This section has been reviewed and updated as needed: May 2014

(OSHA 1910.1200)

Legal Requirements

The provisions of the NC OSHA Hazard Communication Standard require employers to provide employees with information concerning the hazards associated with the chemicals in their workplace. This standard requires a written hazard communication program, container labels, inventory of chemicals, area warning signs, material safety data sheets, and chemical safety training and information sessions.

Responsibilities

For Facilities Services shops, instrument shops, chemical storerooms, and other department functions that use or store hazardous chemicals, the Department Head or his/her designee has responsibility to ensure that labels are proper, that material safety data sheets are obtained and maintained, that chemical safety training is provided, and that the inventory of the hazardous chemicals used or stored in the work area is readily available to employees.

The Department of Environment, Health and Safety will coordinate implementation of the Hazard Communication Standard and will assist Departments in obtaining material safety data sheets and in conducting general safety training and workplace hazard communication inspections.

Chemical Hazard Communication Program

This document shall serve as the written Chemical Hazard Communication Program for the University. It is to be readily available to employees upon request.

Definition of Hazardous Chemicals

The requirements of the Chemical Hazard Communication Program apply to chemicals with one or more of the following hazardous properties:

  • Physical Hazards: Create dangerous situations, and have been proven to be combustible liquid, compressed gas, explosive, flammable, organic peroxide, oxidizer, pyrophoric, and unstable, or water-reactive chemicals.
  • Health Hazards: Chemicals that can produce negative health affects in exposed employees. These can be chemicals that are toxic, carcinogenic, corrosive, irritant, or sensitizing.
  • A chemical is considered to be carcinogenic if (a) it has been evaluated by the International Agency for Research on Cancer (IRAC), and found to be a carcinogen or potential carcinogen; or (b) it is listed as carcinogen or potential carcinogen in theAnnual Report on Carcinogens published by the National Toxicology Program (NTP); or (c) it is regulated by OSHA as a carcinogen.
  • Health hazards can cause either acute or chronic effects. Acute health effects are the negative effects from a substance that occur after one or multiple exposures in a short period of time. (Ex. Spilling Hydrochloric Acid on your hand.) Chronic health effects are the negative effects from a substance that occur over a longer period of time, usually from repeated exposure of low doses. Sometimes delayed for years. (Ex. Being exposed to Asbestos fibers.)

Labels and Other Forms of Warning

Chemical manufacturers, importers, or distributors are required to ensure that each container for hazardous chemicals is labeled with the identity of the hazardous chemicals(s); appropriate hazardous warnings; and the name and address of the chemical manufacturer, importer or other responsible party. University departments are to ensure that chemicals they receive are labeled with the identity of the hazardous chemicals(s) and appropriate hazard warnings. This includes chemicals received from the UNC Scientific Supply or other campus storerooms. If a chemical is placed into a container without a label, that container must also be labeled with the proper chemical information. Also, if a label is removed, it should be replaced immediately.

Warning signs are to be displayed in areas where there may be airborne hazardous chemicals. This would include areas such as welding; operations of internal combustion engines, indoor application of paint, or adhesives; grinding and sanding operations; and removal of asbestos containing materials. The person responsible for producing the above potentially hazardous environments is responsible for posting the area warnings signs. All pipes containing hazardous chemicals are to be labeled.

Chemical Inventory

A current inventory of all hazardous chemicals present in the workplace is to be maintained. The inventory should be kept with the MSDS file a a quick reference for chemicals that are being stored in the area. The Chemical Inventory List should also be updated annually, or as new chemicals are brought in and old chemicals are properly disposed of.

Material Safety Data Sheets (MSDS)

Chemical manufacturers are required to send a Material Safety Data Sheet (MSDS) with the initial shipment of a chemical. The MSDS contains detailed information about physical and chemical properties of the chemical, the physical and health hazards, safe handling precautions, spill clean-up procedures, emergency and first aid procedures. MSDS’s must be made available to employees 24 hours a day, 7 days a week. These forms shall be kept in an area where employees will always have access to the MSDS documents.

University departments are to maintain all Meds received and to make them readily available to their employees in a file or notebook. If an MSDS for a chemical is not received, the chemical manufacturer or distributor should be contacted to obtain the MSDS. Efforts to obtain the MSDS are to be documented by either a telephone log or with copies of correspondence. Assistance in obtaining MSDSs is available from Health and Safety Office.

Information and Training

All employees who work in areas where there are hazardous chemicals are to receive documented chemical safety training. This training is to be done at the time of initial employment and before a new hazard is introduced in the workplace.

Hazardous chemical safety training is to include the following essential information:

  • Interpreting information on labels and MSDSs
  • Location of hazardous materials in the workplace
  • Location and availability of material safety data sheets
  • Acute and chronic effects of chemicals
  • Safe handling procedures
  • Personal protective equipment
  • Methods used to detect leaks and releases
  • First Aid
  • Spill clean-up and emergency procedures
  • Waste disposal

The Department of Environment, Health and Safety has developed training programs including slide programs explaining the Chemical Hazard Communication Program, the toxic effects of chemicals, and the safe handling of hazardous chemicals in the workplace. The Department of Environment, Health and Safety should be contacted to schedule theses programs.

In addition to general chemical safety training it is the responsibility of the supervisor to provide training for the specific chemicals used or stored in the work area and whenever a new hazard is introduced. Training should be documented by keeping records of when training sessions were held, who attended, and the contents/outline of the training.

Routes of Exposure

There are 4 routes of exposure to chemical substances (Inhalation, ingestion, absorption, and injection). The most likely target depends upon the characteristics of the chemical being used.

  1. Inhalation is the primary route of entry which includes airborne contaminants such as gases, vapors, and particulate matter that enters the body.
  2. Absorption can occur very quickly through cuts or abrasions on the skin, and may also occur even when skin is intact. Mucous membranes and eye tissue are particularly vulnerable to absorption.
  3. Ingestion can occur by the direct tasting of chemicals, and by ingesting contaminated food or putting personal items such as make-up on one’s face. This is the reason that food, drinks, cosmetics, and other items are banned from laboratory areas. Labeling containers and practicing good housekeeping are ways of controlling the possibility of ingesting a chemical. If you work in a lab or perform maintenance in a lab, always make sure you wash your hands before leaving.
  4. Injection can occur from needle sticks, broken glass, broken capillary tubes, or broken pipettes. Make sure that carefully planned procedures are in place when handling broken materials. Needle blocks should be in place to prevent accidental needle sticks.

Non-routine Tasks

All jobs or projects involving hazardous chemicals that are being done for the first time or done periodically, shall be considered a non-routine tasks.

Contractors

Contractor employees are to be informed of hazardous chemicals that they may encounter at their work location on campus and provided with the name of the University person(s) from whom chemicals safety information is available. Contractors who use hazardous chemicals are to maintain a list of the chemicals and the MSDSs at the work location on campus.

Trade Secrets

In some cases, the chemical manufacturer may withhold the complete chemical identity from the MSDS if it is a trade secret. However, the chemical and physical properties must be disclosed on the MSDSs. Trade secret information will be available to health professionals for medical treatment of exposed personnel, assessment of hazards and employee exposures, and selection of appropriate safety precautions.

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