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Name: Hazard Communication Program - Interim
Responsible Office: Office of Environmental Health & Safety

Applies to: (examples; Faculty,Staff, Students, etc)

Faculty , Staff , Students , Contractors_Vendors

Policy Overview:

Issued: 05-18-2017
Next Review Date: 08-15-2019
Frequency of Reviews: Annually

The Occupational Safety and Health Administration (OSHA) has promulgated its Hazard Communication Standard (29CFR 1910.1200) to ensure that the hazards of all chemicals are evaluated, and that information is then transmitted to affected employers and employees in the manufacturing sector.

This Hazard Communication Program (HCP) will be used to make our employees more aware of the safety and health hazards associated with chemical substances produced, used, or transported through our facilities.  This HCP is complimentary to the Chemical Hygiene Plan and will apply to all facilities that are not chemical research laboratories, including, but not limited to maintenance, security, custodial services, clinical offices, procedure rooms, clinical laboratories and clerical/administrative staff. This plan will follow the requirements in the 2012 revision of the OSHA Hazard Communication Standard to be consistent with the United Nations Globally Harmonized System (GHS) of Classification of Labeling of Chemicals located in Appendix A of this Plan.

It is our desire to incorporate existing programs such as, but not limited to, area/personnel monitoring and sampling; the respiratory protection program; the hazardous waste management program; the chemical spill plan; the radiation safety program; the fire safety program; the existing work rules; and the implementation of new safety work rules, into this HCP.  In the event of overlapping or contradictory statements the more stringent shall apply.  It is our belief that this HCP will provide the incentive to improve work practices, increase employee use of personal protective equipment and other safety devices, and to follow precautionary measures when handling or using hazardous chemicals.

This policy applies to all STLCOP contractors, faculty, staff, visiting scientists, postdoctoral fellows, students, scholars, and any other person working at or for the College.


Definitions:

Term

Definition

SDS

Safety Data Sheet (SDS) is the term used by GHS for Material Safety Data Sheets

GHS

Globally Harmonized System of Classification and Labeling of Chemicals. GHS defines and classifies the hazards of chemical products and communicates health and safety information on labels and safety data sheets.

 

 

Details:

St. Louis College of Pharmacy has developed a Hazard Communication Plan in accordance with Occupational Safety and Health Administration (OSHA) requirements.  The plan provides information and training on the risks of hazardous chemicals, detection methods and safety measures for hazardous chemicals in the workplace.  Employees should be aware of the following OSHA requirements for handling hazardous chemicals:

  1. HAZARDOUS CHEMICAL INVENTORY
    1. The Environmental Health and Safety Office will maintain SDS for all chemicals used in the facility, and will make these SDS(s) available to employees.
    2. The College will maintain an SDS for all chemicals used in the facility, and will make these SDS(s) available to employees through the MSDSonline 24 hours a day (http://www.stlcop.edu/safety/ehs/chemicalinventory.html ).
  2. LABELING
    1. All chemical containers list the applicable hazard warnings on the manufacturers’ original label.
    2. Labels must not be removed, altered or defaced. Chemicals removed from their original containers must be placed in suitable secondary containers and labeled with the correct information clearly communicating the information found on the manufacturers’ original label, such as chemical name(s), concentrations, hazard warning(s) and target organ information, etc.  Additional hazard information is available through the Environmental Health and Safety Office.
    3. The College shall require, by specific language in purchase orders, that suppliers furnish the appropriate SDS(s) and appropriate labels of all purchased chemicals. The EH&S Office shall report to the College, for appropriate action, any supplier refusing or failing to supply the appropriate SDS(s) or labels. The College shall also require that suppliers certify that their SDS(s) and labels meet the criteria of 29 CFR 1910.1200.
    4. The supervisor or administrator shall assure that the hazard identification labels on incoming containers are not removed or defaced. The supervisor or administrator shall correct any unauthorized removal or defacing of any labels, contrary to College work rules.  The respective department shall take appropriate disciplinary action.
    5. The supervisor or Principal Investigator (PI) shall ensure that chemicals removed from the original container and diluted, mixed, or stored in different containers are labeled with the product identifier, an appropriate signal word, hazard statement(s), pictogram(s), precautionary statement(s) and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.
  3. SAFETY DATA SHEETS
    1. A computerized set of SDS’s will be available to employees through the MSDSonline 24 hours a day (http://www.stlcop.edu/safety/ehs/chemicalinventory.html ).
    2. Material safety data sheets are available from the Environmental Health and Safety Office. SDSs contain additional chemical hazard information.  Information on how to use SDSs for hazardous chemicals in your work can be found at https://www.osha.gov/Publications/OSHA3514.html . Employees can use available SDS copies to take appropriate personal protective measures when working with hazardous chemicals.
  4. EMPLOYEE EXPOSURE RECORDS
    1. Records of employee exposures to hazardous chemicals are maintained at the Environmental Health and Safety Office and are available upon request.
  5. SAFE PRACTICES AND PROTECTIVE EQUIPMENT
    1. Gloves and safety glasses are required when handling materials or performing tasks that present a significant risk to the individual (e.g. mixing concentrated chemicals or cleaning up materials such as blood, urine, feces or vomit).
    2. Acids and bases must be stored separately from each other and from flammable materials.
    3. Oxidizers must not be stored near flammable chemicals
    4. Reactive and explosive chemicals must be stored separately from other chemicals.
    5. Flammable chemicals should not be handled or stored near open flames of other sources of heat, flames or sparks.
    6. Additional information on safe work practices, emergency procedures and protective equipment in your work place is available through your department or upon request from the Environmental Health and Safety Office. Also please review the College’s policies on personal protective equipment and chemical storage guidelines.
  6. EMPLOYEE TRAINING
    1. All employees who will be exposed to hazardous chemicals will be trained upon job assignment by the supervisor or administrator, prior to use of any hazardous chemical. The Environmental Health and Safety Office will provide training in the HCP and in general safety procedures upon request.  The supervisor or administrator will provide specific training in the hazards and safe use and storage of each chemical, spill remediation, and disposal policies, personal protective equipment needed, and the location of the HCP.
    2. If employees may be exposed to hazardous chemicals while performing non-routine tasks, the supervisor, administrator, and/or EH&S will advise the employee(s) of the associated chemical hazards and protective measures.
    3. The Environmental Health and Safety Office will provide current staff training in the HCP and in general laboratory safety procedures annually and upon request.
    4. When a new hazardous chemical or a new hazard of an existing chemical is introduced into the workplace, all affected employees will receive training from the supervisor or administrator for the hazards associated with the chemical.
    5. If employees are assigned to work areas containing vessels or pipes which are unlabeled, or to areas that contain hazardous chemicals, the supervisor, administrator, and/or EH&S will advise the employee(s) of the hazards and protective measures in case of spill or other potential exposure.
    6. Elements of employee training will consist of the following:
      1. Information on the requirements of OSHA Hazard Communication Regulations 29 CFR 1910.1200
      2. Information on the safe handling and use of chemicals in the workplace
      3. An explanation of reading and interpreting appropriate SDS(s) with respect to the physical and health hazards associated with the chemical
      4. An explanation of reading and interpreting information on hazardous chemical labels
      5. Methods employees can use to protect themselves, such as work practices and the use of personal protective equipment, if necessary
      6. Ways employees can obtain and use the available hazard information
      7. If employees may be exposed to hazardous chemicals while performing non-routine tasks, the supervisor, administrator and/or Environmental Health and Safety Office will advise the employee(s) of the associated chemical hazards and protective measures. If employees are assigned to work areas containing vessels or pipes which are unlabeled, or to areas that contain hazardous chemicals, the administrator, supervisor or Environmental Health and Safety Office will advise those employees of the hazards and protective measures in case of spill or other potential exposure.
      8. Information on the monitoring system employed by the College and other methods/observations that may be used to detect the presence or release of a hazardous chemical in the workplace.
      9. An explanation of the existing safety rules, the new rules required by this HCP, and a statement of the disciplinary actions which will be taken for any employee violation.
    7. Training programs for proper use of protective equipment, safety work practices and emergency procedures are provided on a regular basis. Contact your department, Principal Investigator or supervisor, for additional program information. Louis College of Pharmacy provides fire safety training and conducts fire drills in each college building.  For more information on fire safety training contact STLCOP Emergency Management at (314) 446-8133.  The Environmental Health and Safety Office may be contacted at Jones Hall room 1372, by phone at (314) 446-8133 or by calling Public Safety after normal working hours at (314) 446-SAFE (7233).
    8. Annual training on bloodborne pathogens is required of all STLCOP faculty, staff, students, and post-doctoral laboratory personnel with a potential risk of exposure to bloodborne pathogens. Training is available on the STLCOP Emergency Management and Safety course page or by contacting STLCOP EH&S.
      1. For more information, please reference the STLCOP Bloodborne Pathogens Exposure Control Plan.
  7. HAZARD DETERMINATION
    1. It will be the responsibility of the Environmental Health and Safety Office to monitor all other aspects of the Hazard Communication Rule (HCR) with respect to in-house compliance and to audit this HCP, at least on an annual basis, for any updating or amendments. SDS(s) will be the primary source of hazard determinations under the HCP.
  8. HAZARDS of NON-ROUTINE TASKS
    1. Periodically, workers are required to perform non-routine tasks that are hazardous. Examples of non-routine tasks are: confined space entry, tank cleaning, and painting reactor vessels. Prior to starting work on such projects, each affected worker will be given information by their shift supervisor or Office of Environmental Health and Safety about the hazardous chemicals he or she may encounter during such activity. This information will include specific chemical hazards, protective and safety measures the worker should use, and steps the company is taking to reduce the hazards, including ventilation, respirators, the presence of another worker (buddy systems), and emergency procedures.
  9. CHEMICALS IN UNLABELELD PIPES
    1. Work activities may be performed by workers in areas where chemicals are transferred through unlabeled pipes. Prior to starting work in these areas, the worker shall be informed by their shift supervisor or Office of Environmental Health and Safety about the identity and hazards of the chemicals in the pipe, as well as required precautionary measures required to be followed.
  10. HAZARDOUS WASTE REMOVAL
    1. Information on the removal of hazardous and regulated materials is available in the Disposal & Recycling of Hazardous and Regulated Materials Policy accessible by contacting EH&S.
  11. UNSAFE WORK CONDITIONS
    1. Employees that are aware of unsafe work practices, conditions or facilities may contact the Human Resources Office and report said unsafe conditions. Alternatively, the employees may contact the Environmental Health and Safety Office and report the unsafe conditions or practices.  The Human Resources Office and the Environmental Health and Safety Office will keep the identity of the complainant anonymous and will be responsible to investigate or to ensure that a proper investigation is made by an impartial person to evaluate the alleged unsafe work practices, facilities or conditions.  No retaliation against an employee reporting unsafe work practices, facilities or conditions will be permitted.  Every precaution will be made to protect the identity of the individual(s) involved in the reasonable complaint. 
    2. If corrective actions are required, it will be the responsibility of the Environmental Health and Safety Office to ensure that corrective procedures and conditions are implemented and/or that facilities are corrected and restored to a safe condition.
    3. The College Staff Handbook December 2016 further explains general conduct expectations of employees of the College.
      1. Per the Staff Handbook, “The College employs a fair, objective and consistent approach to staff performance issues and disciplinary action. Human Resources provides strategic support to management to assist in evaluating and addressing staff performance issues.”
    4. Employees are asked to remind colleagues to use safe work practices when violations of such are observed.
    5. If violations of safe work practices are still observed, employees are required to report the offense(s) to their immediate supervisor and/or Environmental Health & Safety.
    6. The Progressive Disciplinary Policy outlined in the Staff Handbook will be the course of action for any employees in violation of the Hazard Communications Plan.
  12. INJURY OR ILNESS IN THE WORKPLACE
    1. Injuries or illnesses that occur as a result of workplace hazards are required to fill out the Employee Injury/Accident form on the MyStlcop Forms webpage or below in the Resources section.
    2. Employees will not have disciplinary actions taken against them for reporting an injury or accident in the workplace.
  13. THIRD PARTY CONTRACTORS
    1. It will be the responsibility of EH&S and/or the supervisor or administrator responsible for the affected area to inform contractors of the labeling system and the hazardous chemicals in the area(s) that the contractors’ employees may be exposed
    2. It will be the responsibility of the College to require as a condition in the contractors’ agreement that the contractor and all contractor employees will abide by all College safety rules and personal protective programs or the contractor company’s requirements, whichever is stricter.
    3. It will be the responsibility of the contractors to provide to the EH&S office with SDS(s) on all chemicals and compressed gases brought into the College. A College Services representative shall also require contractors to schedule the use of hazardous materials with the office of EH&S to provide adequate ventilation and to conform to other safe practice. College Services shall also require contractors to conform to College disposal practices or remove all hazardous waste from site upon departure. The EH&S Office will instruct contractors’ employees of the hazards associated with College chemicals in the workplace.
    4. It is the responsibility of the affected department, the Principal Investigator(s) in the affected area, and or the department designated representative, to acquire information on any hazardous materials a contractor may be using on a project at the College. That information shall be reported to the EH&S office for appropriate action with respect to protection of College employees.
  14. PROGRAM AVAILIBILITY
    1. A copy of this program will be made available, upon request, to workers, their designated representatives, and OSHA.

Responsibilities:

Position/Office/Department

Responsibility

Environmental Health & Safety

Monitor all other aspects of the Hazard Communications Plan with respect to in-house compliance and to audit on at least an annual basis for any updating or amendments. SDS(s) will be maintained by EH&S to be used as the primary source of hazard determination under the HCP.

EH&S will also mandate annual employee training on laboratory safety and HCP updates to employees.

Department Supervisors, Administrators, and Principal Investigators

The supervisor or administrator shall assure that the hazard identification labels on incoming containers are not removed or defaced.  The supervisor or administrator shall correct any unauthorized removal or defacing of any labels, contrary to College work rules. 

Employees

Employees are required abide by rules set forth in the Hazard Communications Plan, report unsafe work practices, and report illness or accidents as soon as possible to administrator or EH&S.

Original PDF:

Hazard Communication Program - Interim original PDF