Environmental Health & Safety

Chemical Hazard Communication Program

Prepared by: University of Rochester's Environmental Health & Safety Department (EH&S)

Revised 2/2022

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

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SECTION 1: REQUIREMENTS AND RESPONSIBLITIES

1. SCOPE and REQUIREMENTS
1. Scope:  The Hazard Communication Standard (HazCom) applies to all employees who work in locations where hazardous chemicals are known to be present in such a manner as employees may be exposed under normal conditions of use or in a foreseeable emergency.  Exception: Those employees working in laboratories are covered under another OSHA standard, the “Occupational Exposure to Hazardous Chemicals in Laboratories”, 29 CFR 1910.1450.
2. Applicable Chemicals:  The Standard applies to all chemicals 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 under conditions of use or foreseeable emergencies.  The standard defines a hazardous chemical as one that has health hazards and/or physical hazards.
3. Requirements:
1. 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.
2. Chemical Inventory:  The employer is required to compile a list of the hazardous chemicals present in the workplace. A suggested chemical inventory form to compile the information is available in Appendix 1. 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. A link to Chematix may be found at the following location: http://www.safety.rochester.edu/labsafety/chematix_intro.html.  EH&S will instruct departments/units how to modify their inventories (contact EH&S at 275-3241 for this assistance).
3. Safety Data Sheets (SDSs, formerly known as MSDSs): SDSs must be readily accessible to employees. This requirement can be met by maintaining hard copy SDS binders in the work area or training employees how to access the SDSs online. Once logged into Chematix, click on "Safety Data Sheet Search Through MSDSonline" to search for SDSs.EH&S is available by calling 275-3241 to assist all University staff with locating SDSs.
4. 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 and 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
   • 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.
5. 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. (Refer to Section 2)



4. 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. Deans, Administrator, and Department Heads have the ultimate responsibility for administration of safety in their departments. The HazComm Program is only one of the policies and programs that must be administered under their direction.
2. 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. Completing the most recent edition of EH&S’s Certificate of Hazard Assessment to determine the personal protective equipment needed to protect the  employees (http://www.safety.rochester.edu/ih/ppe/ppeplan1.html)
3. 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
4. Investigating and reporting incidents relating to the use of hazardous chemicals
5. 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
6. Assigning initial and periodic HazCom training on MyPath to employees or scheduling in-person HazCom training. Maintaining training records of all those in the department that have attended training sessions relating to HazCom or track training records via MyPath
3. 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 the appropriate engineering controls, work practices and PPE required for working safely 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
   7. Attending training as required
4. EH&S will oversee general training programs and the availability of Safety Data Sheets. The Unit’s responsibilities include implementation of the HazCom program and:
   
   1. Working with administrators and other employees to develop and implement safe work practices
   2. Providing general awareness training to University personnel through “New Hire Employee Orientation”, MyPath platforms, and as requested by departments
   3. Providing additional training materials and information to assist departments in supplemental training efforts (i.e. chemical specific training)
   4. Assisting departments in evaluating areas where regulated materials are used and determine when exposure monitoring of airborne contaminants is necessary
   5. Assisting departments in performing periodic safety surveys of work areas to ensure compliance with the HazCom Program
   6. Assist departments with inputting chemical inventories into Chematix and training how to manage changes in inventory



5. RECORDS



1. Chemical inventories will be maintained by each department, in addition to 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 HazCom training sessions conducted by department supervisors are to be retained in employee files or in the MyPath transcript
3. Injuries or chemical exposures will be documented on an SMH115 Incident Report Form available on line at http://www.safety.rochester.edu/SMH115.html
4. Medical records will be retained as established by University protocol



6. MULTI-EMPLOYER WORKPLACE



Upon request, 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 or COMMENTS?
Contact EH&S at (585) 275-3241 or e-mail EH&S Questions.

This page last updated 5/17/2022. Disclaimer.