The Hazard Communication Program is designed to inform workers about hazardous chemicals. This is achieved by providing access to information on the physical and health hazards of chemicals, safe handling precautions, and emergency and first aid procedures. This program is also designed to and to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.
Departments are required to establish Hazard Communication Programs to transmit information on the hazards of chemicals used by individuals in their department by labeling containers, ensuring material safety data sheets (MSDSs) are available, and providing training.
The Hazard Communication Program applies to all chemical use at Princeton University, except laboratory areas. Chemical use in laboratories is covered by the Laboratory Standard (see Section C3). In accordance with the OSHA Hazard Communication Standard, certain chemicals are exempt from the standard, including hazardous wastes, food, wood, tobacco, and potentially hazardous substances such as drugs and cosmetics brought to the University for personal consumption.
Under the Hazard Communication Program, individuals who work with hazardous chemicals have the right to know:
Manufacturers, importers, or distributors of chemicals are required to assess the physical and health hazards of their products. This information must be recorded on the product label and included in a material safety data sheet (MSDS).
The manufacturer must label containers with the chemical name(s), hazard warnings, and the manufacturer's name and address.
The manufacturer's label must not be removed or defaced. If the product is transferred from one container to another, the new container must be labeled with the product name, the names of all hazardous chemicals and/or the five most predominant chemical constituents, the Chemical Abstract Service (CAS) number for each chemical, and appropriate hazard warnings.
If the chemical is transferred from a labeled container into a process container, that is, if the transferred material will be used within the workday by the person performing the transfer, the container does not need to be labeled as described above.
Each department must obtain and maintain an MSDS for each hazardous material in their workplace. These MSDSs must be accessible to individuals working with the products during all work hours. If an MSDS is not received with a chemical shipment, the department must obtain the MSDS within a reasonable amount of time.
Each department must develop a written Hazard Communication Program which details how the department will comply with the provisions of the OSHA Standard. The program must include an inventory of hazardous materials used or stored by the department; handling of MSDSs, including where they will be maintained, how they will be obtained, and how to access them; labeling requirements; training requirements; contractor requirements; and provisions for non-routine tasks.
The written program must be accessible to individuals during all work hours, and must be reviewed and updated at least annually. A model written program is available through the Office of Environmental Health and Safety (EHS).
Departments must inform outside contractors of the potential hazards which may be encountered during their work at the University. This includes giving contractors access to the written Hazard Communication Program, the hazardous chemical inventory, and the MSDSs for these chemicals.
Similarly, the contractor is expected to inform and provide departments with a chemical inventory and MSDSs for the materials that will be introduced into the work area in the course of their work at Princeton University. The contractor must also provide information regarding where chemicals will be used and stored.
All individuals who work with hazardous materials must receive training. General training is provided by EHS, and covers the provisions of the federal OSHA Hazard Communication Standard, methods to recognize hazards, hazard evaluation, interpreting MSDSs, common methods to prevent and control chemical exposure, the use and function of personal protective equipment, and general procedures for spill clean-up and hazardous waste.
Specific information about hazardous materials used in the workplace is provided by the individual department. Each department is responsible for informing workers of:
The Department is responsible for assuring that workers attend training and for keeping attendance records of this training.
Special hazards which workers may encounter when performing non-routine duties in the course of their work must be discussed with the worker before the job begins. It is the responsibility of the supervisor to ensure that workers receive specialized training, as needed. EHS may provide assistance in evaluating the hazards and determining the appropriate precautions.