Policy Management 
    
    Mar 29, 2024  
Policy Management
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FAO 9.01pr - Hazard Communication Program :


SUMMARY/SCOPE
Edmonds College is committed to preventing accidents and ensuring the safety and health of its employees. Compliance with all applicable federal and state health and safety rules is required of all employees. Under this program, employees are informed of the requirements of WAC 296-901, the OSHA Hazard Communications Standard, the hazardous properties of chemicals with which they work, safe handling procedures, and appropriate protective measures to prevent exposure or injury.

DESCRIPTION
Identifying Hazardous Chemicals

Exposure to chemical hazards can cause physical harm, such as burns or injury from an explosion or health-related harm such as exposure to a carcinogen.

Each department at Edmonds College maintains an inventory list of hazardous chemicals in their work area and provides Safety Data Sheets (SDS) to the Facilities Department for inclusion in the online database. The inventory list is available from the department supervisor or the Facilities Office and identifies all hazardous chemicals with a potential for employee exposure in the workplace. The inventory list is to be set up for easy cross reference, where the product name on the inventory list, the product label, and the SDS match. Detailed information about the potential physical, health, or other harm that may be caused by exposure to each chemical is included in the SDS for that product.

Labeling and Hazardous Chemical Identification

The labeling system to be used by Edmonds College will follow the requirements in WAC 296-901 to be consistent with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The label on the chemical must convey information about the hazards posed by the chemical through standardized label elements, including symbols, signal words, and hazard statements.

All hazardous chemical containers used at this workplace will have:

  1. The original manufacturer’s label, which must be in compliance with WAC 296-901-14026 and the GHS system, will include:

    a. Product identifier
    b. Signal word
    c. Hazard statement(s)
    d. Pictogram(s)
    e. Precautionary statement(s)
    f.  Name, address, and telephone number of the chemical manufacturer, importer, or another responsible party.
     
  2. Workplace labeling and secondary containers must meet all requirements of the original labeling or include product identifier and words, pictures, symbols, or a combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

Employees and supervisor(s) in each work area will ensure that all containers are appropriately labeled and that no container will be released for use until this information is verified. Workplace labels must be legible and in English.

Small quantities intended for immediate use may be placed in a container without a compliant label, provided that the individual keeps it in their possession at all times and the product is used up during the work shift or properly disposed of at the end of the workday. However, the container should be marked with its contents.

Safety Data Sheet Requirements (previously known as Material Safety Data Sheets)

All employers must maintain in the workplace copies of the required SDS for each hazardous chemical and must ensure that they are readily accessible during each work shift to employees when they are in their work area(s). Electronic access and other alternatives to maintaining paper copies of the SDS are permitted as long as this doesn’t create any barriers to immediate employee access in each workplace. SDS must be available even when power is out in the facility.

The manufacturer or importer of a chemical is required to obtain or develop SDS with specific, detailed information about the chemical’s hazard using the GHS format and the distributor or supplier of the chemical is required to provide this SDS to the purchaser upon request.

College departments and work area supervisors are responsible for ensuring that current SDS for all chemicals in their work area are obtained prior to use and that SDS are readily available to all employees during their work shifts. The product distributor or supplier is required to provide SDS to the purchaser upon request. Supervisors must also provide copies of all SDS to the Facilities Office on receipt, with location and department information for each chemical for inclusion in the online Edmonds College SDS database. Electronic access to SDS database is available here: http://www.edmonds.edu/safety/ehs/

The SDS for each work area are maintained, updated, and managed by each area supervisor, with the electronic database managed by the Facilities Office. If an SDS is not immediately available for a hazardous chemical, employees are not to use that chemical until an SDS and appropriate training is completed.

Employee Information and Training

Employers must provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new chemical hazard that employees have not previously been trained on is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and SDS.

Each department and work area supervisor(s) is responsible to ensure all employees receive WAC 296-901 compliant hazard communications training, ensure all employees understand the program and its requirements, and maintain records of training subject matter, dates, and attendance.  

Employee training must ensure understanding of any operations in their work area where hazardous chemicals are present; and the location and availability of the written Hazard Communication Program, including the required list(s) of hazardous chemicals, and SDS required.

Employee training must, at a minimum, include the following:

  1. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area, such as:

    • Monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.

    • The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;

  2. The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment (PPE) to be used.

  3. The details of the Hazard Communication Program including an explanation of the following:

    • Labels received on shipped containers

    • The workplace labeling system used by their employer

    • The Safety Data Sheet (SDS), including the order of information and how employees can obtain and use the appropriate hazard information.

    • An explanation of any special labeling present in the workplace, to include:

      • What are pictograms?

      • What are the signal words?

      • What are the hazard statements?

      • What are the precautionary statements?

    • Emergency procedures to follow if an employee is exposed to these chemicals.

The Facilities Office has an online resource available for a basic training of the requirements of the Hazard Communication Standard. This does not negate each area supervisor’s responsibility for ensuring complete employee understanding of the hazards and requirements before beginning work in an area that may have exposure risks. Contact the Facilities Office for details.

Below is information to help with training and information sharing. It does not satisfy requirements for worksite-specific training:

  • Review of  WAC 296-901 requirements and the Edmonds College Hazard Communication Program related to chemicals purchased or used in the Horticulture Program.
  • Hazardous Communication Standard - Employee Right to Know video: Right to Know
  • Specifics about GHS, SDS, and labels video: GHS
  • College SDS online database and other information: SDS online database. Environment Health and Safety
  • List of emergency contacts: Emergency Contact list

Prior to introducing a new chemical hazard into any department, each employee in that department will be given information and training as outlined above for the new chemical hazard.

Special Tasks

Before employees perform special (non-routine) tasks that may expose them to hazardous chemicals, their supervisors should inform them about the chemicals’ hazards. Their supervisors should also inform them on how to control exposure and what to do in an emergency. The supervisor will evaluate the hazards of these tasks and provide appropriate controls including PPE and all additional training as required.

Informing Contractors and Other Employers about Chemical Hazards at the College Site(s):

If employees of another employer(s) could be exposed to hazardous chemicals at a college worksite, for example, employees of a construction contractor working on-site, it is the responsibility of the Edmonds College project manager, or purchaser of the service, to provide contractors and their employees with the following information:

  • The identity of the chemicals.
  • How to review the SDS and an explanation of the container labeling system.
  • Safe work practices to prevent exposure.

Purchasers and project managers will also obtain SDS for any hazardous chemical a contractor brings onto the worksite, keeping the original SDS in the area where exposure is possible and will provide a copy to the Facilities Office with specific information about the location(s) where product is in use or could be found, department/area coordinating the work, and the duration that the product will be in use.

Purchasers and project managers will also ensure that all leftover product is promptly removed from the campus when work is complete and that proper disposal is a requirement in the purchasing contract.

Records

Each department that brings hazardous materials or chemicals on campus must maintain records in compliance with all regulations.

  1. Hazardous chemical inventories and SDS must be maintained for 30 years from last use.

  2. Written requests for SDS and labels from distributors shall be retained until the requested information is complete.



RELATED POLICIES AND PROCEDURES
FAO 1.0 Pollution Control Policy

FAO 1.01pr Pollution Control Procedure

FAO 9.0 Hazardous Materials Management Policy

FAO 9.02pr Hazardous Waste Management Procedure

 

SOURCE INFORMATION
(was) 6.5.100 R102 Hazard Communication Program Regulation

WAC 296-901 Globally Harmonized System for Hazard Communication

29 CFR 1910.1200 Hazard Communication

CONTENT OWNER. The primary responsibility for this policy belongs to:
Vice President for Human Resources and Operations

PRIMARY CONTENT CONTRIBUTOR (Director/Dean)
Director of Facilities and Capital Projects

REVIEW PERIOD
Three years.

REVIEW HISTORY
2021-Oct 18  Amended to update content owner and domain name change

2019-Jan 28  Approved by President’s Cabinet

2018-Mar 02  Revised

1996-Oct 21  Adopted

 



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