Table of Contents
This is the web version of the general written Hazard Communication Program (HCP) for NMSU. A similar copy is also located at the Environmental Health and Safety offices. Subsidiary programs have been and will be established, as needed, within NMSU departments, extension locations, and branch campuses. Additional information and a list of hazard communication coordinators, inventory and SDS locations by departments are given in the appendices.
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.
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.
Katrina Doolittle, Director Environmental Health and Safety, 646-3327, is designated as having responsibility for the administration of the NMSU Hazard Communication 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 workareas on a regular basis shall appoint a departmental HazCom Coordinator (HCS Coordinator) and establish a written program for the affected employees. EH&S shall request and review the the chemical inventory on an annual basis.
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 supervision comply with this program.
The "Hazard Communication Program" will consist of five basic components:
- 1. Inventory and audit of hazardous chemicals and materials.
- 2. Labels and labeling of hazardous chemicals and materials containers.
- 3. Safety Data Sheets (SDS) maintenance, distribution, availability and locations
- 4. Personnel training and information, general and specific.
- 5. A written "Hazard Communication Program" as herewith prescribed.
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. Personnel may review the program and chemical listing 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
annual audit, 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 the updated inventory lists
shall be provided to the Unversity EH&S at least annually.
Each listing will note at least the following information (inventory procedures, inventory entry form )
- 1. name & contact information for persons responsible for the area or chemicals
- 2. date the list was compiled 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 or material
- 6. general location within the work area where material is kept
- 7. name of the manufacturer or supplier.(must match the 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 HCS Program Coordinator for the area will ensure that the list is updated.
V. Safety Data SheetS (SDS)
An SDS will be provided on all required chemicals and materials used within the department (see example in Appendices).
There will be a master inventory of all required hazardous chemicals and materials which will be located in the University EH&S. The office will maintain a Master copy of chemical inventory from all subsidiary NMSU HazCom Programs. Each Department will annually forward their information to the 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 at the following locations:
- 1. Room 109, EH&S offices, Academic Research Unit C and/or
- 2. At the workplace or department locations as indicated by departments and users under this program.
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 manufacture or supplier and obtain the SDS for the product. If the SDS can not be obtained and EH&S has been notified, generic safety data may be substituted .
All hazardous chemicals or materials on hand or received must have a label that will specify at least:
- 1. The chemical name.
- 2. Any specific warning or other hazard information.
- 3. Identification of the manufacturer or supplier and address.
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 label to either be introduced by the department or replaced on a hazardous chemical or material container, such a label will display the identification and hazard information noted in Paragraph A above. The label will follow the National Fire Protection Association Hazard Identification (NFPA 704) System (Appendix B).
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 HCS Program 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 in Part V (A) and (C) above.
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.
As applicable personnel will sign a form indicating that they attended a HCS training session, were provided written material, understood the departments policy on Hazard Communication and/or received specific training relative to hazardous chemicals or materials (see Appendix C and other examples in the appendices).
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 (see training presentation in Appendices):
- 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 and information in appendices).
- 5. Description of SDS and how to read, all sections (see example in appendices).
- 6. Location and availability of the written hazard communication program, SDS master and locations, and chemical listing (see Part V).
- 7. Definition of hazardous chemicals or materials (see data in appendix):
- a. Hazardous chemicals
- b. Health hazard
- c. 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 use 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.
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.
It will be responsibility of HCS Program Coordinator 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.
- HCS Program Coordinator will also be responsible for contacting each and all 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 HCS Program Coordinator of such contract, name of contractor, starting date, and type work to be performed.
X. PROGRAM MAINTENANCE - OTHER FUNCTIONS
must furnish a "Safety Data Sheet" applicable to any item on this
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 petty cash purchase, supplier samples or other means without the knowledge of the HCS Program Coordinator.
Appendix A Inventory Information
Appendix B NFPA Label Information
Appendix C Group Training Record
Appendix D Individual Training Record
Appendix E Example SDS & Exercise
Appendix F Definitions
Appendix G Additional Hazard Definitions
Appendix I Laboratory Recommendations
Appendix J Prior Approval Form