Hazard Communication Plan

INTRODUCTION

It is the desire and intent of Monmouth University that employees be informed about the hazardous substances they may encounter in the workplace, and learn the appropriate protective measures to work safely with those substances. The Hazard Communication Program, contained in this document, is intended to comply with the requirements of the OSHA Hazard Communication Standard 29 CFR 1910.1200.

A. Contents:

	Lists of hazardous chemicals found in each work area
	How employees are informed of the hazards associated with non-routine tasks
	How employees are informed of the hazards of chemicals contained in pipes
	How contractors are informed of chemical hazards to which their employees may be exposed to while performing work at Monmouth University

B. Accessibility:

This document is available to all University employees upon request. It is also available to the Assistant Secretary for Occupational Safety and Health, and the Director of the National Institute for Occupational Safety and Health (NIOSH) upon request.
 

C. Monmouth University Employee Responsibility:

It is the objective of Monmouth University to ensure that all employees who handle hazardous chemicals be fully informed of the hazards involved and that they be trained to perform their jobs safely. However, the active participation of each Monmouth University employee in the program is essential to make the Hazard Communication Program a success.

SUMMARY OF THE STANDARDS

This section contains a summary of the OSHA HAZARD COMMUNICATION STANDARD. This summary was prepared by OSHA and is entitled "CHEMICAL HAZARD COMMUNICATION."  It is included so that employees can develop a better understanding of the various requirements of the Standard.

A. Chemicals in the Workplace:

Chemical Manufacturers/Importers:

• Determine the hazards of each product.

Chemical Manufacturers/Importers/Distributors:

• Communicate the hazard information and associated protective measures downstream to customers through labels and MSDS’s.

Employers:

• Identify and list hazardous chemicals in their workplaces.
• Obtain MSDS’s and labels for each hazardous chemical.
• Develop and implement a written hazard communication program, including labels, MSDS’s, and employee training, based on the list of chemicals, MSDS’s and label information.
• Communicate hazard information to their employees through labels, MSDS’s and formal training programs.

B. Hazard Evaluation:

	National Toxicology Program (NTP), Annual Report on Carcinogens,
	International Agency for Research on Cancer (IARC), Monographs
	Regulated by OSHA as a carcinogen.

C. Written Hazard Communication Program:

Employers must develop, implement, and maintain at the workplace a written, comprehensive hazard communication program that includes provisions for container labeling, collection and availability of material safety data sheets, and an employee training program.  It also must contain a list of the hazardous chemicals in each work area, the means the employer will use to inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor vessels), and the hazards associated with chemicals in unlabeled pipes. If the workplace has multiple employers on-site (for example, a construction site), the rule requires these employers to ensure that information regarding hazards and protective measures be made available to the other employers on-site, where appropriate.

The written program does not have to be lengthy or complicated, and some employers may be able to rely on existing hazard communication programs to comply with the above requirements. The written programs must be available to employees, their designated representatives, the Assistant Secretary of Labor for Occupational Safety and Health, and the Director of the National Institute for Occupational Safety and Health (NIOSH).
 
D. Labels and Other Forms of Warning:

Chemical manufacturers, importers, and distributors must be sure that containers of hazardous chemicals leaving the workplace are labeled, tagged or marked with the identity, appropriate hazard warnings, and the name and address of the manufacturer or other responsible party.

In the workplace, each container must be labeled, tagged or marked with the identity of hazardous chemicals contained therein, and must show hazardous warnings appropriate for employee protection. The hazard warning can be any type of message, words, pictures, or symbols that convey the hazards of the chemical(s) in the container. Labels must be legible, in English (plus other languages, if desired), and prominently displayed.

Exemptions to the requirement for in-plant individual container labels are as follows:

• Employers can post signs or placards that convey the hazard information if there are a number of stationary containers within a work area that have similar contents and hazards.

• Employers can substitute various types of standard operating procedures, process sheets, batch tickets, blend tickets, and similar written materials for container labels on stationary process equipment if they contain the same information and are readily available to employees in the work area.

• Employers are not required to label portable containers into which hazardous chemicals are transferred from labeled containers and that are intended only for the immediate use of the employee who makes the transfer.

• Employers are required to label pipes or piping systems.

E. Material Safety Data Sheets:

Chemical manufacturers and importers must develop an MSDS for each hazardous chemical they produce or import, and must provide the MSDS automatically at the time of the initial shipment of a hazardous chemical to a downstream distributor or user. Distributors must also ensure that downstream employers are similarly provided an MSDS.

Each MSDS must be in English and include information regarding the specific chemical identity of the hazardous chemical(s) involved and the common names. In addition, information must be provided on the physical and chemical characteristics of the hazardous chemical; know acute and chronic health effects and related health information; exposure limits; whether the chemical is considered to be a carcinogen by NTP, IARC, or OSHA; precautionary measures; emergency and first-aid procedures; and the identification of the organization responsible for preparing the sheet.

Copies of the MSDS for hazardous chemicals in a given work site are to be readily accessible to employees in that area. As a source of detailed information on hazards, they must be located close to workers and readily available to them during each workshift.

A copy of the non-mandatory MSDS form (OSHA 174) can be obtained from OSHA field officers.

F. List of Hazardous Chemicals:

Employers must prepare a list of all hazardous chemicals in the workplace. When the list is complete, it should be checked against the collected MSDS’s that the employer has been sent.  If there are hazardous chemicals used for which no MSDS has been received, the employer must write to the supplier, manufacturer, or importer to obtain the missing MSDS.

G. Employee Information and Training:

Employers must establish a training and information program for employees exposed to hazardous chemicals in their work area at the time of initial assignment and whenever a new hazard is introduced into their work area.

Information:

At a minimum, the discussion topics must include the following:

• The existence of the hazard communication standard and the requirements of the standard.
• The components of the hazard communication program in the employee’s workplaces.
• Operations in work areas where hazardous chemicals are present.
• Where the employer will keep the written hazard evaluation procedures, communications program, lists of hazardous chemicals, and the required MSDS forms.

Training:

The employee training plan must consist of the following elements:

• How the hazard communication program is implemented in that workplace, how to read and interpret information on labels and the MSDS, and how employees can obtain the available hazard information.
• The hazards of the chemicals in the work area. (The hazards may be discussed by individual chemical or by hazard categories such as flammability.)
• Measures employees can take to protect themselves from the hazards.
• Specific procedures put into effect by the employer to provide protection such as engineering controls, work practices, and the use of personal protective equipment (PPE).
• Methods and observations – such as visual appearance or smell – works can use to detect the presence of a hazardous chemical to which they may be exposed.

H. Trade Secrets:

A "trade secret" is something that gives an employer an opportunity to obtain an advantage over competitors who do not know about the trade secret or who do not use it. For example, a trade secret may be a confidential device pattern, information, or chemical make-up. Chemical industry trade secrets are generally formulas, process data, or a "specific chemical identity." The latter is the type of trade secret information referred to in the hazard communication standard. The term includes the chemical name, the Chemical Abstracts Services (CAAS) Registry Number, or any other specific information that reveals the precise designation. It does not include common names.

The standard strikes a balance between the need to protect exposed employees and the employer’s need to maintain the confidentiality of a bona fide trade secret. This is achieved by providing for limited disclosure to health professionals who are furnishing medical or other occupational health services to exposed employees, employees and their designated representatives, under specified conditions of need and confidentiality.

I. Medical Emergency:

The chemical manufacturer, importer, or employer must immediately disclose the specific chemical identity of a hazardous chemical to a treating physician or nurse when the information is needed for proper emergency or first aid treatment. As soon as circumstances permit, obtain a written statement of need and a confidentiality agreement.

Under the contingency described here, the treating physician or nurse has the ultimate responsibility for determining that a medical emergency exists. At the time of the emergency, the professional judgment of the physician or nurse regarding the situation must form the basis for triggering the immediate disclosure requirement. Because the chemical manufacturer, importer, or employer can demand a written statement of need and a confidentiality agreement to be completed after the emergency is abated, further disclosure of the trade secret can be effectively controlled.  

J. Non-Emergency Situation:

In non-emergency situations, chemical manufacturers, importers or employers must disclose the withheld specific chemical identity to health professionals providing medical or other occupational health services to exposed employees, and to employees and their designated representatives, if certain conditions are met.  In this context, "health professionals" include physicians, occupational health nurses, industrial hygienists, toxicologists, or epidemiologists.

The request for information must be in writing and must describe with reasonable detail to medical or occupational health the need for the information. The request will be considered if the information will be used for one or more of the following activities:

	To assess the hazards of the chemicals to which employees will be exposed.
	To conduct or assess sampling of the workplace atmosphere to determine employee exposure levels.
	To conduct pre-assignment or periodic medical surveillance of exposed employees.
	To provide medical treatment to exposed employees.
	To select or assess appropriate personal protective equipment for exposed employees.
	To design or assess engineering controls or other protective measures for exposed employees.
	To conduct studies to determine the health effects of exposure.

The health professional, employee, or designated representative must also specify why alternative information is insufficient. The request for information must explain in detail why disclosure of the specific chemical identity is essential and include the procedures to be used to protect the confidentiality of the information. It must include an agreement not to use the information for any purpose other than the health need stated or to release it under any circumstances, except to OSHA.

The standard further describes in detail the steps that will be followed in the event that an employer decides not to disclose the specific chemical identity requested by the health professional, employee, or designated representative.  

K. U.S. Department of Labor, Occupational Safety and Health Administration Office:

The regional office listed below operates its own OSHA-approved job safety and health programs. The New York region covers public employees only.

WRITTEN HAZARD COMMUNICATION PROGRAM

The requirements for a written program as described in the Standard are contained in this section. The University’s policies and assigned responsibilities for implementing various requirements of the program are also described.

MONMOUTH UNIVERSITY POLICY AND ASSIGNED RESPONSIBILITIES

1. Right-To-Know Facility Coordinator:

The University has assigned a facility Right to Know Coordinator who will be responsible for coordinating all activities pertaining to this program. The Right to Know Coordinator for the facility is:

2. Labels, MSDS’s and Employee Training:

University Programs for Hazard Determination, Labels, MSDS’s and Employee Training are described in separate sections of this manual under the respective subject headings.

3. List of Hazardous Substances:

It is the policy of the University to develop a list of hazardous chemicals used in each work area. This list will be developed as a result of the facility inventory conducted annually. Material Safety Data Sheets obtained from suppliers for each product will be consulted in order to identify products that are hazardous. This list will be updated as new information becomes available.

4. Hazard of Non-routine Tasks and Unlabeled Pipes:

a) Non-routine Tasks:

Non-routine tasks involving the use of hazardous chemicals include:

Employees being transferred (temporarily or otherwise) to a different position and/or department.

Prior to performing non-routine tasks an employee shall review with his/her supervisor the potential hazards of the task and the proper safety and handling procedures established by the Company. The Material Safety Data Sheets for each hazardous material used should always be consulted prior to performing the non-routine task.

The employee’s supervisor will be responsible for informing him/her on hazards of materials used in non-routine tasks prior to performing the task.

b) Unlabeled Pipes:

Pipes containing hazardous substances shall be labeled. In addition, tags specifying the identity of the hazardous substance will be affixed to exit points of the pipeline system. The person responsible for labeling the pipes and exit valves is: 

Walter Bertelson, Fire and Safety Supervisor

A list of materials contained in the piping systems will be developed. Material Safety Data Sheets for those materials will be maintained in the work area and will be readily accessible to employees. In addition, during the Education and Training of employees, hazardous materials contained in pipes will be addressed.

5. Contractor Information: 

Any contractual agreement between an outside contractor and the University shall address the following concerns:

	The contractor shall provide Material safety Data Sheets on all hazardous materials brought into the university facilities during the performance of the contractual work.
	The contractor shall inform the University representative about any precautionary measures if needed to protect university employees during the performance of the contractual work.
	The contractor shall be advised about the hazards of materials in areas where the contractor’s employees will work. In addition, the contractor will be informed of the availability of this written Hazard Communication Program and the location of the MSDS’s in work areas where the contractor’s employees will be situated.
	A contractor shall acknowledge in writing the receipt of this information and his intent to disseminate the information to his/her employees.

The person responsible for implementing the outside contractor policies is:

Robert Cornero, Director of Campus Planning and Construction

6. Accessibility:

Upon request, this Hazard Communication document will be made available to employees or their designated representatives within 15 working days of the request.

The written program for the facility is maintained in the following locations:

Right to Know Coordinator:   Raymond Rodriguez, Director of Affirmative Action, Human Relations and Compliance, Wilson Hall, Room 306, 1-732-571-7577

- Or -

Safety Department:  Thomas Zambrano, Director/Chief, Campus Police, 1-732-571-3472

- Or -

Facilities Management:   1-732-571-3425

Employees can request to see the written program by contacting their department supervisor or the Right-to-Know Coordinator during normal working hours.  To facilitate the process of obtaining a copy of the Program, a request form (attachment 1) should be used.

HAZARD DETERMINATION:

Products Purchased/Raw Materials

A. Incoming Containers:

B. In-house Transfer Containers:

	"Identity" of the material
	Hazards warnings

Transfer containers used between workshifts and/or by different workers must be labeled with the required information.  The person responsible for ensuring that labels are affixed to transfer containers and other in-house containers in his or her department is the respective Department Head.

C. Labeling System:

The labeling system to be used on in-house containers throughout University Facilities is:

Manufacturer Supplied Label and the New Jersey Worker and Community Right- to-Know Labeling Act

A description of this labeling system will be explained to the employees as part of the Training Program and can be found at the end of this Plan (attachment 2). The person responsible for providing the information to be noted on the workplace labels is the Department Head. Assistance will be provided to the Department Head upon written request to the Right-to-Know Coordinator.

The manufacturer will be relied upon to provide the hazard ratings for each hazardous product. The Department Head is responsible for obtaining any updates or new information that must be included on the labels from the manufacturer.

The Department Head is responsible for complying with the Community Right to Know labeling provisions of the Act as outlined in the following section.  

MATERIAL SAFETY DATA SHEETS:

This section outlines the University procedure for Material Safety Data Sheets (MSDS).  University policies and assigned responsibilities for obtaining, maintaining and distributing MSDS’s for all hazardous substances present at the University are described.

Department Head Responsibilities:

The Department Head is responsible for ensuring that Material Safety Data Sheets (MSDS) are obtained from manufacturers and/or distributors for all materials present in their office/department. If the MSDS is not received or is found to be inadequate, the manufacturers and/or distributors shall be contacted by the Department Head in writing.

Upon receipt of the MSDS, copies of each must be sent to the Right-to-Know Coordinator (the Director of Affirmative Action, Human Relations, and Compliance) and the Director/Chief of the Monmouth University Police and Safety Department.

The original MSDS should be maintained in a central file within the department and should be readily accessible to departmental employees or others on a need-to-know basis.

The responsibility for obtaining the MSDS’s is assigned to the Department Head. Products should not be accepted unless they are accompanied by an MSDS. Free samples may not be accepted unless accompanied by an MSDS.

A list of hazardous materials for each work area shall be developed and a copy sent to the Right-to-Know Coordinator (the Director of Affirmative Action, Human Relations, and Compliance) and the Director/Chief of the Monmouth University Police and Safety Department.

For employees who must travel between University Buildings, the Material Safety Data Sheets are available for review at:

The Office of Affirmative Action, Human Relations and Compliance, the Monmouth University Police and Safety Department, as well as the employee’s department.

EDUCATION AND TRAINING:

The purpose of this section is to outline the University program for Employee Education and Training regarding hazardous chemicals. A description of how employees will be trained and the contents of the training program are provided. The requirements for education and training of employees as described in the Standard are also included.

Elements of the Program:

The Program will consist of an Educational Phase and a Training Phase. During the Educational Information Phase of the program, employees will be informed of the following:

	Explanation of the Standard,
	A review of the University’s compliance Program,
	How to obtain a copy of the written Program,
	The locations of MSDS’s and lists of hazardous substances for each work area, and
	How to read and use MSDS’s and Labels

Objectives:

This session will focus on what the Occupational Safety and Health Administration (OSHA) HAZARD COMMUNICATION STANDARD is. The Standard is sometimes referred to as the "Right-to-Know" Law. The topics to be covered will include:

	Purpose of the Standard
	Chemical manufacturer’s responsibility
	Employer’s responsibilities
	MSDS’s and what they mean
	Labels and what they mean
	The written Hazard Communication Program
	Employee rights under the Standard

The objects for each session of the Hazard Communication Training Program are outlined on the following pages.

It is the policy of Monmouth University that employees are informed about the hazards in their own work areas as well as hazards in other departments where they may be required to work.

Whenever a new hazard is introduced into a department, it is the Department Head’s responsibility to inform the employees regarding the new hazard and to provide appropriate training.  

Training of Employees:

The Right-to-know training program consists of an information phase, and a training phase. The Office of Affirmative Action, Human Relations, and Compliance schedules the information phase. Employees are scheduled for Right-to-Know training (Information Phase) at the time of employment.

The training phase of the Right-to-Know program (which consists of a walk-through of the workplace and hands-on demonstration) addresses chemical hazards the employee may encounter through the performance of his/her responsibilities. This training is the responsibility of the department head. The training is accomplished by discussing classes of hazards of specific chemical hazards using the Material Safety Data Sheets (MSDS) for products which are representative of each hazard class. In addition, occupational health principles, Personal Protection Equipment and controls, and emergency procedures will be discussed in this phase. All training must be documented. Each department may develop and outline covering the areas discussed above, using the guidelines located at the end of this Plan (attachments 3 and 4) or contact the Compliance office for assistance in developing an outline specific to your area. Once the training has been completed a copy of the training outline with the name of the individual providing the training should be forwarded to the Office of Affirmative Action, Human Relations, and Compliance.

EMPLOYEE REQUEST FOR WRITTEN PROGRAM:

As provided by the OSHA Hazard Communication Standard, 29 CFR 1910.1200, I wish to review the Written Hazard Communication Program

My name is: ____________________________________________________________

Department: ____________________________________________________________
 
 

I am requesting the Written Program:

________ for myself

________ as designated representative for ___________________________
 
 

Date of request: ________________________________________________________

Signature: ________________________________________________________
 
 

Request received by: ____________________________________________________

Title: ________________________________________________________________
 
 

Date Written Program received: ___________________________________________

Signature: _____________________________________________________________
 
 

 

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CONDUCTING A WALKTHROUGH (EXERCISE):

DOH regulations require that the education and training program include "informing and physically showing the employees the location of the hazardous substance containers present at the facility with which they work and with which they are likely to work. Employees assigned plantwide or to more than one location may be shown a representative work area where hazardous substance containers are present." N.J.A.C. 8:59-6.3

The purpose of the walkthrough is to guarantee that employees recognize where and how containers of hazardous substances are stored or used in their worksite. The walkthrough gives the employer the opportunity to show the employees how the employer has complied with the Right-to-Know law and to demonstrate safety measures taken at the facility to protect their health. The walkthrough should be viewed as part of the training, a chance to review and highlight major points covered in the classroom.

In preparing for the walkthrough you will first want to identify the area you intend to tour and obtain and review the following so that you will be familiar with the area:

	Floor plan showing major building structures and pieces of equipment
	Simple schematics of any local exhaust ventilation systems
	Process descriptions
	Employee job descriptions
	Right-to-Know Survey Forms
	Results of any pertinent industrial hygiene monitoring surveys
	Description of any past chemical spills or accidents
	Company policies on handling of spills

Next tour the area yourself, locating the following items and making notes on the floorplan or plain paper about what you’ve seen:

	Chemical storage areas including flammable storage rooms and cabinets. note explosion-proof electrical wiring and lighting and separation of incompatible chemicals if applicable.
	Containers of hazardous chemicals such as drums, bags, carboys, bottles, cans, tubes, etc. Note any labels, signs, and placards including "No Smoking" signs.
	Chemical dispensing equipment such as pumps, scoops, shovels, buckets, safety cans, etc. Note provisions for bonding and grounding and non-sparking tools if applicable.
	Chemical handling equipment such as conveyors, piping, mixers, sifters, baggers, drummers, etc.
	Chemical disposal equipment such as drains, sewers, trash receptacles, etc.
	Fixed monitoring systems with audible or visual alarms for chemical detection, if applicable.
	Ventilation systems, both general and local exhaust.
	Respirators, both those for routines use and emergencies.
	Personal protective equipment.
	Fire suppression equipment including portable extinguishers, fixed extinguishing systems (sprinklers, dry chemical carbon dioxide), fire alarms and phone numbers for reporting fires and calling the fire brigade or department.
	Washing facilities, locker and lunchroom facilities. Any emergency eye washes and showers.
	Spill cleanup equipment including flushing water, neutralizing agent, absorbing agent, sealed containers, etc.
	First aid supplies including oxygen and antidote kit if applicable.
	New Jersey Right to Know.
	Central file

When actually conducting the walkthrough avoid making your presentation in noisy areas and keep your group small so everyone can see and hear you. Move slowly and point out the items covered in above. Giving the following additional information will add to your presentation:

	Employee exposure levels to various chemicals present.
	Past spills or accidents involving chemicals, how they were handled, how they should be handled in the future.
	Future improvements planned in ventilation, protective and emergency equipment, etc.

Finally, the walkthrough is a good opportunity to demonstrate how the ventilation system offers employees protection from chemical exposure. Smoke tubes and velometers are useful in visually demonstrating that local exhaust ventilation systems are working properly.

A smoke tube is a very inexpensive item available from many safety supply houses. A small tube filled with a chemical powder is inserted into a rubber squeeze bulb. When the bulb is squeezed, the chemical "smoke" comes out and floats with the air, making currents visible.  It is then possible to see if the air moves into the exhaust hood as intended, or away in some undesirable manner.

Next, a junior velometer may be used to demonstrate and also measure the actual flow of air past a workstation. It measures airflow in feet per minute (fpm). For most purposes, the best place to take the measurement is at the source of the contaminant as the airflows past it into the exhaust hood. The air movement here is called the "capture velocity."

If the hoods have large openings, a velometer may be placed at several places at the hood face and the readings averaged to determine the airflow into the booth.

Before a velometer is used, its calibration should be checked. The meter is held horizontal, and both ports covered, so no airflows through the instrument. The pointer should then be adjusted to rest on zero. It is important to hold the velometer upright when taking a reading.

With very small hoods, such as on grinding wheels, more sophisticated types of velometers with attachments and probes are needed. To determine the adequacy of the airflow, compare the measurements with the accompanying Guideline for Capture Velocity.

GUIDELINE FOR CAPTURE VELOCITY

* Use the high number when any of the following conditions are met:

	Room air currents blow the contaminant away from the hood
	Contaminants are highly toxic
	High production, heavy use
	Small hood-local control only

HANDS ON TRAINING (DEMONSTRATION):

	Guarantee that employees who must use personal protective equipment and respirators can utilize them properly.
	Guarantee that employees who must handle hazardous substances or cleanup leaks and spills can carry out the proper procedures.
	Guarantee that employees who must be involved in firefighting know how to operate fire suppression equipment and understand firefighting principles.
	Guarantee that employees can carry out emergency treatment for exposure such as flushing of the eyes and body, mouth-to-mouth resuscitation.

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