Chapter 11: Hazard Communication Program

The University of Mary Washington, (UMW), in order to comply with the requirements of OSHA’s Hazard Communication Standard by maintaining a list of hazardous chemicals, using Material Safety Data Sheets (MSDS), 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 situation.

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

All employees, or their designated representatives, can obtain further information on this written program, or the hazard communication standard, applicable MSDS’s, and chemical information lists from the Safety Office located in the Physical Plant Building. 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 Environmental Health and Safety Director. 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 a MSDS that is forwarded to the safety office for filing at the active locations for the inventory.

When the purchase of a particular product that requires MSDS does not come with one, one will be requested by the purchaser and forwarded to the safety office for proper posting and inventory accounting.

The Emergency Management and Safety office,maintains the chemical inventory list, along with related work practices in the safety office, Hamlet House, where it is accessible during work 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 MSDS must be maintained.

Material Safety Data Sheets (MSDS’s)
The MSDS’s we use are fact sheets for chemicals which pose a physical or health hazard in the workplace. MSDS’s provide our employees with specific information on the chemicals they use.

Environmental Health & Safety Division is responsible for maintaining the MSDS’s at our facility. 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 Environmental Health & Safety.

The material safety data sheets are kept at Hamlet House. Employees can obtain access to them by contacting Emergency Management and Safety at 540-654-2108.

If an MSDS 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 MSDS’s.

No alternatives to MSDS’s are used in this workplace.

Labels and Other Forms of Warning
Labels list at a minimum, the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer or other responsible party. The chemical identity is found on the label, the MSDS, and the chemical inventory. Therefore, the chemical identity links these three sources of information. The chemical identity used by the supplier may be a common or trade name, or a chemical name. The hazard warning is a brief statement of the hazardous effects of the chemical (i.e., “flammable,” or “causes lung damage”). Labels frequently contain other information, such as precautionary measures (i.e., “do not use near open flame”). Labels are to be legible and prominently displayed, though sizes and colors can vary.

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 theEmergency Management and Safety Division, will refer to the corresponding MSDS 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, no labels are required on the portable container’s as long as the product is used within the 8 hour work 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.

Everyone who works with or is potentially “exposed” to hazardous chemicals, will receive initial training and any necessary retraining on the Hazard Communication Standard and the safe use of those hazardous chemicals by the safety division representative. “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 an understand the information on labels and MSDS’s, 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 MSDS’s, and how to appropriately follow the protective measures we have established. We encourage employees to ask the questions. As part of the assessment of the training program, the EM&
Safety Division representative is 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.

Training Content
Training content is organized according to chemical products that are also within the areas that employees come in contact with. 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 also relative reactions. The format of the training program used is a lecture in addition to audiovisual aids, demonstrations and actual working with MSDS’s and a working ability to understand the content of the MSDS sheets and chemical interactions.

The training plan emphasizes these elements:

  • Summary of the standard and this written program, including what hazardous chemicals are present, the labeling system used, and access to MSDS 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 Orientation class that is held on a specified date. The new employee’s are given a memo during their in-processing and advised of all available training dates. It is the employees 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. 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 particular areas, pointing out specific hazardous areas of concern.

Contractor Responsibility
When contractors will be working at UMW, the Safety representative will:

  • Provide the contractor(s) with MSDS’s for any of our chemicals to which their employees may be exposed to at the Pre Construction briefing, and
  • 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 effected employees.

Each contractor bringing chemicals on-site must provide UMW, Emergency Management and Safety Office with the appropriate hazard information on these substances, including the MSDS’s, 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 MSDS’s, and chemical information lists from the safety office at the Brent Hall or by calling (540) 654-2108.

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