Section 8: Hazard Communication Plan

8.1      Hazard Communication - General

A.     Scope:  This policy applies to the selecting, handling, storing, using, and disposal of all hazardous materials at PVCC from receipt through use; and to all hazardous waste from generation to the final disposal. 

B.     It is the policy of PVCC to manage all hazardous materials and waste in a manner consistent with applicable laws and regulations through the waste management policies contained in this Manual. 

C.     The purpose of this policy is to protect employees, students, and the community from the effects of exposure to hazardous materials. 

D.     The safety committee has the authority to establish, support, and maintain the procedures necessary to ensure compliance with this program (see Section 3: Safety & Health Organization). 

  1. The committee has the authorization to take immediate corrective action in cases of imminent risk of exposure to hazardous material.
  2. All PVCC employees and students have the right to review and access MSDS/SDS’s, inventories of chemicals to which they may be exposed, and the Hazard Communication Program.

8.2      Procedures

A.     Each department is responsible for ensuring that MSDS/SDS are provided by the manufacturer or distributor for all hazardous substances obtained by their department and for confirming that a copy of all MSDS/SDS has been filed with the procurement office.

  1. MSDS/SDS forms shall be available to all employees and students in their work area.  Each department is responsible for maintaining and updating these files.
  2. The facilities manager shall forward any MSDS/SDS received with incoming shipments to the department in receipt of the shipment and the procurement office.
  3. Master MSDS/SDS files shall be kept in the procurement office and the facilities office. 

B.     Labeling Requirements:  These labeling requirements apply to all containers of chemicals used at PVCC, as well as to containers of chemicals and hazardous materials being shipped off-site.  The labeling program shall follow the guidelines in the Chemical Hygiene Plan (Section 7). Also, the following procedures apply:

  1. No unmarked container of chemicals shall be used unless the container is portable and the chemical is for immediate use and under the control of the person who transfers it from a labeled container.

    a. Container means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical.

    b. Pipes or piping systems, and engines, fuel tanks, or other operating systems in vehicles, are not considered to be containers for purposes of this policy.

    c. Immediate use means that the hazardous chemical shall be used only during the class in which it is transferred.
  2. PVCC shall provide a container labeling kit to any employee requesting one. 

    a. Employees shall not remove or deface labels on incoming containers of hazardous chemicals.

    b. Labels for containers of hazardous chemicals shall be defaced after use. 
  3. Label Information for a Single Chemical (Non-Mixture):  PVCC shall provide the appropriate hazard rating and chemical compatibility charts required to label containers.  The label shall include, without limitation, the following:

    a. The personal protective equipment (PPE) required to use or handle the chemical.

    b. The DOT hazard class i.e., whether the chemical is flammable, toxic, irritating, corrosive, water-reactive, or is an oxidizer.

    c. The chemical name as reflected on the MSDS/SDS. 
  4. Label Information for Mixtures:  PVCC shall provide the appropriate hazard rating and chemical data to label containers.  The MSDS/SDS of the chemicals used to create the mixture shall be consulted to determine labeling requirements.

    a. If a mixture has been tested by an approved laboratory as a whole to determine its hazardous characteristics, the results of such testing shall be used to determine whether the mixture is hazardous and to provide the appropriate labeling information.

    b. If a mixture has not been tested as a whole to determine whether the mixture is a health hazard, the mixture shall be assumed to present the same health hazards as do all its components which comprise one percent (by weight or volume) or greater of the mixture.  Scientifically, valid data, such as that provided on the MSDS/SDS, shall be used to evaluate the physical hazard potential of the mixture. The chemical hygiene officer shall be consulted to provide any hazard analysis assistance required.
  5. Labels are not required on the following:
  6. Any pesticide as such term is defined in the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136 et seq.), when subject to the labeling requirements of that Act and labeling regulations issued under that Act by the Environmental Protection Agency.

    a. Any food, food additive, color additive, drug, cosmetic, or medical or veterinary device, including materials intended for use as ingredients in such products (e.g. flavors and fragrances), as such terms are defined in the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301 et seq.) and regulations issued under that Act, when they are subject to the labeling requirements under that Act by the Food and Drug Administration;

    b. Any distilled spirits (beverage alcohols), wine, or malt beverage intended for nonindustrial use, as such terms are defined in the Federal Alcohol Administration Act (27 U.S.C. 201 et seq.) and regulations issued under that Act, when subject to the labeling requirements of that Act and labeling regulations issued under that Act by the Bureau of Alcohol Tobacco, and Firearms.

    c. Any consumer product or hazardous substance as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, when subject to a consumer product safety standard or labeling requirement of those Acts, or regulations issued under those Acts by the Consumer Product Safety Commission.

    d. Any containers of chemicals and hazardous materials being shipped off-site designated as hazardous waste.

C.     Each department shall maintain an inventory of all hazardous materials used, handled, or stored in that department.  The chemical names on the inventory shall correspond with those in the MSDS/SDS.

  1. When a product is no longer in use or an MSDS/SDS is replaced, the old MSDS/SDS shall be archived and the procurement officer shall be notified.
  2. The procurement officer shall supply departments with an annual inventory of the hazardous materials located in their area. Each department shall check this list against their MSDS/SDS Manual and physical inventory and advise the procurement officer of any changes or updates.

D.     All hazardous materials shall be stored in accordance with rules for incompatible chemicals as defined in the MSDS/SDS.

  1. Hazardous chemicals shall be kept in the laboratories in the smallest containers practical.  Quantities stored shall be kept to a minimum.
  2. Flammable chemicals shall be stored in fireproof cabinets that are designated for these chemicals only.
  3. Compressed gas cylinders shall be stored away from traffic, heat sources, and anything flammable.  Cylinders shall be fastened and secured in an upright position.

E.     All environmental and occupational waste requiring special handling based on local, state, and federal regulations shall be disposed of properly.

  1. Infectious waste shall be disposed of as follows:

    a. Contained in leak-proof plastic bags. When there are multiple bags, each bag shall be sealed separately. 

    b. Delivered to the Keats building, room 203, by the person responsible as soon as possible. 

    c. The procurement officer shall be notified when infectious waste needs to be picked up. 
  2. Sharps shall be collected at the point of generation in puncture-resistant sharps containers, and those containers shall be picked up by a qualified, licensed contractor.  A manifest of the waste disposal shall be kept by the procurement officer with the invoice file.
  3. Any paints or thinners that are identified as hazardous shall be disposed of in 55-gallon drums and shall be removed from campus by a qualified, licensed contractor.  A manifest of the removal will be kept by the procurement officer with the invoice file.

F.     See Section 6 of this manual for exposure control measures for bloodborne pathogens and for more detailed information concerning handling and disposing of infectious materials.

G.     Personal Exposure or Spill Response:  PVCC shall ensure that required emergency materials are available as specified on the MSDS/SDS.

  1. PPE, as identified on the MSDS/SDS required for each hazardous substance, shall be worn.
  2. When there is an incident of exposure the employee or student shall follow these guidelines:

    a. Follow the recommendation on the MSDS/ SDS.

    b. Notify immediate supervisor or department head of incident and, if necessary, human resources shall complete an incident or injury report and record on the OSHA 300 Log.

    c. All incidents that require special spill precautions or assistance to clean up shall be reported to the PVCC department of public safety.

H.     Training:  Supervisors and/or department heads shall be responsible for providing training for each employee and student who regularly comes in contact with hazardous materials.  This training shall take place at the time of their assignment and new hazardous products/substances are introduced. Training requirements shall be reviewed as required.

  1. Following the completion of the training program employees and students shall be able to comply with the following:

    a. Describe the requirements of the Hazard Communication Program.

    b. Identify the general chemicals and hazardous materials present on campus. 

    c. Recognize the physical and health effects of these chemicals and hazardous materials.

    d. Describe steps taken to lessen or prevent exposure to chemicals.

    e. Understand potential exposure sources and routes of exposure.

    f.  Describe the methods and observation techniques used to determine the presence or release of hazardous materials in the work area.

    g. Demonstrate how to read labels and MSDS/SDS to obtain appropriate hazard information.

    h. Understand appropriate response procedures, including notification procedures, should an exposure occur.

    i.  Apply the correct procedure in the transfer and storage of all hazardous materials in the work environment.

    j.  Locate and use the personal protective equipment within the department.

    k. Understand how to lessen or prevent exposure to hazardous substances through the usage of control, work practices, and personal protective equipment.

    l.  Understand emergency and first aid procedures to follow if employees are exposed to a hazardous substance(s).

    m. Understand the methods and observation techniques used to determine the presence or release of hazardous substances in their work area.

    n. Use spill containment procedures within their work environment.

    o. Demonstrate the use of the correct procedure for disposing of hazardous material used routinely on the job.

I.     Hazardous Non-Routine Tasks:  No PVCC employee or student shall be required or allowed to perform tasks for which he or she not fully trained.  Before beginning work, all such non-routine tasks shall be evaluated and the related hazard(s) shall be assessed and adequate protective measures shall be developed.

J.     Informing Contractors:  PVCC’s contract representative, who serves as the liaison between the college and the contractor, shall provide information on hazardous substances located on campus that the contractor may come in contact with.

  1. The contractor shall be responsible for training their employees. 

8.3      Definitions

A.     Hazardous Material:  Any substance which, when used as intended in the normal work process, poses a health or safety hazard rating of two or higher to employees or the environment.  These include:

  1. Any material that is flammable at less than 140 degrees Fahrenheit.
  2. Any corrosive material (burns skin or eyes on contact.)
  3. Any reactive material (unstable, explodes, or releases toxic vapors if exposed to other chemicals, or water).
  4. Those chemicals and hazardous substances identified by the Environment Protection Agency (EPA) regulations.
  5. Substances whose allowable concentration in workplace air are established or proposed to be established by the American Conference of Government Industrial Hygienists.
  6. All the substances considered hazardous by the National Institute of Occupational Safety and Health.
  7. Medical and infectious waste.

                B.     Waste: Any material that is no longer needed and which requires disposal.

8.4      Performance Standards

Employees in nursing, facilities, building trades, biology, chemistry, welding, electronics, graphic imaging, and woodworking are aware of the location of their department-specific MSDS/SDS. 

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