CNM will comply with CFR,Title 29 Part 1910.1200,Hazard Communication Standard (HCS) to ensure that the hazards of all produced or incorporated chemicals are evaluated and the information concerning these hazards is transmitted to CNM’s students and employees.
The standard mandates the evaluation of hazardous chemicals present in a workplace and requires training of students and/or employees regarding the hazardous chemicals and related prevention and protective measures for routine and non-routine tasks.
The Hazard Communication Plan
The Hazard Communication Plan (HCP) consists of five major components:
- Identification and inventory of all hazardous chemicals and listing on a Hazardous Chemical List (HCL).
- Acquisition of Material Safety Data Sheets (MSDS) for each hazardous chemical listed on the HCL.
- Labeling of all hazardous chemicals with chemical name, hazards, warning, and the manufacturer's name, address, and the appropriate MSDS.
- Training of all students and employees about the hazardous chemicals in the classroom and workplace and of the Hazard Communication Plan.
- Procedures for protect against hazardous chemicals
CNM’s Safety Office is the coordinator for the Hazard Communication Plan.
Hazardous Chemicals List
- All departments using hazardous chemicals are responsible for identifying and inventorying.
- A current master list will be maintained at the CNM Safety Office. New chemicals will be added as they are received and chemicals no longer inventories will be removed from the list as they are discarded. A formal inventory and updating of the list will be done annually.
- Each hazardous chemical must be cross-referenced to an appropriate Material Safety Data Sheet.
- The master HCL will be maintained in the CNM Safety Office. Partial lists will be maintained in all classroom and /or departments where hazardous chemicals are used.
Material Safety Data Sheets (MSDS)
- The Hazard Communication Standard requires that MSDSs be available to all employees for each hazardous chemical identified and used. If the employer receives a chemical container labeled as a hazard, an MSDS is required.
- The user department will be responsible for acquiring and maintaining updated versions of all MSDSs.
- The MSDS will be written in English and will consist of all information listed on OSHA Form 174, including the specific chemical identity and common names. Interpreters, readers and/or mechanical devices will be made available to all CNM students and employee who require these services for understanding all “Right- To- Know” information
All new procurements of hazardous chemicals will be evaluated and, whenever possible, the least hazardous substance will be purchased.
Training of all employees regarding any new or updated MSDS will be documented.
Purchase orders for hazardous chemicals will include a request for a current MSDS.
Hazardous chemicals will not be accepted without a MSDS.
Hazardous chemicals should not be incorporated into any work or classroom process until an MSDS has been received and reviewed by students and/or employees exposed to the chemical.
Accessibility of Material Safety Data Sheets.
- The MSDSs will be readily available to all students and/or employees at all times.
- If a new MSDS contains changes or new information, the old MSDS will be replaced with the new one in both the master file and the worksite file. Affected personnel will review updated or modified MSDSs.
Labels and Other Forms of Warning
- Containers of hazardous chemicals will be properly labeled with at least the following information:
- Identify of the hazardous chemical;
- Appropriate hazards and warnings (including target organ effect)
- Name and address of the manufacturer.
- Where the manufacturer’s label provides this information, it shall be used in lieu of a CNM, in-house label.
The appropriate MSDS will be reviewed by departments using hazardous chemicals, to verify the warning label.
Unlabeled containers will not be used.
Secondary containers used by several employees will be labeled and semi-permanent label with the following information will be used:
- Identity of the hazardous chemical;
- Appropriate hazards and warnings (including target organ effect)
- Name and address of the chemical manufacturer.
Use the secondary container only for the chemical identified on the label.
The secondary container will be emptied and washed as needed. The label will not be removed, but will remain in place for future uses.
Alternate methods of labeling (signs, placards, batch tickets, process sheets and like written materials) may be used on individual stationary containers in lieu of affixed labels, provided the alternative method identifies the containers to which it applies and conveys the required information and is readily accessible to students and/or employees in their classroom or work area throughout CNM.
All primary and secondary containers will be regularly checked and verified that labels have not been defaced or removed and the information contained on them is current.
Training and Communication
- Prior to use, each student and/or employee, who works with or is potentially exposed to hazardous chemicals will receive training on the Hazard Communication Standard and the specific use of applicable hazardous chemicals
- Prior to the introduction of a new hazardous material or updated hazard, each student and/or employee will receive training on the specific use or handling procedures.
Training will emphasize the following elements:
- A summary of the Hazard Communication Standard and Hazard Communication Plan;
- Hazardous chemical properties, including visual appearance, odor, and methods that can be used to detect the presence or release of hazardous chemicals.
- Physical and health hazards of the chemicals in the classroom and/or work area (including signs and symptoms of exposure) and any medical conditions known to be aggravated by exposure to the chemical.
Procedures to protect against hazards including:
- Personal protective equipment .
- Proper use and maintenance of personal protective equipment
- Work practices or methods to assure proper use and handling of chemicals.
- Emergency response procedures.
- Work procedures to follow to assure protection when cleaning hazardous chemicals and leaks.
- Location of MSDS, interpretation of their contents and labeling information, as well as instructions for students and/or employees in how to obtain and use appropriate hazard information.
- Explanation of the labeling system and instructions for preparing secondary container labels.
Student and/or employee training will be documented and monitored for use in identifying training needs.
- Retraining is required when a chemical hazard changes or when a new hazard is introduced into the workplace.
- It is CNM Safety Offices policy to include hazard communications information into staff meetings
- The training program will be assessed by obtaining input from student and/or employees regarding training they have received and their suggestions for improvement.
- Student and/or employees contemplating undertaking a non-routine task, e.g., instrument repair and cleaning etc., will ensure that all student and/or employees are informed of chemical hazards associated with the performance of these tasks and that appropriate protective measures are taken prior to the beginning of the task.