Hazard Communication & the Globally Harmonized System (GHS)

Risk Management, Environmental Health & Safety Smith Hall 103 Mt. Pleasant, MI 48859 (989) 774-7398 www.cmich.edu/cmuehs 2018

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This guideline was created and issued by the Risk Management, Environmental Health & Safety

Department (RMEH&S) to provide guidance and consistency in management of chemical

containing products that are used by Central Michigan University (CMU) faculty, staff, and

students.

TABLE OF CONTENTS

Section Page

I. SUMMARY ................................................................................................................................3

II. SCOPE .......................................................................................................................................3

III. REFERENCE REGULATIONS .........................................................................................................3

IV. DEFINITIONS ..............................................................................................................................3

V. RESPONSIBILITIES ......................................................................................................................6

A. Deans, Directors and Department Heads: .......................................................................7

B. Supervisors:...................................................................................................................7

C. Employees/Student Employees: .....................................................................................7

D. Risk Management, Environmental Health & Safety: ........................................................7

E. Departments Preparing Specifications for Contractors: (Facilities Management, Plant Engineering & Planning (PEP), etc.): ...............................................................................8

VI. PROCEDURES .............................................................................................................................8

VII. TRAINING ..................................................................................................................................9

VIII. HAZARDOUS MATERIAL INFORMATION ................................................................................... 10

IX. RELATED DOCUMENTS ............................................................................................................. 12

Appendix A: SDS Location Poster - To be posted in areas where chemicals are used or stored .. 13

Appendix B: New or Revised SDS Poster - To be posted in areas where chemicals are used or stored ................................................................................................................ 14

Appendix C: Sample GHS Label ............................................................................................... 15

Appendix D: Sample Secondary/Portable Workplace Label...................................................... 16

Appendix E: Pictogram Labels ................................................................................................ 17

Appendix F: Chemical Compatibility Chart .............................................................................. 18

Appendix G: Model HazCom Program ..................................................................................... 19

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I. SUMMARY

The purpose of this guideline is to assure that all CMU employees who use chemical-containing

products in their work activities are instructed to work with them in a safe manner as required by

Federal Regulation 29CFR 1910.1200 along with Michigan Regulation Part 42, 92, 430 Hazard

Communication Program (HazCom). A Hazard Communication Program is necessary for

communicating workplace chemical hazards to employees. This guideline identifies

departmental responsibilities and the necessary administrative oversight for managing the

HazCom Program. A Model Hazard Communication Program has been attached in Appendix G to

assist departments in writing a HazCom Program specific for their needs.

II. SCOPE

This plan applies to all Central Michigan University employees that utilize any hazardous

chemicals as defined under the Occupational Safety and Health Administration (OSHA) and

Michigan Occupational Safety and Health Act (MIOSHA) Hazard Communication Standard.

Laboratory workers are covered under the Laboratory Safety Standard/Chemical Hygiene

Program, which has similar requirements. Labs address Hazard Communication issues in their

respective Chemical Hygiene Plans (CHP) and are not required to have a written HazCom

program for their departments. Departments operating under the Lab Safety Standard should

ensure operations are consistent with OH Part 431 Hazardous Work in Laboratories and OSHA

Laboratory Standard 29CFR 1910.1450.

III. REFERENCE REGULATIONS

State of Michigan Right to Know Law Act No. 80 Amendments to Act 154 MIOSHA:

Construction Safety Standard Part 42 Hazard Communication

MIOSHA General Industry Safety Standard Part 92 Hazard Communication

MIOSHA Occupational Health Standard Part 430 Hazard Communication

IV. DEFINITIONS

Chemical: Any element, chemical compound, or mixture of elements and/or compounds.

Exposure to chemicals can be in a variety of forms such as: solids, liquids, gases, vapors, dusts,

mists, or fumes.

Chemical Hygiene Plan (CHP): The intent of a CHP is to protect employees from hazardous

chemicals and promote a healthy and safe environment. The CHP includes information to

ensure that employees have working knowledge about the hazardous chemicals they use. The

CHP is also intended to provide information on best practices in laboratory health and safety.

Exposure (or Exposed): Occurs when an employee is subjected in the course of employment

to a chemical that is a physical or health hazard and includes potential accidental or possible

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exposure. “Subjected” in terms of health hazards include any route of entry, for example,

inhalation, ingestion, skin contact or absorption.

Hazard Category: The division on criteria within each hazard class, for example, oral acute

toxicity, and flammable liquids include four categories. These categories compare hazard

severity within a hazard class and should not be taken as a comparison of hazard categories

more generally.

Hazard Class: The nature of the physical or health hazards, for example, flammable solid,

carcinogen, oral acute toxicity.

Hazard Not Otherwise Classified (HNOC): An adverse physical or health effect identified

through evaluation of scientific evidence during the classification process that does not

meet the specified criteria for the physical or health classes.

Hazard Statements: Hazard statements are standardized and assigned phrases that describe the

hazard(s) as determined by hazard classification. An appropriate statement for each GHS hazard

should be included on the label for products possessing more than one hazard.

Hazardous Chemical: Any chemical which is classified as a physical hazard, or a health hazard, a

simple asphyxiant, combustible dust, pyrophoric gas, or HNOC. For example, compressed gas is

considered a physical hazard and wood dust is considered a health hazard.

Health Hazard: A chemical for which there is statistically significant evidence that acute or

chronic health effects may occur. The term “health hazard” applies to chemicals that are:

Carcinogens

Toxic or highly toxic agents

Reproductive toxins

Irritants, corrosives

Sensitizers

Hepatotoxins (affect the liver)

Nephrotoxins (affect the kidneys)

Neurotoxins (affect the nervous system)

Agents which act on the hematopoietic (blood forming) system

Agents that damage the lungs, skin, eyes, or mucous membranes

Label: An appropriate group of written, printed, or graphic information elements concerning a

hazardous chemical that is affixed to, printed on, or attached to the immediate container of a

hazardous chemical, or on the outside of packaging.

Mixture: A combination or solution composed of two or more substances in which they do not react.

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Personal Protection Equipment (PPE): Devices worn by employees to protect against hazards in

the environment. See CMU PPE Written Program.

Eye and face protection (safety glasses, goggles, face shields)

Lab coats

Apron

Hand protection (latex, nitrile, leather, rubber gloves, etc.)

Foot protection (safety shoes, shoe covers, “booties”)

Physical Hazard: A chemical that is classified as having one or more of the following hazardous effects:

Explosive

Flammable (gases, aerosols, liquids, or solids)

Oxidizer (liquids, solids, or gas)

Self-reactive

Pyrophoric (liquid or solid)

Self-heating

Organic peroxide

Corrosive to metal

Gas under pressure

Contact with water emits flammable gases

Pictograms: A composition that may include symbols plus other graphic elements, such as a

border, background pattern, or color, that is intended to convey specific information about the

hazards of a chemical. Eight mandatory pictograms and one non-mandatory pictogram that are

designated under the MIOSHA standard for application to a particular hazard category (see

Appendix E).

Precautionary Statement: A phrase that describes recommended measures that should be

taken to minimize or prevent adverse effects resulting from the exposure to a hazardous

chemical or improper storage or handling.

Pyrophoric Gas: A chemical in a gaseous state that will ignite spontaneously in air at a

temperature of 1300F (54.40C) or below.

Safety Data Sheet (SDS): Formerly known as Material Safety Data Sheet (MSDS). The SDS is a

written or printed material concerning a hazardous chemical that serves as an informational tool

developed by chemical manufacturers including, but not limited to the following information for

a hazardous chemical:

Product Identification

Use Restrictions

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Hazard Identification

Chemical Ingredients

First-Aid Measures

Fire-Fighting Measures

Accidental Release Measures

Handling and Storage Information

Physical and Chemical Properties

Stability and Reactivity Information

Toxicological Information

SDS are in a standardized, sixteen-section format and can be obtained from the chemical

suppliers and many internet sites.

Signal Words: The signal word indicates the relative degree of severity of a hazard. The signal

words used in the GHS are:

“Danger” for the more severe hazards

“Warning” for the less severe hazards

Signal words are standardized and assigned to the hazard categories within endpoints. Some

lower level hazard categories do not use signal words. Only one signal word corresponding to

the class of the most severe hazard should be used on a label.

Simple Asphyxiant: A substance or mixture that displaces oxygen in the ambient atmosphere and

can thus cause oxygen deprivation in those who are exposed, which leads to unconsciousness

and death.

Substance: Chemical elements and their compounds in the natural state or obtained by any

production process, including any additive necessary to preserve the stability of the product and

any impurities deriving from the process used, but excluding any solvent which may be separated

without affecting the stability of the substance or changing its composition.

Trade Secrets: Any confidential formula, pattern, process, device, information or compilation of

information that is used in an employer’s business and that gives the employer an opportunity to

obtain an advantage over competitors who do not know or use it.

Use: To package, handle, react, emit, extract, generate as a byproduct or transfer.

V. RESPONSIBILITIES

This program applies to faculty, staff, student employees, temporary employees, graduate

assistants, and contract employees under the direct supervision of department employees

who may come into contact with or be exposed to hazardous materials at the workplace while

performing their normal duties or during emergency conditions. It also applies to those who

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are involved in the purchase, transportation, or storage of hazardous materials.

A. Deans, Directors and Department Heads:

Designate and empower supervisors who will be responsible for the

preparation and implementation of the Hazard Communication Program

within each work unit.

Actively support this program within individual units.

Ensure an environment where all staff, student employees, and faculty are

encouraged to follow this program.

B. Supervisors:

Implement procedures according to this written program.

Contact RMEH&S for initial training.

Ensure that employees are aware of this written program, instructed on

the details of implementation by supervisors and/or RMEH&S regarding

Hazard Communication.

Ensure that employees are instructed on the location of the SDS, department

specific chemicals and their hazards, secondary workplace labeling system being

used in their department, methods used for detection of releases, and emergency

response information.

C. Employees/Student Employees:

Familiarize themselves and comply with hazard warnings, hazard labels, and SDS so

they can use this information where needed.

Comply with this program and any further safety recommendations provided by

supervisors and/or RMEH&S regarding Hazard Communication.

Conduct assigned tasks in a safe manner.

Wear appropriate PPE.

Obtain training and/or information prior to using chemicals.

D. Risk Management, Environmental Health & Safety:

Document and administer the Hazard Communication Program.

Provide training to supervisors and employees upon request, and maintain

records of RMEH&S provided training.

Assist departments in the selection of PPE for routine or non-routine activities when requested.

Assist departments in providing vendors and contractors SDS and other information

about hazardous chemicals used by CMU employees that contractors and vendors

may be exposed to.

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Maintain SDS for hazardous chemicals provided to RMEH&S by individual

departments for chemicals used and stored at CMU.

Serve as a liaison between CMU and local, county, state, and federal agencies

regarding safety issues.

Review and revise the Hazard Communication Program as necessary to comply with

government regulations.

E. Departments Preparing Specifications for Contractors: (Facilities Management, Plant

Engineering & Planning (PEP), etc.):

Inform contractors of any hazardous chemicals located in the contracted work

area and the precautionary measures to be taken to protect employees during

normal operations and foreseeable emergencies.

Inform contractors that they must provide SDS for all hazardous materials they

propose to bring, use, or store on campus prior to beginning work.

Inform contractors that they are required to maintain SDS on site for all

hazardous materials brought onto university property.

Inform contractors that they must comply with all applicable OSHA, MIOSHA,

DOT, EPA, DEQ, and any other applicable federal, state, and local regulations that

may pertain to the scope of work being provided to CMU.

VI. PROCEDURES

The written Hazard Communication Program is necessary to describe the chemical hazards

present in the workplace and how these hazards will be communicated to the employees. A

Model Hazard Communication Program is included with this Guideline in Appendix G to provide

assistance in preparing individualized documents.

A. The components of this written program must include:

1. A list of all hazardous chemicals located in the specific department/workplace.

2. Methods to ensure containers of hazardous chemicals are clearly labeled with

the identity of the material, as well as the appropriate hazard warnings.

3. Methods to be utilized for acquiring and maintaining SDS for each listed

hazardous chemical. The MIOSHA SDS location poster identifying the location

and the person responsible for obtaining the SDS must be posted in the

department/workplace where chemicals are used or stored (A copy of the

MIOSHA SDS Location Poster can be found in Appendix A).

4. Notifications of new and revised SDS must be posted in the workplace five days

after receipt and remain in place for ten days. The MIOSHA New or Revised SDS

Poster can be utilized for this purpose (A copy of the MIOSHA New or Revised

SDS Poster can be found in Appendix B).

5. SDS are considered to be a source of employee exposure records and MUST be

maintained for at least thirty years; unless, records of the chemical name,

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where and how it was used are maintained for at least thirty years.

6. The SDS must comply with government regulations and be available for

employee use. SDS should be included in the shipment of chemicals by the

manufacturer/importer, etc. If not, contact the manufacturer to request

one. SDS can also be accessed from the RMEH&S website through our

online database: www.cmich.edu/cmuehs.

7. Hazardous chemical information and training must be readily available to

employees, including student and temporary employees at the time of initial

assignment and whenever new hazardous chemicals are introduced into the

work area. When a chemical is used in a “non- routine” manner (a manner other

than what the chemical was originally intended for), the associated hazards for

performing non-routine or emergency tasks that pertain to an operation, for

example, cleaning reactor vessels, confined space entry, etc. must also be

communicated to employees. RMEH&S can provide technical assistance,

information, and training materials to assist departments with compliance.

8. Contractors and vendors must be informed of the presence of hazardous

chemicals that they may encounter while at the university, and contractors must

provide the university with SDS for hazardous chemicals they intend to use for

their work while on campus.

9. Pipes and piping systems containing a hazardous chemical must be identified by

a label, sign, placard, or written operating procedures.

VII. TRAINING

A. Initial Training

Training can be presented in a formal classroom setting using visual media and lecture

methods or it can be an informal on-the-job discussion of the required training

information. With either method, the training must be documented and records

maintained for thirty years. For employees, faculty or student employees whose duties

require them to work with or around hazardous materials, initial training shall be

provided by RMEH&S before they begin their work assignment. This training will cover at

a minimum, the following topics:

1. Overview of Hazard Communication regulations, including employees’ rights under the laws.

2. Methods and observations that may be used to detect the presence or release of

a hazardous chemical in the work area. Examples include air monitoring devices,

visual appearance, or odor.

3. The physical and health hazards of the chemicals typically found in work areas.

4. How to read warning labels and identify the presence or release of hazardous materials.

5. The measures employees can take to protect themselves from the hazards.

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Examples include appropriate work practices, emergency procedures, and

personal protective equipment.

6. Emergency procedures for spills/accidents, including fire hazards, first-aid,

clean-up, protecting storm drains, and proper disposal.

7. Location and availability of this Hazard Communication Program, including

hazardous materials lists and SDS.

8. How to read a SDS and use it to identify (at a minimum)

a. Physical and Health Hazards

b. Exposure Protective Measures including PPE

c. Storage and Handling Procedures

d. Spill Response Procedures

e. First Aid Procedures

9. Details of the Hazard Communication Program include identifying

operations where hazardous chemicals are present, the location and

availability of the written program with the list of hazardous chemicals

present and the SDS, an explanation of the labeling system, and how

employees can use the hazard information.

When needed, RMEH&S will coordinate/schedule Hazard Communication training for

employees. Training DVDs are also available for check-out from the RMEH&S office. Once

viewed, a quiz must be completed and turned in. Call 774-7398 for more information on

this.

B. Site Specific Training

Site specific training shall also be provided on an as-needed basis as new hazards are

introduced into the workplace and for hazards that are newly discovered—for example, if

a new solvent is brought into the workplace, and it has hazards similar to existing

chemicals for which training has already been conducted, no new training is required. It

is the responsibility of the supervisor to coordinate this training. RMEH&S can assist if

needed.

C. Training for Non-Routine Tasks

Periodically, employees, and student employees may be required to perform non-

routine tasks which may involve hazardous materials. Before starting work on such

projects, affected employees shall be given information by their supervisor or principle

investigator (PI) about the hazards to which they may be exposed. If hazardous non-

routine tasks need to be performed by employees, site specific training will be held.

VIII. HAZARDOUS MATERIAL INFORMATION

All purchases of hazardous materials must include the SDS with delivery.

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A list of hazardous chemicals used by a department can be found in the SDS files and must

be systematically and consistently organized. Employees must be trained in how to locate

SDS’s.

SDS’s can be obtained online from the RMEH&S website: www.cmich.edu/cmuehs.

A. Postings

Signs must be posted in the workplace to notify of the following: (See Appendix A)

The location of the SDS and the name of the person from whom to obtain them.

The employer is prohibited from discharging or discriminating against an

employee who exercises the rights regarding information about hazardous

chemicals in the workplace.

The SDS location poster and the poster that notifies employees of new or

revised SDS’s are posted at various locations across campus departments (See

Appendix A and B).

In the event of an emergency call CMU Police: 9-1-1 from any campus phone

or 989-774-3081.

Contact RMEH&S at 989-774-7398.

A. Warnings and Labeling

All original and or shipping containers are to be labeled with the following:

Product Identifier

Signal Word

Hazard Statement(s)

Pictogram(s)

Precautionary Statement(s)

Name, Address, and Telephone Number of the manufacturer, importer,

distributor, or other responsible party

Emergency Contact Information

If a chemical is to be transferred to a secondary/portable workplace container, it must

be labeled with either a copy of the original label OR with appropriate generic labels as

long as all required information is transferred to the blank generic label. Required

information for secondary/portable workplace containers:

1. Product Identifier – use the common chemical name. Abbreviations are not acceptable.

2. Health/Physical Hazards – use general hazard words (i.e. carcinogenic,

flammable, corrosive, etc.).

3. Concentration if applicable.

4. Optional items – include GHS pictograms, other graphics (NFPA, HMIS), symbols:

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label elements must not conflict with other labeling systems.

5. For small containers where it would be difficult to attach a legible label, a tag

may be utilized or labeling rack, or other container of smaller containers may

also be used.

All warnings and labels must be legible, in English, and prominently displayed on

containers, or readily available in the work area throughout each work shift.

For examples of labeling requirements see Appendix C and D.

IX. RELATED DOCUMENTS

Chemical Hygiene Plan (CHP)

Personal Protective Equipment Guidelines

CMU Emergency Action Plans

Appendix A: SDS Location Poster - To be posted in areas where chemicals are used or stored Appendix B: New or Revised SDS Poster – To be posted in areas where chemicals are used or

stored Appendix C: Sample GHS Label Appendix D: Sample Labels for Secondary/Portable Workplace Containers Appendix E: Reference Pictogram Labels Appendix F: Reference Chemical Compatibility Chart Appendix G: Hazard Communication Review/Revision form

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Appendix A: SDS Location Poster - To be posted in areas where chemicals are used or stored

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Appendix B: New or Revised SDS Poster - To be posted in areas where chemicals are used or stored

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Appendix C: Sample GHS Label

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Appendix D: Sample Secondary/Portable Workplace Label

ACETONE

FLAMMABLE LIQUID AND VAPOR

MAY BE FATAL IF SWALLOWED AND ENTERS AIRWAYS

CAUSES SERIOUS EYE IRRITATION

MAY CAUSE RESPIRATORY IRRITATION

MAY CAUSE DROWSINESS OR DIZZINESS

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Appendix E: Pictogram Labels

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Appendix F: Chemical Compatibility Chart

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Appendix G: Model HazCom Program

Hazard Communication Review / Revision (Complete this page after each review or revision)

Name (print) Signature Date

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