4.05   HAZARD COMMUNICATION PROGRAM

The Hazard Communication (HazCom) Standard (29 CFR 1910.1200) was developed by the Occupational Safety and Health Administration (OSHA) for the stated purpose of reducing the occurrence of employee occupational illness and injury due to hazardous chemicals.  OSHA's HazCom Standard is based on a simple concept -- that employees have both a need and a right to know the hazards and identities of the chemicals to which they are exposed when working. When employees have information about the chemicals being used, they can take steps to reduce exposures, substitute less hazardous materials, and establish proper work practices. This program contains requirements for practices designed to protect University faculty, staff, students, volunteers, contractual services employees, visitors and the environment from the hazards of chemicals that may be used during various University-related activities. These efforts will help prevent the occurrence of work-related illnesses and injuries caused by chemicals. 

The HazCom standard's design is straightforward. Chemical manufacturers and importers must evaluate the hazards of the chemicals they produce or import. Using that information, they must then prepare labels for containers and more detailed technical bulletins called material safety data sheets (MSDSs), which must be provided to all purchasers to whom these chemicals/products are shipped.  Employers must establish a written workplace program to communicate the information in the MSDS to their employees.

Basically, UNM’s principal investigators (or persons who possess chemicals) are responsible for developing an inventory of all chemicals in their area, maintaining and keeping labels on containers as they are received, maintaining material safety data sheets in a “readily accessible to employees” format, developing emergency procedures, and providing information and training for employees. 

A.      SCOPE
This program is applicable to all UNM employees, staff, faculty, volunteers, contractors, contractual services employees, students and visitors that may work with or be potentially exposed to any hazardous chemicals during any University-related activities at the Albuquerque Campus.  Operations by the University of New Mexico, not located within Albuquerque, New Mexico (i.e.: branch campuses, research stations, ranches, etc.) shall use the information contained herein as a guide.
B.      DEFINITIONS
Article -  A manufactured item: which is formed to a specific shape or design during manufacture; which has end use functions(s) dependent in whole or in part upon its shape or design during end use; and, which does not release, or otherwise result in exposure to a hazardous substance under normal conditions of use or in a reasonably foreseeable emergency resulting from workplace operations.
Carcinogen -  Any substance or agent capable of causing or producing cancer in mammals, including humans.  A chemical is considered to be a carcinogen if it has been listed as such by the International Agency for Research on Cancer (IARC), by the National Toxicology Program (NTP) (latest edition), or if it is regulated by OSHA as a carcinogen.
Chemical - Any element, chemical compound or mixture of element(s) and/or compound(s).
Combustible Liquid - A liquid having a flash point above 140ºF (60ºC), but below 200ºF (93.3ºC).

Compressed Gas - Any material or mixture that, when enclosed in a container, has an absolute pressure exceeding 40 psi at 21.1°C, or has an absolute pressure greater than 104 psi at 54.4°C, or any flammable material having a vapor pressure greater than 40 psi at 37.8°C.  Compressed gases include liquefied petroleum gas.
Container – Any bag, bottle, box, can, cylinder, drum, or other vessel that contains a chemical.
Corrosive - Acid, base or mixtures having a pH less than or equal to 2 or greater than or equal to 12.5, and materials that burn the skin and cause irreversible tissue damage.  Examples are strong mineral acids (chromic, sulfuric, hydrochloric, or nitric) strong alkalis (potassium hydroxide, sodium hydroxide), rust removers, and acidic or alkaline cleaning fluids.
Cryogenic - Liquefied gases used to provide extremely low temperatures (< –90ºC) for frozen storage and experimentation.  Hazards associated with their use include cold burns, frostbite, high pressure gases, explosions, implosions, toxicity and asphyxiation.
Emergency - Any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment, which may or does result in a release of a hazardous substance into the workplace.

Explosive - Any substance, article, or device which is designed to function by explosion, which is a rapid chemical reaction with the production of noise, heat, and violent expansion of gases.

Flammable Gas - Any material which is a gas at 20 ºC or less and 14.7 psi of pressure which is ignitable at 14.7 psi, when in mixture of 13% or less by volume with air or has a flammable range of at least 12%, regardless of the lower limit. Butane and acetylene are examples of flammable gases.
Flammable Liquid - Liquid with a flashpoint of not more than 140°F (60°C).
Flammable Solid - May cause a fire through friction, absorption of moisture, spontaneous chemical change, ignited readily, and burns so vigorously as to create a serious hazard. Naphthalene, matches, aluminum powder, and magnesium are examples of flammable solids.
Hazardous Chemical - Any solid, semi-solid, liquid, or gaseous chemical which may pose a recognized physical hazard or a health hazard to humans, during normal work functions or during a spill or emergency.  These chemical types would include, but not necessarily be limited to: corrosives (acids, bases); paints; petroleum products; poisons; oxidizers, reactives; solvents; etc.
Health Hazard - Any chemical that may cause various acute or chronic health effects in exposed employees, such that they may be classified as carcinogens, reproductive toxins, sensitizers, hepatotoxins, mutagens, teratogens, nephrotoxins, neurotoxins, etc..
Highly Toxic - A substance having an Oral LD50 (Lethal Dose, 50%) in rats of <50 mg/kg; Skin contact LD50 in rabbits of <200 mg/kg; Inhalation LC50 (Lethal Concentration, 50%) in rats of <200 ppm for 1 hour; Inhalation LC50 in rats of <2,000 mg/m3 for 1 hour.
Irritant: A chemical/material that causes a reversible inflammatory effect on living tissue, and may cause soreness, redness or discomfort.
Material Safety Data Sheet (MSDS) - Written or printed material prepared by the manufacturer of a hazardous chemical that contains information about the hazards of the chemical and the appropriate work practices required for use.
Mutagen - A substance or agent capable of altering the genetic material (chromosomes or genes) in a living cell.
Organic Peroxide - Any organic compound containing the bivalent oxygen-oxygen structure (O=O), and which may be considered a structural derivative of hydrogen peroxide, where one or more of the hydrogen atoms have been replaced by organic radicals.
Oxidizing Gases - A gas which may, generally by providing oxygen, cause or contribute to the accelerated combustion of other materials.
Oxidizer - Any compound that spontaneously evolves oxygen at room temperature causes an oxidation reaction, initiates or promotes combustion, thereby causing fire. The term may include such chemicals as peroxides, chlorates, perchlorates, nitrates, and permanganates.
Physical Hazard - Any hazardous chemical with physical characteristics that make it combustible, explosive, unstable, pyrophoric, flammable, water-reactive, a compressed or cryogenic gas, an organic peroxide or an oxidizer.
Pyrophoric - Any liquid or solid that will ignite spontaneously in air at about or below 140ºF (54.4 ºC).
Sensitizer - A chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical.
Teratogen - A substance or agent, exposure to which will result in the development of malformations in the fetus of a pregnant female.
Toxic - A substance having an oral LD50 in rats of 50-500 mg/kg; Skin contact LD50 of 200 mg/kg – 1 g/kg; Inhalation LC50 rats 200 ppm – 2 ppb for 1 hour; Inhalation LC50 rats of 2,000 g/m3 – 20 g/m3 for 1 hour.
Unstable Reactive - A material, other than an explosive, which in the pure state or as commercially produced, will vigorously polymerize, decompose, condense, or become self-reactive and undergo other violent chemical changes, including explosion, when exposed to heat, friction or shock, or in the absence of an inhibitor, or in the presence of contaminants or in contact with incompatible material.
Water Reactive - A material, upon exposure to water or moisture, that explodes; violently reacts; produces flammable, toxic or other hazardous gases; or evolves enough heat to cause self-ignition or ignition of nearby combustible materials.

C.        RESPONSIBILITIES

1.         Safety and Risk Services (SRS) responsibilities include, but are not limited to:

• developing, maintaining and implementing a University-wide program;
• monitoring compliance with the OSHA Standard;
• working with organizational units to assure that adequate engineering controls are installed;
• providing respirator training and fit testing; and
• providing training for supervisors and chemical safety officers.

2.         Principal Investigators, Directors, Area Managers, and/or Supervisors responsibilities include, but are not limited to:

• printing as copy of this program and allowing all personnel to have access to it;
• ensuring employee compliance with all the procedures outlined in this program;
• ensuring that employees with potential for exposure to hazardous chemicals receive appropriate training and Personal Protective Equipment (PPE) before working with those chemicals;
• identifying, listing and maintaining a current inventory of all chemicals in use or stored in their areas;
• obtaining MSDS for each hazardous chemical from the manufacturer;
• ensuring that MSDS copies are readily available to employees;
• ensuring that chemical containers are labeled properly;
• providing training in the hazards of non-routine tasks (periodic maintenance, cleaning up spills, special shop clean-ups, emptying holding tanks, confined space entry, cleaning of reactor vessels, etc.);
• ensuring that an on-site contractor is provided with the description of hazardous chemicals to which the contractor’s employees may be exposed;
•  making employees aware of potential hazards from unlabeled pipes originating outside the work area that pass through the work area; and
• providing area-specific OSHA Hazard Communication Standard training.

3.         Employees responsibilities include, but are not limited to:

• knowing how to access a copy of this program, and following all procedures outlined in the program;
• ensuring that labels on containers of chemicals are not removed or defaced, and report any unlabeled hazardous material/chemical container;
• being familiar with the contents of the MSDS for the chemicals in their work area;
• promptly reporting hazardous conditions and work related injuries or exposures to their supervisors; and
• wearing/utilizing Personal Protective Equipment when recommended.

D.        HAZARD DETERMINATION

The University will rely on the hazard evaluation performed by the manufacturer or importer of the chemical as provided on the MSDS’s and labels, as the official hazard assessment for commercially acquired chemicals.  UNM employees who develop new chemical mixtures must perform a hazard evaluation as outlined in Appendices A and B of the OSHA HazCom Standard (see Attachment A).  The hazard evaluation and procedures used in this process must be submitted to SRS (attention: Chemical Hygiene Manager).   MSDS and labeling requirements apply to hazardous substances synthesized at UNM and sent offsite. Industrial Hygiene monitoring/surveys will identify and evaluate chemical hazards for specific work areas and/or processes and operations.  Specific requirements for their control shall be required based on the results of the surveys.  Frequency of monitoring shall be as specified in the relevant OSHA regulations.

E.        LABELING

Manufacturer’s label is usually appropriate, and need not be supplemented with additional information.  Otherwise, every container of hazardous material/chemicals delivered to, used at or shipped from UNM must be labeled with the following information:

• Name of the chemical, as it appears on the MSDS;
• Original labels shall have the name and address of the manufacturer;
• An appropriate hazard warnings such as hazard class, i.e., physical hazards, health hazards, target organ and effects, etc.; and
• CAS number, if available or applicable.

The labels must be maintained in a readable condition.  Manufacturer labels must not be defaced or removed unless the container is immediately relabeled with all the required information.  Any container without a label should be reported to the supervisor immediately.  Containers into which waste are being accumulated, must be labeled “Hazardous Waste” and specify the chemical content (see SRS Manual Section 4.07 Hazardous Chemical Waste Program”).

If chemicals are transferred out of the original container, the secondary container must be labeled with the information listed above.  “Homemade” labels may be used for the “end use” containers, if the chemical’s identity and hazard class information is known.  Labels are not required by OSHA on secondary containers intended for the immediate use of the employee who performs the transfer, if the container is soon emptied or does not leave the possession of that employee.   However, SRS recommends that these materials and other non-hazardous substances (e.g. distilled water) should be labeled in order to avoid confusion.  Chemicals must never be placed into a food container or an inappropriately labeled container.

Work area supervisors are responsible for ensuring that all chemical containers are appropriately labeled, and that all pipes must be labeled in accordance with UNM's policy (refer to Attachment C). 

F.         CHEMICAL INVENTORY LIST

The OSHA HazCom standard requires that a list of all hazardous chemicals in the workplace be compiled and maintained, and this inventory shall be readily accessible to employees.  The best way to prepare a comprehensive list, if one has not already been compiled, is to survey the workplace. The list will eventually serve as an inventory of every chemical/material for which an MSDS must be received and maintained on file.  
A completed copy of this inventory (see example of an inventory form in Attachment B) should be placed in the HazCom compliance ring binder with the corresponding MSDSs.  All Departments must maintain a current inventory list of all chemicals used in each work area.  This list is to be updated whenever a new chemical is ordered or chemical use is discontinued.  Chemicals on the inventory are to be identified by the name that appears on the label and the MSDS for that substance/container (and if available, the CAS number).

G.        MATERIAL SAFETY DATA  SHEETS

Under the OSHA HazCom standard, the role of the MSDS is to provide detailed information to employees about each hazardous chemical, including its potential adverse physical and health hazards, its physical and chemical characteristics, recommendations for appropriate protective clothing/equipment, OSHA PEL’s, fire hazards, spill cleanup measures, among many other valuable types of information.  There is no specific format for the MSDS under OSHA HazCom, although there are specific information requirements. OSHA had first developed a non-mandatory format, OSHA Form 174, but now recommends that the ANSI format be used. The MSDS must be in English.  The MSDSs are considered exposure records by OSHA and must be kept for 30 years after an individual leaves the work setting.
Chemical manufacturers, importers, and distributors of hazardous chemicals are all required to develop/obtain and provide the appropriate material safety data sheets to the purchasers to whom they ship chemicals.  It is the responsibility of each principal investigator or other person responsible for any specific workplace to obtain and maintain a MSDS for every chemical/material onsite or newly purchased chemical.  Once a complete list/inventory has been compiled, of the potentially hazardous chemicals in your area, check your files against the inventory you have just compiled. If any are missing a MSDS, contact the manufacturer or your supplier, and request one.  OSHA requires manufacturers to send MSDSs within 30 days of a written or telephoned request.  Most manufacturers have web sites, which allow customers to retrieve or print a MSDS.  MSDSs must be readily accessible to employees and students when they are in the area where the chemicals are used or stored.  As long as employees/students can get the information when they need it, any approach may be used.  Laboratories with large numbers of chemicals may computerize the information and provide access through terminals.  However, SRS recommends that a hard copy of all MSDSs be kept in a ring binder with all the other OSHA HazCom documentation.  As new chemicals are purchased, the inventory and MSDSs should be updated on a monthly basis.
What is the minimum amount of material that requires an MSDS?
The OSHA HazCom standard does not specify a minimum amount.  An early OSHA interpretation once indicated that 2 ounces of ammonia requires an MSDS because this amount would cause injury, but recently another interpretation required disclosure of all chemicals which may pose a health risk regardless of the concentration present in the product.  Therefore, it would be prudent to request, acquire and maintain a copy of every MSDS provided for any product that may be purchased, for which there is not an exemption.  
What items may be exempted from the MSDS requirement?
Exempted are the personal use of articles, food, food additives, alcoholic beverages, cosmetics, drugs and pharmaceuticals, hazardous wastes, tobacco and tobacco products, wood and lumber, office and school supplies, ionizing and non-ionizing radiation, and consumer products.   Retail outlets and stores are under no OSHA obligation to distribute MSDSs for these exempted products/materials to consumers.  However, use of these “exempted” materials in such quantities as would cause occupational exposure in an employment setting would trigger the requirement for the procurement of the MSDSs by employers, and the MSDS would then need to be readily accessible to employees.

H.        REDUCING EMPLOYEE EXPOSURE TO CHEMICALS

1.         Substitution

When possible, substitution of a less hazardous chemical or process can be used to reduce or eliminate chemical exposures.

2.         Engineering Controls

When possible, chemical fume hoods and/or local exhaust ventilation can be used to reduce employee chemical exposures.  Local exhaust ventilation is used to capture and exhaust chemical vapors, preventing the accumulation of high exposures in the employee's breathing zone.

3.         Administrative Controls

If engineering controls cannot be implemented, alteration of work practices can be used to reduce chemical exposures.  This could include limiting the amount of time employees spend working in high exposure areas by rotating personnel.

4.         Personal Protective Equipment (PPE)

Contact with the eyes or skin with chemicals will be prevented by the use of protective garments and equipment which are impervious to the chemicals used.  The type of Personal Protective Equipment necessary will vary depending on the concentration, amount used and the potential for splashing.  It may include goggles, face shield, gloves, gowns, lab coats, aprons and arm sleeves.  SRS can provide your area with advice/guidance on the appropriate PPE.

Respirators.  If employee chemical exposures are found to exceed the OSHA Permissible Exposure Limits, respirators will be provided until feasible engineering or administrative controls can be implemented.  Respirator use and type will be determined by SRS, based on air monitoring results.  If respirator use is necessary, employees must be medically cleared by Employee Occupational Health Services (EOHS) to wear a respirator, and fit-tested and trained by SRS before using a respirator.

All Personal Protective Equipment must be inspected by employees prior to each use.  Personal Protective Equipment must be stored in a clean and sanitary manner.  Respirators should be inspected by supervisors each month to ensure they are being used, stored and cleaned properly.

5.         Hygiene

To prevent the accidental ingestion of chemicals, eating, drinking and smoking are prohibited in areas where chemicals are used.  In addition, employees must wash their hands after using chemicals and immediately prior to exiting the laboratory.

6.         Emergency Eyewash and Shower

If there is a possibility that employees skin or eyes may be splashed by chemicals, an emergency shower/drench hose and plumbed emergency eyewash should be provided in the work area.  Employees must be instructed on the proper use of the eyewash and emergency showers.  If employees’ eyes or skin are splashed, the employee must flush them immediately and continue for 15 minutes.  Employees should then seek medical attention.

I.          EMPLOYEE INFORMATION AND TRAINING

Every UNM employee will receive a basic orientation to the Hazard Communication Program, which will be provided by a chemical safety officer or a supervisor.  It will include the following:

• requirements of the OSHA Hazard Communication Standard;
• explanation of UNM's Hazard Communication Program, including labeling system, MSDSs and how employees can obtain hazard information;
• description of the various methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area;
• general guidance on the selection of protective measures to reduce chemical exposure;
• information on safety resources; and
• emergency procedures to be used in the event of accidental exposure to hazardous chemicals, including emergency phone numbers.

In addition to the general Hazard Communication training, employees must be provided with area-specific on-the-job training.  This training is to be conducted by the supervisor and will inform employees of the following:

• the location of UNM's written Hazard Communication Program, the chemical inventory list and MSDSs for their work area;
• the specific physical and health hazards present in their work area;
• the operations in their work area where hazardous chemicals are used;
• the specific protective measures required when using the chemicals in their work area, including the procedures that have been implemented to protect them from exposure to hazardous chemicals;
• the specific methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area; and
• the location of eye washes and safety showers, to be used in the event of a chemical exposure.

The general hazard communication training will be conducted at the time of the employees initial assignment.  Area specific training will be conducted whenever a new hazard is introduced into the work area, when the employee transfers to another job and whenever the employee demonstrates behavior that indicates a lack of understanding of the safe handling of chemicals.

Supervisors are responsible for ensuring that employees with potential exposure to hazardous chemicals receive the appropriate training before working with those chemicals.  To ensure that supervisors are knowledgeable of their training responsibilities, SRS will conduct train-the-trainer courses and provide training templates for all supervisors.

Non-Routine Tasks.  Supervisors must provide employees with the hazard information for non-routine tasks before the tasks are attempted.  This includes reviewing the MSDSs and explaining the appropriate work practices to be followed.

All training must be documented by the individual presenting the training session, and kept on file in event of an OSHA inspection.

J.         INFORMING CONTRACTORS

If chemicals are to be used by UNM personnel in the same area that contractor employees are assigned, the Principal Investigator and the UNM Project Manager have the responsibility of informing the contractor employees of the potential hazards in the work area of, including but not limited to, the following:

• the hazardous chemicals to which they may be exposed while working in the area;
• precautionary measures the contractor employees should take to lessen the risk of exposure and the steps UNM has taken to lessen the risks;
• the location of MSDSs for the products used by UNM personnel;
• UNM's written Hazard Communication program; and
• UNM's chemical labeling system.

Upon request, the contractor is to provide SRS with a list of the hazardous chemicals and MSDSs for those chemicals that they are bringing onto UNM property.  The contractor may also be asked for a copy of their Hazard Communication Program and training documentation.  Outside contractors must inform UNM of any hazardous chemicals used in the performance of their operations/duties at UNM, provide MSDSs if requested,  and inform UNM employees of the availability of these copies.