Environmental Health & Safety

Hazard Communication Program for Strong Memorial Hospital

Prepared by: Environmental Health & Safety

(Revised 2022)

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

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SECTION 2: REQUIRED EMPLOYEE INFORMATION & TRAINING

The OSHA Hazard Communication Standard requires that employees be informed of the requirements of the Standard, the location of the written Hazard Communication Plan, operations in the workplace involving hazardous chemicals or drugs, lists of hazardous chemicals / drugs used in the workplace and the location of SDSs for these agents. Review of this program and completion of the attendance sheet and quiz meets the minimum requirement for awareness training. The supervisor must provide documented site-specific training to all staff on the chemicals and drugs used in the work area.

The University's Written General Hazard Communication Plan is available from EH&S (x5-3241) and through the web at http://www.safety.rochester.edu/ih/hazcom/hazcomindex.html .

1. TRAINING


1. Required Training and Frequency of Training
   The University provides employees with information and training to ensure they are mindful of the hazards of chemicals present in their work area. Awareness Training is made available at New Hire Orientation before the employee's initial work assignment begins and is part of annual mandatory in-service training. Also, there is a HazCom general training module on MyPath (EHS Hazard Communication & Global Harmonization). Site-specific training must be provided at the initial job assignment by the employee's supervisor. Upon request, EH&S can provide additional training in those departments where special hazards have been identified.
   Environmental Health & Safety (EH&S) can provide reference and/or electronic materials to assist the supervisor in training for site specific chemicals or procedures that may introduce a risk to the employees.
   Upon request, SMH Pharmacy is also available to provide information on hazardous drugs.
   Retraining is required when a new hazard is introduced in a work area. Supervisors may request the assistance of EH&S with information or materials, if desired. Documentation of site specific hazards, special hazards, new hazards or changed hazards will be maintained by the employee's department.
2. Purpose and Content of Training
   The purpose of Hazard Communication training is to inform individuals of the risks and hazards associated with chemical or hazardous drug handling and what to do if an emergency occurs. General awareness training consists of an overview of:


1. The existence of the HazComm program and its requirements;
2. How to read and understand the material found on a SDS;
3. Methods to minimize employee exposure to hazardous chemicals;
4. Signs and symptoms associated with exposure to hazardous chemicals;
5. Location and availability of known reference materials, including SDS, outlining the hazards, safe handling, storage, and disposal of hazardous chemicals;
6. Proper use and limitations of personal protective equipment (PPE);
7. Proper use of emergency equipment and the limitations of safety equipment; and,
8. Emergency procedures to follow in the event of a chemical spill.

Site-specific training needs to be provided by the supervisor at the employee's initial job assignment. Continuing employee training for special hazards in an employee's work area will be the responsibility of the supervisor.



2. READING AND INTERPRETING SDSs & LABELS


The two key written materials that convey information on the hazards of chemicals are Safety Data Sheets (SDSs) and labels. The Hazard Communication Standard requires that SDSs be available for all hazardous chemicals and that all containers of these chemicals be labeled. This section gives valuable information on what to expect and how to use the information on SDSs.
1. Safety Data Sheets (SDSs)
   A copy of the Safety Data Sheet (SDS) must be readily available for all chemicals used. SDSs are sent by the manufacturer/supplier for the first order of the chemical.
   Departments must maintain department-specific chemical inventories and their SDSs. On-line access to department inventories will be maintained in Chematix at http://www.safety.rochester.edu/labsafety/chematix_intro.html. Departments will be responsible for providing EH&S with their initial inventory which is utilized to populate Chematix. Thereafter, it will be the responsibility of the department to maintain a current inventory. Any staff member may request a copy of any SDS from the applicable department, by calling EH&S at 275-3241 or 24/7 by calling the Poison Control Center at 1-800-222-1222.
   Patient Care Areas which order chemical products outside of SMH departments will maintain an inventory of the chemical products from outside vendors along with copies of the Safety Data Sheets.
   The 2012 update to the Hazard Communication Standard reuires that by June 1, 2015 all Safety Data Sheets follow a standard 16-section format:
   • Section 1, Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.
   • Section 2, Hazard(s) identification includes all hazards regarding the chemical; required label elements.
   • Section 3, Composition/information on ingredients includes information on chemical ingredients; trade secret claims.
   • Section 4, First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.
   • Section 5, Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.
   • Section 6, Accidental release measures lists emergency procedures; protective equipment; proper methods of containment and cleanup.
   • Section 7, Handling and storage lists precautions for safe handling and storage, including incompatibilities.
   • Section 8, Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment (PPE).
   • Section 9, Physical and chemical properties lists the chemical's characteristics.
   • Section 10, Stability and reactivity lists chemical stability and possibility of hazardous reactions.
   • Section 11, Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.
   • Section 12, Ecological information* provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment.
   • Section 13, Disposal considerations* provides guidance on proper disposal practices, recycling or reclamation of the chemical(s) or its container, and safe handling practices. To minimize exposure, this section should also refer the reader to Section 8 (Exposure Controls/Personal Protection) of the SDS.
   • Section 14, Transport information* provides guidance on classification information for shipping and transporting of hazardous chemical(s) by road, air, rail, or sea.
   • Section 15, Regulatory information* identifies the safety, health, and environmental regulations specific for the product that is not indicated anywhere else on the SDS.
   • Section 16, Other information includes the date of preparation or last revision.
   
   *Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).
2. Labels and Signs
   The hazard and precautionary statements on the label outline the appropriate measures to be taken in case of an emergency and gives the main hazard(s) associated with the use of the chemical. If a label is missing from a container in which the chemical can be properly identified, a new label shall be affixed containing the appropriate information. Never mix chemicals that do not have proper labels. Never assume an unlabeled container is harmless. Also, never remove any label unless you immediately replace it with a new label containing the information from the previous label. Labels are an important first source of information on the chemicals used in the workplace. Labels can be seen as a condensed version of a SDS. The 2012 revision of the HazComm Standard requires that by June 1, 2015, all chemical container labels contain six standard elements:
   • Name, Address and Telephone number of the manufacturer, importer or other responsible party
   • Product Identifier - The same identifier must be on both the label and Sec. 1 of the SDS
   • Signal Word - "Warning" (less severe) or "Danger" (more severe)
   • Hazard Statement(s) - Describe the nature of the hazard, including, where appropriate, the degree of hazard
   • Precautionary Statement(s) - Describe recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to the hazardous chemical or improper storage or handling
   • Pictograms - Graphic symbols used to communicate specific information about the hazards of a chemical
   
   A description of the HazComm pictograms can be found in Appendix 2
   
   • All purchased chemicals and solutions must be labeled with the required 6 elements.
   • In-house prepared solutions that will remain within SMH must have identity labels showing:
     • The identity of the hazardous chemical(s) with proper names
     • Appropriate hazard warnings such as FLAMMABLE or CORROSIVE, etc.
   • Product labels and DOT shipping labels must be retained on all bulk quantities of chemicals.
   • Signs indicating the location of safety showers and eyewash stations, and other safety and first aid equipment are required.
   • Warning signs are required in areas or on equipment where special or unusual hazards exist.
3. LIMITING CHEMICAL EXPOSURES
   Four main methods exist to control exposure: substitution, engineering controls, safe work practices, and personal protective equipment (PPE). Actions made when procuring, storing, and disposing of chemicals can limit exposures.
1. Substitution / Engineering Controls
   Substitutions with less hazardous chemicals, followed by engineering controls are the preferred methods of reducing exposure. Engineering controls should be used whenever the chemical hazard information on the chemical label or the SDS indicates a need. A common need for engineering controls is indicated when an SDS states "use local exhaust". Examples of engineering controls include, isolating the chemical by using isolation rooms or using remote equipment, and using special local ventilation such as a chemical fume hood.


2. Safe Work Practices
   Safe work practices offer another method to reduce exposure after the use of engineering controls. SDS and chemical labels should be reviewed for specific work practice instructions before using chemicals. Additional safe work practices include not working alone, keeping chemical containers covered when possible, washing hands after using chemicals, and reducing the amount of chemicals used or stored.


3. Personal Protective Equipment (PPE)
   PPE should be used in addition to, but not as a substitute, for engineering controls and safe work practices to reduce exposure. PPE may consist of respiratory protection, eye protection, face protection, gloves, hearing protection, and protective clothing. SDSs and chemical labels contain specific information on the proper PPE needed. When PPE is selected, its use shall be in accordance with OSHA standard 29 CRF 1910 subpart I, sections 132-139, and in consultation with the manufacturer.
   Personnel must wear PPE to help prevent chemical exposures. The EH&S Personal Protective Equipment Plan has more detail on requirements regarding PPE use and selection. The UofR EH&S Respiratory Protection Program document also has information regarding the respirator program requirements.  Adequate PPE needed for the performance of an employee's job function is to be provided by the supervisor at no cost to the employee.
4. Chemical Procurement, Distribution, Storage and Disposal
1. Procurement
1. Before a substance is used, a SDS with information on proper handling, storage, and disposal shall be obtained and made available for those who will be using the substance. No container is to be accepted without an adequate identifying label. Manufacturers' labels are not to be defaced or removed.
2. Whenever possible, supervisors should consider using alternative chemicals for very hazardous chemicals.
3. To reduce future wastes, purchase only those quantities necessary.
2. Distribution
   When chemicals are transported by hand or cart, the container should be placed within a second, larger container or bucket.
3. Storage
1. Periodic inventories must be conducted. An example of a chemical inventory sheet is located in Appendix 1. Updated information is to be entered into the University's Chemical Inventory / SDS System. The Environmental Compliance/Hazardous Waste Unit (275-2056) must be consulted before disposal of unneeded or excess items. A visual inspection for replacement, deterioration, and of container integrity should be performed when inventories are updated annually.
2. Chemicals must be stored correctly. Consult the SDS and product labels for recommended storage procedures. Manufacturers should be consulted for additional storage recommendations.
4. Disposal
1. All hazardous waste generated shall be disposed of in accordance with local, state and federal regulations. The Environmental Compliance/Hazardous Waste Unit shall be contacted for guidance on the disposal of any chemical waste.
2. Training on the proper disposal of hazardous waste is available by contacting the Environmental Compliance/Hazardous Waste Unit (275-2056). The EH&S website has the University of Rochester Management of Hazardous Materials and Waste Guide

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

This page last updated 10/6/2023. Disclaimer.