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Contact:
Environmental Health
  and Safety
714 W. Lombard Street
Baltimore, MD 21201
410-706-7055
Fax 410-706-8212

COMMITMENT

The University is fully committed to providing a safe and healthful work environment for every employee. Sometimes it is necessary for employees to work with or around potentially hazardous substances. In these instances, it is important that employees are aware of the substances identity, health-related and physical properties, and the safe work practices required to minimize potential hazards. This Hazard Communication Program has been developed to foster employee health and safety.

UNIVERSITY RESPONSIBILITY

It is the responsibility of the University to:

• Prepare a list of potentially hazardous substances in commercial workplaces
• Ensure that all containers are properly labeled
• Maintain and make available to employees Material Safety Data Sheets (MSDSs) for each hazardous substance in the workplace
• Provide employees with the required information and training
• Develop and implement a written Hazard Communication Program

EMPLOYEE RESPONSIBILITY

Active employee participation is essential to the success of the Hazard Communication Program. University employees must:

• Be alert to the potential hazards of substances in your workplace
• Follow the safe work practices that have been established to protect your health and safety.

I. LIST OF HAZARDOUS SUBSTANCES

1. Hazardous substances known to be present in commercial workplaces: housekeeping, engineering support services, dental clinics and photographic services will be listed on the Chemical Information List.
2. The name of the substance that appears on this list will be the same as the one that appears on the label and the MSDS for that substance.
3. The Chemical Information List is available to all employees working in the workplaces listed above.
4. The workplace supervisor is responsible for the continuous updating of this list and forwarding that information to EHS.

II. CONTAINER LABELS

1. Each container of hazardous material used or shipped to or from the workplace must have a hazard warning label with the following information:
   
   • name of the chemical
   • appropriate hazard warning
   • name and address of the manufacturer
     
2. Portable or secondary containers shall be labeled in the same way.
3. The workplace supervisor is responsible to ensure that each container has the appropriate warning and that the label is intact.
4. Any container without a label should be reported immediately to the workplace supervisor. A label should not be defaced or removed unless the container has been emptied. When containers are emptied, labels need to be defaced before discarding the container(s).

III. MATERIAL SAFETY DATA SHEETS (MSDS)

1. A Material Safety Data Sheet (MSDS) containing information required by the Maryland "Access to Information about Hazardous and Toxic Substances Act" and the MOS/OSHA Hazard Communication Standard will be kept by EHS for each substance on the Chemical Information List. The MSDS will be the current edition as supplied by the manufacturer.
2. EHS (410.706.7845) is responsible for maintaining a current file of material safety data sheets. It can also make available generic data systems for chemicals used in the laboratory upon request by telephone, fax (410.706.8212) or written notice.
3. As new and significant health information about any hazardous substance on the Chemical Information List becomes known, a revised MSDS will be obtained and placed in the file.

IV. COMMUNICATING HAZARD INFORMATION

1. TO EMPLOYEES

All employees working with or potentially exposed to hazardous substances will be appropriately informed and trained.

a. Essential hazard information includes:

• requirements of the Access to Information about Hazardous and Toxic Substances Law
• requirements of the Hazard Communication Standard
• location of hazardous substances in the workplace
• location of the written Hazard Communication Program, Chemical Information List and MSDSs

b. Training shall address:

• physical and health hazards of hazardous substances
• safe work practices, emergency procedures, and protective equipment to minimize exposure to hazardous substances
• explanation of the labeling system, how to read a MSDS, and where to obtain hazard communication information

2. This information and training needs to be provided at the time of an employee's initial assignment to work with or around hazardous substances, or whenever a new hazard is introduced into the work area.
3. Before any non-routine task is performed, employees need to be instructed in the potential hazards of the task and will be informed of the appropriate work practices to be followed.
4. Employees need to be informed of hazardous substances in unlabeled pipes and the potential hazards involved in the event of exposure to these substances.

2. TO CONTRACTORS

Oside contractors will be informed by the University Contracting Officer about the hazardous substances they may be exposed to while working at the University, and how the contractors' employees can protect themselves from these substances.

Outside contractors shall inform the University Contracting Officer about any hazardous substances they may bring into the workplace so that employees may receive the necessary information and training to protect their health and safety. The contractors' employees shall be responsible for defacing the labels of empty containers of hazardous substances that they have on the premises of University or associated areas.

The University Contracting Officer is responsible for the exchange of hazard information with outside contractors.

If you have any questions about the Hazard Communication Program, please contact the Chemical Hygiene Officer, Office of Environmental Health and Safety at 410.706.3490.

V. GUIDANCE ON IMPLEMENTING THE UNIVERSITY HAZARD COMMUNICATION

PROGRAM (University-HCP)

A summary of the key requirements and responsibilities for implementing the University-HCP is shown below.

A. University-HCP Implementation Responsibilities

B. Common Questions on Program Implementation

1. What is a hazardous chemical?

OSHA's Hazard Communication Standard (29 CFR 1910.1200) broadly defines a hazardous chemical as any chemical whose presence or use is a "physical hazard or a health hazard." Chemicals defined as "physical hazards" include combustible liquids, compressed gases, explosives, flammables, organic peroxides, oxidizers, pyrophorics, and unstable or water-reactive chemicals. Chemicals defined as "health hazards" include those that cause either acute or chronic health effects due to exposure by inhalation, ingestion or direct skin or eye contact. The term health hazard includes chemicals which are carcinogens, reproductive toxins, mutagens, teratogens, irritants, corrosives, sensitizers, and chemicals that damage a specific organ or system (e.g., hepatotoxins, nephrotoxins). Supervisors and employees may wish to consult the OSHA Hazard Communication Standard for more detailed definitions of both physical and health hazards. Additional information can be obtained by attending the EHS HAZCOM/CHEMICAL HYGIENE training programs or calling Occupational Safety and Health on 410.706.3490.

The University-HCP program uses OSHA's broad definitions to refer to the hazardous properties which may be associated with chemicals. However, to determine whether certain chemicals pose physical or health risks to employees and require inclusion in the University & HCP Program, specific attention should be given to the exposure potential of chemicals present in the work area. Exposure potential is dependent on the following: 1) the quantity of the chemical used; 2) the manner in which the chemical is used; and 3) the means available to control release of or exposure to the chemical. Additional factors that may influence the effects of chemicals on the health of employees are the potency or toxicity of the chemical and any characteristics of the persons using the chemical that may place them at increased risk (e.g., medical conditions, sensitivity to the chemical).

2. How can I get a copy of OSHA's Hazard Communication Standard?

A copy of the standard is available from Occupational Safety and Health, EHS, 410.706.3490.

3. Why can't I simply rely on the manufacturers/suppliers MSDS to determine whether a chemical is hazardous?

The chemical and physical properties of the material (e.g., its volatility, flammability, reactivity), as well as its toxic properties (e.g., carcinogen or reproductive hazard), can be used to define the hazard potential that the material presents to employees. The risk of experiencing harmful health effects varies with the degree of exposure in a given work operation. Factors influencing the degree of exposure include the quantity of chemical, the manner in which it is used, and the means available to control the release of, or exposure to the chemicals. Therefore, the determination of what constitutes a hazardous chemical needs to be made by the supervisor for his/her work area.

4. What information must be maintained and made accessible to employees at the work site?

MSDSs (information contained within) for hazardous chemicals, and labels that identify the chemical and list the critical hazard information must be maintained and made accessible at the work site. In certain cases, the information in the MSDS section covering precautions and safe handling and use may apply more to chemical usage in industrial processes. Therefore, University users of chemicals should factor in their own working requirements and conditions of use when selecting appropriate work practices, personal protective equipment, and engineering controls. Laboratories do not have to maintain chemical listings under the Hazard Communication Standard.

5. What if I find that the manufacturer's or supplier's MSDS provides incomplete information or is missing critical information?

The Office of Environmental Health & Safety maintains a large library of MSDSs and a number of computer databases. If you need information, contact EHS safety and health personnel on 706-3490.

6. What if the manufacturer's or supplier's MSDS does not include the names or identity of the chemical component(s)?

Information relating to the chemical identity or name of a hazardous chemical may be withheld by the chemical manufacturer, importer or employer if it is deemed a trade secret. However, information about its harmful properties can not be withheld and must be included in the MSDS. Also, the chemical identity must be made available to health professionals and certain designated individuals to render medical treatment, to bring about protective measures in an emergency or, when requested in non-emergency situations, to protect employees who may be potentially exposed. For such disclosures, a written statement of confidentiality may be required prior to release of the chemical identity or, in an emergency situation, as soon as circumstances permit.

7. If an employee works with several hazardous chemicals in a process, is it necessary to maintain an MSDS for each hazardous chemical present?

Employees must have access to information related to potentially hazardous chemicals in each work area. This information may be the manufacturer's MSDS or some other source that contains pertinent health and safety information. The supervisor, however, needs to develop safe operating procedures for processes that cover groups of hazardous chemicals designed to identify and control the collective hazards associated with these chemicals.

8. Do I have to re-label all incoming containers of hazardous chemicals?

Manufacturers and suppliers of hazardous chemicals are required to label their containers with the identity of the chemical and the appropriate hazard warnings. Therefore, in most cases, incoming containers will not have to be re-labeled. If the majority of employees in a work area speak a language other than English, supervisors need to add the necessary information in that language as long as the information is presented in English as well.

9. Do I need to label processing equipment?

For stationary process containers (including automated processing equipment--such as autoanalysers or DNA synthesizers), signs, placards, or other written operating procedures need to be used in place of labels as long as it is clear to which containers these instructions refer.

10. Do I need to label transfer containers?

When transferring hazardous chemicals from a labeled container to another, the portable or transfer container does not have to be labeled if only one person handles the container and the container is filled and emptied by that person during the workday. In situations where other persons may be exposed to the chemicals present in the portable or transfer container, it is always necessary to label the container to inform those who are potentially exposed about the hazards associated with the chemical and the necessary precautions to minimize their exposure.

11. Does laboratory glassware need to be labeled ?

Laboratory containers such as beakers, test tubes, etc., do not have to be labeled with hazard information since they are usually intended for immediate use. However, it is good laboratory practice to identify the contents of all containers.

12. In addition to labels, what other forms of Warning should be used to identify the presence of hazardous chemicals?

In some cases, warning signs on doors need to be used to alert persons not to enter the work area unless they are aware of the necessary safeguards. Door signs need to provide the names and telephone numbers of the persons to contact in case of emergency. This information is especially important for visitors or employees not assigned to that area.

13. If MSDSs and labels are maintained at the work site why is it necessary to train employees?

MSDSs and labels have limited value unless the employees understand how to use the information and are aware of actions to be taken to avoid or minimize hazardous exposures and thus the occurrence of adverse health effects. Training provides this opportunity and allows supervisors to assess their employees' level of understanding of the material and their use of written standard operating procedures (SOPs) or protocols.

14. What additional training programs covering chemical safety are available?

The Office of Environmental Health and Safety offers a training program entitled "HAZCOM/ CHEMICAL HYGIENE." Contact EHS safety and health personnel for a course announcement. Training in Hazard Communication for support personnel is provided by Environmental Health and Safety. This training is required by law.

15. What if I believe that I have not been provided with the required hazard information?

All University employees have the right to discuss their safety and health concerns with their supervisor, Environmental Health and Safety, and the University Risk Management Committee without fear of reprisal for expressing their concerns.

16. Are employees of outside contractors covered under the University-Hazard Communications Program?

Employees working under contract at the University are subject to their employer's Hazard Communication Program to the extent that hazardous chemicals are being supplied and used by the contractor. Contract employees potentially exposed to chemicals present at a University facility can obtain University-Hazard Communications Program information from the University Contract Officer for the contract. University contractors must submit a listing of hazardous chemicals they bring onto University facilities and provide corresponding MSDSs to the University Contract Officer for the contract. University contractor personnel/employees are responsible for defacing the labels of any empty container of hazardous material they have used on University premises.

17. Are University contract employees covered under the University-Hazard Communications Program?

University contract employees working in teaching, research, engineering support areas and clinics are subject to the University-HCP. These employees are required to attend the HAZCOM/ CHEMICAL HYGIENE training given by Occupational Safety and Health, EHS. It is their supervisor's responsibility to schedule the contract employee's training before work actually starts in the workplace.

18. Who can I contact if I have questions on implementing any of the requirements of the University-Hazardous Communications Program?

Chemical safety specialists within the Occupational Safety Division (OSD), EHS provide technical guidance on matters pertaining specifically to the University-Hazardous Communications Program.