LARAMIE COUNTY COMMUNITY COLLEGE PROCEDURE
SUBJECT - Hazardous Materials Communication Program (Right‑To‑Know)
REFERENCE
DATE
NUMBER – 6765
I. Introduction
An increased awareness of hazards associated with workplace chemicals has been reflected in legislation designed to inform and train employees in the use of hazardous materials. The Hazard Communication Standard, and OSHA regulation (29 CFR 1910.1200), places specific responsibilities on employers to inform employees about the hazards of chemicals with which they work. The standard was first issued in 1983 and targeted the manufacturing sector; however, in 1987, it was expanded to coverall employers engaged in the handling and use of hazardous materials. Over the years, it has become known as the "Worker's Right-To-Know" legislation. The Federal OSHA Act provides for states to develop their own occupational safety and health regulations which meet or exceed the federal program. The Wyoming Occupational Health and Safety (WOHS) Rules and Regulations includes the Hazard Communication Standard, as Chapter XXI. Laramie County Community College is mandated to comply with this statute.
II. Purpose
The purpose of the Hazard Communication Program at Laramie County Community College is to ensure that employees are effectively informed about safety and health hazards associated with materials found in the workplace. It also achieves compliance with state and federal regulations. This program provides for:
A. Preparation of a list of hazardous chemicals for each workplace
B. Ready access to material safety data sheets
C. Required labels bearing materials identity and hazardous properties
D. Proper training in recognition of hazards, safe handling and use of chemicals for all employees
III. Scope
A. "Employee" is any person receiving a paycheck from LCCC, whether full or part time. All students employed by LCCC are also referred to as "Employee".
B. The requirements of the Hazard Communication Program apply to chemicals with one or more of the following hazardous properties:
1. Physical Hazards
a. Combustible
b. Flammable
c. Reactive
d. Pressurized (compressed gases)
2. Health Hazards
a. Toxic
b. Carcinogenic
c. Corrosive
d. Irritant
e. Sensitizing
3. A chemical is considered to be carcinogenic if (a) it has been evaluated by the International Agency for Research and Cancer (IARC) and has been found to be a carcinogen or suspect carcinogen; or (b) it is listed as a carcinogen or suspect carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP); or (c) it is regulated by OSHA as a carcinogen.
IV. Inventory
A. LCCC will establish an inventory of all hazardous substances known to be on the premises or in workplaces under its control. The inventory will include all chemicals obtained commercially and those hazardous substances which are produced on site.
B. The inventory will contain the following, at a minimum:
1. department, area name
2. building and room number
3. chemical name
4. chemical abstracts service (CAS) number
5. manufacturer
6. container size
7. hazard classification(s).
C. Each department or area will maintain a copy of the list of chemicals under its control. Major additions or deletions to the inventory, which are not processed through the HazCom office, shall be reported to the HazCom Office and to the Physical Plant Hazardous Waste Control Office by the department or area.
V. Material Safety Data Sheets
A. Suppliers and/or manufacturers are required by state and federal law to supply a material safety data sheet (MSDS) to the user on all "first time" orders or when a revision in a given MSDS is made. The MSDS contains information of specific chemical identity, physical and chemical characteristics, acute and chronic health effects and related health information, exposure limits, safe handling precautions, emergency and first aid procedures, spill clean‑up procedures, and in many cases, disposal procedures.
B. The supervisor, or a person appointed by the supervisor, is responsible for maintaining a workplace MSDS file. A master MSDS file is maintained in the HazCom office and the Physical Plant Hazardous Waste Control Office. Every MSDS received from a source other than the HazCom Office will be copied and sent to the HazCom Office and Physical Plant Hazardous Waste Control Office master files. The location of the MSDS file may be checked in an inspection of the workplace.
VI. Labels
A. All chemical containers are required to bear a label marked with the content identity and appropriate hazard warnings. Labels on containers shall not be removed or defaced. If a label is unintentionally damaged a new label shall be applied marking the contents and hazards.
B. When material is transferred to a secondary container, the new container will be labeled with the contents and hazards (except if the contents will be entirely used during that work shift by the employee transferring the material). All pipes containing hazardous materials shall be labeled.
C. If an empty container is being disposed, the label shall be defaced, removed or marked "empty".
VII. Training
A. Every college employee who works in an area with hazardous chemicals will receive basic training on the Hazard Communication Program at the Right-To-Know Orientation during the first month of employment. The basic training will include a summary of the components of the written Hazard Communication Program. The location of the written program, lists of hazardous chemicals, and the required material safety data sheets will be discussed. Personal obligations in adhering to this program will be covered. This training will be provided by each department or area after consultation with the HazCom Office.
B. All employees who work in areas where there are hazardous chemicals are also to receive formal, documented chemical safety training by their department of area. This training will include, at least, the following information:
1. How the Hazard Communication Program is implemented in the workplace
2. Interpreting information of labels and MSDS's
3. Location and availability of lists of hazardous chemical and MSDS's
4. The hazards of the chemicals in the workplace (mentioning acute and chronic effects)
5. Safe handling procedures
6. Personal protective equipment, if required
7. Methods and observations workers can use to detect the presence of hazardous chemicals to which they may be exposed
8. Spill clean-up
9. Emergency procedures
10. Waste disposal
C. Supervisors will train workers over whom they have authority regarding the specific hazards associated with the performance of individual jobs. Documentation of training shall include an outline of the training, who attended, when the training was held, and the instructor's name. As new hazards are introduced to the workplace, supervisors are responsible for training their employees and documenting the additional training. The original or legible copies of training documentation shall be forwarded to the HazCom Office.
VIII. Outside Contractors
A. Outside contractors must also be informed of the hazardous materials to which their employees may be exposed while performing their work. Work area supervisors are responsible for informing outside contractors/vendors as to the location of hazardous materials and Material Safety Data Sheets. Physical Plant employee have access to a central file of all work area hazardous material inventories and MSDS in order that they can be kept informed.
IX. Responsibilities
A. The Hazard Communication Program will be developed, implemented, updated and supervised by the HazCom Office. The Right-To-Know Orientation will be developed and supervised by the HazCom Office.
B. Department or Area heads and supervisors shall be responsible for assuring that all provisions of LCCC Hazard Communication Program are met within their respective unit. Supervisors shall retain a copy of this policy for their employees. HazCom will assist units in obtaining material, safety data sheets and in conducting training.
C. HazCom Office has the responsibility and authority to inspect department or area compliance with the Hazard Communication Program.
We wish to thank the University of Wyoming's Department of Environmental Health and Safety for its assistance in LCCC program's development.