XVIII Procedure for the use of Hazardous Materials
- Hazardous Chemical use guidelines.
- Requirement for use and storage of hazardous materials.
- Comply with the OSHA hazard communication standard.
The purpose of this policy is to provide faculty and staff clear direction for safe handling of hazardous materials and to comply with OSHA requirements.
The list of hazardous materials regulated under the OSHA hazard communication standard, 29 CFR1910.1200 is not all-inclusive because any material that meets OSHA criteria is considered hazardous. Beyond the immediate health hazards such as acute toxicity or the physical hazard such as flammability are the target organs effects that, by and large, are delayed health effects. Delayed effects manifest themselves some time after exposure and often at dosages lower than those that may cause immediate health effects. Included in the list of delayed effects are neuro-toxic effects, liver and kidney effects, and dermal or lung sensitization.
The OSHA Subpart Z-Table list of Chemicals is OSHA's floor list of hazardous materials. These chemicals have Permissible Exposure Limits. Other chemicals defined as hazardous are those listed by the International Agency for Research on Cancer, the National Toxicological Program, or OSHA have determined to be carcinogenic.
The hazardous material regulated under the Hazard Communication Standard are listed below:
- Chemical Source List
- 29CFR 1910, Subpart Z
- American Conference of Governmental Industrial Hygienists Threshold Limit Values
- National Toxicology Program carcinogens
- OSHA carcinogens
- Based on Composition - 1%if hazardous component and 0.01% if carcinogens
- Based on physical hazards
- Combustible liquid
- Compressed gas
- Organic peroxide
- Water reactive
- Based on Test results
- DOT corrosive
- Lethal dose equal to less than 500 mg/kg oral
- Lethal dose equal to or less than 1000mg/kg dermal
Lethal concentration equal to or less than 2000 ppm or 20mg/L/1 hour inhalation. Sensitizers (NOTE: There is no requirement under the HCS for an employer to move a worker who has developed an allergic response to a chemical that he is working with to another area where that employee would not be exposed).
- Lung toxins
Other criteria- Situations where a chemical is released in concentration above an exposure limit.
Labels on hazardous substances need an identifier so they can be cross-referenced to the MSDS for the substances and to the location of the substance on the chemical inventory.
Areas/department that contain hazardous material will maintain a file containing Material Safety Data Sheets, which will be accessible to all employees. Employee will be apprised of the hazards of the chemicals in their workplace. An inventory will be performed with the results forwarded to the safety office. The inventory will consist of the chemical and MSDS for each.
Hazardous Chemical use guidelines:
- Security is a prerequisite to safety
- Access to areas in which hazardous materials are used or stored will be limited.
- To minimize vandalism and unauthorized use of hazardous materials, all areas that contain hazards materials must be secured when not in use.
- Security plans must be reviewed with the safety office to provide maximum practical separation of large concentration of people from areas in which hazardous materials are used and/or stored.
- Possession of hazardous materials without prior approval is prohibited.
- All hazardous material purchased must adhere to the purchasing policy.
- Each facility that uses hazardous material must be approved and periodically inspected by the safety office.
- Individual facilities may be approved to handle materials of varying degrees of hazards.
Requirement for use and storage of hazardous materials:
To comply with the OSHA hazard communication standard, each supervisor must:
- Prepare a written hazard communication program.
- Compile a list of hazardous material in the workplace
- Keep a file of MSDS for all hazardous materials.
- Label all hazardous materials.
- Train and inform employee about the chemical and physical hazards.
This requirement does not apply to:
- Employees such as office workers, who encounter hazardous chemicals only in non-routine/isolated instances (e.g. a worker who occasionally changes the toner in a copier).
- Employees such as office workers whose exposures would be the same as the general public or other people in the building (e.g. employee incidentally exposed to anti-corrosive chemicals added to the humidification system or chemical used to clean office area and bathrooms).
- Hazardous substances subject to the EPA, CERLA, and RCRA rules, tobacco, woods unless it has been treated with a hazardous material, articles that release only minute traces of the hazardous materials, foods or alcoholic beverages, drugs, cosmetics, radiation and biological hazards.
- Hazardous consumer products where the employer can show that they are used in the workplace for the purpose intended by the manufacturer or importer of the product, and result in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumer when used for the purpose intended.
- Nuisance particulates where the manufacturer or importer can establish that they do not pose any physical or health hazards.
- Allergic reactions which some people who have become sensitized to certain chemicals experience when exposed to very small quantities of these chemicals, quantities that may not cause any harmful effects to the majority of the population.
Laboratories and operations where hazard materials are handled only in sealed containers (e.g. warehouse) are exempt from the HSC’s requirement for a hazard communication standard. See the FSU Chemical Hygiene Plan for laboratory requirements.
- It is recommended that all plans inclusive of safety rules and procedures be submitted to the Safety Director for review, and to the Department Head for information.
- All areas that contain hazardous materials will be subject to inspections by the safety director at least annually.
- Emergency plans for each area that contain hazardous material must be clearly defined, prominently posted in each area and practiced at least annually by those working in the area.
- Each area that contains hazardous materials will have a safety notebook readily accessible. This notebook will include all appropriate MSDS, the safety plans, and any other pertinent safety information.
- The area supervisor must accept responsibility for remaining current on the particular hazards associated in his/her facility. The University will provide the most appropriate and current information readily accessible for this purpose.
- A procedure for the inspection of areas that contain hazardous material on a regular basis will be develop by the safety office and approved by the safety committee.
These inspection procedures will include the following:
- Pre-use inspection procedure and approval of the facility.
- In-use monitoring.
- The authorization of the safety office to cause immediate cessation of activity in instances of unsafe condition that poses an immediate and significant threat of injury, material damage, or environmental contamination.
Employees need to be provided with information and training about hazardous materials present in their work area before their initial assignment to the area. Retraining must take place when the hazard changes, not just when a new hazardous material is introduced into the workplace. Employees need to be informed of the contents of the Hazard Communication Standard, the physical and health hazards of the chemicals they work with, safe handling procedures and ways to protect themselves from these materials. They also need to be informed of the hazards associated with non-materials in unlabeled pipes.
Classroom training of employees is often desirable but not essential. OSHA does not mandate how employees are to be trained. OSHA requires that, if asked by an OSHA inspector, the employees must be able to answer questions about the hazards, if any, of the chemicals used. Informal group or individual discussions with a supervisor, posted notices, or handout booklets can be effective. Commercial Acanned@ programs can be effective if supplemented with information specific to the work site.
Information provided to employees must include as a minimum:
- The content and requirements of the OSHA Hazard Communication Standard.
- The content, location, and availability of the Hazard Communication Program.
- The Permissible Exposure Levels, action levels and other recommended exposure limits for hazardous materials in the workplace.
- Signs and symptoms associated with exposures to the hazardous materials used in their workplace.
- The location and availability of MSDS, the list of hazardous materials are present.
Employee training must include as a minimum:
- Methods and observations that may be used to detect the presence or release of hazardous materials.
- The hazards associated with the materials used in their workplace.
- The measures they can use to protect themselves from these hazards, including specific procedures such as appropriate work practices, personal protective equipment to be used, and emergency procedures.
- The details of the employer’s HCP.
- Initial training will be supplied by the safety office. Subsequent training will be the responsibility of the of the area supervisor.
- Training will cover acute hazards, chronic hazards, as well as explosion, fire and mechanical problems.
- Proper chemical handling techniques will be emphasized during the training exercised.
- Pertinent legal issues (such as" RIGHT-TO-KNOW") will be explained and documented, during hazard communication on training.
- The area Chemical Hygiene Officer must be technically competent to understand the operations that employ hazardous materials in his/her area, and must be aware of and involved in all the safety related issues in his/her area.
- The area Chemical Hygiene Officer will receive regular briefing by the safety office on pertinent regulations, new developments in the handling of hazardous materials, health concerns, etc.
- The safety office will document all briefing.
To obtain the best estimate of the extent of usage of Hazardous Materials At FSU, a complete inventory of all chemicals in every area that contain hazardous material will be maintained.
The chemical inventory will accomplish the following:
- All materials whose identity and purity is in doubt will be disposed of at the time of the inventory.
- To maintain a reasonable estimate of the amount and types of materials in use at FSU, an ongoing inventory system will be implemented at the area supervisor level.
- The Chemical Hygiene Officer must accept responsibility for the safe storage of all hazards materials employed in his/her project.
- The Chemical Hygiene Officer will alert the safety office of the acquisition of any new hazardous material by the user.
- The purchasing department will receive MSDS and other safety warning materials supplied by the manufacturer of various hazardous materials used at FSU. This MSDS will be forwarded to the safety office for distribution to the appropriate users. The safety office will also keep an up-to-date, easy to access file of all MSDS used at FSU.
- The Safety Director will maintain an up-to-date listing of all location at FSU in which hazardous materials are currently being used.
- Proper facilities must be provided for the storage of hazardous materials.
- Hazardous material storage will be clearly identified, labeled distinctly and routinely inventoried.
- The Safety Office will approve all hazardous material storage locations. Periodic inspection will be conducted to verify compliance to regulations.
- Poorly labeled or labels having expired an expiration date on material containers must be disposed of properly following state and federal approved disposal laws.
Guidelines for the transportation of hazardous material on campus are as follows:
- Only approved vehicles and equipment, and properly trained personnel will be allowed to transport hazardous materials.
- Vendor deliveries will be subject to the same rules.
- Guidelines for the proper disposal of hazardous materials will be maintained by the safety office. The area supervisor must assume responsibility for advising the safety office of any unusual toxicity hazard or danger associated with any material submitted for disposal.
- The safety committee will develop and revise policy for the University.
- The University safety committee must approve exception to these policies.