Environmental Health & Safety

Hazard Communication Program for Strong Memorial Hospital

Prepared by: Environmental Health & Safety
(Revised 4/7/2015)

Printable file is available with Adobe Acrobat Reader: PDF Version of Hazard Communication Program for SMH

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SECTION 1: REQUIREMENTS AND RESPONSIBLITIES

1. SCOPE AND REQUIREMENTS

The following are the requirements of the Hazard Communication Standard.

1. Scope: The Hazard Communication Standard (HazComm) applies to all employees who work in locations where hazardous chemicals or drugs are known to be present in such a manner as employees may be exposed under normal conditions of use or in a foreseeable emergency. Those employees working in laboratories are covered under another OSHA standard "Occupational Exposure to Hazardous Chemicals in Laboratories", 29 CFR 1910.1450.



2. Applicable Chemicals: The standard applies to all chemicals or hazardous drugs, which are defined as hazardous by the standard and are used in the workplace in a manner in which employees may be exposed to the chemicals or drugs under conditions of use or foreseeable emergencies.


Requirements:
3. Written Program: The employer is required to develop and maintain a written Hazard Communication Program, which describes how the requirements of the Standard will be met. This document is designated as the written program. A copy of this manual can be found on the University's EH&S web site UofR EHS Occupational Safety Hazard Communication Program.



4. Chemical Inventory: The employer is required to compile a list of the hazardous chemicals present in the workplace along with corresponding Safety Data Sheets (SDSs, formerly known as MSDSs). All employees must have access to this information during their work shifts. A suggested chemical inventory form to compile the information is available in Appendix 1. Within Strong Memorial Hospital, all departments who are responsible for bringing chemicals onsite are responsible for maintaining department specific chemical inventories with corresponding Safety Data Sheets. For example, Hospital Stores, Facilities, Materials Processing, the Pharmacy and Environmental Services all maintain department specific chemical inventories. Due to the integrated nature of Patient Care Units (i.e., staff and chemicals from various SMH departments) the following procedure will apply:
   • A centralized chemical inventory/SDS system will be maintained by EH&S. This system, called Chematix, is networked to provide ready access to the inventories and SDSs. EHS will instruct Departments/Units how to modify their inventories (contact EH&S at 275-3241 for this assistance).
   • Patient Care Units that procure chemicals outside of SMH departments must maintain their chemical inventory as listed in the previous entry.
   • EHS is available to assist all SMH staff with locating SDSs by calling 275-3241.
   • Emergency information for exposures to chemicals is available 24/7 by calling the Poison Control Center at 1-800-222-1222.



5. Labels: All containers of hazardous chemicals must be labeled with the following information:
   • Identity of the hazardous chemical(s)
   • Signal Word
   • Hazard Statement(s)
   • Precautionary Statement(s)
   • Pictogram(s)
   • Name / Address of the chemical manufacturer, importer or other responsible party
   
   Exceptions to this rule include:
   • Containers in which chemicals are transferred from a labeled container for immediate use by the employee performing the transfer; and,
   • Alternatives to labels may also be used such as signs, placards, process sheets, operating procedures or other written materials instead of affixing labels to individual stationary process containers as long as the alternatives contain the required labeling information.
   • Secondary container labels must include at least the product identifier and hazard warnings.



6. Training: Employers (supervisors) are required to provide information and training to employees on this standard and the hazards of the chemicals used in the workplace.
2. RESPONSIBILITIES
   
   Responsibility for implementing the HazCom Program resides with each department where hazardous chemicals are utilized in a non-laboratory setting. The responsibility for implementing and fulfilling the mandates of the HazCom Program are as follows:
   1. Supervisors have primary responsibility for:
      1. Informing and training employees on potential hazards associated with the chemicals in their work area, and when new chemical hazards are introduced;
      2. Supervising employees in the implementation of engineering controls, safe work practices, and Personal Protective Equipment (PPE) used to reduce potential exposure to the lowest practical level;
      3. Investigating and reporting incidents relating to the use of hazardous chemicals;
      4. Selecting chemicals, supervising the use and disposal of chemicals, and maintaining access to a current chemical inventory, and availability of SDS of hazardous chemicals for all work locations under their direction; and,
      5. Ensuring direct reports complete mandatory in-service training annually, which includes a HazCom module.
   2. Employees responsibilities include:
      1. Awareness of the hazards associated with the chemicals used and the methods of reducing exposures;
      2. Planning and using chemicals in accordance with established safe work practices and protocols;
      3. Using all of the PPE required for working with a chemical;
      4. Disposing of chemicals in an appropriate manner;
      5. Reporting unsafe conditions to their supervisor;
      6. Reporting incidents of hazardous chemical exposure to their supervisor; and
      7. Attending training as required under this standard.
3. RECORDS
   1. Chemical inventories will be maintained by each department, in the University's Chemical Inventory/ SDS System, Chematix. A link to Chematix may be found at: http://www.safety.rochester.edu/labsafety/chematix_intro.html.
   2. Attendance records of HazComm training sessions conducted by department supervisors are to be retained in employee files, in an office training file, or electronically (i.e. MyPath transcript).
   3. Injuries or chemical exposures will be documented electronically through the Employee Incident/Injury Reporting System found on the web at http://www.safety.rochester.edu/SMH115.html.
   4. Medical records will be retained as established by University protocol.
4. MULTI-EMPLOYER WORKPLACE
   
   EH&S will provide an inventory of the chemicals and a copy of the SDSs to outside contractors for those hazardous chemicals used by the university in the immediate work/construction area.
   
   Outside contractors are required to have a SDS for any hazardous chemical brought onto University property and have them readily available to their employees and to the University. Contractors using particularly hazardous materials (based on flammability, toxicity or stench odor) must receive EH&S approval prior to use.

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QUESTIONS?
Contact the EH&S Occupational Safety Unit at 275-3241 or e-mail EH&S Questions.

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