The Occupational Safety & Health Administration (OSHA) has introduced a regulation entitled Hazard Communication. This regulation applies to all University employees who have the potential for exposure to hazardous chemicals on the job.

Purpose
Marquette University’s Hazard Communication Program is designed to inform all employees who may be potentially exposed to hazardous chemicals on the job. Marquette’s Written Hazard Communication Program is available for review by employees at the Student Employment Office and the Office of Risk Management.

Scope
This program encompasses all Marquette facilities and is available to all employees.

Background
Modern life would be impossible without chemicals. Plastics, synthetic clothing, drugs, and building materials are just a few of the things that are made from chemicals. Chemicals must be treated with respect as many can cause injury or illness if not handles properly. Chemicals may be found in many unexpected places on the job. Chemicals are found in chemical companies, business places and nearly everywhere including our homes.

Everyday chemicals include household polishes, detergents, pesticides, office copier toner, etc. Chlorine is used as a disinfectant in drinking water and swimming pools. Gasoline, a chemical handled by millions of people on a daily basis is extremely flammable and contains cancer-causing ingredient (benzene). Properly used, it causes no health or fire hazards.

Contents

1. Roles and Responsibilities in regards to hazardous chemicals.
2. Criteria for labels and other forms of warning.
3. Criteria for Material Safety Data Sheets (MSDS).
4. The university's methods of informing employees of the chemical hazards in the workplace.
5. The locations of the Lists of the Hazardous Chemicals on campus.
6. The university's methods of informing contractors of hazardous chemicals.
7. Exemptions
8. Summary

1. Responsibilities

The Hazard Communication Standard affects everyone who manufactures, distributes, provides, uses or stores hazardous chemicals in the workplace.

By law, Chemical manufacturers or Distributors must determine the physical and health hazards of each product that they make or distribute. Then they must let users know about those hazards by using container labels and MSDS’s.

Employers must develop a written hazard communication program. They must also:

1. Inform employees about the Hazard Communication Standard.
2. Explain how it’s being put into effect in their workplace.
3. Provide information and training on hazardous chemicals in the workplace including:
   1. Recognizing, understanding and using labels and MSDS’s.
   2. Use safe procedures when working with hazardous substances.

Employees must take positive actions to protect themselves as well. They must read labels, MSDS’s and follow their instructions and warnings.

OSHA has developed these safety regulations and Marquette University has developed a compliance program to protect you. The only person who can keep you safe on the job however, is YOU!

Make these rules part of your job:

1. Identify hazards before you start a job. If you aren’t familiar with a chemical, read the MSDS.
2. Respect all warnings and precautions, don’t take chances.
3. When in doubt, ask your supervisor.
4. Know in advance what could go wrong and what to do about it.
5. Know how and where to get help.
6. Learn basic first aid measures.

2. Labeling and Other Forms of Warning

Every container of hazardous chemicals is labeled by the manufacturer. The actual format may differ, but the labels must contain similar types of information. That makes it easy to find out at a glance about the chemical’s possible hazards, and the basic steps you can take to protect yourself against those risks.

The label may use words or symbols to tell you:

1. The common name of the chemical.
2. The name, address, and emergency phone number of the company that made or imported the chemical.
3. A signal word.
   In order of seriousness, signal words are: Danger, Warning, and Caution.
4. The principal hazards:
   1. Physical hazards such as explosiveness, reactivity, etc., (Will it explode, catch fire, reactive?).
   2. Health hazards such as toxicity, etc., (Is it toxic? Could it cause cancer? Is it an irritant?).
5. Recommended precautionary measures.
   Basic protective clothing, equipment, and procedures that are recommended when working with this chemical.
6. The first-aid instructions.
7. The proper handling and storage instructions.

If using an unlabeled container, notify your supervisor and ask for instructions. The label contains valuable information but if you don’t find everything you need, refer to the MSDS.

To determine if a chemical is hazardous, check the container’s label. There are different types of labels, but all will tell you if a chemical is hazardous. Many Marquette University chemical substances may contain a hazard coding label. Read the labels on all containers and follow all instructions. If you have questions, ask your supervisor or refer to the MSDS.

Marquette University maintains labels, as provided by manufacturers or distributors, on containers of hazardous chemicals and will not remove or deface existing labels on such containers. When transferring a chemical from one container to another, the new container must be labeled properly. Empty containers which may be reused for other purposes must have their original labels removed or obliterated and relabeled as shown below:

1. Identity of the chemical,
2. Appropriate hazard warnings, and
3. Supplier name and address.

3. Material Safety Data Sheets (MSDS)

An MSDS is a written or printed data sheet concerning a chemical which is prepared and distributed by chemical manufacturers and/or distributors.

Updates of MSDS’s on campus are done as new or updated manufacturer MSDS’s are received. New materials introduced into work areas will be controlled by the appropriate departments. MSDS files are maintained throughout our facilities for all hazardous chemicals used in work areas.

MSDS's are in English and available to all employees and contain the following:

The MSDS will provide you with everything you need to work safely with chemicals. MSDS’s may differ in format or length but you will find a summary of everything that’s known about the chemical, its hazards, and precautions to take to avoid injury and illness when handling that particular hazardous substance.

Read the MSDS before using a chemical substance.

4. Training

Employees who work with or are potentially exposed to hazardous chemicals receive initial training on the Hazard Communication Standard and the safe use of those hazardous chemicals using audiovisual materials and classroom type training.

Programs giving an overview of Hazard Communication may include any of the following videos:

• Hazard Communication Today
• Introduction to Working Safely with Chemicals
• Your Health Matters

Regular safety meetings should be used to review or add to the information presented in the initial training. Supervisors should refer to the various University Web Sites to assure that they are aware of updated policies and procedures and as a source of information.

The training plan emphasizes these items:

• Summary of the Hazard Communication Standard (HCS) and the written program.
• Chemical and physical properties of hazardous materials (e.g., flash point, reactivity) and methods that can be used to detect the presence or release of chemicals (including chemicals in unlabeled pipes).
• Physical hazards of chemicals (e.g., potential for fire, explosion, etc.)
• Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
• Work procedures for protection when cleaning up hazardous chemical spills.
• Procedures to protect against hazards (e.g., personal protective equipment, proper use, and maintenance; work practices or methods to assure proper use and handling of chemicals; and, procedures for emergency response).
• The location of MSDS’s, how to read and interpret the information on MSDS’s and chemical containers, and how employees may obtain additional hazard information.
• Hazard Communication Posters are displayed throughout Marquette University facilities on official University bulletin boards located in each building. These posters identify the person to contact for more information.

Supervisors must be aware of training programs offered by the University and attend refresher courses to provide additional employee training concerning workplace hazards when:

• Chemicals with new hazards are introduced into the workplace.
• Equipment changes are made which could cause new or increased employee exposure.
• Procedures and work practices are introduced or changed which could cause new or increased employee exposure.
• Employees are transferred from one work area to another where different hazards may be present.

Video programs covering specific chemical hazards that are available to departments include:

• Corrosive & Irritant Chemicals
• Flammable Chemicals
• Carcinogenic Chemicals
• Poisonous & Toxic Chemicals
• Biological Hazards
• Radiation Hazards
• Cleaning Chemicals

Training Documentation

Documentation for Marquette University’s Hazard Communication Program is in the form of a self test with a passing grade (70%) and is included in each employee’s training file. Records for administrative and faculty employees are maintained by Business Services, records for support staff employees are maintained by Human Resources (except Facility Services employee records are maintained within their department) and records for student employees will be maintained by Student Employment.

Retraining

Supervisors conducting retraining will prepare a written record of the training provided and request the trained employee to sign and date the record. A permanent safety training record is maintained in the employee’s training files.

Non-Routine Tasks

Employees required to perform non-routine tasks, e.g., cleaning tanks, entering confined spaces, etc., should inquire on training sessions that are available from the Risk Management Web Site or Dept. regarding potential exposure to hazardous chemicals and proper precautions to take to reduce or avoid exposure.

5. Locations of the lists of Hazardous Chemicals on Campus

The official list of hazardous chemicals known to be present in the Marquette University workplace can be found in Public Safety. Employees may contact their supervisors or Department of Public Safety regarding chemicals used in their jobs.

6. Contractors

MU purchase orders will contain a brief description of the contractor’s responsibilities. Contractors bringing hazardous chemicals on site are responsible for providing MSDS’s with appropriate hazard information. MU employees working in the vicinity of the contractor’s work site, may review the contractor’s MSDS’s. In turn, MSDS’s of MU chemicals used at the work site may be reviewed by the contractor’s employees.

7. Exemptions

Not all University areas are subject to this standard and hazardous materials are generally identified. If you have questions regarding your department, please contact Risk Management.

All users of chemicals and their supervisors in all University departments should be aware of the hazardous substances holding areas in Chemistry and Biology. Facilities Services and Purchasing have programs in place for chemical and hazardous waste disposal from these sites. Marquette is a small quantity generator under the federal act and must comply with regulations.

The regulations require that the name of each chemical to be stored and/or to be disposed must be clearly marked on each container. As a general rule, chemicals should not be combined, however, in situations where that is acceptable; all substances included must be clearly marked and dated on the container. The date of the accumulation of the stored material must also be clearly marked.

In the case where the exact chemical information is not known, we have contracted with certified laboratories to test the substances. If the composition is unknown, this must also be clearly marked and dated as to placement in any storage or disposal container. Individuals from Chemistry and Biology will assist in log maintenance and shall be trained in the proper protocols for handling these substances.

8. Summary

Marquette’s Hazard Communication Program is designed to ensure safe handling of chemicals on the job and may also be helpful to you at home. Contact your supervisor or the Risk Management Office if you have any questions about this program or safe handling of chemicals on the job.

Marquette University follows a “least risk” policy for all hazardous materials procured, received, handled, stored and disposed of. This means that only the quantity of material absolutely necessary should be on hand.

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