HAZARD COMMUNICATION PROGRAM

INTRODUCTION

It is the desire and intent of the University of the Sciences in Philadelphia (USP) that employees be informed about the hazardous substances they may encounter in the workplace, and learn the appropriate protective measures for working safely with these substances. The Hazard Communication Program, which is described in this document, is intended to comply with the requirements of the OSHA Hazard Communication Standard 29 CFR 1910.1200, and to provide information for everyone who may be exposed to hazards on our campus.

Hereafter, the University of the Sciences in Philadelphia will be referred to in the text as the University, and the OSHA Hazard Communication Standard 29 CFR 1910.1200 will be referred to in the text as the Standard.

Upon request, this Hazard Communication document will be made available to employees or their designated representatives.  The written program for the University is located in:

*	The Safety Department:	Griffith Hall, room #300 or #325
		Griffith Building, Room #B1
*	Safety Web Page

Employees may request to see the written program by contacting their Departmental Supervisor or the Safety Department.

IDENTIFICATION AND LABELS

Hazard Identification Requirements

The University does not manufacture products (SIC Code outside 20-39) and are thus exempt from the Hazard Identification requirements of The Standard under section (b) (4) or section (b) (5) of The Standard.

The University will rely upon the hazard evaluations performed by the chemical manufacturer/importer of all raw materials or products purchased by the University. Material Safety Data Sheets obtained from suppliers on all chemicals purchased shall be used in determining the health and physical hazards of materials present at the University.

The persons responsible for ensuring that incoming containers are labeled with the required information are:

• Environmental Health and Safety Officer
• Director of Facilities Services
• Assistant to the Safety Officer/Central Stockroom Manager
• Manufacturing Laboratory Manager
• Vivarium Supervisor
• Fleet Maintenance Manager
• Custodial Manager
• Groundskeeping Manager

Chemical Labeling System

The labeling system to be used on in-house containers throughout the University facilities are a combination of :

Hazard Warning - means any words, pictures, symbols or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical (potential for fire or explosion) or health hazard (signs and symptoms that may occur from exposure, acute or chronic health effects) of the chemicals in the containers. This must include the chemicals target organ effects. Ex.) hepatotoxin (liver effects), neurotoxin (affects nervous system).

The Environmental Health and Safety Officer and the Assistant to the Safety Officer will review the labeling system periodically and update as needed.

No container may be accepted unless it is properly labeled with the required information.

Labeling of Secondary/Transfer Containers

All secondary containers must be labeled with either an extra copy of the original manufacturer's label or with labels that identify the contents and any appropriate hazard warnings. For help with labeling, see either the Assistant to the Environmental Health and Safety Officer or the Environmental Health and Safety Officer. Hazard warning labels may be requested from the Central Stockroom.

The employer is not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. Transfer containers used between workshifts and/or by different workers must be labeled with the required information.

Labeling of Piping Systems

Pipes containing hazardous substances shall be labeled. In addition, tags specifying the identity of the hazardous substance will be affixed to exit points of the pipeline system.

A list of materials contained in the piping systems will be developed. Material Safety Data Sheets for those materials will be maintained in the Facilities Services Department and will be readily accessible to employees.

The person responsible for labeling the pipes and exit valves is the Director of Facilities Services.

CHEMICAL HAZARD SAFETY WARNINGS

1. Poison
2. Suspected carcinogen
3. May cause adverse reproductive effects
4. May be fatal or cause blindness if swallowed: cannot be made non-poisonous
5. May be fatal if inhaled
6. May be fatal if absorbed through the skin
7. May be fatal if swallowed
8. Causes severe skin and eye burns
9. Causes severe eye burns
10. May cause delayed lung injury
11. May cause lung injury
12. May cause nervous system injury
13. May cause blood disorders
14. May cause liver injury
15. May cause kidney injury
16. May cause cyanosis
17. May cause chloracne
18. May cause cardiovascular system injury
19. May cause thyroid injury
20. May cause allergic respiratory reaction
21. Gas extremely irritating to eyes and respiratory tract
22. Vapor extremely irritating to eyes and respiratory tract
23. Dust extremely irritating to eyes and respiratory tract
24. Extremely flammable
25. Causes skin and eye burns
26. Causes eye burns
27. Causes skin burns
28. Lachrymator, causes eye irritation
29. Contact with acids liberates poisonous gas
30. Highly reactive
31. Water reactive
32. Heat sensitive, can violently decompose if heated
33. Heat and shock sensitive, impact or heating can cause violent decomposition
34. Unstable at room temperature, may violently decompose
35. Strong oxidizer, contact with other material can cause fire
36. Strong reducing agent, contact with other material can cause fire
37. Ignites if exposed to air
38. Can explode on impact if water content is 10% or below
39. Forms explosive peroxides
40. Contact with water may cause flash fire
41. Contact with water forms flammable vapor
42. Contact with water forms flammable liquid
43. Do not allow water to get into container because of violent reaction
44. Flammable
45. Flammable solid
46. Flammable mixture
47. Harmful if inhaled
48. Harmful if absorbed through skin
49. Harmful if swallowed
50. Radioactive
51. Gas irritating to eyes and respiratory tract
52. Vapor irritating to eyes and respiratory tract
53. Dust irritating to eyes and respiratory tract
54. Oxidizing material
55. Reducing agent
56. Spontaneously combustible
57. May form explosive peroxides
58. Unstable at room temperature, may decompose
59. Heat and shock sensitive, impact or heating can cause violent decomposition
60. Heat sensitive, can decompose if heated
61. Impact or elevated temperatures can cause violent decomposition
62. Can violently decompose at elevated temperatures
63. Repeated exposure to vapor or dust may cause eye injury
64. Causes skin and eye irritation
65. Causes skin irritation
66. Causes eye irritation
67. May cause allergic skin reaction
68. Stench
69. May violently polymerize
70. Do not allow water to get into container because of reaction
71. Reacts with water
72. Contact with amines may form shock sensitive mixtures
73. Contact with metals may form shock sensitive materials
74. Combustible
75. Combustible mixture
76. Potential peroxide former
77. Can ignite when heated in presence of moisture
78. May polymerize
79. Contents under pressure
80. Powdered material may form explosive dust-air mixtures
81. Can decompose at elevated temperatures
82. Impact or elevated temperatures can cause decomposition
83. Decomposes in water
84. Contents may develop pressure if exposed to water
85. Contents may develop pressure upon prolonged storage
86. Contents may develop pressure on prolonged exposure to heat
87. Dried product residue can act as an oxidizer, drying on clothing or other materials may
      cause fire 
88. Do not allow water to get into container because of possible reaction
89. Since emptied containers retain product residue, follow safe warning even after container is emptied
90. Low hazard or usual industrial handling
91. The toxicological properties of this material have not been investigated
92. The toxicological properties of this material have not been fully investigated
93. The physical-chemical properties of this material have not been investigated
94. The physical-chemical properties of this material have not been fully investigated
95. The physical-chemical and toxicological properties of this material have not been investigated
96. The physical-chemical and toxicological properties of this material have not been fully investigated              
100. Flush to sewer with copious amounts of water
101. Neutralize with sodium bisulfate and flush to sewer with copious amounts of water
102. Neutralize with sodium bicarbonate and flush to sewer with copious amounts of water
200. Dispose of in an approved chemical incinerator, compounds containing halogens or sulfur
        and suspected carcinogens should be disposed of in an incincerator equipped with an
        afterburner and scrubber
400. Dispose of in an approved chemical landfill
500. Uncontaminated material may be disposed of in a sanitary landfill. Check local codes.
600. Irritant (unspecified)
601. Toxic (unspecified)
602. Hygroscopic (unspecified)
603. Lachrymator
604. Cancer suspect agent
605. Mutagen
606. Corrosive
607. Moisture-sensitive
608. Light-sensitive
609. Teratogen
610. Explodes when heated
611. Harmful (unspecified)
612. Readily absorbed through skin

MATERIAL SAFETY DATA SHEETS (MSDS)

The Environmental Health and Safety Officer and the Assistant to the Safety Officer are responsible for establishing and monitoring the University's MSDS program. Each department must obtain and maintain an MSDS for each hazardous material in their workplace. The departmental supervisor is responsible for ensuring that MSDS's are maintained in the assigned areas in his/her department.

Chemical manufacturers or importers shall ensure that employers are provided an appropriate material safety data sheet with their initial shipment, and with the first shipment after a material safety data sheet is updated. The chemical manufacturer or importer shall either provide material safety data sheets with the shipped containers or send them to the employer prior to or at the time of the shipment.

If the material safety data sheet is not provided with a shipment that has been labeled as a hazardous chemical, the responsible department shall obtain one from the manufacturer, importer or distributor as soon as possible. The manufacturers and/or distributors shall be contacted a second time if the MSDS is not received or is found to be inadequate. The responsibility for obtaining original MSDS's is assigned to the individual or department purchasing the material for use. Call the Safety Department if there is any difficulty.

MSDS’s shall be readily accessible to all employees in their work area(s) during each work shift. If an MSDS is not available, immediately contact the manufacturer, the Security Office (X7000) or the Central Stockroom (X8843).

Copies of MSDS’s for all hazardous chemicals in use will also be kept in the :

*

Central Stockroom

Griffith Building - Room #B10

Click here for additional information on MSDS's from the Laboratory Safety Manual.

EMPLOYEE TRAINING AND INFORMATION

Employees and student workers must receive training by their supervisor:     

*	at the time of their initial assignment, and
*	whenever a new hazard is introduced into their work area.

The training must include a review of:

*	The requirements of the Hazard Communication Standard
*	Any operations in their work area where hazardous chemicals are present; and
*	The location and availability of the written hazard communication program, the list of hazardous chemicals present and Material Safety Data Sheets for materials used at the work site.
*	Recognition
	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.
*	Hazards
	The 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.
*	Control
	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 (e.g., dilution)
	engineering controls (e.g., ventilation)
	emergency procedures (e.g., accidental exposure, spill, fire, accident, etc.)
	personal protective equipment to be used (PPE) (e.g., gloves, respirators)
*	Hazard Communication Program
	The details of the hazard communication training and information program developed by the employer include:
	an explanation of the labeling system, and
	the material safety data sheet, and
	how employees can obtain and use the appropriate hazard information and learn to protect themselves.
	The program consists of an information phase and a training phase.
	General information is provided and explained during New Employee Orientation classroom training conducted by the Safety Department.
	Specific information and training is provided by the supervisors at each worksite. On the job training, dealing with specific hazards of chemicals, substances, equipment, proper personal protective equipment, etc. relating to an employee's work area will be provided by departmental supervisors.

All employees exposed or potentially exposed to hazardous substances are to participate in the training and information program established by the University. Each department is responsible for assuring that workers attend training.

HAZARDOUS NON-ROUTINE TASKS

Prior to performing non-routine tasks, an employee shall review with his/her supervisor the potential hazards of the task and the proper safety and handling procedures;   including ventilation, respirators, presence of another employee, and emergency measures.  The MSDS for each hazardous material used should always be consulted prior to performing the non-routine task.

CONTRACTOR INFORMATION

Departments must inform outside contractors of the potential hazards which may be encountered during their work at the University. This includes giving contractors access to the written Hazard Communication Program, the hazardous chemical inventory, and the MSDS's for these chemicals.

Similarly, the contractor is expected to inform and provide departments with a chemical inventory and MSDS's for the materials that will be introduced into the work area in the course of their work at the University. The contractor must also provide information regarding where chemicals will be used and stored.

The contractor shall inform the Director of Facilities Services about any precautionary measures if needed to protect employees during the performance of the contractual work.

CHEMICALS IN UNLABELED PIPES

Work activities are sometimes performed by employees in areas where chemicals are transferred through unlabeled pipes.

As part of the supervisor training program, employees will be informed about the hazardous chemicals in unlabeled pipes.

Prior to starting work in these areas, the employee shall contact the Director of Facilities Services for information regarding:

A)  Chemicals in the Pipes
B)  Potential Hazards
C)  Safety and Handling Precautions

LIST OF HAZARDOUS CHEMICALS

It is policy to develop a list of hazardous chemicals used in each work area.   This list is developed as a result of the facility inventory, and is located in the Central Stockroom Office, Griffith Building - Room #B1.  Further information on each chemical may be obtained by consulting the Material Safety Data Sheets (MSDS), also located in the Central Stockroom, Room #B10.  This inventory will be updated as new information becomes available.  The chemical inventory is maintained by the Environmental Health and Safety Officer and the Assistant to the Environmental Health and Safety Officer.

EXAMPLES OF LABELS