Written Hazard Communication Program

1. Introduction

The purpose of this program is to ensure that Worcester Polytechnic Institute is in compliance with OSHA Hazard Communication Standard (HCS), 29 CFR 1910.1200.

The Director of Environmental Health and Safety is the safety coordinator of the HCS program.

Each employee at WPI will be informed of the HCS and its requirements, their rights under the Standard, the nature of material hazards in the workplace, and how to avoid harm from undue exposure to those hazards.

Further information about this written program, applicable Safety Data Sheets (SDS'S) or the Hazard Communication Standard in general, is available from Daniel Sarachick, dtsarachick@wpi.edu, Environmental Health and Safety, or Michael Carney, mjcarney@wpi.edu Human Resources Director. 

2. Hazardous Materials List

Environmental Health and Safety will maintain a list of all hazardous materials used at WPI. Manufacturers and suppliers will be relied upon to determine whether each material is hazardous or not, based on information supplied on each SDS. If neither an SDS nor assurance that one is not needed is furnished with any material when received from the supplier, that material will not be placed into use until such documentation is available.

The list will be updated upon receipt of any hazardous material not previously listed. The master list of hazardous materials is maintained by Environmental Health and Safety.

Appendix C gives more details concerning the list, as well as detailed information regarding physical and health hazard data.

3. Safety Data Sheets

The Safety Data Sheet (SDS) provides technical information relating to chemical, physical and hazard information for a hazardous material. The OSHA Standard states that the employer must maintain a complete and accurate SDS for each hazardous chemical that is used or stored in the facility.

Environmental Health and Safety will maintain the central file containing an SDS for every item on the list of hazardous materials. All employees will have access to the list of materials and to the SDS'S at all times. SDS's are available on the Environmental Health and Safety homepage.

Because WPI has a decentralized purchasing and receiving system, the following procurement policy is necessary. Each time a new hazardous material is ordered by a department, an SDS must accompany all materials received. Make a copy of the SDS for your department file, and forward the original to Environmental Health and Safety. If you do not receive a copy of the SDS upon receipt of the material, do not use it until one arrives. Contact Environmental Health and Safety for any problems experienced in obtaining an SDS from a vendor.

A few sample SDS's are enclosed in Appendix A.

4. Labeling

Each hazardous material container at WPI must have a proper label with the identity of the hazardous chemical, as well as appropriate hazard warning labels. The warning may be in the form of words, pictures, symbols or combinations which convey the hazard(s) of the chemicals in the container. All labels must be legible and prominently displayed.

Any containers into which materials are transferred for in-house use, other than for immediate transfer for use by the employee filling the container, shall be labeled consistently with the label on the original container.

Any container label which is removed or defaced in the course of its use or storage shall be promptly replaced. Laboratory Supervisors shall be responsible for insuring that annual inspections of hazardous chemicals are conducted in order to insure the appropriate labeling of chemical containers.

Appendix B contains sample labels and National Fire Protection Association chemical hazard identification systems information.

5. Employee Training and Information

Each employee who works with or may be exposed to hazardous materials shall be informed of the provisions of the Hazard Communication Standard, including the location and availability of the hazardous materials lists, the SDS files, and the Written Hazard Communication Program. In addition, the essential features of this information shall be posted on bulletin boards located in all areas where hazardous materials are stored or used within WPI.

Each employee who works with or may be exposed to hazardous materials shall receive training on the hazardous properties and safe use of those materials. Recipients of this training shall include employees who occasionally may be exposed as well as those who are regularly exposed. Additional training shall be provided for employees whenever a new hazard is introduced into their work areas. Hazardous material training is to be conducted by Environmental Health and Safety. The training will emphasize the following elements:

• Identity of hazardous materials in the work area.
• Means of identifying hazardous materials.
• Physical and health hazards associated with the materials.
• Symptoms of overexposure to hazardous materials.
• Procedures to protect against hazards under normal use conditions.
• Procedures to protect against hazards in emergency conditions.
• First aid procedures where appropriate.
• Procedures in case of a spill or leak of hazardous materials.

Environmental Health and Safety will maintain records of training received by all employees and will schedule the initial training as well as any additional training needed as functions change and as new hazards are introduced into particular work areas.

New employees will be given the Hazard Communication Training manual at their orientation by the Human Resources Department. Additional training will be provided by the Department of Plant Services, Environmental Health and Safety, upon notification by the Human Resource Department of all new employee hiring's within all affected departments at WPI.

As of January 31, 1991, laboratories are no longer subject to the provisions of this standard. On that date employers must be in full compliance with the OSHA Laboratory Standard, 29 CFR 1910.1450. OSHA has set up this laboratory standard to address the specific safety needs of the research and commercial laboratory.

Information on the OSHA Laboratory Standard as it applies to WPI can be obtained by contacting Environmental Health and Safety. 

Work areas where employees only handle chemicals in sealed containers which are not opened under normal working conditions shall not remove or deface any labels on the containers and forward all copies of the SDS to Environmental Health and Safety at ehs@wpi.edu. Employees will also receive appropriate training on how to detect the presence or release of a hazardous chemical, how to protect themselves from any hazards, what an SDS is and how to obtain one, and where the Written Hazard Communication Program is kept, what it is, and how to arrange to see it. This training will be given as per the above format.

6. Nonroutine Tasks

Environmental Health and Safety, with assistance from each department head, will be responsible for identifying nonroutine tasks at WPI. These tasks might include: nonroutine maintenance and cleaning of equipment; response to emergencies such as fires, floods or explosions which could release hazardous materials which do not occur on a regular basis. Environmental Health and Safety will schedule and oversee appropriate training in hazard recognition and avoidance for the workers to be assigned to the task.

7. Outside Contractors

Environmental Health and Safety, with assistance from the Plant Services Department, shall be responsible for all communication and training with outside contractors and their employees regarding hazardous materials. The contractors shall be informed of all chemical hazards in the work area, as well as the location of any required SDS at WPI.

In addition, all contractors will be requested to review with Environmental Health and Safety or the Worcester Polytechnic Institute Project Engineer all information regarding material hazards to be introduced by the activities of the contractor. Environmental Health and Safety will then be responsible for transmitting such hazard information to employees who work in the affected area(s) and might be exposed to the hazards.