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Hazard Communication (OSHA Regulation 29 CFR 1910.1200)

Chemical Safety

Meharry Medical College (MMC) has developed a written Hazard Communication Policy (HAZCOM) [link to procedure pending] to reduce the risk of injury and illness due to exposures to chemical based products during the course of work activities. This policy provides information to assist staff in identifying and evaluating hazardous chemicals in their workplace. Training requirements for all staff required to use chemical containing products are also outlined.

The HAZCOM program provides an overview of the requirements of the HAZCOM program.

Each Department is responsible for providing site specific training to include information specific to their workplace for the hazards associated with the chemicals they work with. The EHS department can assist with specific chemical safety training per request.

The specific information required to be provided includes:

• A written inventory of the hazardous chemicals known to be present in the workplace
• The name and contact information of the designated responsible party for that department.
• The location and access information for the Safety Data Sheets (SDS) for each chemical containing product.
• The location of the department’s hazard communication training records.
• Emergency response procedures.

Labels:

• All containers of hazardous chemicals used in the workplace must be labeled.
• The labels must be in English but warnings in foreign languages may be included to assist non-English speaking staff.
• Labels must include the identity of the hazardous chemical as well as the signal word, hazard statement, pictogram(s) and precautionary statement(s) related to the product.
• Secondary containers into which hazardous chemicals are transferred from labeled containers and which are intended for the immediate use of the employee who performs the transfer are exempt from the labeling requirements. Once the container is left unattended, it must be properly labeled.

Safety Data Sheets:

• The Safety Data Sheet (SDS) provides relevant safety information and warnings applicable to hazardous chemicals.
• The SDS must be readily available to all staff during their work shift via paper copy. Electronic access and other alternatives to maintaining paper copies of the SDS are permitted as long as no barriers to immediate access in each workplace are created by such options.
• It is the responsibility of the designated hazard communication contact person or supervisor in each department to make sure the most recent SDS is present for review by staff.
• Manufacturers are expected to provide the SDS for their products. The SDS is typically also available on the product manufacturer/distributor web site. Meharry has an ELECTRONIC SDS DATABASE that can be used to help manage and maintain updated SDSs. Contact EHS for assistance. [provide link to electronic database]
• Where employees must travel between workplaces during a shift, the safety data sheets may be kept at the primary workplace location. In this situation, staff in the field must be able to immediately obtain the required information in an emergency.

Employee Information and Training

All personnel must be supplied with information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new chemical hazard is introduced into their work area.

The following information must be provided to employees:

• The requirements of the Hazard Communication program.
• Any operations in their work area where hazardous chemicals are present.
• The location and availability of the written Hazard Communication program including the required list of hazardous chemicals and the safety data sheets for their work area.

Employee training must include the following:

• Methods and observations that may be used to detect the presence of a hazardous chemical in the work area.
• The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified of the chemicals in their work area.
• The measures that employees can take to protect themselves from these hazards.
• The details of the hazard communication program including an explanation of the labels received on shipped containers and the workplace labeling system, the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

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