University of Wisconsin - Stout

The purpose of this program is to inform interested persons, including employees, that the University of Wisconsin-Stout is complying with the OSHA Hazard Communication Standard, Title 29, Code of Federal Regulations, 1910.1200, as incorporated by reference into the Wisconsin Administrative Code, Comm 32.  Compliance is achieved by compiling a hazardous chemical list, by using material safety data sheets (MSDS), by ensuring that containers are labeled, by providing our employees with training, and by making hazardous material information available.

This program applies to all work operations where employees may be exposed to hazardous substances under normal working conditions or during an emergency situation.

The Director of Safety & Risk Management Services is the program coordinator, acting as the Chancellor's representative, who has overall responsibility for the program. The program coordinator will review and update the program, as necessary. Copies of the written program may be obtained from the Director of Safety & Risk Management Services, in the University Services building.

All employees, or their designated representatives, can obtain further information on this written program, the hazard communication standard, applicable MSDS's, and chemical information lists from the Director of Safety & Risk Management Services, in the University Services building. Department supervisors are responsible for obtaining MSDS from the manufacturers of the chemical substances they purchase, keeping a current list of their hazardous substances and the corresponding MSDS. Under this program, our employees will be informed by their supervisors of the contents of the Hazard Communication Standard, the hazardous properties of chemicals with which they work, safe handling procedures, and measures to take to protect themselves from these chemicals. Signs and symptoms of exposure to chemicals in the work place and appropriate first aid measures will also be covered.

If after reading this program, you find that improvements can be made, please contact the Director of Safety & Risk Management Services. We encourage all suggestions because we are committed to the success of our written hazard communication program. We strive for clear understanding, safe behavior, and involvement in the program from every level of the university.

Our chemical inventory is a list of hazardous chemicals known to be present on campus. Anyone with the potential to come into contact with the hazardous chemicals on the list needs to know what those chemicals are and how to protect themselves. That is why it is so important to identify each and every hazardous chemical in the workplace and evaluate the chemical hazards whether the chemicals are found in containers or generated by work operations such as welding fumes or exhaust vapors. The hazardous chemicals on the list can cover a variety of physical forms including liquids, solids, gases, vapors, fumes, and mists.

The chemical inventory lists, along with work practices used in our facility, are located in various places depending on the responsible work unit, where they are accessible during work hours. After the chemical inventory is compiled, it serves as a list of every chemical for which an MSDS must be maintained. The MSDS we use are fact sheets for chemicals which pose a physical or health hazard in the workplace. Employees may obtain access to these lists and MSDS by inquiring of their supervisors.

Chemical inventory lists and MSDS are kept at the following locations in our facility and the associated individuals are responsible for maintaining the lists and associated MSDS current.

  1. Director of Safety & Risk Management Services
  2. Departments must maintain their own chemical inventory list with corresponding MSDS. This must be accessible to the employees at all times.

The procedure followed if the MSDS is not received at time of first shipment of a hazardous chemical is to request a FAX copy from the manufacturer. Alternatives and supplemental information to MSDS's include:

  1. Chemical dictionaries and Merck Index available from the Director of Safety & Risk Management Services
  2. On-line compilation via UW-System @ http://www.uwsa.edu/oslp/safety/uwsres/msds.htm

Labels in our facility describe at least the chemical identity and appropriate hazard warnings. The chemical identity is found on the label, the MSDS, and the chemical inventory. Therefore, the chemical identity links these three sources of information. The chemical identity used by the supplier may be a common or trade name, or a chemical name. The hazard warning is a brief statement or symbol of the hazardous effect(s) of the chemical, e.g. "flammable," or "causes lung damage." Labels frequently contain other information, such as precautionary measures (e.g. "do not use near open flame"), but this information is provided voluntarily by the university and is not required by rule. Our labels are legible and prominently displayed, although their sizes and colors may vary.

Employees who transfer material are responsible for ensuring that all hazardous chemicals in non-original containers are properly labeled and updated as necessary. This is mandatory for any non-original container of hazardous material which remains in the facility after the transferring employee's shift ends.

Posters are used to inform employees about the hazard communication standard. Typical posters explain the HMIS and NFPA information systems. The labeling system used on non-original containers follows HMIS/NFPA and DOT warning label standards.

The following procedures are used to review and update label information when necessary and to ensure that labels are replaced which fall off or become unreadable:

Each employee who works with or may be potentially "exposed" to hazardous chemicals will receive initial training from their supervisor, and any necessary retraining, on the Hazard Communication Standard and the safe use of those hazardous chemicals will be provided by the Director of Safety & Risk Management Services. "Exposure" means that "an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or adsorption, etc.) and includes potential (e.g. accidental or possible) exposure." Whenever a new hazard is introduced, or new information becomes available regarding an old hazard, additional training must be provided.

Information and training are critical parts of the hazard communication program. We train our employees to read and understand the information on labels and MSDS's, determine how the information can be obtained and used in their own work areas, and understand the risks of exposure to the chemicals in their work areas as well as the ways to protect themselves.

Our goal is to ensure employee comprehension and understanding including being aware that they are exposed to hazardous chemicals, knowing how to read and use labels and MSDS's, and appropriately following the protective measure we have established. We ask our employees to ask the Director of Safety & Risk Management Services questions regarding this program. As part of the assessment of the training program, the Director of Safety & Risk Management Services will ask for input from employees regarding the training they have received, and any suggestions they may have for improving it. In these ways we hope to reduce the incidence of chemical source illnesses and injuries.

All employees who work with OSHA hazardous materials must receive training. The format of our training program is mixed media combined with lecture presentations. The training program emphasizes the following elements:

  1. Summary of the standard and this written program;
  2. Chemical and physical properties of hazardous materials;
  3. Methods to detect the presence or release of hazardous chemicals
  4. Physical hazards of chemicals
  5. Health hazards of chemicals including signs and symptoms of exposure to chemicals and any medical conditions known to be aggravated by such exposure
  6. Procedures to protect against hazards such as personal protective equipment, proper use and maintenance; work practices or methods to assure proper use and handling of chemicals; and procedures for emergency response
  7. Work procedures to follow to assure protection when cleaning hazardous chemical spills or leaks
  8. Where MSDS are located, how to read and interpret the information on labels and MSDS's, and how employees may obtain additional information

The procedure to train new employees at the time of their initial assignment and the procedure to retrain affected employees when new hazards are introduced is the responsibility of the employee's immediate supervisor. All training must be documented in writing with the written records retained by the responsible work unit. Copies of training documentation should be forwarded to the Director of Safety & Risk Management Services who also may be called upon for assistance as necessary.

Each contractor bring chemicals into our facility must provide, in advance, the appropriate hazard information on these substances. This information shall include an inventory list of the chemicals, the pertinent MSDS's, the labels used, and any precautionary measures to be taken in working with these chemicals. Contractors' employees working in areas of our facility which contain OSHA hazardous materials must be apprised of the chemicals present, any hazards they represent, and appropriate work procedures to protect themselves from chemical injury.