March 1991 (1st Revision)
April 1996 (2nd Revision)
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(Modified for Web Page September 1998)
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May 2012 (7th Revision)
January 2018 (8th Revision)
Office of Safety and Environmental Programs
School of Marine Science
Virginia Institute of Marine Science
College of William & Mary
Gloucester Point, Virginia 23062
TABLE OF CONTENTS
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 in the Office of Safety and Environmental section.
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
- Safety Data Sheets (SDS)
- 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.
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, SDS, 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 SDS for all chemicals within the individual department or work areas.
- Forward any SDS 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 SDS.
- Distribute incoming SDS to appropriate departmental Program Coordinators.
- Maintain the master copy of the list of hazardous chemical substances submitted by each work center.
- Implement the Hazardous Waste Management Program
- Make routine checks of all VIMS/SMS work areas to ensure safe practices are followed.
II. HAZARDOUS CHEMICAL INVENTORY LIST
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 lab manager.
Further information on each chemical can be obtained by reviewing the SDS in the Office of Safety and Environmental Programs or in the immediate work area.
B. Hazard Category Determination
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 SDS.
III. SAFETY DATA SHEETS
The SDS 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 SDS must be studied in detail. Any questions regarding interpretation of information contained on the SDS should be directed to the Office of Safety and Environmental Programs, or the distributor for further information.
When chemicals are ordered SDS will be forwarded under separate cover to the attention of the Office of Safety and Environmental Programs.
A complete file of all SDS for hazardous chemicals used at VIMS will be kept in labeled red binders located in the Office of Safety and Environmental Programs. A copy of each pertinent SDS will be sent to the appropriate department program coordinator by the Office of Safety and Environmental Programs. These SDS will be kept in labeled binders easily accessible to employees and students within the department.
IV. LABELS AND OTHER FORMS OF WARNING
The primary purposes of a label are to identify the material in the container and to serve as a warning in regard to the hazards of that material. The label serves as a visual reminder that the material in the container may pose a health hazard. The label is not intended to be the sole source of information. Should additional information be required, it can be found on the SDS.
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)
- Precautionary and prevention statements and disposal instructions
- Name and address of the manufacturer, distributor, importer, or other responsible party
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.
V. EMPLOYEE/STUDENT INFORMATION AND TRAINING
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 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 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.
- Overview of the Hazard Communication Standard Program
- The labeling system and how to use it
- SDS 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
The above topics, as a minimum, will be stressed during the training.
D. Follow-up Training
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.
VI. HAZARDOUS NON-ROUTINE TASKS
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.
Examples of non-routine tasks:
Task................................................... Potential Hazard
Disturbing/removing asbestos .............. Exposure to friable asbestos insulation
Dismantling duct systems ..................... Perchloric acid
VII. ON-SITE CONTRACTORS
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 person at VIMS of any hazardous chemicals that they intend to use at the job site. Copies of the SDS sheets for those chemicals must be provided to the Office of Safety and Environmental Programs and must be available at the job site.
VIII. CHEMICAL WASTE MANAGEMENT PROGRAM
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. If no one can be contacted or if the spill is immediately dangerous, the Gloucester County emergency dispatcher can be contacted by telephoning-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.
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.
B. Hazardous Waste Disposal
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.