Chapter 11: Hazard Communication Program

The University of Mary Washington, complies with the requirements of OSHA’s Hazard Communication Standard by maintaining a list of hazardous chemicals, using Safety Data Sheets (SDS), ensuring that containers are labeled, and training employees. In addition, we provide information to subcontractors involved in specific projects so that they may forward the information and train their employees.

This program applies to all work operations at UMW where employees may be exposed to hazardous substances under normal working conditions or during an emergency.

The Director of Emergency Management and Safety is the program coordinator, acting as the representative for UMW. The OEMS Director will review and update the program, as necessary. Copies of the written program may be obtained from OEMS, located in Hamlet House.

All employees, or their designated representatives, can obtain further information on this written program, the hazard communication standard, applicable SDS, and chemical information lists from OEMS located in Hamlet House. Under this program, our employees will be informed of the contents of the Hazard Communication Standard, CFR 1910.1200, the hazardous properties of chemicals with which they work, safe handling procedures, and measures to take to protect themselves from these chemicals. Our employees will also be informed of the hazards associated with non-routine tasks, such as the cleaning of tanks, vessels, tunnels, and the hazards associated with chemicals in unlabeled pipes.

If after reading this program, you find that improvements can be made, please contact the Director of OEMS. We encourage all suggestions, and are committed to the success of our written hazard communication program. UMW strives to promote clear understanding, safe behavior, and involvement in the program from every level of our staff.

Hazard Evaluation Procedures

UMW ‘s chemical inventory is a list of hazardous chemicals known to be present on campus not just in the work areas, but in special facilities such as Jepson Science Center and Melchers Hall. Anyone coming in contact with the hazardous chemicals that are listed needs to know what chemicals are and how to protect themselves. This is why it is important that hazardous chemicals are identified, whether they are found in a container or generated in work operations (for example, welding fumes, dusts, and exhaust fumes). The hazardous chemicals on the list can cover a variety of physical forms including liquids, solids, gases, vapors, fumes, and mists. Sometimes hazardous chemicals can be identified using purchase orders. Identification of others requires an actual inventory of the facility.

Presently all chemicals that come through the UMW Storeroom are accompanied with an SDS that is forwarded to OEMS for filing at the active locations for the inventory. When the purchase of a product that requires an SDS does not come with one, one will be requested by the purchaser and forwarded to OEMS for proper posting and inventory accounting.

OEMS maintains the chemical inventory list, along with related work practices in the Safety Office at Hamlet House, where it is accessible during normal business hours.

UMW does not manufacture any chemicals and, therefore, does not make any hazard determinations.

After the chemical inventory is compiled, it serves as a list of every chemical for which an SDS must be maintained.

Safety Data Sheets (SDS)

The SDS we use are fact sheets for chemicals which pose a physical or health hazard in the workplace. SDS provide our employees with specific information on the chemicals they use.

OEMS is responsible for maintaining the SDS for all campuses. They will contact the chemical manufacturer or vendor if additional research is necessary. All new procurements for the Housekeeping Division must be cleared by the Director of OEMS.

The SDS are maintained at Hamlet House. Employees can obtain access to them by contacting OEMS at 540-654-2108.

If an SDS does not accompany a shipment of a product, the manager of the stockroom will contact the company’s distribution representative and request an applicable MSDS to be faxed or mailed as soon as possible.

UMW does not generate SDS. No alternatives to SDS are used in this workplace.

Labels and Other Forms of Warning

Labels information will contain information required by the Global Harmonization System, including:

Product Identifier
GHS Signal Words (Warning, Danger)
Hazard Statements
Precautionary Statements
Pictograms
Supplemental Information (if any)
Contact and Emergency Information for the Manufacturer

The labels must have the above information. Any chemical that does not meet the label standard shall have a new label provided by the manufacturer.

Supervisors are responsible for ensuring that all hazardous chemicals in containers are properly labeled and updated, as necessary. Supervisors also ensures that newly purchased materials are checked for labels prior to use.

Supervisors, with the assistance of OEMS, will refer to the corresponding SDS to assist employees in verifying label information.

If an employee transfers a chemical from a labeled container to a portable container, it is intended only for their IMMEDIATE use. UMW requires labeling on the portable container, and the product must be used within an 8-hour shift.

No alternatives to labeling are used in this workplace.

The following procedure is used to review and update label information when necessary and to ensure that labels that fall off or become unreadable are immediately replaced. Supervisors are to inspect areas that these products are stored to ensure that labels are of good quality and readable. If the integrity of the label diminishes, it is to be removed from available stock.

Training

Everyone who works with or is potentially “exposed” to hazardous chemicals will receive initial training, any necessary retraining on the Hazard Communication Standard, and the safe use of those hazardous chemicals by OEMS. “Exposure” means that “if an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.) and includes potential (e.g., accidental or possible) exposure.” Whenever a new hazard is introduced or an old hazard changes, additional training will be provided.

Information and training is a critical part of the hazard communication program. We train our employees to read and understand the information on labels and SDS, we demonstrate how the information can be obtained and used in their work areas, and how to understand the risks of exposure to the chemicals in their work areas as well as the ways to protect themselves.

UMW’s goal is to ensure employee comprehension and understanding, which also includes being aware that if they are in fact exposed to hazardous chemical, knowing how to read and use labels and SDS, and how to appropriately follow the protective measures OEMS has established. We encourage employees to ask the questions. As part of the assessment of the training program, OEMS representative are to ask for input from employees regarding the training that they have received, and their suggestions for improving it. In this way, we hope to reduce any incidence of chemical source illnesses and injuries.

All employees receive training for hazard communication. This training is provided during the New Employee Safety Training.

Training Content

Training content is organized according to chemical products that are within the areas that employees encounter. Each department is trained in the proper use of the chemicals that will be applicable, such as housekeeping. Extensive training in the application of cleaning products and the reactive natures of different mixtures is reviewed with all housekeepers, as well as proper application and protective measures. The Grounds Department is trained in the application of pesticides, herbicides and the Proper Protective Equipment choices and relative reactions. The format of the training program used is a lecture in addition to audio/visual slides, demonstrations, working with SDS and understanding the content of the SDS and chemical interactions.

The training plan emphasizes the following elements:

Summary of the standard and this written program, including what hazardous chemicals are present, the labeling system used, and access to SDS information and what it means.
Chemical and physical properties of hazardous materials (e.g., flash point, reactivity) and methods that can be used to detect the presence or release of chemicals (including chemicals in unlabeled pipes).
Physical hazards of chemicals (e.g., potential for fire, explosion, etc.).
Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
Procedures to protect against hazards (e.g., engineering controls; work practices or methods to assure proper use and handling of chemicals; personal protective equipment required, and its proper use, and maintenance; and procedures for reporting chemical emergencies).

All new employees are directed to attend the New Employee Safety Training that is held on a specified date. The new employees are given a memo during their initial orientation and advised of all available training dates. It is the employee’s responsibility to inform their supervisor of the next date closest to the hire date and advise them that this is a required attendance. These classes are held in Lee Hall 412 or in a Virtual Setting. When a new hazard is introduced, employees will be briefed at their monthly safety meetings of additional hazards as well as increased or reduced hazard levels of a particular product.

All employees are to be retrained on an annual basis as a refresher to the Hazardous Communications Standard.

Hazards of Unlabeled Pipes

Supervisors are to inform employees of the hazards of chemicals contained in unlabeled pipes in their work areas by performing a walk though of areas, pointing out specific hazardous areas of concern.

Contractor Responsibility

When contractors will be working at UMW, OEMS will:

Provide the contractor(s) with SDS for any of our chemicals to which their employees may be exposed to at the Pre-Construction briefing.
Relay necessary label and/or emergency precautionary information to the contractor. Supervisors on site will be informed of all hazards and will be responsible for forwarding all applicable information to all affected employees.

Each contractor bringing chemicals on-site must provide OEMS with the appropriate hazard information on these substances, including the SDS, the labels used, and the precautionary measures to be taken in working with these chemicals.

Additional Information

Any employee or their designated representatives may obtain further information on this written program, the Hazard Communication Standard, applicable SDS, and chemical information lists from OEMS at Hamlet House or by calling 540-654-2108.