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In the last two years SMU has disposed of 23,073 lbs of hazardous materials.
RMEHS.006
Effective date-March 1990
Southern Methodist University (SMU) has a commitment to provide each of its employees a safe and healthy work environment. It is recognized that laboratory processes and other essential procedures frequently require the use of chemicals that have potentially hazardous properties. When using these substances, it is important that workers are aware of the identity and toxic or hazardous properties of the chemical, since an informed employee is more likely to be a careful employee.
This written Hazard Communication Program has been developed by SMU to ensure that all employees receive consistent and accurate information about the hazardous substances they work with in compliance with the Occupational Safety and Health Administration’s (OSHA) Hazard Communication Standard (29 CFR 1910.1200). This operating procedure addresses the following program elements:
This operating procedure applies to all faculty and staff members (full- and part-time) who may be exposed to, under normal conditions of use or in a foreseeable emergency, any chemical which may be present in the workplace. University personnel who work in laboratory operations must also comply with the University’s Chemical Hygiene Plan.
Each department is responsible for implementing the following program elements of this written program into their operations and ensuring compliance by their employees. The Office of Risk Management and Environmental Health & Safety (RMEH&S) is responsible for auditing program compliance and provide consulting resources to each department.
5.1. Any substance listed in the following references shall be considered hazardous:
OSHA 29 CFR 1910, Subpart Z - Toxic and Hazardous Substances;
ACGIH Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment;
The Annual Report on Carcinogens by the National Toxicology Program; or
Monographs by the International Agency for Research on Cancer (IARC).
5.2 Any human epidemiological study, individual case report or animal toxicological testing which indicates that a material presents a health hazard, will be considered hazardous, provided the study indicated an adverse health effect that is likely to occur, the results are statistically significant, and that the study was conducted in accordance with scientific principles.
5.3 Each department shall develop and maintain a Chemical Inventory List (CIL) for every hazardous substance known to be present in their work area(s). The identity of the substance appearing on the CIL shall be the same name that appears on the manufacturer’s label and the MSDS for that substance. Specific procedures for developing and maintaining the CIL are provided in APPENDIX C of this operating procedure. The CIL shall be updated at least annually to accurately reflect all the hazardous chemicals present in each department’s work area(s).
6.1 No hazardous chemicals shall be accepted for use at the University, or shipped to any other location, unless labeled with the following information:
Identity of the hazardous chemical(s);
Appropriate hazard warnings; and
Name and address of the chemical manufacturer, importer or other responsible party.
6.2 No hazardous chemical shall be used in the work area unless labeled with at least the following information:
Identity of the hazardous chemical(s); and
Appropriate hazard warnings.
6.3 All labels shall be legible, in English, and prominently displayed on the container. The identity of the material that appears on the label shall be the same as the chemical name that appears on the manufacturer’s material safety data sheet (MSDS) and the department’s CIL.
6.4 If the hazardous chemical is regulated by OSHA in a substance specific health standard, the label used shall be in accordance with the requirements of that specific standard.
6.5 In certain situations involving individual stationary process containers, the label may be replaced by a sign, placard, process sheet, batch ticket, or other means to convey the identity of the hazardous chemical and the appropriate hazard warnings. If these other forms of warning are used, they must be readily accessible to employees in their department or work area during each work shift.
6.6 In accordance with OSHA’s Hazard Communication Standard, labels are not required on portable containers into which hazardous chemicals are transferred from labeled containers, if and only if, the contents of the portable container are intended for immediate use by the employee who performed the transfer. Labeling of the portable container will prevent any possible misuse of the material by others and is highly recommended.
6.7 Any portable container of a hazardous chemical that is not intended for immediate use shall be properly labeled by the department. The "in-house" label can be either hand-made or pre-printed and shall contain the information identified in Section 6.2. Employees with questions concerning the appropriate in-house label to use should refer to the manufacturer’s MSDS or ask their supervisor.
6.8 No label on a container is to be defaced or removed unless the container is immediately marked with the required information. No employee shall remove any label unless specifically directed to do so by their supervisor. Any container without a label shall be immediately reported to the work area supervisor.
Manufacturers, suppliers, and importers of hazardous chemicals are required to develop and provide a material safety data sheet (MSDS) for their products. The MSDS provides detailed information concerning the chemical’s composition, health and safety hazards, proper disposal practices and appropriate handling and control measures.
7.1 Central MSDS File-- A central hard-copy MSDS file shall be maintained in the RMEH&S offices. This central file is compiled of MSDS received and processed by the University’s Purchasing Department. In addition to the central file, the RMEH&S provides access to computer-based MSDS files via their department web page at - http:// www.smu.edu/business_services/RISKMGT/EHSMain.asp
7.2 Departmental MSDS File -- Each department or work area shall maintain a departmental file that contains copies of all manufacturers’ MSDS for each chemical listed on their CIL. This file must contain the most current version of the manufacturers’ MSDS and shall be readily accessible to any employee in the work area at any time during their work shift.
Each new employee shall receive a brief introduction to the SMU Hazard Communication Program, as well as other EH&S topics, during their new employee orientation program sponsored by the Human Resources Department.
8.1 Training Curriculum -- the training program shall include the following:
Overview of the OSHA Hazard Communication Standard;
How to recognize and detect the presence of hazardous chemicals in the work area;
How to access and read a MSDS;
Labeling requirements and procedures;
Identification of hazard categories;
Protective controls and measures; and
Any department specific procedures regarding hazardous chemicals.
8.2 Initial Training -- shall be provided by the supervisor to each employee on the hazardous chemicals in their work area at the time of their initial assignment.
8.3 Refresher Training -- shall be provided by the supervisor to their employees whenever a new physical or health hazard that the employees have not previously been trained about is introduced into their work area.
8.4 Non-routine Tasks -- prior to performing any non-routine task that could involve exposure to hazardous chemicals, the supervisor shall review with the employee(s) all potential hazards of the task. The supervisor shall prescribe appropriate work practices and protective controls. RMEH&S can provide consulting services to the department on the non-routine task.
All contractors performing any work on University property shall provide a list of all hazardous chemicals they will be using. The chemical list shall be provided to the contractor’s designated University liaison or project coordinator. The contractor shall provide, upon request, a copy of any and all MSDS for the chemicals they are using when requested by the University.
SMU shall provide, upon request, a copy of the University’s Hazard Communication Program and shall inform the contractor, prior to the start of their work, the location and potential hazards of all known hazardous chemicals they may be present in their work area.
Appendix A -- Definitions
Chemical name - means the scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemistry Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation.
Combustible liquid - means any liquid having a flashpoint at or above 100 0F (37.8 0C) but below 200 0F (93.3 0C), except any mixture having components with flashpoints of 200 0F (93.3 0C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.
Compressed gas - means a:
gas or mixture of having, in a container, an absolute pressure exceeding 40 psi at 70 0F (21.1 0C); or
gas or mixture of gases having, in a container an absolute pressure exceeding 104 psi at 130 0F (54.4 0C) regardless of the pressure at 70 0F (21.1 0C); or
liquid having a vapor pressure exceeding 40 psi at 100 0F (37.8 0C) as determined by ASTM D-323-72.
Employee - means a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered.
Explosive - means a chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.
Exposure or exposed - means that an employee is subjected in the course of employment to a chemical that is a physical or health, and includes potential (e.g. accidental or possible) exposure. "Subjected" in terms of health hazards includes include any route of entry (e.g. inhalation ingestion, skin contact or absorption.)
Flammable - means a chemical that falls into one of the following categories:
Gas, flammable - means: (i) A gas that, at ambient temperature and pressure, forms a flammable mixture with air at a concentration of thirteen (13) percent by volume or less; or (ii) A gas that, at ambient temperature and pressure, forms a range of flammable mixtures with air wider than twelve (12) percent by volume, regardless of the lower limit.
Liquid, flammable - means any liquid having a flashpoint below 100 0F (37.8 0C), except any mixture having components with flashpoints of 100 0F (37.8 oC) or higher, the total of which make up 99 percent or more of the total volume of the mixture.
Solid, flammable - means a solid, other than a blasting agent or explosive as defined in 29 CFR 1910.109 (a), that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard. A chemical shall be considered to be a flammable solid if, when tested by the method described in 16 CFR 1500.44, it ignites and burns with a self-sustained flame at a rate greater than one-tenth of an inch per second along its major axis.
Flashpoint - means the minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite.
Foreseeable emergency - means any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.
Hazardous chemical - means any chemical which is a physical or a health hazard.
Hazard warning - means any words, pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical and health(s), including target organ effects, of the chemical(s) in the container(s).
Health hazard - means a chemical for which there is statistically significant evidence based on at east one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term " health hazard" includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizes, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.
Material Safety Data Sheets (MSDS) - a written or printed material concerning a hazardous chemical which is prepared in accordance with OSHA requirements.
Mixture - means any combination of two or more chemicals if the combination is not, in whole or in part, the result of a chemical reaction.
Oxidizer - means a chemical other than a blasting agent or explosive as defined in 29 CFR 1910.109 (a), that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.
Physical hazard - means a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.
Unstable (reactive) - means a chemical which in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shocks, pressure or temperature.
Work area - a room or defined space in a workplace where hazardous chemicals are produced or used, and where employees are present.
Appendix B -- Exemptions
1.0 Total Exemptions
In accordance with the OSHA Hazard Communication Standard (29 CFR 1910.1200) the University’s Hazard Communication Program does not apply to:
1.1 Any hazardous waste subject to regulations issued under the Environmental Protection Agency’s (EPA) Solid Waste Disposal Act, Resource Conservation and Recovery Act (RCRA) of 1976;
1.2 Any hazardous substance which is the focus of remedial or removal action being conducted under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA);
1.3 Any tobacco or tobacco products;
1.4 Wood or wood products, including lumber which will not be processed, where the chemical manufacturer or importer can establish that the only hazard they pose to employees is the potential for flammability or combustibility. Wood or wood products which have been treated with a hazardous chemical covered by the OSHA Hazard Communication Standard, and wood which may be subsequently sawed or cut, generating dust, are not exempt.
1.5 Articles as defined as any manufactured item other than a fluid or particle which,
Is formed to a specific shape or design during manufacture;
Has end use function(s) dependent in whole or part upon its shape or design during end use; and
Under normal conditions of use does not release more than small (trace) quantities of a hazardous chemical, and does not pose a physical hazard or health risk to employees.
1.6 Food or alcoholic beverages which are sold, used, or prepared in a retail establishment and foods intended for personal consumption by employees while in the workplace;
1.7 Any drug, as defined in the Federal Food, Drug and Cosmetic Act, when it is in solid, final form for direct administration to the patient, any drugs which are packaged by the chemical manufacturer for sale to consumers in a retail establishment, and any drugs intended for personal consumption by employees while in the workplace.
1.8 Cosmetics which are packaged for sale to consumers in retail establishments, and cosmetics intended for personal consumption by employees while in the workplace.
1.9 Any consumer product or hazardous substance as defined in the Consumer Product Safety Actand the Federal Hazardous Substance Act respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the intended purpose;
1.10 Nuisance particulates where the chemical manufacturer or importer can establish that they do not pose any physical or health hazard covered defined by under the OSHA Hazard Communication Standard;
1.11 Ionizing and non-ionizing radiation; and
1.12 Biological hazards.
2.0 Labeling ExemptionsIn accordance with the OSHA Hazard Communication Standard (29 CFR 1910.1200) the following items are exempt from labeling requirements:
2.1 Any pesticide that are subject to labeling requirements and regulations as defined in the Federal Insecticide, Fungicide, and Rodenticide Act, issued by the EPA;
2.2 Any chemical substance or mixture that is subject to labeling requirements and regulations as defined in the Toxic Substances Control Act (ToSCA), issued by the EPA;
2.3 Any food, food additive, color additive, drug, cosmetic, or medical or veterinary device or product, including materials intended for use as ingredients in such products that is subject to labeling requirements and regulations as defined in the Federal Food, Drug, and Cosmetic Act or the Virus-Serum-Toxin Act of 1913, as issued by the Food and Drug Administration (FDA) or the Department of Agriculture, respectively;
2.4 Any distilled spirits, wine, or malt beverage intended for non-industrial use when subject to labeling requirements and regulations as defined in the Federal Alcohol Administration Act, issued by the Bureau of Alcohol, Tobacco, and Firearms (BATF);
2.5 Any consumer product or hazardous substance as subject to the labeling requirements and regulations as defined in the Consumer Product Safety Act and the Federal Hazardous Substances Act, respectively, as issued by the Consumer Product Safety Commission; and
2.6 Agriculture or vegetable seed treated with pesticides as subject to labeling requirements and regulations as defined in the Federal Seed Act, as issued by the Department of Agriculture.
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