Hazard Communication Program

NMSU Hazard Communication Program

This is the web version of the general written Hazard Communication Program (HCP or HazCom) for NMSU. A similar copy is also located at the Environmental, Health and Safety Department. Additional information on the inventory system, workplace labeling, safety data sheets and OSHA updates in Global Harmonization System are given on the NMSU EH&S website on the Hazard Communication Page.

I. POLICY

New Mexico State University (NMSU) will maintain an effective “Hazard Communication Program” in accordance with the current New Mexico Occupational Health and Safety Act regulation 29 CFR 1910.1200.

II. PURPOSE

The above noted regulation sets forth “to ensure that the hazards of chemicals produced or imported by chemical manufacturers or importers are evaluated, and that information concerning their hazards is transmitted to affected employers and employees. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, Safety Data Sheets and personnel training.”

This program, as well as the regulation, is otherwise referred to as the “Right to Know Law”, which in effect is designed to provide knowledge, warning, protection and training to employees who may be exposed to hazards of chemicals and other materials.

III. RESPONSIBILITY

David Shearer, Environmental Health and Safety, (phone 575-646-3327) is designated as having responsibility for the administration of the NMSU Hazard Communication (HazCom) Program. EH&S will act as the general HazCom Program Coordinator for NMSU. Each university department, office, division, campus, or component that uses chemicals in its work areas on a regular basis shall appoint a departmental HazCom Coordinator (HCS Coordinator) and establish a written program for the affected employees. Through its inspection of labs, shops, buildings, research facilities, campuses and farms, EH&S will work to ensure these areas are in compliance with the HazCom regulations and this plan.

All personnel (faculty, staff, technical assistants and certain matriculating students) will fully participate in the program as it may apply to their work area and work responsibility. Each supervisor shall ensure that those employees and areas under his or her supervision comply with this program.

The “Hazard Communication Program” will consist of five basic components:

  1. A written “Hazard Communication Program” as herewith prescribed.
  2. Inventory and audit of hazardous chemicals and materials.
  3. Safety Data Sheets (SDS) maintenance, distribution, availability and locations.
  4. Labels and labeling of hazardous chemicals and materials containers.
  5. Personnel training and information, general and specific.

The written “Hazard Communication Program” for the University with its associated inventory list, records, materials, etc., will be maintained and located in the NMSU Environmental, Health and Safety (EH&S) offices. As appropriate, affected personnel may review the program, training, and chemical listings at this location. A copy of this written “Hazard Communication Program” may also be reviewed on the safety website (safety.nmsu.edu). Subsidiary programs established by NMSU components shall be made available to affected employees at a location designated in the respective program.

IV. MATERIALS, INVENTORY, AUDITS

An initial inventory of all chemicals and materials will be made of all new work areas and facilities. An ongoing audit of the HazCom Inventory, will be conducted thereafter.

All hazardous chemicals and materials required will be identified and listed. A copy of the HazCom Inventory for each work area will be kept with the SDSs for that area (or in a secure location if the SDSs are in the public areas) and an updated chemical inventory shall be reposted at least annually.

Each listing will note at least the following information:

  1. Name & contact information for persons responsible for the area or chemicals.
  2. Date the chemical or chemicals was received and/or updated.
  3. Building & room/area location of the work or storage area.
  4. Name and hazard(s) of the chemical or product.
  5. Typical maximum quantity of the chemical(s) or material(s).
  6. General storage unit or location within the work area where material is kept.
  7. Name of the manufacturer or supplier (from SDS).

A system will be maintained to add any newly introduced hazardous chemicals or materials to the inventory. Typically the person responsible for material will update the list for the specific work area and ensure that the master list is updated. The lab or area supervisor or department manager shall ensure that the list is updated.

V. SAFETY DATA SHEETS (SDS)

Safety Data Sheets (SDSs) are required for all hazardous chemicals, substances, and materials used within the NMSU departments (more information).

There will be a master inventory of all required hazardous chemicals and materials which will be located in the EH&S offices. The office will maintain a master copy of chemical inventories from all NMSU Programs and departments using chemicals. At least annually each department will forward updated chemical use information to NMSU Environmental, Health and Safety, Academic Research Unit C. All departments and users will obtain and maintain SDSs for each hazardous material in use or storage at NMSU.

SDSs as well as the inventory of chemicals and materials used in a specific work area or for a specific work assignment will be available to personnel during their work period. These items will be placed:

  1. At the workplace or department locations as indicated by departments and users under this program.
  2. The inventory listing and audits will be used to ascertain that there is an SDS as may be required for each chemical or material item and that all containers are properly labeled and stored.

In the event an SDS is not available or should a new chemical or material be introduced for use without a required SDS, the immediate supervisor should be promptly notified. That supervisor and/or HazCom Coordinator for the area will contact the manufacturer or supplier and obtain the SDS for the product. If the SDS cannot be obtained and EH&S has been notified, generic safety data may be substituted.

VI. LABELS AND LABELING

All hazardous chemicals or materials on hand or received must have a manufacturer label that will specify:

  1. Product identifier (commonly the chemical name).
  2. Warning & other hazard information for each hazard class and category to include:
    1. A harmonized signal word
    2. Pictogram
    3. Hazard statement
    4. Precautionary statements must also be provided
  3. Supplier identification to include name, address and emergency phone number (for product information).

A hazardous chemical or material label will not be removed from its container, nor will such a label be defaced.

Should it become necessary for a workplace label to either be added by the department or replaced on a hazardous chemical or material container, this workplace or secondary container label will display the information required by the suppliers label (see above) or the container can be labeled with an alternative system that meet the requirements for the standard. OSHA has indicated that the labeling systems using the National Fire Protection Association (NFPA) 704 Hazard Rating is permitted for workplace containers. NMSU provides training on and uses the NFPA alternate labeling system for workplace label (more information).

All containers of hazardous chemicals or materials will be received, and the label assured to be affixed on each and all containers by Staff, Faculty, Graduate and Undergraduate Students that have received HCS training.

It will be the responsibility of each department Supervisor/Coordinator to ensure that all secondary containers are properly labeled with a duplicate of the manufacturer’s label or a department’s label as noted above.

VII. INFORMATION AND TRAINING

All personnel will be trained on the “Hazard Communication Program”/”Right to Know Law” at time of initial assignment and periodically thereafter. Initial training will be by EH&S with additional information provided by supervisor when new equipment, chemical or other hazard is introduced into the work area. Supervisors are responsible to ensure employees receive and understand required training and information for site-specific hazards.

All applicable personnel will be provided written material on the NMSU HazCom Program and/or received specific training relative to hazardous chemicals or materials and pass a quiz indicating that their understanding of NMSU HazCom Program.

General program information and training will be accomplished by lecture, photo slides, movie, video, literature, or combination, and will cover the contents of this program to include a review of the following (Please use this registration link for the Hazard Communication Class offered by EH&S):

  1. NMSU (Employer) policy statement (see Part I).
  2. The basic definition of the regulation (see Part II).
  3. Statements of responsibility, both program and personnel (see Part III).
  4. Information relating to labels, general, those used by the department and placards (see Part VI).
  5. Description of SDS and how to read, all sections (see Part V)
  6. Location and availability of the written hazard communication program, SDS master and locations, and chemical listing (see HazCom Page).
  7. Definition of hazardous chemicals or materials – OSHA 1910.1200(c):
    1. Hazardous chemicals
    2. Health hazard
    3. Physical hazard
  8. Steps that department personnel can take to lessen or prevent exposure to hazardous chemicals or materials, i.e., knowledge of chemicals, storage, posting, personal protective equipment, chemical loads, warnings, eye wash and safety showers, training, etc.
  9. Methods and observation techniques used to determine the presence or release of hazardous chemicals or materials in a work area, i.e., flame or fire, smell or odor, fumes, etching, color, irritation, etc.
  10. The emergency procedure to take in the event there is exposure to a hazardous chemical.
  11. Notice of hazardous chemicals or materials in an individual’s work area.

VIII NON-ROUTINE WORK OR TASKS (PRIOR SAFETY APPROVAL)

Periodically, personnel may be required to perform non-routine work or tasks requiring the use of hazardous chemicals, materials or work in associated hazardous locations. The Hazcom Program Coordinator for the area will be informed about and prior to starting such projects.

The Program Coordinator and other department safety committee will complete (or arrange) a hazard analysis (Prior Approval) via safety review of the task (prior approval form) and ensure that each affected individual is given information about the chemicals, materials, or exposure of such activity. Such information shall include:

  1. Specific hazards that may be associated with the chemical or material.
  2. Protective and other safety measures to be taken.
  3. Measures the department is taking to lessen or prevent hazards, i.e., ventilation, respirators, storage, safety watch personnel, postings and barriers, fire extinguishers, other personal protective equipment, etc.
  4. Review of the chemical or material, SDS or other technical information applicable to the work.
  5. Review emergency procedures to be taken.

IX. INFORMING CONTRACTORS

It will be the responsibility of the NMSU Project Manager to provide contractors with the following information:

  1. Any hazardous chemicals to which they may be exposed while on the site.
  2. Precautions and controls to be taken to lessen or prevent possible exposure by use of appropriate protective measures.

NMSU Project Manager will also be responsible for contacting contractors before work is started to gather and disseminate any information concerning chemical hazards that the contractor may be bringing onto the worksite. It will be the responsibility of any department official initiating a work or construction contract to notify EH&S of such contract, name of contractor, starting date, and type work to be performed.

X. PROGRAM MAINTENANCE – OTHER FUNCTIONS

Purchasing/SDS Supply

A boiler plate statement will be applied to all purchase orders on request in order to obtain applicable SDS on all required chemicals or materials.

“Suppliers must furnish a “Safety Data Sheet” applicable to any item on this purchase request.”

Other supplied chemicals or materials: No chemical or material requiring a SDS will be introduced into the department or any work area of the department by cash purchase, supplier samples or other means without the knowledge of the HCS Program Coordinator.


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