The purpose of this policy is
to ensure that
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
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.
I. Posting of Notification
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)
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)
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.
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
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.
site representative is also responsible for ensuring that MSDSs for hazardous
substances brought onto the
IX. Employee Training and Information
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
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:
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.
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
LHU Project Managers (individual who contractor reports to) are responsible for
· Informing contractors of the requirements of this program
· Collecting MSDS