Hazard materials program

The purpose of this program is to provide the safest working environment for the employees of Lynn University by reducing the risk of exposure to hazardous chemicals. In compliance with OSHA Hazard Communication Standard (29 CFR Part 1910.1200), the University’s Program focuses on five primary topics to achieve this objective:

• Hazard determination;
• Written hazard communication program;
• Product Labels;
• Safety Data Sheets (SDSs); and
• Worker Training

The Hazardous Materials Program of Lynn University fulfills the Hazard Communication Standard promulgated by the Occupational Safety and Health Administration.

Lynn University is dedicated to providing safe and healthful facilities employees, and complying with federal and State occupational health and safety standards. Employees share responsibility for minimizing their exposure to hazardous chemical substances. The Hazardous Materials Program shall be implemented for all non-laboratory facilities at the University where hazardous chemicals are handled (see Hazardous Determination section).

The University’s Hazardous Materials Program applies to employees who are exposed to hazardous chemicals under normal operating conditions or in the event of a foreseeable emergency. A review of all departments and employee positions has been completed to determine which have reasonable potential for occupational exposure to hazardous materials during the performance of work. Listed below are those departments or programs that employ individuals covered by the hazard communication program:

Facility Services
Mechanical Services
Grounds Dept.
Food Services
Athletic Trainer
Aviation
Culinary Lab
Science
Health Services

In general, the hazard communication program does not apply to administrative office employees.

The OSHA Hazard Communication Standard has five primary components that Lynn University must fulfill:

• Hazard determination;

• Written program;

• Container labeling;

• Safety Data Sheets (SDS); and

• Training

The University maintains a copy of the OSHA Hazard Communication Standard, available for employee review during regular business hours at Auxiliary Services. A copy of the standard is also accessible on the internet at www.osha.gov.

Article - A manufactured item formed to a specific shape or design that has end use functions dependent upon that shape/design, and that does not release or otherwise result in exposure to a hazardous chemical under normal conditions of use. A chair is an article. Wood that is cut during construction of the chair may be considered hazardous due to health effects associated with inhalation of dusts.

Chemical - Any element, chemical compound or mixture of elements and/or components.

Consumer Commodity - Any article, product, or commodity which is available to consumers; and which is used in the same manner, frequency and duration as the typical consumer.

Employee - A worker who may be exposed to hazardous chemicals during normal operating conditions or during foreseeable emergencies. Workers such as office workers who encounter hazardous chemicals only in non-routine, isolated instances are not covered by the Hazard Communication Program.

Exposure or Exposed - Means that an employee in the course of employment comes in contact (inhalation, ingestion, skin contact or absorption) with a chemical that is a physical or health hazard; and includes potential (including accidental) exposure.

Foreseeable Emergency - Any potential occurrence such as, but not limited to equipment failure, container rupture or failure of control equipment that could result in an uncontrolled release of a hazardous chemical into the workplace.

Hazardous Chemical - Any chemical which is a physical or health hazard.

Health Hazard - A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. Hazardous chemicals include carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system and agents which damage the lungs, skin, eyes or mucous membranes.

Immediate Use - Means that the chemical will be under the control of and used only by the person who transfers it from a labeled container, and only within the work shift in which it is transferred. Safety Data Sheets (SDS)- a document that contains information on the potential hazards (health, fire, reactivity and environmental) and how to work safely with the chemical product. SDSs are prepared by the supplier or manufacturer of the material. It is intended to tell what the hazards of the product are, how to use the product safely, what to expect if the recommendations are not followed, what to do if accidents occur, how to recognize symptoms of overexposure, and what to do if such incidents occur. OSHA Hazard Communication Standard (HCS) require SDSs to be in a uniform format, and include standardized section numbers, headings and associated information.

Mixture - Any combination of two or more chemicals other than components resulting from a chemical reaction.

Non-Routine Tasks - Tasks involving the use of a hazardous material for a purpose other than that intended (e.g., using gasoline to degrease a stove), or tasks that are not conducted routinely and that involve the use of a hazardous material (e.g., cleaning a boiler’s combustion chamber).

I. Background
The Occupational Safety and Health Administration (OSHA), under Title 29 Code of Federal Regulations 1910.1200, has issued a Hazard Communication Standard (HCS) which requires employers to establish hazard communication programs to transmit information on the hazards of chemicals to their employees. With very few exceptions, OSHA considers all chemicals hazardous. Workers have a right to know and must have access to chemical information such as SDS’s and labels with Pictograms. Chemical manufacturers and importers must determine whether chemicals they produce or import are hazardous, and if they are, develop Safety Data Sheets (SDSs), and warning labels. Both must be sent downstream with the chemicals. All employers must train employees who use chemicals as a normal integral part of their job.

II. Hazard Determination
Chemical manufacturers must evaluate their products to determine associated hazards. The information about the chemicals’ hazards must be given to each purchaser of that chemical. Hazard warnings and other information are commonly provided on the container label and the Safety Data Sheets (SDS).

III. Container Labeling
As required by federal OSHA regulations, containers (e.g., spray bottles, 1-gallon jugs, 5-gallon pails, drums, etc.) of hazardous chemicals must be clearly labeled with the following information:

1. Chemical or Product Name;
2. Chemical formulas and acronyms are not acceptable forms of labeling when used alone;
3. Manufacturer Name, Address, and Telephone Number;
4. Applicable Hazard Information (e.g., “Flammable,” “Corrosive,” etc.);
5. Appropriate Health Hazard Warnings (e.g., “Inhalation Hazard,” “Eye Irritant,” etc.)

IV. Chemical Inventory and Safety Data Sheets
As required by OSHA regulations, all employees must have unobstructed access to an SDS for each chemical product they may use or potentially be exposed to during their work. The Director of Auxiliary Services is the administrator of the chemical inventory and SDS for all of Lynn University. The position is to maintain the inventory in a computerized file and make the inventory available whenever requested by University personnel. In addition, SDS for each chemical is available. It is the direct responsibility of each individual area around campus to supply their on-hand inventory and SDS three (3) times per year on the first Monday in February, May and October of each calendar year directly to the Director of Auxiliary Services.

The areas responsible for collecting and reporting chemical inventory and SDS are as follows (this includes vendors operating on campus within these areas that store material on campus):

Area Responsible Person Divisional Vice President
Facility Services Director of Facility Services SVPA
Mechanical Services Director of Mechanical SVPA
Grounds Dept. Grounds Manager SVPA
Food Services Food Service Manager SVPA
Athletic Trainer, Head Trainer
Aviation Dean, College of Aviation VPAA
Culinary Lab Instructor, Culinary Lab VPAA
Science Chair of Science Department VPAA
Health Services Head Nurse VPSA

Responsible areas are to use the template provided by the Director of Auxiliary Services and submit their inventory electronically via email. Any questions regarding this Policy are to be addressed to the Director of Auxiliary Services.

V. Training
To effectively educate employees, Lynn University has developed a training program to meet the training requirements of the Hazard Communication Standard. It is the responsibility of each department/program/division to provide its employees training for processes that are unique to that department/program/division. Department Heads therefore discuss the University’s Hazardous Materials Program with employees on a periodic basis. Additional information will be provided whenever the potential for exposure to hazardous chemicals is altered or whenever new and significant information is received by the department/program/division concerning the hazard of a chemical. New or newly assigned employees shall be provided training before working with or in a work area containing hazardous chemicals.

Students registered in courses where they may be exposed to hazardous chemicals under normal operating conditions or foreseeable emergencies should be provided training before working with or in a work area containing hazardous chemicals/materials. Training is the responsibility of the instructor.

The training program shall include but is not limited to the following: information on interpreting labels and SDS and the relationship between these two methods of hazard communication; how to obtain a SDS, introduction to toxicology and risk assessment, acute and chronic effects, safety handling, protective equipment to be used, first aid treatment with respect to the hazardous chemicals used by faculty, staff and students; and general safety instructions on handling, cleanup procedures, and disposal of hazardous chemicals.

Departments/program/division and individuals providing training shall keep a record of the dates of training sessions and the names of the employees and/or students attending. Copies of training records shall be submitted to the Employee Services Office within 5 working days of the training session.

VI. Rights of Employees and Students
1. Employees and students shall not be required to work with a hazardous chemical from a container that does not have a label, except for a portable container intended for immediate use by the employee or student who performs the transfer.

2. Employees that are routinely exposed to hazardous chemicals shall be informed of such exposures and shall have access to SDS for the hazardous chemicals. In addition, such employees shall receive training on the hazards of the chemicals and on measures they can take to protect themselves from those hazards.

3. The University shall provide, at no expense to employees, appropriate personal protective equipment to protect employees from exposures to hazardous chemicals. Students may be required to purchase routine personal protective equipment (e.g., eye protection, lab coats, etc.); however, departments or division shall provide specialized personal protective equipment (e.g., respirator, face protection, gloves, barrier creams, etc.).

4. No department/program/division shall discharge, cause to discharge, or otherwise discipline or in any manner discriminate against an employee because the employee has filed a complaint, assisted an inspector of the State or Federal government, or has instituted or caused to be instituted any proceeding under or related to the Occupational Safety and Health Act or the Right to Know Act or has testified or is about to testify in any such proceeding or because of the exercise of any rights afforded pursuant to the provisions of the Act on behalf of the employee or on behalf of others, nor shall pay, position, seniority or other benefits be lost for exercise of any right provided by the Act.

VII. Old Equipment Disposal
All old A/C and mechanical equipment that is to be disposed of will be disposed of by Lynn University staff. Equipment removed from its operational position is to be moved to the maintenance yard. All hazardous materials are to be removed by and properly disposed of by the University or its vendors. The University or its authorized vendors can remove parts from the equipment prior to its ultimate disposal. Parts are to be properly labeled and stored in inventory for future use.

To learn more about this policy or the supporting procedures, please contact Auxiliary Services.