hazard communication global harmonization system …€¦ · 19/10/2015 · compliance with the...

HAZARD COMMUNICATION GLOBAL

HARMONIZATION SYSTEM (GHS)

PROGRAM

1910.1200

J. Sargeant Reynolds Community College Safety Office

October 19, 2015

JSRCC Hazard Communication Global Harmonization System Program

Wednesday, March 30, 2016

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Contents RECORD OF CHANGES ...................................................................................................................... 3

Table 1 Record of Changes .................................................................................................................. 3

I. INTRODUCTION ............................................................................................................................ 4

II. DEFINITION OF HAZARDOUS MATERIALS / CHEMICALS ........................................................... 4

III. HAZARDOUS MATERIAL INVENTORY LIST ................................................................................. 4

IV. SAFETY DATA SHEETS (SDS) ...................................................................................................... 5

V. PROCUREMENT OF HAZARDOUS MATERIALS ........................................................................... 7

VI. LABELS AND OTHER FORMS OF WARNING ............................................................................... 8

VII. HAZARDOUS WASTE DISPOSAL ................................................................................................. 8

VIII. EMPLOYEE INFORMATION AND TRAINING .............................................................................. 9

IX. EMERGENCY PROCEDURES ..................................................................................................... 12

X. HAZARDOUS NON-ROUTINE TASKS .......................................................................................... 12

XI. UNLABELED PIPES ...................................................................................................................... 13

XII. ON-SITE CONTRACTORS........................................................................................................... 13

XIII. PROGRAM REVIEW ................................................................................................................... 14

Appendix A CHEMICAL INVENTORY ........................................................................................... 15

Appendix B NON-ROUTINE TASK ................................................................................................ 16



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RECORD OF CHANGES

Submit recommended changes to this document to Reynolds Community College’s Chief of Police, Continuity

Coordinator.

Table 1 Record of Changes

Change

Number

Section

and/or Page

Number

Description of Change Date of

Change Posted By



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I. INTRODUCTION

The Occupational Safety and Health Administration (OSHA) Hazard Communication Standard was

promulgated to ensure that all chemicals purchased, used, and destroyed by an employer would be

evaluated and that information regarding the hazards would be communicated to employees. The goal

of the standard is to reduce the number of chemically related occupational illnesses and injuries. In

compliance with the Hazard Communication Standard ("Right-to-Know") (29 CFR 1910.1200), the

Hazard Communication Global Harmonization System Program (HCGHSP) applies to J. Sargeant

Reynolds Community College (college) faculty, staff, and students who may work with or be in proximity

to hazardous chemicals or chemical products. This program also applies to contractors that perform

work at any college facility. Questions concerning the Hazard Communication Global Harmonization

System Program (HCGHSP) are to be directed to the Safety Manager at 523-5722. In accordance with

J. Sargeant Reynolds policy 4-35 PERSONAL AND ENVIRONMENTAL SAFETY all departments must

notify the Safety Manager immediately of any external or internal Safety Audit requests or visits.

Hazardous chemicals and materials are used interchangeably in this program.

II. DEFINITION OF HAZARDOUS MATERIALS / CHEMICALS

Any substance or mixture of substances which (i) is toxic, (ii) is corrosive, (iii) is an irritant, (iv) is a

strong sensitizer, (v) is flammable or combustible, or (vi) generates pressure through decomposition,

heat or other means, if such substance or mixture of substances may cause substantial personal

injury or illness during or as a result of handling or use (this includes compressed gas cylinders).

III. HAZARDOUS MATERIAL INVENTORY LIST

Each department’s HCGHSP staff person must complete and maintain a list of all known hazardous

material used on college ground. As new hazardous materials are brought into and or remove from the

department this list shall be edited and certified for accuracy by the department’s HCGHSP staff person.



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The department manager/head will reconcile the beginning balances of hazardous material inventory

on August 1 of each academic year. The Safety Manager will perform random inspections and or audits

starting Feb 1 of each academic year and to conclude by July 1 of the academic year to verify

recordkeeping and physical inventory. Each entry on the list must include:

• Chemical name

• Common/trade name

• Manufacturer

• Quantity

The original inventory list will be maintained in the individual department along with the SDS. Each

department’s SDS will be housed on the Safety Committee share point site in assigned folder, until the

recommended VCCS prescribed MSDS ON-LINE system is activated. A copy of the inventory list must

be sent to the Safety Manager. The Safety Manager will ensure that an updated copy of the inventory

list is provided to the Department of Police Dispatch. Discarded or no longer needed MSDS and SDS

must be kept for a period of thirty (30) years.

IV. SAFETY DATA SHEETS (SDS)

The identified Department’s HCGHSP staff person is responsible for compiling and maintaining a

complete record of all the inventory list and Safety Data Sheets (SDSs) associated with any

hazardous materials received and used by the college. Department’s HCGHSP staff person must

notify the college Safety Manager of their method of providing access to the SDS. The college’s

students, employees and on-site contractors may access the college’s current SDS(s) for hazardous

materials through the physical and/or electronic copy method:

1) Physical copy (Reynolds approved SDS binder)



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a) Department specific SDS are available at the department where hazardous materials

are used.

Departments should follow the protocol below in maintaining a Reynolds approved SDS binder:

• Binder must be visibly labeled as containing SDS

• Binder must remain “readily available” at all times

• Binder must be restricted or mounted to prevent being taken from the assigned area

• SDS must be filed in a systematic method to allow for quick location of chemical (example:

alphabetically by chemical name)

• All SDS must be in good, readable condition

• Each SDS must be complete, with no missing pages or torn information

• The following areas on the SDS should be highlighted for quick reference in an emergency

situation: chemical name, first aid measures, manufacturer, phone number and release

measures

2) Electronic copy

If the department has selected to provide access to SDS electronically then the following protocol

should be followed:

• The designated computer(s) must be clearly marked for obtaining SDS by the end-user

• The computer(s) must be in close proximity of the chemical’s area of use

• The selected web address must be clearly posted as well as noted as a desktop icon for

quick, easy reference (i.e. Fisher Scientific –www.fishersci.com)

• Directions for obtaining a SDS by computer must be written in step-by step form and

clearly posted on/next to the computer(s)



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• The computer(s) must be connected to a printer (in the same area) allowing for the SDS to

be generated in hard copy if desired

• Reynolds approved SDS binder(s) with the required hard copied SDS(s) will be made

accessible at all times, as a backup

A Reynolds binder must meet the approval of the Safety Manager.

V. PROCUREMENT OF HAZARDOUS MATERIALS

The college’s Purchasing Officer is responsible for ensuring that all purchase orders for chemicals

processed through the Purchasing Department include a statement requiring a Safety Data Sheet

(SDS) from the vendor. Once hazardous material products are purchased, shipped to and received

at the college, if the hazardous material is shipped without the SDS, the Warehouse Supervisor or

other college recipient will not accept shipment of the item. If, the hazardous material is shipped with

the SDS it is the college protocol that the receiver(s) of such products (e.g., Warehouse personnel)

perform the following:

• Review the product’s accompany “Bill of Lading” or Invoice for accuracy

• Inspect, ensure that the products are delivered in a proper and safe manner

• Inspect, ensure that the products are free from damage

• Record a copy of all SDSs, other pertinent documentation on the hazardous material that is

directly shipped to and received at its site

• Submit one (1) copy SDS to the end-user(s) of record

Individuals purchasing an over-the-counter (otc) hazard chemical (product) must immediately obtain

an SDS for the product at the time of purchase and/or prior to use or upload the SDS from the

manufacturer’s web site. The purchaser must update the Departments Hazardous Material Inventory

list once the product is on campus grounds. The hazardous Material Inventory List procedure must be

followed. It is the responsibility of the End Use to ensure that the SDS is received upon delivery from



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the Warehouse personnel. The end user should not accept deliveries by warehouse staff of such

items marked as hazardous material without its SDS.

VI. LABELS AND OTHER FORMS OF WARNING

The OSHA Hazard Communication Standard requires that hazardous chemicals (product) be labeled

by manufacturers. The label must be written in English and contain the following:

• Chemical identity

• Appropriate hazard warnings (e.g. signal words and pictogram)

• Name & address of chemical manufacturer, importer, or other responsible party

Upon delivery of chemicals, the purchaser and/or the receiver will verify that chemicals are labeled

properly. If chemicals are transferred from the manufacturer's containers to secondary containers, the

department manager of each section will ensure that the containers are labeled with the identity of the

chemicals and appropriate hazard warnings. Additionally, the department managers will ensure that

labels will not be removed or defaced and will be replaced if the label is excessively worn or torn.

VII. HAZARDOUS WASTE DISPOSAL

The college Safety Manager monitors various HCGHSP department specific disposal methods to

include but not limited to disposal requisition created in eVA and/or third party vendor relationships.

Prior to initiating any disposal requisition, the department-designated employee is to notify the Safety

Manager via e-mail of their disposal request. Together, the Safety Manger and the department

designated employee will track the disposal of hazardous waste by way of the college’s Hazard

Waste Manifest Information System (HWMIS). HWMIS is a procedure in which hazardous materials

are identified and tracked as part of the disposal process using a series of permanent, linkable,

descriptive documents (e.g. manifests), commonly referred to as the cradle-to-grave management



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system. All HWMIS (MSDS/SDS) documents are uploaded and housed on Reynolds Safety

Committee share-point site. The primary HCGHSP participating departments are as follows:

• School of Nursing and Allied Health

o Dental

o Nursing

o Optician

o Emergency Medical Services

o Medical Labs

• School of Mathematics, Science and Engineering

o Biology Labs

o Chemistry

• School of Business

o Automotive

o Culinary

o Diesel

o Horticulture

o Welding

o Offices

• Warehouse

• Facilities Management and Planning

• Police Department

VIII. EMPLOYEE INFORMATION AND TRAINING



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All Reynolds employees are required to receive initial / awareness level hazard communication

training provided by the Safety Manager. All HCGHSP department designated employees are

required to receive additional instruction to perform the following:

• Purchase hazard material in the eVA system this training will be provided by Purchasing

department representative

• Upload SDS documents to Safety committee’s share-point this training will be provided by

the Safety Committee Chair

• Maintain Reynolds approved SDS binder this training will be provided by the Safety

Manager

• Hazard waste inventory and disposal protocol this training will be provided by the Safety

Manager

Employees who may be exposed to hazardous chemicals in the workplace shall receive additional

training on each chemical hazard (not necessarily each chemical). New employees shall be trained

as soon as possible after hiring and before they are assigned to work with hazardous chemicals. All

hazardous material training shall be documented. The appropriate manager, laboratory manager,

supervisor and department head ensure that all required hazard communication training is completed.

Initial training shall include a brief discussion of the OSHA Hazard Communication Standard.

Additional training shall be conducted by managers, laboratory managers, supervisors, and

department heads on specific chemical hazards in each workplace, and when a new hazard (not

necessarily a new chemical) is introduced into the work area. All training will include interpretation of

container labeling, use and interpretation of SDS, methods and observations that may be used to

detect the presence of a hazardous material in the work area. This will include air monitoring,

presence of odor, visual appearance of the material, etc., where to find information on the health and



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physical hazards of the hazardous materials in the work area, protective equipment available to the

employee that will provide protection while working with or around the hazardous material and how to

obtain protective equipment, and who to contact to obtain further information about a specific

hazardous material or work condition. The appropriate manager, laboratory manager, supervisor, or

department head shall maintain documented records of training. Records of training shall include a

copy of the Hazard Communication Policy, a description of materials used (e.g. audio-visuals), and

the date training was completed. All employees completing hazard communication training shall sign

a training roster. Follow up shall be conducted by supervisors to ensure that affected employees

remain aware of the Hazard Communication Standard and its requirements. These employees must

be shown where the Safety Data Sheets are located within their department. Each employee must

have a general familiarity of the hazardous properties of the chemicals in their work area and the

protective measures being implemented.



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IX. EMERGENCY PROCEDURES

In the event that an employee is involved with a chemical spill and/or exposed to a hazardous

chemical/material, the following emergency procedures will be implemented by the employee:

• Report any major spill/exposure to supervisor and the Department of Police

• Evacuate non-essential personnel from the immediate area, if necessary.

• Refer to SDS to take appropriate actions

• Limit exposure to the chemical

• Seek medical attention, if necessary

Safety Manger will provide immediate/emergency assistance in the coordination of the disposal of

hazardous substances. See the college Crisis Emergency Management Plan (CEMP) for additional

information on chemical spills.

X. HAZARDOUS NON-ROUTINE TASKS

Potential hazardous non-routine tasks at the college must be identified by each respective

department manager and documented on Appendix B. Appendix B is to include at minimum the

following:

• Hazardous chemicals/materials needed to perform the task and their specific hazards

• Safety measures to be used/taken

• Measures being taken to prevent/lessen the hazard, e.g. engineering controls,

administrative work practices, personal protective equipment

• Review of pertinent SDS

• Review of emergency control procedures

http://www.reynolds.edu/campus_life/police/emerg_op_plan/Crisis-Emergency-Management-Plan.pdf



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Each department will forward a copy of Appendix B to the Safety Manager. Prior to starting a

documented hazardous non-routine task the employee is to receive a copy of Appendix B for his/her

specific task by their immediate supervisor.

XI. UNLABELED PIPES

Work activities are often performed in areas where chemicals are transferred through pipes. These

pipes are not required to be labeled; however, the employees need to be aware of potential hazards.

Prior to starting work in areas having unlabeled pipes, the employee shall contact the college’s

Facility Manager to determine:

• The identity of the chemical in the pipes

• Potential hazards

• Safety Precautions

The college’s Facility and Safety Managers will team up to have any / all reasonably accessible

unlabeled pipes, that have been identified to carry hazard chemical /material, inspected biannual

(August and February) for leaks, worn parts and etc.

XII. ON-SITE CONTRACTORS

Director of Facilities Management and Planning and Safety Manager will team up to designate three

(3) staff members, one on each campus to serve as the college’s first point-of-contact (POC(s) for its

on-site contractors. Prior to the contractors starting work, the POC(s) will perform the following:

• Inform on-site contractors of the college’s hazard communication global harmonization

system program (HCGHSP)

• Request any SDS from the contractors for any hazardous materials that will be used

• Work with the Safety Manager to provide the contractors with

• Copies of all relevant SDS with respect to the contractor’s work area



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• Information on any precautionary measures that need to be taken to protect their

employees

• The chemical labeling system used by the college

The college’s point-of-contact (POCs) for on-site contractors is not responsible for administering,

leading, performing or assisting any external or internal Safety Audit.

XIII. PROGRAM REVIEW

This written Hazard Communication Global Harmonization System Program (HCGHSP) for the

college will be reviewed in a collaborative effort by the college Safety Manager and Compliance

Officer twice a year (August and February) and updated as necessary. All updates to the college’s

written HCGHSP will be made for the sole purpose of supporting the college’s continuous effort to

establish, execute and enhance a prescribed way to address /communicate college-wide safety

matters to include, but is not limited to the following:

• Identifying and recognizing Hazardous Chemicals (products) used by the college

• Recordkeeping and providing access to the college’s SDS(s)

• Implementing a college-wide plan for handling and disposing Hazardous Waste materials

(i.e. commodity code approver for hazardous waste disposal requisitions)

• Identifying, recognizing and empowering the college’s Safety Manager

• Researching, developing and implementing, a college-wide communication mechanism to

address Safety issues that include, but are not limited to the scope of this HCGHSP



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Appendix A CHEMICAL INVENTORY

Please see the Safety Manger for this list.



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Appendix B NON-ROUTINE TASK

Please see the appropriate Manager / Department Head for this list.

hazard communication global harmonization system …€¦ · 19/10/2015 · compliance with the...

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