HAZARD COMMUNICATION GLOBAL HARMONIZATION SYSTEM (GHS) PROGRAM 1910.1200 J. Sargeant Reynolds Community College Safety Office October 19, 2015
HAZARD COMMUNICATION GLOBAL
HARMONIZATION SYSTEM (GHS)
PROGRAM
1910.1200
J. Sargeant Reynolds Community College Safety Office
October 19, 2015
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Contents RECORD OF CHANGES ...................................................................................................................... 3
Table 1 Record of Changes .................................................................................................................. 3
I. INTRODUCTION ............................................................................................................................ 4
II. DEFINITION OF HAZARDOUS MATERIALS / CHEMICALS ........................................................... 4
III. HAZARDOUS MATERIAL INVENTORY LIST ................................................................................. 4
IV. SAFETY DATA SHEETS (SDS) ...................................................................................................... 5
V. PROCUREMENT OF HAZARDOUS MATERIALS ........................................................................... 7
VI. LABELS AND OTHER FORMS OF WARNING ............................................................................... 8
VII. HAZARDOUS WASTE DISPOSAL ................................................................................................. 8
VIII. EMPLOYEE INFORMATION AND TRAINING .............................................................................. 9
IX. EMERGENCY PROCEDURES ..................................................................................................... 12
X. HAZARDOUS NON-ROUTINE TASKS .......................................................................................... 12
XI. UNLABELED PIPES ...................................................................................................................... 13
XII. ON-SITE CONTRACTORS........................................................................................................... 13
XIII. PROGRAM REVIEW ................................................................................................................... 14
Appendix A CHEMICAL INVENTORY ........................................................................................... 15
Appendix B NON-ROUTINE TASK ................................................................................................ 16
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RECORD OF CHANGES
Submit recommended changes to this document to Reynolds Community College’s Chief of Police, Continuity
Coordinator.
Table 1 Record of Changes
Change
Number
Section
and/or Page
Number
Description of Change Date of
Change Posted By
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I. INTRODUCTION
The Occupational Safety and Health Administration (OSHA) Hazard Communication Standard was
promulgated to ensure that all chemicals purchased, used, and destroyed by an employer would be
evaluated and that information regarding the hazards would be communicated to employees. The goal
of the standard is to reduce the number of chemically related occupational illnesses and injuries. In
compliance with the Hazard Communication Standard ("Right-to-Know") (29 CFR 1910.1200), the
Hazard Communication Global Harmonization System Program (HCGHSP) applies to J. Sargeant
Reynolds Community College (college) faculty, staff, and students who may work with or be in proximity
to hazardous chemicals or chemical products. This program also applies to contractors that perform
work at any college facility. Questions concerning the Hazard Communication Global Harmonization
System Program (HCGHSP) are to be directed to the Safety Manager at 523-5722. In accordance with
J. Sargeant Reynolds policy 4-35 PERSONAL AND ENVIRONMENTAL SAFETY all departments must
notify the Safety Manager immediately of any external or internal Safety Audit requests or visits.
Hazardous chemicals and materials are used interchangeably in this program.
II. DEFINITION OF HAZARDOUS MATERIALS / CHEMICALS
Any substance or mixture of substances which (i) is toxic, (ii) is corrosive, (iii) is an irritant, (iv) is a
strong sensitizer, (v) is flammable or combustible, or (vi) generates pressure through decomposition,
heat or other means, if such substance or mixture of substances may cause substantial personal
injury or illness during or as a result of handling or use (this includes compressed gas cylinders).
III. HAZARDOUS MATERIAL INVENTORY LIST
Each department’s HCGHSP staff person must complete and maintain a list of all known hazardous
material used on college ground. As new hazardous materials are brought into and or remove from the
department this list shall be edited and certified for accuracy by the department’s HCGHSP staff person.
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The department manager/head will reconcile the beginning balances of hazardous material inventory
on August 1 of each academic year. The Safety Manager will perform random inspections and or audits
starting Feb 1 of each academic year and to conclude by July 1 of the academic year to verify
recordkeeping and physical inventory. Each entry on the list must include:
• Chemical name
• Common/trade name
• Manufacturer
• Quantity
The original inventory list will be maintained in the individual department along with the SDS. Each
department’s SDS will be housed on the Safety Committee share point site in assigned folder, until the
recommended VCCS prescribed MSDS ON-LINE system is activated. A copy of the inventory list must
be sent to the Safety Manager. The Safety Manager will ensure that an updated copy of the inventory
list is provided to the Department of Police Dispatch. Discarded or no longer needed MSDS and SDS
must be kept for a period of thirty (30) years.
IV. SAFETY DATA SHEETS (SDS)
The identified Department’s HCGHSP staff person is responsible for compiling and maintaining a
complete record of all the inventory list and Safety Data Sheets (SDSs) associated with any
hazardous materials received and used by the college. Department’s HCGHSP staff person must
notify the college Safety Manager of their method of providing access to the SDS. The college’s
students, employees and on-site contractors may access the college’s current SDS(s) for hazardous
materials through the physical and/or electronic copy method:
1) Physical copy (Reynolds approved SDS binder)
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a) Department specific SDS are available at the department where hazardous materials
are used.
Departments should follow the protocol below in maintaining a Reynolds approved SDS binder:
• Binder must be visibly labeled as containing SDS
• Binder must remain “readily available” at all times
• Binder must be restricted or mounted to prevent being taken from the assigned area
• SDS must be filed in a systematic method to allow for quick location of chemical (example:
alphabetically by chemical name)
• All SDS must be in good, readable condition
• Each SDS must be complete, with no missing pages or torn information
• The following areas on the SDS should be highlighted for quick reference in an emergency
situation: chemical name, first aid measures, manufacturer, phone number and release
measures
2) Electronic copy
If the department has selected to provide access to SDS electronically then the following protocol
should be followed:
• The designated computer(s) must be clearly marked for obtaining SDS by the end-user
• The computer(s) must be in close proximity of the chemical’s area of use
• The selected web address must be clearly posted as well as noted as a desktop icon for
quick, easy reference (i.e. Fisher Scientific –www.fishersci.com)
• Directions for obtaining a SDS by computer must be written in step-by step form and
clearly posted on/next to the computer(s)
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• The computer(s) must be connected to a printer (in the same area) allowing for the SDS to
be generated in hard copy if desired
• Reynolds approved SDS binder(s) with the required hard copied SDS(s) will be made
accessible at all times, as a backup
A Reynolds binder must meet the approval of the Safety Manager.
V. PROCUREMENT OF HAZARDOUS MATERIALS
The college’s Purchasing Officer is responsible for ensuring that all purchase orders for chemicals
processed through the Purchasing Department include a statement requiring a Safety Data Sheet
(SDS) from the vendor. Once hazardous material products are purchased, shipped to and received
at the college, if the hazardous material is shipped without the SDS, the Warehouse Supervisor or
other college recipient will not accept shipment of the item. If, the hazardous material is shipped with
the SDS it is the college protocol that the receiver(s) of such products (e.g., Warehouse personnel)
perform the following:
• Review the product’s accompany “Bill of Lading” or Invoice for accuracy
• Inspect, ensure that the products are delivered in a proper and safe manner
• Inspect, ensure that the products are free from damage
• Record a copy of all SDSs, other pertinent documentation on the hazardous material that is
directly shipped to and received at its site
• Submit one (1) copy SDS to the end-user(s) of record
Individuals purchasing an over-the-counter (otc) hazard chemical (product) must immediately obtain
an SDS for the product at the time of purchase and/or prior to use or upload the SDS from the
manufacturer’s web site. The purchaser must update the Departments Hazardous Material Inventory
list once the product is on campus grounds. The hazardous Material Inventory List procedure must be
followed. It is the responsibility of the End Use to ensure that the SDS is received upon delivery from
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the Warehouse personnel. The end user should not accept deliveries by warehouse staff of such
items marked as hazardous material without its SDS.
VI. LABELS AND OTHER FORMS OF WARNING
The OSHA Hazard Communication Standard requires that hazardous chemicals (product) be labeled
by manufacturers. The label must be written in English and contain the following:
• Chemical identity
• Appropriate hazard warnings (e.g. signal words and pictogram)
• Name & address of chemical manufacturer, importer, or other responsible party
Upon delivery of chemicals, the purchaser and/or the receiver will verify that chemicals are labeled
properly. If chemicals are transferred from the manufacturer's containers to secondary containers, the
department manager of each section will ensure that the containers are labeled with the identity of the
chemicals and appropriate hazard warnings. Additionally, the department managers will ensure that
labels will not be removed or defaced and will be replaced if the label is excessively worn or torn.
VII. HAZARDOUS WASTE DISPOSAL
The college Safety Manager monitors various HCGHSP department specific disposal methods to
include but not limited to disposal requisition created in eVA and/or third party vendor relationships.
Prior to initiating any disposal requisition, the department-designated employee is to notify the Safety
Manager via e-mail of their disposal request. Together, the Safety Manger and the department
designated employee will track the disposal of hazardous waste by way of the college’s Hazard
Waste Manifest Information System (HWMIS). HWMIS is a procedure in which hazardous materials
are identified and tracked as part of the disposal process using a series of permanent, linkable,
descriptive documents (e.g. manifests), commonly referred to as the cradle-to-grave management
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system. All HWMIS (MSDS/SDS) documents are uploaded and housed on Reynolds Safety
Committee share-point site. The primary HCGHSP participating departments are as follows:
• School of Nursing and Allied Health
o Dental
o Nursing
o Optician
o Emergency Medical Services
o Medical Labs
• School of Mathematics, Science and Engineering
o Biology Labs
o Chemistry
• School of Business
o Automotive
o Culinary
o Diesel
o Horticulture
o Welding
o Offices
• Warehouse
• Facilities Management and Planning
• Police Department
VIII. EMPLOYEE INFORMATION AND TRAINING
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All Reynolds employees are required to receive initial / awareness level hazard communication
training provided by the Safety Manager. All HCGHSP department designated employees are
required to receive additional instruction to perform the following:
• Purchase hazard material in the eVA system this training will be provided by Purchasing
department representative
• Upload SDS documents to Safety committee’s share-point this training will be provided by
the Safety Committee Chair
• Maintain Reynolds approved SDS binder this training will be provided by the Safety
Manager
• Hazard waste inventory and disposal protocol this training will be provided by the Safety
Manager
Employees who may be exposed to hazardous chemicals in the workplace shall receive additional
training on each chemical hazard (not necessarily each chemical). New employees shall be trained
as soon as possible after hiring and before they are assigned to work with hazardous chemicals. All
hazardous material training shall be documented. The appropriate manager, laboratory manager,
supervisor and department head ensure that all required hazard communication training is completed.
Initial training shall include a brief discussion of the OSHA Hazard Communication Standard.
Additional training shall be conducted by managers, laboratory managers, supervisors, and
department heads on specific chemical hazards in each workplace, and when a new hazard (not
necessarily a new chemical) is introduced into the work area. All training will include interpretation of
container labeling, use and interpretation of SDS, methods and observations that may be used to
detect the presence of a hazardous material in the work area. This will include air monitoring,
presence of odor, visual appearance of the material, etc., where to find information on the health and
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physical hazards of the hazardous materials in the work area, protective equipment available to the
employee that will provide protection while working with or around the hazardous material and how to
obtain protective equipment, and who to contact to obtain further information about a specific
hazardous material or work condition. The appropriate manager, laboratory manager, supervisor, or
department head shall maintain documented records of training. Records of training shall include a
copy of the Hazard Communication Policy, a description of materials used (e.g. audio-visuals), and
the date training was completed. All employees completing hazard communication training shall sign
a training roster. Follow up shall be conducted by supervisors to ensure that affected employees
remain aware of the Hazard Communication Standard and its requirements. These employees must
be shown where the Safety Data Sheets are located within their department. Each employee must
have a general familiarity of the hazardous properties of the chemicals in their work area and the
protective measures being implemented.
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IX. EMERGENCY PROCEDURES
In the event that an employee is involved with a chemical spill and/or exposed to a hazardous
chemical/material, the following emergency procedures will be implemented by the employee:
• Report any major spill/exposure to supervisor and the Department of Police
• Evacuate non-essential personnel from the immediate area, if necessary.
• Refer to SDS to take appropriate actions
• Limit exposure to the chemical
• Seek medical attention, if necessary
Safety Manger will provide immediate/emergency assistance in the coordination of the disposal of
hazardous substances. See the college Crisis Emergency Management Plan (CEMP) for additional
information on chemical spills.
X. HAZARDOUS NON-ROUTINE TASKS
Potential hazardous non-routine tasks at the college must be identified by each respective
department manager and documented on Appendix B. Appendix B is to include at minimum the
following:
• Hazardous chemicals/materials needed to perform the task and their specific hazards
• Safety measures to be used/taken
• Measures being taken to prevent/lessen the hazard, e.g. engineering controls,
administrative work practices, personal protective equipment
• Review of pertinent SDS
• Review of emergency control procedures
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Each department will forward a copy of Appendix B to the Safety Manager. Prior to starting a
documented hazardous non-routine task the employee is to receive a copy of Appendix B for his/her
specific task by their immediate supervisor.
XI. UNLABELED PIPES
Work activities are often performed in areas where chemicals are transferred through pipes. These
pipes are not required to be labeled; however, the employees need to be aware of potential hazards.
Prior to starting work in areas having unlabeled pipes, the employee shall contact the college’s
Facility Manager to determine:
• The identity of the chemical in the pipes
• Potential hazards
• Safety Precautions
The college’s Facility and Safety Managers will team up to have any / all reasonably accessible
unlabeled pipes, that have been identified to carry hazard chemical /material, inspected biannual
(August and February) for leaks, worn parts and etc.
XII. ON-SITE CONTRACTORS
Director of Facilities Management and Planning and Safety Manager will team up to designate three
(3) staff members, one on each campus to serve as the college’s first point-of-contact (POC(s) for its
on-site contractors. Prior to the contractors starting work, the POC(s) will perform the following:
• Inform on-site contractors of the college’s hazard communication global harmonization
system program (HCGHSP)
• Request any SDS from the contractors for any hazardous materials that will be used
• Work with the Safety Manager to provide the contractors with
• Copies of all relevant SDS with respect to the contractor’s work area
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• Information on any precautionary measures that need to be taken to protect their
employees
• The chemical labeling system used by the college
The college’s point-of-contact (POCs) for on-site contractors is not responsible for administering,
leading, performing or assisting any external or internal Safety Audit.
XIII. PROGRAM REVIEW
This written Hazard Communication Global Harmonization System Program (HCGHSP) for the
college will be reviewed in a collaborative effort by the college Safety Manager and Compliance
Officer twice a year (August and February) and updated as necessary. All updates to the college’s
written HCGHSP will be made for the sole purpose of supporting the college’s continuous effort to
establish, execute and enhance a prescribed way to address /communicate college-wide safety
matters to include, but is not limited to the following:
• Identifying and recognizing Hazardous Chemicals (products) used by the college
• Recordkeeping and providing access to the college’s SDS(s)
• Implementing a college-wide plan for handling and disposing Hazardous Waste materials
(i.e. commodity code approver for hazardous waste disposal requisitions)
• Identifying, recognizing and empowering the college’s Safety Manager
• Researching, developing and implementing, a college-wide communication mechanism to
address Safety issues that include, but are not limited to the scope of this HCGHSP
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Appendix A CHEMICAL INVENTORY
Please see the Safety Manger for this list.
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Appendix B NON-ROUTINE TASK
Please see the appropriate Manager / Department Head for this list.