Hazard Communcation Program

INTRODUCTION

The Occupational Safety and Health Administration Hazard Communication Standard was promulgated to insure that all chemicals would be evaluated and that information regarding the hazards associated with these chemicals would be communicated to employers and employees.  The goal of this standard is to reduce the number of chemically related occupational illnesses and injuries.

In order to comply with the Hazard Communication Standard, this written program has been established for Hampden-Sydney College.  This program covers all departments of the College except the departments of Biology, Chemistry, Physics, and Psychology, which are covered by The Laboratory Standard.  The Dining Services (operated under contract by ARAMARK) also has a separate program.  Copies of the Hazard Communication Program and/or the Chemical Hygiene Plan will be available in the following locations.

HAZARD COMMUNICATION PROGRAM

Athletic Training Facilities

Department of Human Resources

Fine Arts Department

Moore Student Health Center

Physical Plant

Publications Department

CHEMICAL HYGIENE PLAN (The Laboratory Standard)

Biology Department

Chemistry Department

Physics Department

Psychology Department

BASIC COMPONENTS OF THE PROGRAM INCLUDE:

HAZARDOUS CHEMICAL INVENTORY LIST

Each department head will be responsible for maintaining the department's own inventory of hazardous chemicals or products.  This inventory should include chemicals or products with labels indicating CAUTION, WARNING, DANGER, FLAMMABLE, POISON, CORROSIVE, OXIDIZER, etc.  A master chemical inventory will be maintained in the Chemistry Department Stockroom and will be updated yearly and when Material Safety Data Sheets (MSDS) for additional chemicals are received.

MATERIAL SAFETY DATA SHEETS (MSDS)

All hazardous chemicals in departments covered by the Hazard Communication Program are purchased materials; no hazardous chemicals or intermediates are manufactured or prepared in these departments.  Therefore, the College shall rely on determinations of hazard made by the chemical manufacturer as indicated on the MSDS.

MSDS should be provided by the manufacturer or distributor on the initial shipment of a product or chemical, or upon request.  MSDS provide information concerning the hazards of the chemical product.  These documents include the identity of the chemical, physical and chemical characteristics, health hazards, primary routes of entry, permissible exposure limits, precautions for safe handling, and emergency and first aid procedures.

Obtaining MSDS:

If there is a product for which there is no MSDS available, the department should request one from the manufacturer or the distributor of the product.

If there is no response within thirty (30) calendar days of sending the request, a follow-up letter should be sent.

A third request will be made if no response to the second request is received within fifteen (15) calendar days of submission.

If no MSDS is received after three documented requests, the Safety Committee is to be notified and, if appropriate, the Virginia Occupational Safety and Health Administration (VOSHA) will be contacted. 

When an MSDS is received by any department from the manufacturer or distributor, it is the responsibility of the department head to forward a copy to the Chemistry Department Stockroom within five (5) calendar days of receipt. 

When the Chemistry Stockroom Manager receives an MSDS for another department, it will be sent to the appropriate department, and a copy will be retained in the Chemistry Department Stockroom.

The MSDS will be reviewed for completeness when received by the Chemistry Stockroom Manager.

Maintenance of MSDS:  The chairman or head of each department or a designated person in the department will be responsible for the maintenance and placement of an MSDS folder or notebook.  All MSDS insertions/deletions will be routed through this person.

Accessibility of the MSDS:

As a source of detailed information on hazardous chemicals, the MSDS will be accessible to all employees on all shifts.  These will be kept in a labeled notebook or folder in the department office or in the immediate work place.            

A labeled master file containing copies of all MSDS for the College will be kept in the Chemistry Department Stockroom.

LABELS AND OTHER FORMS OF WARNING

The Hazard Communication Standard requires that manufacturers label hazardous chemicals.  The label must contain the following:  chemical identity, appropriate hazard warnings, and name and address of the chemical manufacturer, importer, or other responsible party.

Upon the chemical's arrival, the individual who ordered it must insure that the chemical is labeled properly.  If everything is correct, the recipient should date and initial the container.  If the above-stated information is not available, Hampden-Sydney College may refuse to accept the order.  Original labels must not be removed from any container received.  When chemicals are transferred from the manufacturer's containers to secondary containers, the secondary container must be fully labeled with the identity of the chemicals and appropriate hazard warnings.

EMPLOYEE INFORMATION AND TRAINING

As part of the new-employee orientation and training program, the College requires new employees whose duties may cause them to be exposed to, or come in contact with, any hazardous chemical to attend a health and safety orientation.  The Director of Human Resources is responsible for organizing and conducting this initial training.  Training will consist of at least one training session.  The format for the training program will be a combination of verbal presentations and visual aids appropriate for such training.  At a minimum the following topics will be covered. 

  • An overview of the requirements of the Hazard Communication Standard.
  • How to review MSDS and where they are kept.
  • The labeling system and how to use it.
  • Steps the College has taken to lessen or prevent exposure to chemicals.
  • Safety/emergency procedures to follow if exposure occurs.
  • Chemicals that may be present in work locations.
  • Location and availability of the written program.

Following each training session, each employee is required to sign and date his/her training record, verifying attendance.  Before any new employee can begin work which requires the use of the potential exposure to hazardous chemicals, training as indicated above must be completed.

Additional training, as appropriate, will be conducted for employees assigned to the following departments:  Physical Plant, Athletics, Moore Student Health Center, Fine Arts, and Publications.

The department head or chairman is responsible for conducting or arranging for any additional training needed to assure that employees are properly trained and oriented regarding any hazardous chemicals specific to their area of responsibility.

Records of attendance of all employee-training sessions will be sent to the Director of Human Resources and maintained as a part of the employee records.

NON-ROUTINE TASKS

Before an employee begins a hazardous, non-routine task, he or she must report such anticipated activities to his or her supervisor to determine the hazard involved and the protective equipment required.

ON SITE CONTRACTORS

Often one or more contractors work on site at the College.  Contractors will be provided with the following information:

•·   Hazardous chemicals to which the contractor's employees may be exposed.

•·   Precautions necessary to protect employees during normal operating conditions and foreseeable emergencies. 

•·   Labeling system used in the work place.  Chemical mixtures done on site have stick-on labels.  Labels indicate products/hazard/remedy and do not have symbols for corrosive, etc.  Notebooks are in each custodial closet with chemicals and in the Buildings & Grounds Stockroom office.

It is the responsibility of the Director of Physical Plant to ensure that all Material Safety Data Sheets of chemicals to which the contractor's employees may be exposed are made available at a central location in the work place along with an example of the labeling system in use.  The Director of Physical Plant must inform each contractor of the availability of this information and its location.  Each contractor is responsible for insuring that all hazardous materials and chemicals brought to the job site by the contracting company are properly labeled before work begins.

It is the responsibility of the contractor, upon completion of work on campus, to remove and properly dispose of all hazardous chemicals.  It is not the College's responsibility.

It is the responsibility of the Director of Physical Plant to ensure that the above regulations are reviewed with the contractor in advance and to ensure that these regulations are adhered to throughout the contracted period. 

PROGRAM REVIEW

Written Hazardous Chemical Communication programs for Hampden-Sydney College and for the respective offices and departments that have specific programs will be reviewed annually by the College Safety Committee and updated as necessary.   

 HAZARDOUS WASTE DISPOSAL POLICY

The Resource Conservation and Recovery Act

This act (RCRA) establishes a complete regulatory process for the handling of hazardous waste from generation through disposal.  Under RCRA, the United States Environmental Protection Agency (EPA) regulates owners and operators of hazardous waste treatment, generators, transporters, and storage or disposal facilities.  Hampden-Sydney College, like all colleges and universities, is a generator of hazardous waste materials and is thus covered by the Resource Conservation and Recovery Act.

Organizations that generate (1) less than 100 kilograms (about 220 pounds or 25 gallons) per month of non-acutely-hazardous waste and (2) less than 1 kilogram of acutely hazardous waste are classified as conditionally exempt small quantity generators.  Hampden-Sydney College comes under this classification.  It is extremely advantageous to keep the level of waste generation below the levels of a small quantity generator so that the College will not become subject to the requirements applicable to the larger generators.

Conditionally exempt small generators are required to:

•·         Identify all hazardous waste generated.

•·         Send this waste to a hazardous waste facility or a landfill or other facility approved by the State for industrial or municipal wastes.

•·         Never accumulate more than 1000 kg (2200 pounds) of hazardous waste on their property.

Waste Minimization

Generators of hazardous waste must certify on each manifest that they have tried to minimize the amount of hazardous waste generated at the site.  The volume can be reduced in a number of ways, such as changing procedures, reducing the scale of an operation, reducing a waste's hazard at the point of generation, and substituting materials.  The method of storing and consolidating waste can also affect the amount of hazardous waste generated.  Since any material mixed with a hazardous waste automatically becomes a hazardous waste (for legal purposes) and adds to the total volume, all waste should be identified so that non-hazardous waste can be kept out of the hazardous waste system.  Purchase and store only what is needed.  Do not purchasing large quantities because of price breaks.  Gifts of usable chemicals must be approved in writing by the chairman of the department accepting them.  This approval must include a list of the chemicals and a description of their condition.  Previously opened chemicals from other institutions will not be accepted.

Waste Collection

Approximately once a year, or more often if a significant volume has accumulated, the College will have waste shipped to a licensed treatment or disposal facility by a shipper licensed to transport the type of waste produced.  Waste will be stored in an appropriate manner in the department generating it until it is transferred to either the Buildings and Grounds Department or the Chemistry Department shortly before shipment for off-campus disposal.  It is illegal under the hazardous-waste-treatment laws of Virginia for Hampden-Sydney to store or dispose of any hazardous waste that it did not generate.  Therefore, the College cannot store or dispose of any personal hazardous waste or any hazardous waste from another business or institution.  It is necessary that the department keep an accurate record of the amount of waste being generated; therefore, the Chemistry Department stockroom should be sent an inventory of waste chemicals any time one is requested and should be notified when the accumulation is increased by more than 5 gal. or 50 lbs. of hazardous waste, or when any amount of acutely hazardous waste is generated. (see below)

ACUTELY HAZARDOUS MATERIALS  (Listed in table 3.1-3 of Virginia Hazardous Waste Management Regulations)

If Hampden-Sydney generates more than 1 kg (approximately 2.2 lbs) of acutely hazardous waste in a calendar month, or stores more than that amount for any period of time, it will be subject to all of the regulations that apply to generators that generate more than 1000 kilograms of hazardous waste per calendar month.  If anyone orders an acutely hazardous chemical or carries out a procedure that is expected to produce an acutely hazardous product, prior approval must be obtained from the Provost and Dean of the Faculty, who will immediately notify the chairman of the College Safety Committee.

Guidelines for Collecting Waste Materials

Avoid the use of common waste containers.  If waste chemicals are collected separately, they will be easier to identify, treat, and store. Waste chemicals must be stored in appropriately labeled containers. Liquids must be stored in labeled, screw-capped bottles or safety cans. Solid wastes are to be stored in bottles, jars, or plastic-lined, sealed boxes.

Identify waste chemicals as completely as possible.  List all constituents regardless of hazard, and keep a running log of material that is added to containers.  Label each container with the words HAZARDOUS WASTE and the date the accumulation began.  Give approximate percentages of each constituent in the final waste.  Identify the person(s) responsible for creation of the waste should additional information be needed.