I. INTRODUCTION
A. Purpose
B. Scope
C. Responsibilities

II. HAZARDOUS CHEMICAL INVENTORY LIST
A. Location
B. Hazard Category Determination

III. MATERIAL SAFETY DATA SHEETS
A. Introduction
B. Procedures

IV. LABELS AND OTHER FORMS OF WARNING
A. General
B. Requirement
C. Procedures

V. EMPLOYEE/STUDENT INFORMATION AND TRAINING
A. Introduction
B. Topics
C. Topics
D. Follow-up Training

VI. HAZARDOUS NON-ROUTINE TASKS
A. General
B. Examples

VII. ON-SITE CONTRACTORS

VIII. CHEMICAL WASTE MANAGEMENT PROGRAM
A. Hazardous Waste Management
B. Hazardous Waste Disposal

IX. PROGRAM REVIEW

The Federal Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS)(29CFR1910.1200), adopted by the Commonwealth of Virginia and enforced by the Virginia Occupational Safety and Health Administration (VOSHA) was promulgated to ensure that all chemicals produced or imported would be evaluated and that information regarding their hazards and appropriate protective measures would be communicated to all employers and employees. The goal of the standard is to reduce the number of chemical related occupational related illnesses and injuries and to promote safety and awareness in the work place.

In order to comply with the requirements of the HCS, this written program has been established for the Virginia Institute of Marine Science/School of Marine Science (VIMS/SMS). All work areas within VIMS/SMS are included in this program. This document is available for review by any employee:

• The document is accessible over the VIMS computer network and in the Office of Safety and Environmental section under Administration

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This program covers all faculty, staff, students, volunteers, guests, and contractors who may become directly or indirectly involved with or exposed to any chemical substance, product or other hazardous material in the work area. This includes receipt, packaging, storage, transport, use, disposal, or emergency response and cleanup activities, under normal conditions of use.

Basic components of this program include:

• Hazardous Chemical Inventory List
• Material Safety Data Sheets (MSDS)
• Labels and other Forms of Warning
• Employee Information and Training
• Non-routine Tasks
• Unlabeled Pipes
• On-site Contractors

Hazardous Waste Management and Hazardous Waste Disposal are the subjects of other documents.

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1. Department and Work Center Heads

• Ensure that all persons under their supervision are made aware of the HCS Program and that compliance with the program is mandatory by state and federal law.
• Ensure that all persons under their supervision attend the mandatory HCS training sessions presented by the Office of Safety and Environmental Programs as soon as possible after reporting for work.
• Ensure that immediate supervisors supplement this training by further educating or training their personnel on the specific hazards of the chemicals in their work areas, safe practices to use while working with chemicals, and proper use of labels, MSDS, and storage of hazardous waste.
• The Department and Work Center Heads will appoint a Hazard Communication Standard/Chemical Waste Management Program Coordinator and submit his/her name to the Office of Safety and Environmental Programs.

2. Individuals (Faculty, Staff, Students, Volunteers, and Guests)

• Follow all established safety regulations and procedures.

3. Hazard Communication Standard/Chemical Waste Management Program Coordinators

• Maintain an up-to-date, accessible file of MSDS for all chemicals within the individual department or work areas.
• Forward any MSDS received directly from a distributor to the Office of Safety and Environmental Programs for compilation, reproduction, and distribution.
• Prepare, maintain, and update as needed, a list of hazardous chemicals used or stored within the department or work center. The list should include the name, physical description, quantity, and specific location of the hazardous chemicals. This list shall be submitted to the Office of Safety and Environmental Programs annually in July).

4. Office of Safety and Environmental Programs

• Develop, coordinate, implement, maintain, and monitor the VIMS Hazard Communication Standard/Chemical Waste Management Program.
• Schedule and conduct new employee training and other special training as required. Training shall be documented and the documentation shall be maintained in the Office of Safety and Environmental Programs.
• Establish and maintain a master file of all MSDS.
• Distribute incoming MSDS to appropriate departmental Program Coordinators.
• Maintain the master copy of the list of hazardous chemical substances submitted by each.
• Implement the Hazardous Waste Management Program
• Make routine cheeks of all VIMS/SMS work areas to ensure safe practices are followed.
• Review all purchase orders for hazardous chemical substances to ensure an MSDS is on hand. If no MSDS is available, submit request letter to the appropriate distributor requesting same.

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A. Location

A list of all known hazardous chemicals used at VIMS available from the Office of Safety and Environmental Programs. A list of all hazardous chemicals used by each department is available from each department program coordinator.

Further information on each chemical can be obtained by reviewing the MSDS in the Office of Safety and Environmental Programs or in the immediate work area.

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All hazardous materials used at VIMS are purchased materials. There are no manufactured or intermediate hazardous chemicals produced at VIMS. Therefore, VIMS shall rely on the hazard determination made by the chemical manufacturer as indicated on the MSDS.

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A. Introduction

The MSDS is the primary source of chemical hazard information for the user. Labels primarily serve to identify compounds in use and to provide a quick hazard warning. To determine the properties and effects of a particular substance, the MSDS must be studied in detail. Any questions regarding interpretation of information contained on the MSDS should be directed to the Office of Safety and Environmental Programs, or the distributor for further information.

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When chemicals are ordered and an MSDS is not on file, the requester shall specify on the purchase order that chemicals not be shipped without a corresponding MSDS. The following suggested statement can be used: "Shipper: Do not ship without MSDS. MSDS may be forwarded under separate cover to the attention of the Office of Safety and Environmental Programs."

All MSDS should be forwarded to the Office of Safety and Environmental Programs for review and processing. If necessary, the Office of Safety and Environmental Programs will submit a letter to the manufacturer requesting additional required information. After three documented, unsuccessful requests to a manufacturer or distributor for MSDS information, the Office of Safety and Environmental Programs will report the difficulty to VOSHA.

A complete file of all MSDS for hazardous chemicals used at VIMS will be kept in labeled red binders located in the Office of Safety and Environmental Programs (Clayton Annex, Room 102A). A copy of each pertinent MSDS will be sent to the appropriate department program coordinator by the Office of Safety and Environmental Programs. These MSDS will be kept in labeled binders easily accessible to employees and students within the department.

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The Hazard Communication Standard requires that all hazardous chemicals be labeled by the manufacturer. The label must contain the following:

• Chemical identity/complete description of contents
• Appropriate hazard warning(s)
• Name and address of the manufacturer, distributor, importer, or other responsible party

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Upon receipt of any new chemical, the person receiving the shipment will ensure that the container is properly labeled. Any chemical without proper labeling must not be accepted.

It is also the responsibility of that individual, or a designated representative within that department, to periodically check for the presence or absence of labels on all chemical containers and to replace a missing or damaged label, if necessary.

When chemicals are transferred from the original container to a secondary container, the individual making the transfer will ensure that the secondary container is properly labeled with the chemical name and appropriate hazard warning(s). Preprinted labels can be ordered from various distributors. There is an exception to the requirement for labeling of secondary containers for portable containers into which hazardous chemicals are transferred from labeled containers and which are intended only for the immediate (same work shift) use of the individual who performs the transfer. This container must be under continuous control of the user. If it is left unattended in the work place, it is no longer under control and must be labeled or the contents returned to the original container..

For stationary process containers such as a mixing vessel, signs, placards, process sheets, batch tickets, operating procedures, or other appropriate written materials may be used to communicate the hazard.

The labeling procedures used at VIMS will be reviewed by the Office of Safety and Environmental Programs and changed as necessary.

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Training is the heart of the Hazard Communication Program as it ties all aspects of the program together. The program is successful only when all personnel are fully aware of the potential chemical hazards in their work areas. Special requirements such as work practices, emergency response actions, and use of personal protective equipment must be well understood in order to work safely. This training and information program is designed to develop good working habits and to stress the employee/student role in working safely with hazardous chemicals. Many chemicals are have little or no odor and cannot be seen in their gaseous state. Training is the only proactive means of alerting personnel to the presence of their hazards.

New employees, students, volunteers, and long term guests at VIMS shall attend a Hazard Communication Standard information and training program soon after their arrival on campus. The Office of Safety and Environmental Programs is responsible for conducting this initial training. The individual's supervisor is responsible for ensuring that he or she attends this training at the earliest opportunity. Training will consist of an approximately one hour session of video presentation and discussions. Training sessions will be presented on a regular schedule and additional sessions can be scheduled if required. Following each training session, each individual will sign and date the training certificate verifying attendance. Records of training shall be maintained by the Office of Safety and Environmental Programs.

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The following topics, as a minimum, will be stressed during the training:

• Overview of the Hazard Communication Standard Program
• The labeling system and how to use it
• MSDS use and location
• Typical chemicals present during work operations
• Physical/health effects of hazardous chemicals
• Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area
• Use of personal protective equipment
• Work practices to lessen or prevent exposure to chemicals
• Safety/emergency procedures
• Chemical hazardous waste management procedure
• Location and availability of this program

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At the completion of the initial training, personnel should have a basic knowledge of safety and procedures to be followed when working with hazardous chemicals and of sources of information about those chemicals. However, specific work practices and hazardous chemicals being used will vary depending on the area to which the individual is assigned. It is imperative that the individual be informed of the hazardous materials in the work area and of the specific procedures to be followed when performing his or her duties.

This training will be conducted by an individual designated by the Department or Work Center Head for each work area, usually the person in charge of this follow-up training will be the principal investigator on the project or the individual's immediate supervisor, and will cover as a minimum the hazardous materials and operating procedures pertinent to that work area. Training should be provided any time new hazardous chemicals are introduced into the work area or operating procedures are changed.

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A. General

Periodically, certain persons may be required to perform hazardous non-routine tasks. Prior to starting work on such tasks, each affected person will be given information by the supervisor regarding any hazardous chemicals to which he or she may be exposed. This information will include, as a minimum, specific chemical hazards, protective or safety measures required, and measures already taken such as ventilation, respirators, administrative controls, presence of other employees, and emergency procedures to lessen potential hazards.

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Examples of non-routine tasks:

Task................................................... Potential Hazard

Disturbing/removing asbestos .............. Exposure to friable asbestos
insulation

Transformer/capacitor/other ................ Exposure to PCBs
electrical equipment repair

Dismantling duct systems ..................... Perchloric acid

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It is the responsibility of each person supervising the work of an outside contractor to provide the contractor with the following information prior to executing contractual work:

• Presence of hazardous chemicals to which they may be exposed while on the job site
• Precautions that need to be taken to reduce the possibility of exposures (safety procedures, protective equipment, etc.)
• Location of emergency equipment such as eye wash stations, showers, fire extinguishers, etc.

It is the responsibility of the contractor to inform the contracting officer at VIMS of any hazardous chemicals that they intend to use at the job site. Copies of the MSDS sheets for those chemical must be provided to the Office of Safety and Environmental Programs and must be available at the job site.

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A. Hazardous Waste Management

Minimization of waste is the most basic strategy employed in the management of any form of waste especially hazardous or chemical waste. One important aspect of a waste minimization program is the concept of "less is better." This concept includes buying only the quantity that is expected to be used. Although it may appear less expensive to buy in large quantities, it is in fact more expensive when the cost for disposal of the unused portion is taken into consideration.

All waste containers must be labeled correctly prior to collection. In order for wastes to be disposed of, the exact contents, including approximate percentage breakdown, must be known. Testing of unknowns prior to disposal is very costly.

Consolidation of similar wastes into appropriate containers is good practice. It is far less expensive to package, transport and dispose of a 1-gallon bottle of acid waste than several 1-pint bottles.

It is important not to let waste accumulate in a lab especially when individual projects are completed and specific knowledge of the waste materials may be forgotten or lost. Waste chemicals will be transferred to the chemical waste storage facility maintained by the Office of Safety and Environmental Programs in a timely and expeditious manner.

All chemical waste to be transported to the chemical waste storage facility for disposal will be in safe, well-sealed, labeled containers. Contaminated glassware (e.g. broken thermometers, pipet tips, etc.) must be placed in puncture-proof containers. Hazardous waste labels are available from the Office of Safety and Environmental Programs.

All hazardous waste will be transported to the hazardous waste shed by the Office of Safety and Environmental Programs. Under no circumstances will privately-owned vehicles be used. All waste will be securely transported in the authorized vehicle as follows:

If in glass containers, each container must be placed in a separate non-breakable container so as to avoid touching another breakable container. Each container must be braced to avoid tipping, breaking, or leaking. All containers must be properly marked with the name of the waste and the words hazardous waste clearly visible.

Any spill of hazardous chemicals must be reported immediately . During working hours the spill will be reported by dialing 7000, the VIMS telephone console and asking the attendant to notify the Office of Safety and Environmental Programs. Large quantities of chemical waste should not be transported outside of normal working hours; however, if there is a substantial spill after working hours (nights, weekends, holidays), an attempt should be made to contact the VIMS Emergency Response Coordinator (see the tag affixed to telephones) or anyone on the staff of the Office of Safety and Environmental Programs. If no one can be contacted or if the spill is immediately dangerous, the Gloucester County emergency dispatcher can be contacted by telephoning 9-911. Properly trained and protected personnel will come to evaluate and clean-up the spill. Minor spills can be cleaned up with towels etc. and controlled as hazardous waste. For additional information, consult the Chemical Hygiene Plan.

The Office of Safety and Environmental Programs will provide the initial HAZMAT Response Team during working hours and will take necessary action to obtain additional support and notify proper authorities.

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The Office of Safety and Environmental Programs is responsible for all actions required to dispose of hazardous waste generated at VIMS once this waste has been transferred to the storage facility. Hazardous waste will be stored, controlled, inventoried, and disposed of in accordance with all applicable laws and regulations.

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