Safety & Environmental Management

Hazard Communication Program

The intent of this written program is to describe how the University of Wisconsin Green Bay is complying with 29 CFR 1910.1200 Hazard Communication. The program covers labeling of hazardous materials, hazardous materials inventory, maintenance and availability of MSDSs, employee training, outside contractors in the workplace, and designation of program responsibilities.

The University of Wisconsin Green Bay is committed to maintaining a safe work environment for its employees. Employees will be informed of hazards they may encounter in the workplace and provided with training and necessary Personal Protective Equipment to perform tasks safely.

Table of Contents: LABELS
  1. All incoming containers of hazardous chemicals must be labeled, tagged or marked with the following information:
    • Identity of the hazardous chemical
    • Appropriate hazard warning
    • Name and address of the chemical manufacturer, importer or other responsible party
    Although area supervisors are ultimately responsible for ensuring that incoming containers are properly labeled, all Campus employees are expected to check containers brought into the workplace and bring deficiencies to the attention of the area supervisor.

  2. All portable containers within the work area will be labeled, tagged or marked with the following information:
    • Identity of the hazardous material
    • Appropriate hazard warning
    Note: A portable container is considered any container into which a substance has been transferred (typically from the original container) and then moved around the work area. The employee who transfers the substance is responsible for immediately labeling the portable container.

  3. Additional labeling requirements:
    • All labels will be written in English
    • Chemical formulas are not acceptable in identifying a substance - the name must be written out in English
    • No employee shall deface an existing label unless the container is immediately marked with required information.
INVENTORIES
  1. Each Campus department will maintain an inventory of hazardous substances in the work area. At a minimum this inventory should meet the following criteria:
    • Match inventory listing of product/chemical with names used on MSDSs so that employees can readily access MSDS information for a product/chemical.
  2. Inventory will be updated annually.
  3. Annual inventories will be forwarded to Jill Fermanich, University Safety Manager, who maintains the central Campus inventory.
MATERIAL SAFETY DATA SHEETS (MSDSs)
  1. Each Campus department shall maintain a MSDS for each substance in the hazardous chemical inventory. MSDSs shall be in English.
  2. The MSDS file shall be kept in a location that meets the following criteria:
    • Readily accessible to all employees on all working shifts
    • Location known to all employees in the work area
  3. Area supervisors are responsible for maintaining an accurate and comprehensive MSDS file.
  4. A copy of each new MSDS received should be sent to Jill Fermanich, University Safety Manager, who maintains a central Campus MSDS file.
  5. See Appendix C for information on accessing the UW System MSDS Database.
  6. MSDSs will be kept indefinitely for a product, even when the product is no longer used in the work area. Areas may dispose of old MSDSs when updated versions are received. The central MSDS file will maintain all copies of MSDSs, both updated and old versions.

EMPLOYEE INFORMATION AND TRAINING
  1. All new employees will receive Hazard Communication training either through a video presentation or through a live presentation. Supervisors are responsible for ensuring employees receive this training.
  2. Content of this general training will include the following:
    • Hazard Communication - regulatory background/authority and details of the campus program
    • Labeling requirements
    • Materials Safety Data Sheets - content and availability
    • Campus policy on maintaining hazardous chemical inventory
    • Hazards associated with
      • flammable/combustible materials
      • corrosive materials
      • toxic materials
    • Appropriate Personal Protective Equipment (PPE) for working with
      • flammable/combustible materials
      • corrosive materials
      • toxic materials
    • Campus emergency procedures
    • Bloodborne Pathogen awareness training
  3. In addition to this general introductory training, area supervisors are responsible for training employees on specific routine and non-routine hazards that may be found in the work area. This training will include specific area work procedures and required PPE.
  4. Employees will receive additional training when new hazards are introduced into the work area. At a minimum this will include:
    • a review of the product label and MSDS
    • discussion of appropriate work procedures and PPE requirements
OUTSIDE CONTRACTORS
  1. When outside contractors perform work on the Campus, we need assurance that the outside contractor has a Hazard Communication Program meeting minimum requirements for the Standard in place. We also want to ensure that outside contractors have access to information on hazards they may encounter in our workplace, MSDS availability and our labeling system. To meet these goals the following language will be included in all purchase orders where outside contractors will be doing work on our Campus:
    Yes Will you use hazardous materials on site?

  2. No

    If yes, the contractor agrees to the following:

    • Have an established Hazard Communication Program for contractor employees.
    • Ensure all contractor employees comply with all applicable health and safety standards.
    • Notify area supervisors in advance if any UW Green Bay employee/student could be potentially exposed to a hazardous material used by the contractor.
    • Have MSDSs for materials used by contractor on Campus readily available for reference by contractor employees and UWGB employees and supervisors if they have questions regarding effects of substance being used.
    • Upon initial inspection of the work area, contractor will contact UWGB area supervisor with any questions concerning hazards present in the workplace, labeling system, accessibility of MSDSs and availability of the Campus Hazard Communication Written Program.

  3. To ensure compliance with this policy, the Campus University Safety Manager will conduct random audits of outside contractor work.
RESPONSIBILITIES
  1. Administration:
    • require employee involvement in program at all levels
    • consider Hazard Communication and safety responsibilities when conducting performance reviews
  2. Campus University Safety Manager:
    • update written Hazard Communication Program as needed
    • provide support for the training component of this Program as requested
    • maintain central Campus inventory
    • maintain central Campus MSDS file
    • conduct random audits to ensure outside contractor compliance with Hazard Communication requirements stipulated in purchase order
    • provide support to area supervisors in implementing Program components
  3. Area Supervisors:
    • exemplify Standard compliance by their own practices
    • ensure proper labeling of substances in work area
    • maintain and update annually an inventory of hazardous chemicals in the work area
    • maintain a MSDS file for all hazardous substances in the work area
    • ensure all new employees receive introductory Hazard Communication training either via video presentation or live presentation
    • provide orientation to all new employees on specific hazards in work area
    • train all employees on new hazards introduced into work are
    • identify non-routine employee tasks and ensure employees receive training in performing tasks safely
  4. Employees:
    • ensure proper labeling of substances in work area
    • review MSDSs as requested by supervisor
    • attend training as requested by superviso
    • follow established work procedures and wear PPE as required
    • keep all personal protective equipment in good operating condition
    • report any Program deficiencies noted (for example: missing MSDS, improper labeling or unsafe conditions) to supervisors for correction
    • be certain to understand the hazards associated with materials and tasks before beginning the work, if in doubt ask their supervisor
    • suspend operations or deactivate equipment in the event of immediate danger to life, health, or the environment; report such actions immediately to supervisor
APPENDIX A
HAZARD COMMUNICATION STANDARD
29 CFR 1910.1200