PURPOSE
The purpose of this policy is
to ensure that
SCOPE
University-wide.
INTRODUCTION
The implementation of an
effective Right-to Know Program will require the sincere effort and cooperation
of all faculty, staff, and support personnel.
Simply stated, the cooperation of every member of the
DEFINITIONS
Hazardous substance:
Any chemical or mixture
defined under Section # _____ of the Act (35 P.S. 7303). The term includes hazardous mixture. The term does not include substances
naturally existing and not created as a result, or in connection with, a
manufacturing process.
Workplace: Any building or work area, or contiguous group of
buildings or work areas, at one geographical location composing a plant site in
Work area: Any room, section of a room, or defined space within a
workplace where workers are based for the regular performance of their duties.
Material Safety Data Sheet (MSDS): A written
document prepared by a manufacturer, supplier, or importer in conformity with
Section 4 of the Act (35 P.S. 7304) for the purpose of transmitting information
concerning a chemical or chemicals in a product.
Hazardous Substance Survey Form (HSSF): A
form containing specific information on the hazardous substances stored or used
in the workplace.
Label: A sign, emblem, sticker, or marker affixed to or
stenciled into a container listing the information required under the Act.
PROCEDURE
I. Posting
of Notification
The
Environmental Health and Safety Office is responsible for posting and
maintaining the Pennsylvania Worker and Community Right-to-Know Act’s Employee
Workplace Notice in each building of
In
addition, each department will ensure a MSDS Location Poster be prominently
displayed at each work area where hazardous chemicals or toxic substances are used
or stored.
II. Inventory
(List of Hazardous Chemicals)
Each
department will complete an inventory annually on all hazardous substances and
products stored or used within their work area.
The Office of Environmental Health and Safety will maintain and keep a master
inventory of all hazardous substances or products used or stored at
Each
department is responsible for updating their department’s inventory upon
receipt of, or discontinuation of, hazardous substances and forwarding that
information to Environmental Health and Safety to ensure that the “Master List”
is kept current.
III. Material
Safety Data Sheets (MSDS)
A
Material Safety Data Sheet will be obtained by Environmental Health and Safety
for all hazardous substances/products on
Environmental
Health and Safety is responsible for filing, maintaining, and storing the MSDS
in a designated Master File. The Master
file will be located in Room 102 of Glennon Infirmary and will be accessible for
emergency information on all shifts through the Department of Law Enforcement. Each department will maintain copies of the
MSDS for all hazardous substances used or stored within the department. The MSDS will be kept in binders labeled
“MSDS” and will be centrally located and readily available without intervention
or permission of management or supervisor in the department. It is the department’s responsibility to keep
their MSDS binders current and their employees informed of the location and
accessibility of them.
Environmental
Health and Safety is to be notified when a hazardous substance is discontinued,
an MSDS is replaced, or when a new hazardous substance has been ordered for use
by the department. Each MSDS is to be kept
on file for as long as the hazardous substance is used or stored on campus.
IV. Obtaining
Material Safety Data Sheets
By
law, all hazardous substances purchase must come with a MSDS. When purchasing a hazardous substance please
request a MSDS. An order is not complete
until an MSDS has been received. If you do
not receive a MSDS with your order, you should notify the EHS department and contact
the vendor immediately to request a MSDS for the product.
When
a department receives a new or updated MSDS, a copy is to be placed in the
department’s MSDS binder and a copy
forwarded to Environmental Health and Safety for review and inclusion in
the Master File. MSDSs are to be
received at
V. Making
Information Available
Copies
of Material Safety Data Sheets are to be available to employees or their
representatives upon written request to Environmental Health and Safety within
five working days. A copy of each
request is maintained in Environmental Health and Safety.
VI. Hazardous
Substance Survey Form (HSSF)
A
workplace Hazardous Substance Form will be completed and forward to each
department by Environmental Health and Safety no later than April 1 of each
year and shall include hazardous substances that were present in the workplace
during the prior calendar year. Each
department will post the HSSF immediately upon receipt in areas were notices to
employees are normally posted. In addition, the HSSF is to be revised whenever
a new hazardous substance or product is used or stored in the workplace. The completed form is to be provided to employees
of LHU and if requested, to the Department of Labor and Industry.
VII. Labeling
and Other Forms of Warning
Federal
law requires that all sold hazardous substances and products contain the
following label information - the identity of the chemical, an appropriate
warning, the name, and the address of the manufacturer. These labels are not to be removed or defaced. As long as a chemical is in its original
container, there are no other label requirements. In addition, all ports of pipelines that
contain a hazardous substance must be properly labeled as to its contents,
warning information, and protective equipment needed.
All
chemical containers (regardless of their hazard) must be labeled during use or
storage.
A
chemical that has been transferred from its original container to another must
be labeled with the name of the chemical, an appropriate warning, date of
transfer, and the person responsible for its use. However, there is no labeling requirement on
portable containers where a hazardous substance was transferred from a labeled
container and it is intended only for the immediate use by the employee
performing the transfer. Hazardous
substances left in the portable containers beyond the employee’s work shift must
be labeled according to the Act’s requirements.
Immediate use means the current work shift of that employee making the
transfer, not to exceed eight (8) hours.
Otherwise, all secondary containers, not intended for immediate use must
be labeled.
VIII. Informing
other Employers
All
contractors will be given information (MSDS) about hazardous substances their
employees may be exposed to on a LHU job site, along with suggested precautions
for the employees. This will be done by
the LHU site representative in conjunction with EHS. Should there be an acknowledged hazard present,
the site representative is responsible for informing the contractor and
documenting the notification.
The
site representative is also responsible for ensuring that MSDSs for hazardous
substances brought onto the
IX. Employee Training and Information
Environmental
Health and Safety is responsible for ensuring that each employee at
All
employees who routinely use, handle, or are exposed to hazardous substances in
their workplace will receive training within 30 days of employment. They will also be required to participate in
annual retraining. This training will consist
of:
·
Discussion of
employee rights and employer responsibilities
·
Locations and
right to access
·
Locations of Material
Safety Data Sheets and their availability to employees
·
Instructions on
how to read a MSDS to obtain hazard information
·
Procedures to
follow if overexposed to hazardous substances
·
The symptoms of
overexposure
·
How to reduce or
prevent exposure to hazardous substances through the use of control procedures,
work practices, and personal protective equipment
·
Steps the university
has taken to reduce or prevent exposure
·
An introduction
to the basic concepts of toxicology including, but not limited to:
Ø Routes of entry
Ø Target organs
Ø Reversible and irreversible effects
Ø Exposure limits
Ø Lethal dose values
Ø Synergistic and antagonistic effects
Ø Carcinogen, mutagens and teratogens
Emergency reporting procedures including
chemical spills, accidents, fire reporting, biological hazards, and radiation emergencies.
Non-Routine
Tasks- periodically, employees may be required to work with or around hazardous
chemicals that are not routinely found in the workplace and for which routine
training has not been held. Employees must be trained prior to starting work in
such a work area. The supervisor is responsible for ensuring that employees
receive appropriate training. The training must include the following:
- Specific chemical hazards of the job
- Specific hazards associated with chemicals in the
work area
- Protective and safety measures the employee must
take if problem occur
- Measures taken to reduce the hazards, including
but nit limited to ventilation, respirators, and presence of other
employees and emergency procedures
- Spill or leak cleanup procedures
- Resources available for additional information
X. Recordkeeping
Records
of all employees who have been trained will be kept in the Office of Environmental
Health and Safety; copies will be sent to the employee’s supervisor. A copy will be made available to an employee
upon their written request.
Training
records will contain the name, department, training dates, training content,
signature of employee, along with the name of the person giving the training.
XI. Health
and Exposure Records
The employee medical record which is
a record concerning the health status of an employee which is made or
maintained by a physician, nurse, or other health care personnel must be kept
and maintain for the duration of an employee’s employment plus 30 years.
The employee exposure record that contains information
concerning the employee’s exposure to hazardous substance(s) must be kept and
maintained for at least 30 years.
Environmental
Hazard Survey Form (EHSF)
Environmental Health and Safety will complete an
Environmental Hazard Survey Form if requested by the Department of Labor and
Industry and provide a copy to employee upon request. An EHSF documents
information concerning those environmentally hazardous substances that are
emitted, discharged, or disposed of from the workplace.
Responsibilities
Departments are responsible for
·
Ensuring that all
hazardous substances containers in their employees’ work location are properly
labeled
·
Conducting,
maintaining, and updating chemical
inventories
·
Ensuring that
Material Safety Data Sheets for all hazardous substances in their work location
are maintained, updated, and available to all employees
·
Ensuring that
each of their employees receives training as required
Employees are responsible for
·
Using only these
chemical containers that are properly labeled
·
Notifying their
supervisor if labels are missing or inadequate
·
Notifying their
supervisor if MSDSs are not available or are inadequate
·
Using the
chemical consistent with instructions on its label
Environmental Health and Safety is responsible for
·
Coordinating the
development and updating of the program
·
Assisting
departments in implementing the program
·
Provide training
at the request of departments
·
Consulting and/or
assisting departments with employee training
·
Conduct periodic
inspection for compliance and program evaluation
Outside Contractors doing work at LHU are responsible
for
·
Informing the LHU
Project Manager of their intent to use hazardous substances and to provide the
LHU Project Manager with the appropriate MSDSs
·
Training their
worker on the potential hazards of the work area and provide documentation of
training to LHU project Manager
·
Comply with
LHU Project Managers (individual who contractor
reports to) are responsible for
·
Informing
contractors of the requirements of this program
·
Collecting MSDS