SUNY COBLESKILL HAZARD COMMUNICATION PROGRAM
I: General
The purpose of this written program is to ensure that SUNY Cobleskill is in compliance with the OSHA Hazard Communication Standard (HCS) 29 CFR 19 10.1200 and the New York State Right to Know Law.
The Environmental Health and Safety Officer (Suna Stone-McMasters) is the overall coordinator of the campus program and acts as the representative of the Vice President for Administration (Gary Miller) who has overall responsibility.
Each employee in the facility will be informed of the availability of this written program, the contents of the hazard communication standard (HCS) and the “Right to Know” legislation. Employees will be advised of all known hazardous properties of the chemicals they work with, and the measures they need to take to protect themselves from these chemicals. Any employee who routinely handles chemicals or materials that meet the OSHA HCS definition of “hazardous” will be given initial training upon hire. At least annually, each employee will be offered refresher training in Hazard Communication/Right to Know.
II: List of Hazardous Chemicals
The Environmental Health and Safety (EH&S) Officer will maintain an inventory of all hazardous chemicals used in the facility, and update the list as necessary.
Each campus department will be responsible for maintaining a list of all hazardous chemicals used in their areas and will update this list as inventory changes. Inventory lists shall be forwarded to the EH&S Office if so requested by the EH&S Officer.
III: Material Safety Data Sheets
Material Safety Data Sheets (MSDS) must be accessible for all employees at SUNY Cobleskill who handle hazardous materials. The Environmental Health and Safety Officer will maintain a Material Safety Data Sheet (MSDS) on every hazardous chemical or substance used at SUNY Cobleskill in a centralized file located in the EH&S Office in the Facilities Management building.
The department supervisor will also be responsible for ensuring that an MSDS for every hazardous substance or chemical used in their area is maintained in a file in their area and available for review by any employee within that department who may use the chemical in the course of their job duties. If a department supervisor or chair requires assistance in compiling or updated their MSDS files they may request assistance from the EH & S Officer by calling x5411.
As chemicals are ordered and received, the original MSDS will be sent to the EH&S Officer so that the master inventory can be updated. Department chairs or supervisors should ensure that a copy of that MSDS is placed in their departmental file. As MSDS's are received by the EH&S Officer, a copy will be made and forwarded to the appropriate department employee who ordered the substance, or the departmental supervisor or chair. The EH&S Officer shall review all MSDS's received by SUNY Cobleskill for accuracy and completeness in accordance with OSHA guidelines ,i.e. all MSDS's must meet the criteria of OSHA Form 174 or equivalent. The EH&S Officer will contact the manufacturer or supplier and/or the localPublic Employee Safety and Health (PESH) area office if inaccuracies are noted on any MSDS received at SUNY Cobleskill.
IV: Ordering New Chemicals
A copy of the MSDS will be requested in advance of ordering any new chemical and sent to the attention of the EH&S Officer so that the hazard information can be reviewed prior to ordering. Whenever feasible, safer substitutes or the least hazardous substance shall be ordered. (The EH&S Officer is available to assist any department in reviewing hazard information found on the MSDS and also in exploring safer chemical alternatives by calling x.5411 or e-mail StoneMSA@cobleskill.edu. MSDS's must be received at SUNY Cobleskill prior to or at the time of receipt of the first shipment of any potentially hazardous substance purchased from a vendor. SUNY Cobleskill reserves the right to discontinue procurements from vendors failing to provide approved MSDS's in a timely manner.
V: Samples and donations
No SUNY Cobleskill employee shall accept “sample” chemicals, free chemicals or demonstration lots of any chemicals or donations of chemicals from other institutions without first notifying their department supervisor and the EH&S Officer in writing. In addition, an accurate and current MSDS for any sample or free hazardous chemical must be provided prior to approval of acceptance. Disposal of an unwanted “free” sample can be costly. Any SUNY Cobleskill employee who accepts trials or samples of hazardous products or knowingly accepts chemical donations and brings them onto SUNY Cobleskill property without following these procedures may be subject to disciplinary action.
VI: Labels and Hazard Warnings
It is the policy of SUNY Cobleskill that all chemical containers, both original containers and any transfer containers, (ie spray bottles, pails, safety cans, lab bottles, flasks, etc,) must be properly labeled at all times. The EH&S Officer is responsible for ensuring that the campus complies with this important component of our hazard communication program.
Each supervisor, department head, or chair is responsible for ensuring that all chemicals used in their area are properly labeled. Containers received from vendors shall be labeled so that at least the manufacturer and address, hazard properties and frill chemical and trade names are clearly legible on the container. Transfer containers such as spray bottles, etc., shall be labeled in accordance with the hazard warnings specified on the product's MSDS and shall, at minimum, include the trade and chemical name, hazard warnings,, e.g.: FLAMMABLE, CORROSIVE, IRRITANT, OXIDIZER, PEROXIDE-FORMER, etc. and supplier or manufacturer (i.e., Baker, Fisher, Butchers, State Chemical, Nalco, John Deere, Agway, etc.) If target organ data is specified on the original container (i.e.: affects liver and kidneys; can cause skin sensitization; reproductive hazards, etc.) then that information should also be included on the transfer or secondary container label. Never remove a label from any container unless you immediately replace it with another one. The EH&S Officer will periodically audit departments at random to check for accuracy of all container labels on SUNY Cobleskill property. The EH&S Officer is also available to assist departmental supervisory personnel in meeting their responsibilities under this provision.
VII: Unlabeled Containers or Unknowns
Unlabeled containers are illegal and forbidden. All unlabeled containers whose contents you are not absolutely certain of should be immediately reported to the EH&S Office (x.5411).
Departmental supervisory personnel shall periodically check that all containers in their departmental area(s) are properly labeled. The EH&S Office is available to assist campus supervisors in meeting their responsibilities under this important requirement.
Any unlabeled containers found on campus may be considered potentially dangerous “unknowns” and may be confiscated or otherwise removed by the EH&S Officer. If it is necessary to sample and/or dispose of unlabeled chemicals the department may be charged for any and all costs of sampling and disposal. Departments where repeated or flagrant labeling violations are encountered will be required to attend additional Hazard Communication and Right to Know training.
VIII: Training
Each employee who routinely works with or is potentially exposed to hazardous chemicals will receive initial training on the Hazard Communication Standard and the New York State Right to Know law upon hire and annually thereafter. Such training will be coordinated through the EH&S Office and written rosters of attendance will be kept. Every effort will be made to offer such training within the first two weeks of hire. (The Human Resources Office will notify the EH & S Officer of names and departments of all new employees no later than one week after hire).
The initial and refresher trainings offered by the EH&S Office will include:
- A summary of the HCS standard and this written program
- Physical and health hazards associated with potential exposure to workplace chemicals
- How to read an MSDS and where they are available in the work area (i.e., through your supervisor or the EH&S Officer)
- Inventory of toxic substances in each work area
- An explanation of protective equipment needed to work safely with the product and a review of safe work practices
- Hazardous chemical properties including visual appearance and odor and methods that can be used to detect the presence or release of hazardous chemicals
- Emergency procedures, i.e., how to handle chemical leaks or spills
In addition, training will be offered whenever new chemicals or hazardous substances are introduced into the work area. These trainings will be conducted by the employee supervisor and will include a thorough review of the hazards of the new chemical (i.e., a review of the MSDS). The supervisor may contact the EH&S Officer for assistance in reviewing hazards of any new chemicals.
The Environmental Health and Safety Officer will maintain records of trainings including copies of attendance rosters and training outlines. Attendance will be taken at training sessions and departmental supervisors will be advised of training needs. Copies of all safety training rosters are forwarded by the EH&S Office to the Human Resources Department. Failure to attend Hazard Communication/Right to Know training may result in disciplinary action.
IX: Contractor Employees
The EH & S Office, upon notification from the Facilities Management Director or a designated SUNY Construction Fund representative or Facilities Coordinator, shall advise outside contractors of any hazardous substances they may encounter in the course of their work at SUNY Cobleskill. Material safety data sheets shall be made available to the appropriate outside contractor representative upon request. SUNY Cobleskill is not responsible for conducting or coordinating the outside contractor's hazard communication program. SUNY Cobleskill reserves the right to request copies of all material safety data sheets from an outside contractor if any campus employees may be exposed to chemicals used by outside contractors on SUNY Cobleskill property or if the EH&S office or Facilities Management supervisory personnel determines that use of the outside contractor's product(s) could potentially result in an exposure to any campus employee.
X: Non-Routine Tasks
Facilities Management and other departmental supervisors contemplating a non-routine task, e.g. boiler repair, will consult with the EH&S Officer and will ensure that employees are informed of chemical hazards associated with the performance of these tasks and appropriate protective measures. This will be accomplished by a meeting of supervisors and the EH&S Officer with affected employees before such work is begun.
XI: Additional Information
For more information about any aspect of the SUNY Cobleskill Hazard Communication written program or for additional information about safe use and handling of chemicals contact Suna Stone-McMasters in the Environmental Health and Safety Office at (518) 255-5411.
Hazard Communication Standard 1910.1200
Hazard Communication Standard 1910.1200 App. A
Hazard Communication Standard 1910.1200 App. B
Hazard Communication Standard 1910.1200 App C
Hazard Communication Standard 1910.1200 App D
Hazard Communication Standard 1910.1200 App ENew York State Labor Department's Albany office can provide written NYS labor regulations, which are identical to the federal OSHA regulations. The phone number is (518) 457-5508. To view the State Right to Know poster, visit:
http://www.labor.state.ny.us/pdf/sh908.pdf.