Employee Right-to-Know Hazard Communication Program (HazCom) for All Non-Laboratory Facilities at UIC

Employee Right-to-Know Hazard Communication Program (HazCom) for All Non-Laboratory Facilities at UIC

PURPOSE Per the Occupational Health & Safety Administration (OSHA), employees have the right-to-know about the hazards of chemicals in the workplace and how to work with hazardous chemicals in a manner that keeps themselves and others safe. The OSHA Hazard Communication Standard (29 CFR 1910.1200), aka HazCom, was created to ensure that employers provide their employees with guidance to understand the hazards of the chemicals they work with. This written Hazard Communication Program is one of the ways the University of Illinois at Chicago educates its employees about chemical hazards. As an institution in Illinois, these regulations are enforced by the Illinois Department of Labor (IDOL). APPLICABILITY This Program applies to students and employees, including contract employees under the direct supervision of UIC employees, who may come into contact with or be exposed to hazardous materials at the workplace while performing their normal duties or during emergency conditions. It also applies to those who are involved in the purchase, transportation, or storage of hazardous materials. SCOPE This HazCom Program establishes requirements for the use of chemical labels, Safety Data Sheets (SDSs), personal protective equipment (PPE) evaluations, chemical inventories, and employee information and training on hazardous chemicals in the workplace. The UIC Environmental Health & Safety Office (EHSO) implemented this written HazCom Program to assist in campus compliance with these regulations and is Page 2

currently being administered by our Lab Safety Advisor, Carlos Lopez (clopez21@uic.edu, 3.2436). UIC areas subject to the HazCom standard and this written Program include, but are not limited to: Physical Plant and all applicable satellite locations on campus Department & college shops (e.g., machine, wood and metal working, glass fabrication, automotive, dental, etc.) Visual & Performing Arts studios, classrooms, and stages Police Department (e.g., the firing range) Grounds & Building Maintenance Housekeeping Campus recreational pools Greenhouses Any applicable areas where non-routine operations are performed by the Trades (e.g., Electricians, Pipefitters, Heating, Lighting, & Power [HLP], Welders, etc.) Utilities Building Service Workers NOTE: Persons working with hazardous chemicals in research laboratories shall utilize and conform to the UIC Lab Safety Plan (in accordance with the OSHA Occupational Exposure to Hazardous Chemicals in Laboratories Standard, 29 CFR 1910.1450), which supersedes this Hazard Communication Program. For more information about the UIC Lab Safety Plan, go to: www.uic.edu/depts/envh. HAZARD DETERMINATION A hazard determination shall be made for every chemical used in the workplace, so that the persons using the chemical and those working in the area are properly instructed on what kind of exposure controls, such as ventilation or personal protective equipment, should be used. The hazard determination identifies all of the hazards associated with Page 3

a particular chemical or product and is based on information provided in Safety Data Sheets (SDSs), container labeling, and any other information that may be available in reference books or from the manufacturer. Manufacturers, importers, and distributors are required to perform the appropriate hazard determination for the chemicals they produce or sell. Characteristics associated with hazardous chemicals are defined below. Health Hazards Health hazards in humans occur when exposure to chemicals or environmental pollutants cause adverse signs and symptoms to one s health. There are two types of health hazards: acute (immediate and/or of short duration; severe or intense) or chronic (developing slowly and/or of long duration). The most common types of chemicals that are health hazards include: Carcinogens- cause or presumed to cause cancer Toxic or highly toxic- cause death at or above a premeasured dose or concentration in relation to body weight, duration, exposure route, and site of contact Irritants-cause an inflammatory effect on living tissue by chemical action at the site of contact (i.e. skin, eyes) Corrosives- cause destruction of or irreversible alterations in living tissue. Corrosives can burn and even dissolve living tissues. Most corrosives are acids and bases. Sensitizers- cause an allergic reaction/ increased sensitivity to normal tissue over repeated exposure Target organ toxins- cause adverse signs & symptoms when exposed to a specific bodily organ, system, or blood.. Note- See the section of this document entitled Hazard Identification Labels for the labels that correspond to each of these hazards. Page 4

Physical Hazards A chemical with physical hazard generally can cause physical harm to the body or even death. The chemical itself does not necessarily have to enter or come in contact with the body to cause harm. Chemicals that create physical hazards have the hazardous potential to burn or explode, violently react to air, water, or specific chemicals, and/or spontaneously combust. Some chemicals with physical hazards also present health hazards due to their toxicity. OSHA defines a chemical as possessing a physical hazard if there is scientifically valid evidence that it is a(n): Combustible liquid- Combustible liquids easily ignite causing a fire or explosion. Compressed gas- A compressed gas cylinder can act as a missile if dropped or punctured. Explosive- An explosive reacts violently and releases energy which can cause severe harm and death. Flammable- Flammables are more readily ignited than combustible materials. A flammable readily catches fire. Organic peroxide- Over time, organic peroxides can form crystals which can be explosive. Oxidizer An oxidizer helps a fire burn harder and faster. Pyrophoric- Pyrophorics ignite spontaneously on contact with air or water. Reactive (unstable)- Air- and water-reactive chemicals can violently produce gases and even explode when they come in contact with air or water. Note- See the section of this document entitled Hazard Identification Labels for the labels that correspond to each of these hazards. Additional Hazardous Chemicals The broad definition OSHA uses to define hazardous chemicals includes paints, cleaning compounds, inks, dyes, and many other common substances. Chemical manufacturers and importers are required to determine if the chemicals they produce or Page 5

repackage meet the definition of a hazardous chemical. A chemical mixture may be considered as a whole or by its ingredients to determine its hazards. A chemical may be considered as a whole if it has been tested as a whole and an SDS has been issued accordingly. Otherwise the mixture must be evaluated by its components. If the mixture contains 1.0 percent or more of a hazardous chemical, or 0.1 percent of an ingredient listed as a carcinogen or suspected carcinogen, the whole mixture is assumed to have the same health and/or carcinogenic hazards as its components. CHEMICAL INVENTORIES Using the above criteria for hazardous chemicals, EHSO shall initially collect, compile, and review chemical inventories of hazardous chemicals used or created in each applicable UIC facility. The inventory shall include the name of the product and the manufacturer. The identity of the substance on an inventory list shall be the same name that appears on the manufacturer s label, in-house label, and the SDS for that substance. Once inventories are established for applicable UIC facilities, each facility's supervisor shall be responsible for maintaining their chemical inventory and updating them at least annually to accurately reflect all the hazardous chemicals present in the workplace. EXEMPTIONS The following materials are not covered by the Hazard Communication Standard: Any hazardous waste as defined by the Resource Conservation and Recovery Act (RCRA) regulations issued by the Environmental Protection Agency (EPA). Page 6

These regulations concern the safe handling of hazardous waste. Refer to the Waste section of the UIC EHSO website for additional information ). Consumer products (including pens, pencils, adhesive tape) used in the workplace under typical consumer usage. Articles (i.e., plastic chairs, tires, etc). Foods, drugs/medications, or cosmetics intended for personal consumption by employees while in the workplace. Any drug in solid form used for direct administration to the patient (i.e., tablets or pills). (Exceptions- Liquid, aerosol, or intravenous medications are not exempt from coverage under the provisions of the standard.) Wood or wood products. (Exceptions- Wood dust, wood or wood products treated with a hazardous chemical covered by this standard, and wood which may be subsequently sawed or cut, generating dust, are not exempted.) SAFETY DATA SHEETS (SDSs) SDSs shall be available to the employees for all hazardous chemicals to which there is potential or actual exposure. Each individual facility's supervisor is responsible for ensuring that SDSs are available for all hazardous chemicals. A product can not be used until a complete SDS is on file. SDSs may be in paper format or saved electronically (bookmarked on a computer, saved on a USB, etc.), as long as every employee can readily access the media at all times. If the latter is not feasible, then all SDSs must be maintained in a file or binder in a clearly identified location. UIC offers the MSDSonline.com service to help departments keep track of inventory and also maintain HazCom compliance. Ensure all SDS are entered into your MSDSonline.com Page 7

e-binder. If you have trouble accessing your e-binder please contact EHSO via labsafety@uic.edu or clopez21@uic.edu. If an SDS is not included in a chemical shipment/purchase, contact or go to the manufacturer's website or login to your MSDSonline.com account to search for the appropriate SDS. Recordkeeping All SDSs shall be kept for 30 years after the use of the substance has been discontinued. When a substance is no longer actively used or purchased, its SDS shall be removed from the active file and placed in a file for inactive substances. These shall be maintained for 30 years. If an employee exposure to a particular hazardous chemical occurs, a copy of the SDS for that product shall become part of the employee's medical records. Medical records must be kept for 30 years after employment termination. Exposure means that an employee is subjected to a toxic substance or harmful physical agent in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.), and includes past exposure. Occupational exposures do not include situations where the employer can demonstrate that the toxic substance or harmful physical agent is not used, handled, stored, generated, or present in the workplace in any manner different from typical non-occupational situations. CONTAINER LABELING & HAZARD IDENTIFICATION LABELS Container Labeling No hazardous chemicals shall be accepted for use at the University, unless labeled with the following information, at a minimum: Page 8

1. Identity of the substance, in legible English print. 2. Appropriate signal word (Danger or Warning). 3. Hazard statements 4. Precautionary Statements to minimize exposure 5. Supplier info including name, address and a contact number 6. Pictograms to communicate the hazards Example: Chemical containers must have its original manufacturer's label intact. If the label becomes illegible, falls off, or the content of the container has been modified, the facility's supervisor or assigned user is responsible for preparing an appropriate label with the name of the chemical and the appropriate hazard warnings immediately. Secondary Container Labeling Page 9

When a chemical is transferred from its original container to another container (the secondary container), it must be labeled with either a copy of the original label or with an appropriate hazard label. Also, if a chemical has been modified or if the container is being reused for another substance (the container must be compatible with the new substance and properly cleaned), then the original label must be removed or fully defaced, and a new label must be attached. An appropriate secondary container label must have 1) the chemical name and 2) the appropriate hazard warning(s)/precaution(s). UIC has adopted the GHS (Globally Harmonized System), a universal labeling system employing pictograms. The following is an example of the label to be used on campus and blank labels are available for duplicating via: http://www.uic.edu/depts/envh/hss/labsafetylabels.html : Example of a Properly Completed Label Flammable Chemical Name: Lacquer Thinner Date Received: 2/8/10 Date Opened: 2/24/10 Hazard Identification Labels The hazards associated with chemicals must be properly identified on the outside of chemical storage areas (e.g., cabinets) and outside the facility's means of egress (i.e. outside the door). UIC has recently adopted the Globally Harmonized System (GHS) for the classification and labeling of chemicals. The following hazard symbols are acceptable hazard class labels (which represent the most common hazards, but are not limited to), and are available for duplicating via http://www.uic.edu/depts/envh/hss/labsafetylabels.html or custom labels may be Page 10

purchased at numerous safety supply vendors (e.g., Lab Safety Supply- www.labsafety.com, or Grainger- www.grainger.com). Signal Words Signal words tell you how severe a hazard is. A key part of the GHS is that labels and SDS will consistently use the same three signal words: Danger, Warning, and Caution. Based on the severity and imminent impact of a potential hazard, the American National Standards Institute (ANSI) established signal words to be associated with the following hazards to be printed on hazardous chemical label: Page 11

DANGER! (most severe and immediate hazards) Extremely flammable liquid Flammable gas Pyrophoric solid Oxidizer Corrosive Highly toxic (poison) by inhalation, absorption, or ingestion Sensitizer to lungs WARNING! (moderate severity) Flammable liquid or solid Irritant (severe respiratory, skin, or eye) Toxic by inhalation, absorption, or ingestion Sensitizer (skin) Combustible liquid Irritant, (moderate respiratory, skin, or eye) Irritant, defatting skin Potential suffocation Harmful by absorption or ingestion Note- Colors may be used with or without the safety alert symbol to represent each signal word, but are not mandatory: HAZARD ASSESSMENT & PERSONAL PROTECTIVE EQUIPMENT SELECTION Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, and protective shields and barriers, shall be provided (by the user's department, at no cost to the employee). PPE must be used, and maintained in a sanitary and reliable condition wherever needed to prevent exposure to environmental hazards, chemical hazards, radiological hazards, or mechanical irritants.. Page 12

UIC departments and facilities with assistance from the EHSO shall assess the workplace to determine if hazards are present, or likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or are likely to be present, the department/facility with assistance from the EHSO shall: 1. Select and have each affected employee use PPE that will protect the affected employee from the hazards identified in the hazard assessment. 2. Communicate the PPE selection decisions to each affected employee. 3. Select PPE that properly fits each affected employee. The department/facility with assistance from EHSO shall verify that the required workplace hazard assessment has been performed through a general hazard assessment that identifies: 1. The workplace evaluated. 2. The person certifying that the evaluation has been performed. 3. The date(s) of the hazard assessment. 4. All potential hazards observed with recommendation(s) for health and safety precautions. The department/facility with assistance from EHSO shall provide training to each employee who is required by this section to use PPE on: 1. When and what PPE is necessary. 2. How to properly don, doff, adjust, and wear PPE. Page 13

3. The limitations of the PPE. 4. The proper care, maintenance, useful life, and disposal of the PPE. Each affected employee shall demonstrate an understanding of the training specified above, as well as the ability to use PPE properly, before being allowed to perform work requiring the use of PPE. Retraining of employees shall be performed when there is reason to believe that any affected employee who has already been trained does not have the understanding and skills required above. Retraining is required, but not limited to, situations where: 1. Changes in the workplace cause the previous training to be void/inapplicable. 2. Changes in the type(s) of PPE to be used cause the previous training to void/inapplicable. 3. Inadequacies in an affected employee s knowledge or use of assigned PPE indicated that the employee has not retained the necessary understanding or skill. If the employees provide their own protective equipment, the department/facility with assistance from EHSO shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment. Defective or damaged PPE shall not be used. Note- Please refer to the Respiratory Protection Policy on the EHSO website (http://www.uic.edu/depts/envh/hss/documents/uic%20respirator%20program.pdf ) for special requirements in regards to the potential need for respiratory protection. Page 14

EMPLOYEE TRAINING Prior to starting work with hazardous chemicals, each new or existing employee shall either initially attend a live Hazard Communication Training Session or complete online HazCom Training located on the EHSO website, where they shall receive information on the following topics: 1. Overview of Hazard Communication regulations, including employees' right under the HazCom standard. 2. Physical and health hazards of hazardous chemicals. 3. Chemical labeling and hazard identification requirements. 4. How to read warning labels and identify the presence or release of hazardous materials. 5. Emergency procedures for spills/accidents, including fire hazards, first aid, cleanup, and disposal. 6. Location and availability of this Hazard Communication Program, including hazardous material inventories and SDSs. 7. How to read an SDS and use it to identify (at a minimum): a. Physical and Health Hazards b. First Aid Procedures c. Protective Measures d. Storage and Handling Procedures 8. Chemical exposure controls and prevention. Page 15

Upon completion of the training program, each employee shall sign a form documenting that he/she has received the training (if in-person) or complete and pass the online certification program. Workers trained under the Hazard Communication Program are required by the Illinois Department of Labor (IDOL) to receive annual refresher training. The annual refresher training will be provided by the facility supervisor on site-specific precautions with hazardous chemicals. RESPONSIBILITIES EHSO Shall: 1. Establish, maintain, and annually update the written UIC Hazard Communication Program. 2. Conduct annual safety inspections of all UIC facilities under HazCom provisions, and provide ongoing health and safety guidance. 3. Maintain a central electronic library (database) for all University SDS. 4. Develop and maintain the University s hazardous chemical master inventory. 5. Conduct hazard assessments, and PPE assessments as needed for facilities that fall under HazCom provisions. 6. Provide initial, general HazCom training to applicable employees. Facility Supervisors Shall: Page 16

1. Identify the hazardous materials normally associated with jobs under their supervision and make sure their employees receive the appropriate Hazard Communication training before they begin any work assignment involving hazardous materials. 2. Notify EHSO regarding the use of new hazardous materials or new uses for existing hazardous materials. 3. Contact EHSO for assistance with site specific hazard assessments and PPE assessments. 4. Ensure personnel use the protective measures prescribed by SDSs and local operating instruction when working with hazardous materials. 5. Ensure personnel use, transport, and store hazardous materials in a safe manner. 6. Ensure hazardous material containers are labeled properly (including portable containers) and hazard placards are posted outside the area s entrance. 7. Ensure current SDSs are available and accessible for the hazardous materials used. Ensure all SDS are entered into your MSDSonline.com e-binder. If you have trouble accessing your e-binder please contact EHSO via labsafety@uic.edu or clopez21@uic.edu. Employees Shall: 1. Familiarize themselves with hazard warnings, hazard labels, and SDSs so they can use this information where needed. Page 17

2. Follow the protective measures prescribed by SDSs and local operating manual instructions when working with hazardous materials. PROGRAM EVALUATION EHSO shall maintain, evaluate, and revise the UIC Hazard Communication Program at least annually to ensure its effectiveness. Page 18

APPENDIX A Page 19

APPENDIX B Page 20