Hazard Communication Program

The supervisor or designee is responsible for identifying and listing all hazardous chemicals stored, used or generated in their work area. The intent of this inventory is to identify all hazardous and radioactive materials. Hazardous chemicals purchased since the mid-1980s should have hazard warnings on the container label which will aid laboratory personnel in determining what chemicals should be included on the inventory. Materials that are non-hazardous do not have to be placed on the inventory.

List the following materials on chemical inventory:

1. Flammable and Combustible Liquids - Flash Point < 200 deg. F.
2. Compressed gases of any type
3. Flammable solids
4. Air and/or water reactive materials
5. Toxic/poisonous materials
6. Organic Peroxide and other oxidizers
7. Pyrophoric materials
8. Unstable chemicals
9. Radioactive materials
10. Corrosive acids and bases
11. Carcinogens
12. Controlled Substances

Materials that are not required to be listed on chemical inventory:

1. Amino acids
2. Salts
3. Buffer solutions
4. Non-hazardous materials
5. Soaps/surfactants
6. Silica
7. Assay or other testing kits
8. IV fluids and drugs that are neither controlled substances nor hazardous materials

This Chemical Inventory also serves as a list of all materials for which an SDS must be maintained and is the initial step necessary for completion of the rest of the program. Compiling the chemical inventory is not a one-time effort. Like all components of the Hazard Communication plan, the inventory must be updated and maintained as SDSs are updated, chemicals are substituted or no longer used or new chemicals are brought on site. The Chemical Inventory Form (non-mandatory) is provided to assist in completing and maintaining the Chemical Inventory. 

The ECTC Environmental Health and Safety Coordinator (EHSC) is responsible for establishing and monitoring the ECTC SDS program. He/she will ensure that procedures are developed to obtain the necessary SDSs and will review incoming SDSs for new or significant health and safety information. He/she will see that any new information is communicated to affected employees.  A list of all departments in ECTC which implement SDS sheets and the supervisors or designees responsible for obtaining and maintaining SDSs are available on the ECTC website.

The supervisor or designee will ensure that all Safety Data Sheets are available for every hazardous chemical used in the work area and are available to employees on all work shifts and will determine the method used to organize, store, and maintain the SDSs.

Supervisors will also ensure that:

• Current SDSs are maintained and are checked regularly to ensure there is a corresponding and current SDS for each chemical on the Chemical Inventory
• If there are SDSs for chemicals that are not on the Chemical Inventory, the supervisor or designee will determine the reason for the discrepancy (e.g. the chemical is no longer used, chemical overlooked during inventory) and take the necessary corrective action
• An SDS must be provided with the initial shipment of any hazardous substance and with any shipment for which an SDS has been updated
• If an SDS is needed from the supplier, the supervisor or designee will immediately contact the supplier by telephone and request the missing SDS be sent via e-mail, fax or regular mail
• When an SDS is received, review it for changes in health and safety information, notify employees of changes as needed, file and add to Chemical Inventory as appropriate
• Store old SDSs for chemicals that are no longer in use or no longer present in the work area in an archive file, indicating the dates the material was actively used and where the materials were actively used for a period of time not to exceed 30 years.

SDSs can be in any format, as long as all of the required information is included and must be in English. This requirement does not prevent a chemical manufacturer or employer from translating SDSs from English into other languages, in order to assist non-English speaking employees with training, comprehension and hazard recognition.

SDSs must contain the following information:

• Identification
• Hazard(s) identification
• Composition/information on ingredients
• First-aid measures
• Firefighting measures
• Accidental release measures
• Handling and storage
• Exposure control/personal protections
• Physical and chemical properties
• Stability and reactivity
• Toxicological information
• Ecological information
• Disposal considerations
• Transport information
• Regulatory information
• Other information

Employees are not to use any hazardous chemical until an SDS is obtained online and employees have been instructed in the hazards and safe handling methods of the chemical.  

An SDS contains very technical information. Moreover, it is essential that the supervisor understands the significant information about each chemical to ensure employees are provided appropriate information for the safe handling and use to reduce the risk of chemical exposure. The Office of Environment Health and Safety is available to help supervisors understand the information contained on an SDS. 

The ECTC Environmental Health and Safety Coordinator (EHSC) is responsible for the ECTC Hazard Communication Program and will ensure that all program elements are carried out.

All employees receive Hazard Communication training upon hire. Additionally, anyone who works with or is potentially exposed to hazardous chemicals, including non-routine tasks, will receive initial training on the hazard communication standard and this plan before starting work. The supervisor must ensure that all employees, those they supervise, as well as other employees working in the area under their supervision (i.e. employee from another department) are provided with the current hazard information for the chemicals that may be encountered.  The supervisor or the designee will conduct the unit-specific training focusing on the specific chemical hazards that employees may encounter. This training will be provided either before or at the time the employee is assigned to work with a hazardous chemical. Additional training shall be provided for employees whenever a new hazard is introduced into the work area. Unit-specific training will include at a minimum:

• An overview of the OSHA hazard communication standard
• The hazardous chemicals present at his/her work area
• The physical and health risks of the hazardous chemicals
• Symptoms of overexposure
• How to determine the presence or release of hazardous chemicals in the work area
• Explanation of routine and non-routine tasks involving encounters with hazardous materials
• Emergency procedures involving hazardous materials
• How to reduce or prevent exposure to hazardous chemicals through use of control procedures, work practices and personal protective equipment
• Steps the college has taken to reduce or prevent exposure to hazardous chemicals
• Procedures to follow if employees are overexposed to hazardous chemicals
• How to read labels and SDSs to obtain hazard information
• Locations of the SDS files, Chemical Inventories, and written Hazard Communication program

Prior to introducing a new chemical hazard into any section of this college, each employee in that section will be given information and training as outlined above for the new chemical hazard. Please contact the ECTC Environmental Health and Safety Coordinator for support and/or for additional training resources.

Outside contractors are utilized by many ECTC departments for a variety of activities including: construction, renovation, testing and maintenance. There is a reciprocal responsibility between ECTC and the contractor to fulfill the requirements of the Hazard Communication Standard.

The ECTC employee who coordinates/oversees the work of a contractor must advise the contractors of their responsibility to provide appropriate hazard information (SDSs) for all hazardous chemicals brought onto all properties controlled by ECTC.
Additionally, it is the responsibility of the ECTC employee overseeing contracted work to provide the contractor with information about the hazardous substances to which they may be exposed while at an ECTC site, and if applicable, the labeling system in use, protective measures to be taken, safe handling procedures, and the location and availability of SDSs.

It is the responsibility of the ECTC Environmental Health and Safety Coordinator (EHSC) to provide other employers and contractors with information about hazardous chemicals that their employees may be exposed to on a job site and suggested precautions for employees. It is the responsibility of the ECTC Environmental Health and Safety Coordinator (EHSC) to obtain information about hazardous chemicals used by other employers to which employees of this college may be exposed.

Building-Related Hazards

Contractors perform the majority of renovation work in ECTC buildings. However, employees in other units may also need to disturb installed building materials for various purposes, so this information applies universally.

Work activities are sometimes performed by employees in areas where chemicals are transferred through unlabeled pipes. Prior to starting work in these areas, the employee shall contact the ECTC Environmental Health and Safety Coordinator (EHSC) for information regarding:

• The chemical in the pipes
• Potential hazards
• Required safety precautions.