NMSU Hazard Communication Plan

This is the web version of the general NMSU Hazard Communication Plan (HCP) for NMSU.  Information on chemical inventory tracking, chemical container labeling, chemical safety data sheets and hazard communication training at NMSU is provided here.

Hazard Communication Policy

The NMSU Hazard Communication Plan is maintained in accordance with current OSHA Hazard Communication regulations (29 CFR 1910.1200). 


The purpose of this program is to ensure that employees are informed about:

  • Elements of the NMSU Hazard Communication Program

  • Type of hazardous materials in the workplace

  • How to obtain and interpret safety information about the hazards

  • Appropriate protective measures

  • Hazard communication training available employees


EHS&RM is responsible for the maintenance NMSU Hazard Communication Program. EHS&RM serves as the Hazard Communication Program Coordinator for the university. Each department, office, division, campus, or other administrative unit that uses and stores hazardous chemicals in work areas, on a regular basis, must appoint a unit HazCom Coordinator (may also be the unit Chemical Hygiene Officer) and establish a written HazCom procedure for employees that work with hazardous materials within the unit.

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 consists of five basic components:

  1. Written Hazard Communication Plan (this page).

  2. Hazardous Chemical Inventory

  3. Safety Data Sheets (SDS)

  4. Chemical Container Labels and Warnings

  5. Hazard Communication Training

The NMSU Hazard Communication Program is maintained by EHS&RM.

Hazardous Material Inventory

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.

Safety Data Sheets

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 EHS&RM 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 EHS&RM, Academic Research BLDG 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 EHS&RM has been notified, generic safety data may be substituted.

Chemical Container 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.

Hazard Communication 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 EHS&RM 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 HazCom information and training for NMSU employees is at Hazard Communication (HazCom) - Online.

  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.

Non-Routine Work Requiring Prior 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.


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 work site. 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.

Program Maintenance and 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.