Table of Contents

• Purpose
  
• Definitions
  
• General
  
• Inventory of Hazardous Chemicals
  
• Material Safety Data Sheets (MSDS)
  
• Labels and Other Forms of Warning
  
• Training
  
• Contractors and Other "Outside" Employers
  
• Non-Routine Tasks
  
• Additional Information
  
• References
  

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Purpose

To ensure that Florida State University is in compliance with Hazard Communication Standard in accordance with state and federal regulations.

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Definitions

EH&S: Department within the University's Finance and Administration Division that is responsible for the administration of the Hazard Communication Program.

HCS: Hazard Communication Standard (HCS), OSHA, 29 CFR 1910.1200, establishes uniform requirements to make sure that the hazards of all chemicals imported into, produced, or used in U.S. workplaces are evaluated, and that this hazard information is transmitted to affected employees.

HCC: Hazard Communication Coordinator (HCC), coordinator of the facility hazard communication program.

MSDS Material Safety Data Sheet (MSDS), form that is required to be developed for each hazardous chemical by the producer/importer, and must be provided with automatically at the time of the initial shipment. Distributors must also ensure that downstream employers are similarly provided an MSDS. MSDSs contain information concerning the characteristics (physical, chemical, etc.), hazards, health information and other safety related information.

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General

The Hazard Communication Coordinator (FSU Hazardous Materials Manager) is the overall coordinator of the facility program acting as the representative of the President of the University, who has overall responsibility.

In general, each employee of Florida State University shall be apprised of the substance of the HCS, the hazardous properties of chemicals they work with, and measures to take to protect themselves from these chemicals.

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Inventory of Hazardous Chemicals

Inventories of hazardous chemicals shall be maintained in each work area/laboratory where the materials are being used and provided to the Hazard Communication Coordinator. The hazardous chemical inventories should be updated upon receipt of hazardous chemicals in that area. Also, the inventories should be reviewed annually to ensure accuracy.

Upon receipt of new chemicals or extremely hazardous chemicals, an MSDS should be entered into the file for the laboratory/work area. Additionally, the Hazard Communication Coordinator should be notified and an MSDS provided.

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Material Safety Data Sheet (MSDS)

MSDSs should be located in accordance with the following:

Current (materials still in use):

• At a minimum, each work area/laboratory shall have a selection of MSDSs for the more highly dangerous materials in their area, other MSDSs should be available as necessary.
• Each department shall have a centralized location for review of other MSDSs of chemicals used in their department.
• EH&S will maintain a selection of MSDSs for review along with other resources for MSDS collection and review (including Internet and manufacturer information).
• Upon receipt of new duplicate MSDSs, the old MSDS may be discarded if the information is the same on both MSDSs.

Past (materials no longer in use)

• A file maintained with the MSDSs
• Each MSDS shall be dated to indicate the date of last use of the material
• MSDSs maintained for at least 30 years beyond last use date

Each MSDS shall consist of a fully completed OSHA Form 174 or equivalent. The Hazard Communication Coordinator will ensure that all MSDSs that are received are kept in their appropriate locations. All MSDSs will be readily available to all employees.

Each work area/laboratory shall designate an individual to be responsible for acquiring and updating MSDSs for materials in their area. Each MSDS that is received should be reviewed for accuracy and completeness. All new procurements for each area should be reviewed to ensure that the least hazardous material for any use is selected. MSDSs that meet the requirements of the HCS must be fully completed and received at the designated location either prior to or at the time of the first shipment of any potentially hazardous chemical purchased from a vendor. It may be necessary to discontinue procurements from vendors failing to provide an approved MSDS in a timely manner. Updates shall be provided to the HCC.

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Labels and Other Forms of Warning

Each work area/laboratory shall designate an individual to ensure that all hazardous chemicals in the facility are properly labeled. Labels on purchased chemicals shall list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer, or other responsible party. The corresponding MSDS shall be used to verify label information. Immediate use containers, small containers containing materials for use during a contiguous period by a single individual or group, do not require labeling. All other containers require labeling, including chemical name and hazard identification. Some chemicals may require additional information to identify unique characteristics (i.e. Peroxide-forming chemicals need purchase date and open date).

Personnel designated by EH&S should conduct routine inspections to ensure that labeling requirements are being met.

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Training

Each employee who works with or may be potentially exposed to hazardous chemicals shall receive initial training on the HCS and the safe use of those chemicals within 30 days of employment. Additional training should be provided for employees whenever a new hazard is introduced into their work area. Hazardous chemical training will be conducted by EH&S Hazardous Materials Section and the respective laboratory designee.

EH&S provided training will emphasize the following elements:

• A summary of the standard and this written program;
• Discussion of general chemical properties including visual appearance, odor and methods that can be used to detect the presence or release of hazardous chemicals;
• Potential physical and health hazards associated with exposure to workplace chemicals;
• General procedures to protect against hazards, e.g., personnel protective equipment, work practices, and emergency procedures;
• Hazardous chemical spill and leak procedures; and
• Where MSDSs are located, how to understand their content, and how employees may obtain and use the appropriate hazard information.

Work area/laboratory specific training will augment the EH&S training to highlight the specific information and procedures associated with the chemicals and procedures in that area.

Periodic retraining shall be scheduled at least annually for laboratory areas and biennially for other areas on campus.

The Hazard Communication Coordinator will monitor and maintain records of employee training and advise on training needs.

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Contractors and Other "Outside" Employers

The Hazard Communication Coordinator, upon notification from management, will advise outside contractors of any chemical hazards, which may be encountered in the normal course of their work on the premises. Also, the Hazard Communication Coordinator will ensure that all individuals are trained through verification of training records prior to commencement of work.

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Non-Routine Tasks

Supervisors contemplating a non-routine task shall consult with the Hazard Communication Coordinator and shall ensure that employees are informed of chemical hazards associated with the performance of these tasks. Information shall include, but not be limited to, chemical characteristics, potential health hazards, and appropriate protective measures. This will be accomplished by a meeting of supervisors and the Hazard Communication Coordinator with affected employees before such work is begun.

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Additional Information

Further information on this written program, the Hazard Communication Standard, and applicable MSDSs is available through the Department of Environmental Health & Safety.

Regulatory information is available from the State of Florida's Division of Labor and Employment Security.

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References

1. Hazard Communication Standard (HCS), OSHA, 29 CFR 1910.1200
2. Occupational Safety and Health, Florida Administrative Code Chapter 442
3. Occupational Exposure to Hazardous Chemicals in Laboratories, OSHA, 29 CFR 1910.1450

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