Hazardous Communication Program

What Every Employer Nees to Know About HazCom and GHS (PDF)
GHS and SDS Training (PowerPoint)

Fort Lewis College is complying with the requirements of OSHA's Hazard Communication Standard by:

  • Identifying hazardous materials
  • compiling a list of hazardous chemicals
  • using Safety Data Sheet’s (SDSs)
  • ensuring that containers are properly labeled, and
  • training our workers.

In addition, we will provide this same information to subcontractors involved in a specific project so that they may provide this information and train their employees. 

This program applies to all work operations on campus and the Hesperus campus where faculty, students and staff may be exposed to hazardous substances under normal working conditions or during an emergency situation.  The Environmental Health & Safety (EH&S) director is the program coordinator and has overall responsibility for the program.  The EH&S department will review and update the program on an annual basis, or more often, as necessary.

Copies of the written program may be obtained from the Environmental Health & Safety office, Education Business Hall, Room 181.  All employees and students can obtain further information on this written program, the hazard communication standard, applicable SDSs, and chemical information lists from the EH&S office. 

Under this program, our employees will be informed of the contents of the Hazard Communication Standard, the hazardous properties of chemicals with which they work, safe handling procedures, and measures to take to protect themselves from these chemicals. Our employees will also be informed of the hazards associated with non-routine tasks, such as the hazards associated with chemicals in unlabeled pipes. 

After reading this program if you find improvements can be made, please contact the EH&S department.  We encourage all suggestions because we are committed to the success of our written hazard communication program. We strive for clear understanding, safe behavior, positive reinforcement and involvement in the program from every level of Fort Lewis College. 

Hazard Evaluation Procedures

Our chemical inventory is a list of hazardous chemicals known to be present on campus.  Anyone who comes into contact with the hazardous chemicals on the list needs to know what those chemicals are and how to protect themselves. That is why it is so important that hazardous chemicals are identified, whether they are found in a container or generated in work operations (for example, welding fumes, dusts, and exhaust fumes). The hazardous chemicals on the list can cover a variety of physical forms including liquids, solids, gases, vapors, fumes, and mists. 

Sometimes hazardous chemicals can be identified using purchase orders.

Identification of others requires an actual inventory of the facility. The EH&S director updates the inventory as necessary and keeps the chemical inventory list, along with any related work practices followed on campus.  The list of chemicals can be found in the Education Business Hall, Room 181 where it is accessible during work hours. 

Fort Lewis College relies on the manufacture or importer to identify the hazardous material present in the products it purchases and uses on campus. 

Safety Data Sheets (SDSs)

The SDSs we use are fact sheets for chemicals which pose a physical or health hazard in the workplace. SDSs provide our employees with specific information about the chemicals they use.  The EH&S director, and department representatives are responsible for obtaining/maintaining the SDSs at our college. The EH&S director will contact the chemical manufacturer or vendor if additional research is necessary. 

The SDSs are kept in paper form by each department that uses hazardous chemicals.  Alternatively, SDSs can be located on the EH&S website and through the JJ Keller website which partners with MSDS On-Line. Employees can obtain access to them by submitting a written request for paper copies or by downloading them.

The procedures followed if the SDS is not received at time of first shipment is for the department ordering the material to follow-up with the supplier, and forward this information to the EH&S department.  No chemicals should be introduced to Fort Lewis College without first evaluating the SDS and ensuring appropriate safeguards are in place.  The EH&S department will assist the departments if the need arises. 

Labels and Other Forms of Warning

Labels will follow the Hazard Communication Standard 2012 and the Global Harmonization Standard for labeling of chemicals which requires the name, address and phone number of the manufacturer, distributor or other responsible party, the product identifier, signal word (Danger or Warning), hazard statement(s), precautionary statements and pictograms. 

With the assistance from the EH&S director the individual departments are responsible for ensuring that all hazardous chemicals in in-plant containers are properly labeled and updated, as necessary.  This same process applies to newly purchased materials.  Each department is responsible for ensuring the proper labeling of any shipped containers.  Employees will refer to the corresponding SDS in verifying label information.

Informational handouts are available to inform employees about the hazard communication standard and about the Hazardous Materials Identification System (HMIS) and the National Fire Protection Association (NFPA) labeling systems used on campus and shipped containers.  Copies are available in the EH&S office. 

If employees transfer chemicals from a labeled container to a portable container that is intended only for their IMMEDIATE use, no labels are required on the portable container.  Labels must be replaced if worn, damaged or missing by the person responsible for maintaining the container.  Departments should inspect containers on an on-going basis.

Training

Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training and any necessary retraining on the Hazard Communication Standard and the safe use of those hazardous chemicals by either department trainers or EH&S.  Exposure means that an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption) and includes potential exposure.   Whenever a new hazard is introduced or an old hazard changes, additional training is required. 

Information and training is a critical part of the hazard communication program.

We train our employees to read and understand the information on labels and

SDSs, to determine how the information can be obtained and used in their own work areas, and to understand the risks of exposure to the chemicals in their work areas as well as the ways to protect themselves both on and off the job. 

Our goal is to ensure employee comprehension and understanding including being aware that they are exposed to hazardous chemicals, knowing how to read and use labels and SDSs, and appropriately following the protective measures we have established.  We ask our employees to ask their immediate supervisor questions with support offered by the EH&S department.  As part of the assessment of the training program, employees will be asked about the training they have received and for their suggestions for improving it.  In this way, we hope to reduce any incidence of chemical source illnesses and injuries. 

Training Content

Training content emphasizes the following elements:

  • Summary of the standard and this written program, including what hazardous       chemicals are present, the labeling system used, and access to SDS information and what it means.
  • Chemical and physical properties of hazardous materials (e.g., flash point, reactivity) and methods that can be used to detect the presence or release of  chemicals (including chemicals in unlabeled pipes).
  • Physical hazards of chemicals (e.g., potential for fire, explosion, etc.).
  • Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
  • Procedures to protect against hazards (e.g., engineering controls; work   practices or methods to assure proper use and handling of chemicals; personal   protective equipment required, and its proper use, and maintenance; and procedures for reporting chemical emergencies). 

The individual departments will train new employees at the time of their initial assignment.  The introduction of new hazards require training specific to the new hazards.  Immediate on-the-spot training will be conducted by supervisory personnel for any employee or student worker who requests additional information or appears to lack understanding of a specific chemical hazard.  Training will be documented and will be kept by EH&S.

Responsibilities

Environmental Health & Safety

  • Ensures that overall program is functioning properly through periodic inspections and review
  • Insures the master chemical inventory list is updated as new SDSs are received and added to the campus inventory. Archive all old or obsolete MSDSs
  • Request additional information from chemical manufacturers or suppliers when needed to support departments or thoroughly review SDSs
  • Provide consultation and training to the campus community

Department Chairs, Directors, or Designates

  • Ensures the program is functioning properly within area(s) of responsibility
  • Ensure chemicals are properly used, stored and labeled
  • Coordinates and communicates HazCom activities with Department personnel
  • Ensures Department inventory and SDS lists are updated when new hazardous materials are received
  • Review SDSs with new or transferred employees and identifies location of the SDSs and chemical inventory list
  • Document training of employees, indicating date, time, location and brief description of the type of training received
  • Ensure only the minimum amount necessary is kept at teaching or work stations
  • Ensures that employees adhere to the above and this program.

Employees

  • Comply with chemical safety requirements of this program
  • Report any problems with storage or use of chemicals
  • Use only those chemicals for which you have been trained
  • Use chemicals only for specific assigned tasks in the proper manner 

Hazards of Non-routine Tasks

When employees are required to perform any non-routine tasks that could potentially expose them to hazardous chemicals, the immediate supervisor will inform their workers of the potential hazards.

Hazards of Unlabeled Pipes

We inform employees of the hazards of chemicals contained in unlabeled pipes in their work areas by having the immediate supervisor identify the hazards, or another knowledgeable individual who is qualified by experience or education.

Multi-Employer Facility

When contractors or any other employers' workers (i.e., painters, electricians, or plumbers) will be working at this workplace, the EH&S director will:

  • Provide the other employer(s) with SDSs for any of our chemicals to which   their employees may be exposed during initial or subsequent project review meetings
  • Relay necessary label and/or emergency precautionary information to the other   employer(s) in the same manner. 

Each contractor bringing chemicals on-site must provide the EH&S director with the appropriate hazard information on these substances, including the SDSs, the labels used and the precautionary measures to be taken in working with these chemicals. 

Additional Information

All employees and students can obtain further information on this written program, the hazard communication standard, applicable MSDSs, and chemical information lists from the EH&S director at the Education Business Hall, Room 181, phone 6926.