HAZARD COMMUNICATION

The Engineering ProgramTexas A&M University

Safe Use, Handling & Storage of Chemicals and Other Affected Materials

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Topics to Review • The Texas Hazard Communication Act• The TAMU HazCom Program• Requirements for “Laboratory Departments”• HazCom Implementation Plans • Supervisor Responsibility for Compliance• HazCom in:

– Research Labs

– Teaching Labs

– Chemical Storerooms

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What is HazCom?

The Texas Hazard Communication Act is a state law that requires public employers to provide employees with

specific information on the hazards of chemicals to which they

may be exposed in the

workplace.

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HazCom Requirements• Written Program (EHSD)

– Duties & Responsibilities

– Non-Routine Release

– Training

– Inventory

– Labeling

– MSDS

– Supervision

– Notice to Employees

– Records

– Reports

• Implementation Plans– Workplace - Dept

– *Work Area - Supervisor

*Optional

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HazCom Facts

• Texas is not an “OSHA State.”• HazCom for state agencies is under TDH.• Private employers are regulated by OSHA.• The Texas HazCom Act and TDH Rules are

similar, but not identical with the OSHA Standard.• Texas does not have a “Lab Standard.”• TDH does recognize that research labs are

different from other work places.

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Definitions

Employee: anyone (including students) who is on the payroll of TAMU or a TAMUS Agency and who may be exposed to hazardous chemicals in the

workplace under normal working conditions or foreseeable emergency.

Facility: Geographical location of one or more workplaces. TAMU and the

Riverside Campus are facilities.

Workplace: Usually a single building (BioBio) or complex of buildings (Chemistry) where similar work activities are conducted.

Work Area: Room, lab or defined space within a workplace where hazardous chemicals are present, produced, used, or stored and where employees are present.

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HazCom at TAMU

Texas Hazard Communication Act: Enforced by TDH

TAMU HazCom Program: Administered by EHSD

Workplace Implementation Plan: Dept. or Administrative Unit

Work Area Implementation Plan: Room, lab or space

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HazCom in Research Departments

• Appoint Hazard Communication Coordinator

• Prepare a Workplace Implementation Plan

• Post official TDH “NOTICE TO EMPLOYEES”

• Urge supervisors to complete a Work Area Implementation Plan

• Require supervisors to certify (at least annually) that all required training is complete and current.

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Workplace Implementation Plan

•Name of Department or Unit•Responsible Person or Position•Location of Training Records•Location of MSDSs•“Notice to Employees” Location•Person Responsible for Inventory•Location of Inventory File

See “Fill-in-the-Blank” Form

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SPECIAL WORK AREAS

• Teaching Labs

• Chemical Stockrooms

• Research Labs

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Hazardous Chemical Inventory

Workplace quantities: > 50 gal. or 500 lbs

Listed Extremely Hazardous Substances

Controlled Substances

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LABELS

PRIMARY CONTAINERS

•Original label•Intact•Good condition•Not removed or defaced

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• identity of material as on MSDS

• health and physical hazards (including target organs.)

• manufacturer’s name and address

Primary Containers

Labeling Requirements

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LABELING Secondary Containers

Other Work Places Full label required on

EVERY CONTAINER Identity of material as on

MSDS Written hazard warnings Target organs

•Research Labs•Full label NOT required•Identify contents

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TEACHING LABS

Container Labels• Primary containers must have Full Labels

• Small 20containers may be labeled on rack or holder

Chemical Inventory• Incorporate into the Workplace Inventory.

– Workplace must report > 50 gal or > 500 lb. (or > TPQ) for the Tier II Report

Primary container labels must include:•identity of contents..same as on MSDS•hazard warnings (including target organs or systems)•Mfgr. name & address

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CHEMICAL STOCK ROOMS

•Label all containers (unless for immediate use).

• Include in Workplace Inventory. Workplace must report > 50 gal or 500 lb. or > TRQ.

NOTE:A room or area that is connected to, and accessible ONLY through a research lab, is considered to be part of the lab.

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MSDS REQUIREMENTS•READILY ACCESSIBLE - within one work shift•CURRENT - most recent

EHSD Recommendation: •Maintain printed copy for:

–hazardous materials in use–reasonable likelihood of exposure–highly hazardous substances present in the work area

•Train employees on how to access MSDS –http://ehsd.tamu.edu--MSDS Search–Call EHSD 845-2132–Call manufacturer & request copy

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Required Training

General lab safety

Chemical safety training

Work site specific training

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Changes in Training Requirements

• “New employee video” (aka “Category I Training) DOES NOT satisfy training requirements.

• Training ONLY for employees who have “routine exposure to hazardous chemicals.

• “Category II” Training now called “Hazard-Specific Training.”

• There is no requirement to repeat training.

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TRAINING RECORDSDate Training Provided

Name(s) of Instructors

Attendance List - Names MUST be legible

Subjects Covered

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GENERAL TRAINING

•General Lab Safety•General Chemical Safety by Hazard Class•Labeling Requirements•General Ways to Access MSDS Information•Interpretation and Relationship of Labels & MSDS•Safe Handling Procedures•Proper Storage & Separation of Incompatible Chemicals•Minimizing Exposure -- PPE & Safety Equipment•General Emergency Procedures•Spill Response & Cleanup•Management & Disposal of Hazardous Chemical Waste

Can be provided by EHSD

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SPECIFIC TRAINING

Site-SpecificChemical-SpecificHazard-Specific

Supervisor Responsibility

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Specific Information and Training

• Provide appropriate information and training to new or newly assigned employees before he/she work with or handles hazardous chemicals.

• Additional training is required when:– a new or significantly increased hazard is

introduced into the work area, – if the potential for exposure is significantly

increased

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SITE-SPECIFIC TRAINING

•Where hazardous materials are located and used. •Unusual or particularly hazardous materials or procedures

•Location and access to MSDS & other safety information.

•Location and use of safety equipment (including PPE)

•Storage & labeling procedures in the lab

•Emergency equipment & procedures, first aid

•Exposure prevention and recognition

•Proper storage of hazardous materials

•Location and use of spill equipment

•Specific hazard information on the chemicals in the lab

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MSDS INFORMATION•Chemical and Common Names•Hazardous Ingredients•Physical and Chemical Characteristics•Physical Hazards•Health Hazards•Primary Routes of Entry•Exposure Limits•Confirmed or Potential Carcinogen•Proper Handling and Storage•Control Measures•Emergency and First Aid Procedures•Date of Preparation or Latest Revision•Name, Address, Phone of Mfgr. or Responsible Party

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Hazard Communication

Compliance in Research Laboratories

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CHARACTERISTICS OF A RESEARCH LABORATORY

(According to TDH & OSHA)

»Relatively small quantities of hazardous chemicals present and/or used.

»Not for production

»Containers, etc are designed for one person to easily and safely manipulate.

»Multiple chemicals and procedures used.

»Protective lab practices and equipment available and in common use.

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HazCom Requirements for RESEARCH LABS

•Technically qualified SUPERVISION

•“Ready” access to Material Safety Data Sheets

•LABELING on primary containers

•Employee TRAINING prior to potential exposure

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CONSEQUENCES of NON-COMPLIANCE

Loss of Research Lab Exemption

Fines

Personal & Employer Liability

Personal & Employer Aggravation

Paperwork

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WORK AREA IMPLEMENTATION PLAN

Not required,but HIGHLY RECOMMENDED

ADVANTAGESMinimal effort

Proof of Training Compliance

Customized Lab Safety Manual

Reduction of Legal and Regulatory Liability

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OPTIONS FOR WORK AREA PLAN

•Do nothing or “Do it yourself.”

•Basic Plan

•Basic Plan plus Lab-Specific Protocols

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OPTION IBASIC IMPLEMENTATION PLAN

•Commitment to Safety & Health•Lab location•Responsible persons•Training documentation•Sketch of lab •MSDS Access - specific information•Hazard warnings•Hazard identification & labeling •Chemical inventory

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OPTION IILABORATORY SAFETY PLAN

Basic Plan plus:• Principles of Laboratory Safety• Strategies for Minimizing Exposure

– Engineering controls

– Administrative controls

– Protective equipment

• Laboratory Safety Rules and Procedures

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Laboratory Safety Rules & Procedures• Prudent practices

• Personal hygiene

• Food & drinks in the lab

• Personal protective equipment

• Chemical fume hoods

• Chemical storage

• Hazardous waste

• Housekeeping

• Facility & equipment maintenance

• Guards & shields

• Glassware

• Fire prevention

• Cold traps & cryogenic hazards

• Pressurized systems

• Unattended operations

• Working alone

• Prior approval

• Vigilance

• Everyday hazards

• Regulated/restricted areas or procedures

• Accident reporting

• Emergency information

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Working With Hazardous Chemicals

• Toxic Chemicals– High acute or unknown toxicity

– High chronic toxicity

– High chronic toxicity - animal use

– Reproductive toxins

– Chemicals produced in the lab

• Physical hazards– Flammable solvents

– Corrosive chemicals