ensure that this information is readily accessible during each work shift to employees when they are in their work area(s).
  • If an MSDS is not provided by a manufacturer, the Facilities Services/EH&S Office shall: after an unsuccessful attempt to attain the MSDS via the internet, phone, or written request.
  • Send a written request to the manufacturer within seven (7) working days from the date of the employee request.
  • Provide a copy of the written request to the employee requesting the MSDS.
  • Notify the employee within fifteen (15) days of receipt of the MSDS.
  • Notify the Director of the State Department of Industrial Relations if a response has not been received from the manufacturer within twenty-five (25) working days from the date of the request.
  • To retrieve an MSDS from the Internet:
  • Open browser.
  • Go under File menu and select Open.
  • Type in: http://hq.msdsonline.com/sonoma2276/Search/Default.aspx. Then press the Return key.
  • The Material Safety Data Sheet database will appear, enter the name of the product or any know information in the spaces provided and press Return. Be sure to locate the exact name of the product from the appropriate manufacturer. The same product made by different manufacturers may have different ingredients.
  • Click the Print button in the browser menu.

Employee Training

Hazard communication training shall consist of the following:

Explaining The MSDS

This entails how to use its contents to identify any hazard to which the employee is exposed, or equivalent form, either in written form or through training programs.

Training Employees Who May Be Exposed To Hazardous Substances

The department shall ensure that each of the following hazard communication requirements are covered:

  1. Material Safety Data Sheets (MSDS)
    • Any health hazards associated with the use of the chemical.
    • Precautions for handling, necessary personal protective equipment or other safety precautions necessary to prevent or minimize exposure to the hazardous substance.
    • Emergency procedures for spills, fire, disposal, and first aid. This information may relate to an entire class of hazardous substances to the extent appropriate and related to the job.
    • Significant revisions in the MSDS shall be provided to employees in writing by the department within thirty (30) days after receipt by Facilities Services/EH&S.
  2. Employee Rights
    • To personally receive information regarding hazardous substances to which they may be exposed.
    • For their physician or collective bargaining agent to receive such information.
    • Protection from dismissal or other discrimination due to the employee's exercise of their rights afforded by State law.
  3. Hazard Communication
    • The requirements of the Hazard Communication Program.
    • Any operations in their work area where hazardous substances are present.
    • The location and availability of the written Hazard Communication Program.
    • The methods and observations that may be used to direct the presence or release of hazardous substances in the work area. Examples are:
    • monitoring conducted by the University.
    • continuous monitoring devices.
    • visual appearance or odor of hazardous substances when being released.
    • The physical and health hazards of the substances in the work area, and the measures they can take to protect themselves from these hazards. These measures shall include specific procedures the department has implemented to protect employees from exposure to hazardous substances, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
    • The details of the Hazard Communication Program including an explanation of the labeling system, the MSDS, and how employees can obtain and use the appropriate hazard information.

Record Keeping

Material Safety Data Sheets (MSDS)

Each MSDS will be continuously accessible through the internet database

Employee Exposure Records

Each employee exposure record will be preserved and maintained for the term of employment plus thirty (30) years according to the procedures specified in the Employee Medical Monitoring Program. These records include:

  • Work place monitoring and measurements of a toxic substances or harmful physical agents.
  • Biological monitoring results which directly assess the absorption of a toxic substance or harmful physical agent by body systems.
  • Material safety data sheets.
  • In the absence of the MSDS, a chemical inventory or any other record which reveals where and when a material was used and the identity of a toxic substance or harmful physical agent.

Departments using any regulated carcinogens have additional reporting and record keeping requirements under CAL/OSHA.

Employee Exposure and Medical Record Analyses

Each analysis using exposure or medical records will be preserved and maintained for at least thirty (30) years.

Training

Training records will be retained for at least three years and will include documentation of hazard communication training for each employee, specifically:

  • Employee name or other identifier.
  • Training dates.
  • Types of training and the name of the training provider.

Reference

Title 8, California Code of Regulations, Sections 337-340.2 and 5194.

Appendices

Appendix A To Sec. 1926.59 - Health Hazard Definitions (Mandatory)

Although safety hazards related to the physical characteristics of a chemical can be objectively defined in terms of testing requirements (e.g. flammability), health hazard definitions are less precise and more subjective. Health hazards may cause measurable changes in the body such as decreased pulmonary function. These changes are generally indicated by the occurrence of signs and symptoms in the exposed employees such as shortness of breath, a non-measurable, subjective feeling. Employees exposed to such hazards must be apprised of both the change in body function and the signs and symptoms that may occur to signal that change.

The determination of occupational health hazards is complicated by the fact that many of the effects or signs and symptoms occur commonly in non-occupationally exposed populations, so that effects of exposure are difficult to separate from normally occurring illnesses. Occasionally, a substance causes an effect that is rarely seen in the population at large, such as angiosarcomas caused by vinyl chloride exposure, thus making it easier to ascertain that the occupational exposure was the primary causative factor. More often, however, the effects are common, such as lung cancer. The situation is further complicated by the fact that most chemicals have not been adequately tested to determine their health hazard potential, and data do not exist to substantiate these effects.

There have been many attempts to categorize effects and to define them in various ways. Generally, the terms 'acute' and 'chronic' are used to delineate between effects on the basis of severity or duration. 'Acute' effects usually occur rapidly as a result of short-term exposures, and are of short duration. 'Chronic' effects generally occur as a result of long-term exposure, and are of long duration. The acute effects referred to most frequently are those defined by the American National Standards Institute (ANSI) standard for Precautionary Labeling of Hazardous Industrial Chemicals (Z129.1-1982) - irritation, corrosivity, sensitization and lethal dose. Although these are important health effects, they do not adequately cover the considerable range of acute effects which may occur as a result of occupational exposure, such as, for example, narcosis. Similarly, the term chronic effect is often used to cover only carcinogenicity, teratogenicity, and mutagenicity. These effects are obviously a concern in the workplace, but again, do not adequately cover the area of chronic effects, excluding, for example, blood dyscrasias (such as anemia), chronic bronchitis and liver atrophy.

The goal of defining precisely, in measurable terms, every possible health effect that may occur in the workplace as a result of chemical exposures cannot realistically be accomplished. This does not negate the need for employees to be informed of such effects and protected from them. Appendix B, which is also mandatory, outlines the principles and procedures of hazardous assessment.

Health Hazards
For purposes of this section, any chemicals which meet any of the following definitions, as determined by the criteria set forth in Appendix B are health hazards.
Carcinogen:
A chemical is considered to be a carcinogen if either of the following are true:
  • It has been evaluated by the International Agency for Research on Cancer (IARC) and found to be a carcinogen or potential carcinogen.
  • It is listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition).
  • It is regulated by OSHA as a carcinogen.
Corrosive
A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. For example, a chemical is considered to be corrosive if, when tested on the intact skin of albino rabbits by the method described by the U.S. Department of Transportation in Appendix A to 49 CFR Part 173, it destroys or changes irreversibly the structure of the tissue at the site of contact following an exposure period of four hours. This term shall not refer to action on inanimate surfaces.
Highly Toxic
A chemical falling within any of the following categories:
  • A chemical that has a median lethal dose (LD (INFERIOR 50)) of 50 milligrams or less per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each.
  • A chemical that has a median lethal does (LD (INFERIOR 50)) of 200 milligrams or less per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each.
  • A chemical that has a median lethal concentration (LC (INFERIOR 50)) in air of 200 parts per million by volume or less of gas or vapor, or 2 milligrams per liter or less of mist, fume, or dust, when administered by continuous inhalation for one hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each.
Irritant
A chemical, which is not corrosive, but which causes a reversible inflammatory effect on living tissue by chemical action at the site of contact. A chemical is a skin irritant if, when tested on the intact skin of albino rabbits by the methods of 16 CFR 1500.41 for four hours exposure or by other appropriate techniques, it results in an empirical score of five or more. A chemical is an eye irritant if so determined under the procedure listed in 16 CFR 1500.42 or other appropriate techniques.
Sensitizer
A chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical.
Toxic
A chemical falling within any of the following categories:
  • A chemical that has a median lethal dose (LD (INFERIOR 50)) of more than 50 milligrams per kilogram but not more than 500 milligrams per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each.
  • A chemical that has a median lethal dose (LD (INFERIOR 50)) of more than 200 milligrams per kilogram but not more than 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between two and three kilograms each.
  • A chemical that has a median lethal concentration (LC (INFERIOR 50)) in air of more than 200 parts per million but not more than 2,000 parts per million by volume of gas or vapor, or more than two milligrams per liter but not more than 20 milligrams per liter of mist, fume, or dust, when administered by continuous inhalation for one hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each.
Target Organ Effects
The following is a target organ categorization of effects which may occur, including examples of signs and symptoms and chemicals which have been found to cause such effects. These examples are presented to illustrate the range and diversity of effects and hazards found in the workplace, and the broad scope employers must consider in this area, but are not intended to be all-inclusive.
Hepatotoxins
Chemicals which produce liver damage. Signs & Symptoms: Jaundice, liver enlargement. Chemicals: Carbon tetrachloride; nitrosamines.
Nephrotoxins
Chemicals which produce kidney damage. Signs & Symptoms: Edema, proteinuria. Chemicals: Halogenated hydrocarbons; uranium.
Neurotoxins
Chemicals which produce their primary toxic effects on the nervous. system Signs & Symptoms: Narcosis, behavioral changes, decrease in motor functions. Chemicals: Mercury; carbon disulfide.
Agents which act on the blood or hematopoietic system
Decrease hemoglobin function, deprive the body tissues of oxygen. Signs & Symptoms: Cyanosis, loss of consciousness. Chemicals: Carbon monoxide; cyanides.
Agents which damage the lung
Chemicals which irritate or damage the pulmonary tissue. Signs & Symptoms: Cough, tightness in chest, shortness of breath. Chemicals: Silica; asbestos.
Reproductive toxins
Chemicals which affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogenesis). Signs & Symptoms: Birth defects, sterility. Chemicals: Lead; DBCP
Cutaneous hazards
Chemicals which affect the dermal layer of the body. Signs & Symptoms: Defatting of the skin, rashes, irritation. Chemicals: Ketones; chlorinated compounds.
Eye hazards
Chemicals which affect the eye or visual capacity. Signs & Symptoms: Conjunctivitis, corneal damage. Chemicals: Organic solvents; acids.

Appendix B To Sec. 1926.59 - Hazard Determination (Mandatory)

The quality of a hazard communication program is largely dependent upon the adequacy and accuracy of the hazard determination. The hazard determination requirement of this standard is performance-oriented.

Chemical manufacturers, importers, and employers evaluating chemicals are not required to follow any specific methods for determining hazards, but they must be able to demonstrate that they have adequately ascertained the hazards of the chemicals produced or imported in accordance with the criteria set forth in this Appendix.

Hazard evaluation is a process which relies heavily on the professional judgment of the evaluator, particularly in the area of chronic hazards. The performance-orientation of the hazard determination does not diminish the duty of the chemical manufacturer, importer or employer to conduct a thorough evaluation, examining all relevant data and producing a scientifically defensible evaluation.

For purposes of this standard, the following criteria shall be used in making hazard determinations that meet the requirements of this standard.

Carcinogenicity
As described in paragraph (d)(4) and Appendix A of this section, a determination by the National Toxicology Program, the International Agency for Research on Cancer, or OSHA that a chemical is a carcinogen or potential carcinogen will be considered conclusive evidence for purposes of this section.
Human data
Where available, epidemiological studies and case reports of adverse health effects shall be considered in the evaluation.
Animal data
Human evidence of health effects in exposed populations is generally not available for the majority of chemicals produced or used in the workplace. Therefore, the available results of toxicological testing in animal populations shall be used to predict the health effects that may be experienced by exposed workers. In particular, the definitions of certain acute hazards refer to specific animal testing results (see Appendix A).

Adequacy and Reporting of Data.

The results of any studies which are designed and conducted according to established scientific principles, and which report statistically significant conclusions regarding the health effects of a chemical, shall be a sufficient basis for a hazard determination and reported on any material safety data sheet. The chemical manufacturer, importer, or employer may also report the results of other scientifically valid studies which tend to refute the findings of hazard.