Hazard Communication Plan

Reynolds Community College

Effective Date: March 11, 2013
Revised Date: July 19, 2024

INTRODUCTION

The Occupational Safety and Health Administration (OSHA) Hazard Communication Standard was promulgated to ensure that all chemicals purchased, used, and destroyed by the college 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 Program (HCP) applies to J. Sargeant Reynolds Community 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 Reynolds facility.

Questions concerning the Hazard Communication Program (HCP) are to be directed to the Safety Officer at (804) 523-5740. Additionally, departments must notify the Safety Officer and the Department of Police immediately of any external or internal Safety Audit requests or visits.

Hazardous chemicals and materials are used interchangeably in this program. This program includes:
1. DEFINITION OF HAZARDOUS MATERIALS
  OSHA defines a hazardous chemical as a substance for which there is statistically significant evidence, based on at least one scientific study, showing that acute or chronic harm may result from exposure to that chemical. Any product or chemical which could meet this definition, will have a Safety Data Sheet (SDS), which provides details on the hazards. A more appropriate definition of a hazardous chemical would be the following:
  
  Any substance or mixture of substances which:
  1. is toxic,
  2. is corrosive,
  3. is an irritant,
  4. is a strong sensitizer,
  5. is flammable or combustible, or
  6. 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).
2. HAZARDOUS MATERIAL INVENTORY LIST
  Each department must complete a list of all known hazardous materials used by the department. This list will be amended as new hazardous materials are introduced into or removed from the department. In addition, the department must complete an initial inventory for any new work area and conduct annual audits to ensure the lists are inclusive and up to date. Each entry on the list must include:
  - Chemical name
  - Common/trade name
  - Manufacturer
  The original inventory list will be maintained in the respective department along with the SDS. A copy of the inventory list and related SDS must also be sent to the Safety Officer who keeps a comprehensive college list. The Safety Officer will ensure that an updated copy of the list is provided to the Department of Police Dispatch.
3. SAFETY DATA SHEETS (SDS)
  The college's Safety Officer is responsible for compiling and maintaining a comprehensive record of all the inventory list and Safety Data Sheets (SDSs) associated with any hazardous materials received and used by the college. Departments must notify the college Safety Officer of their method of providing access to the SDS. Reynolds students, employees and on-site contractors may access the college's current SDS(s) for hazardous materials through the following two methods:
  1. Physical copy within labeled binders
    1. Specific SDS, within each department, are available at the department where any hazardous materials are utilized or stored.
    2. Comprehensive SDS are available (Please contact the Safety Officer at (804) 523-5740 or mcwilliams@reynolds.edu for this information).
    3. Maintenance of Physical SDS Binders
      Department should follow the standard below in maintaining a physical binder containing SDS.
      - Binder must be visibly labeled as containing SDS
      - Binder must remain accessible 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 finding in the event of an emergency situation: chemical name, first aid measures, manufacturer and phone number
  2. Electronic copy
    1. Electronic SDS Copies
      If the department has selected to provide access to SDS electronically the following standards should be incorporated:
      - The computer(s) for access must be clearly marked as the method for obtaining SDS
      - 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
      - Directions for obtaining a SDS by computer must be written in step-by-step form and clearly posted on/next to the computer(s)
      - 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
      - A labeled SDS binder with the required hard copied SDS(s) will be made accessible at all times, as a backup
4. PROCUREMENT OF HAZARDOUS MATERIALS
  1. Purchasing Office/eVA Orders
    The Reynolds Financial Operations Department shall have oversight regarding all solicitations for the purchase of chemicals or compounds which may contain toxic or hazardous substances, (i.e., cleaning, janitorial supplies, pesticides, chemicals of all types, etc.) according to the following Terms and Conditions:
    - SAFETY DATA SHEETS: Safety Data Sheets and descriptive literature shall be provided with the bid/proposal for each chemical and/or compound offered. Failure on the part of the bidder/offeror to submit such data sheets may be cause for declaring the bid/proposal as nonresponsive.
    Once hazardous material products are purchased, shipped to and received at the college, it is Reynolds protocol that the receiver(s) of such products (e.g., Warehouse personnel) perform the following:
    - Review the "Bill of Lading" for the product or accompanied 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 the original SDSs to the Safety Officer and one (1) copy to the end user(s) of record
    If a hazardous material is shipped without the SDS, the college will not accept shipment of the item.
  2. Over-The-Counter Purchases
    Individuals purchasing an over-the-counter (OTC) hazard chemical (product) must immediately obtain an SDS for the product at the time of purchase. The Hazardous Material Inventory List procedure must be followed.
5. LABELS AND OTHER FORMS OF WARNING
  The OSHA Hazard Communication Standard requires that hazardous chemicals (product) be labeled by manufacturers. The label must contain the following: (The label must be written in English)
  - Chemical identity
  - Appropriate hazard warnings
  - Name and address of chemical manufacturer, importer, or other responsible party
  Hazardous materials used in the work area must be properly labeled with the manufacturer's label. The department (individual originating the order) must indicate the need for the manufacturer's label information on the purchase order to ensure that chemicals are labeled properly upon delivery. Any chemicals without proper labeling will not be accepted. 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.
6. HAZARDOUS WASTE DISPOSAL
  HAZARD WASTE MANIFEST INFORMATION SYSTEM (HWMIS)
  
  In order to comply with the Federal Environmental Protection Agency's (EPA) published regulations on Hazard Waste Disposal and Transport, departments with hazardous waste will follow the Hazard Waste Manifest Information System (HWMIS) developed by the college Safety Officer.
  
  The HWMIS is a procedure in which hazardous materials are identified and followed 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 system.
  
  A department with hazardous waste to dispose must follow the procedures below:
  - Generate a hazardous waste disposal requisition in eVA and use commodity code # 96871. The college Safety Officer has been designated as an eVA commodity code approver for hazardous waste disposal requisitions. The departmental approval process remains unchanged.
  - Use only hazardous waste transporters that are registered with the Department of Toxic Substances Control.
  - Ensure that the EPA ID number is documented on the manifest generated by the hazardous waste transporters.
  - Each party involved in the waste disposal must sign and keep one of the manifest copies.
  - Request a Uniform Hazardous Waste Manifest (UHWM) which is the shipping document that travels with hazardous waste from the point of generation, through transportation, to the final treatment, storage, and disposal facility (TSDF). This document is required to show proof that the hazardous waste has been disposed of appropriately by the transporter.
  - Scan and email a copy to the Safety Officer.
  Note that under EPA regulations, individuals who continue to dump chemical waste down the drain will face stiff fines and a possible jail term. This punishment will be levied against the offending employee and not the College.
7. EMPLOYEE INFORMATION AND TRAINING
  Prior to beginning work, new employees assigned to a department that handle hazardous materials will be given health and safety training. Employees will be provided general safety training, as well as task specific training, in regards to individual job duties and associated hazards within the department. General safety training will be provided by the Safety Manager and the task specific training will be provided by the department manager. The Safety Manager will maintain a record of employees provided general safety training.
  
  Re-training for all employees is required when processes change which involve additional hazards and as necessary to enhance employee awareness.
  
  General safety training will cover the following topics:
  - An overview of the requirements of the Hazard Communication Standard 19101200
  - Location and availability of the written hazard communication program, the chemical inventory and SDS.
  - Chemicals present in work operations and their associated physical and health hazards. Methods used to determine the presence or release of hazardous chemicals in the area
  - Work practices which could reduce or eliminate exposures.
  - Personal protective equipment (PPE) to be worn to prevent or reduce exposures (i.e. gloves, goggles, lab coats, etc.)
  - Safety/emergency procedures to follow if exposure occurs
8. 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
  - Limit exposure
  - Seek medical attention, if necessary
  The College Safety Officer will provide immediate/emergency assistance in the coordination of the disposal of hazardous substances.
  
  Contact the College Safety Officer for additional information regarding protocols following a chemical hazards, accidents and incidents at (804) 523-5740.
9. HAZARDOUS NON-ROUTINE TASKS
  If an employee is required to perform non-routine work in a hazardous location or using hazardous chemicals/materials, the employee shall be advised and/or must contact their immediate supervisor in the area where the work is to be performed for special precautions before beginning any non-routine work. Each affected employee should be given information on (at a minimum) the following:
  - Hazardous chemicals/materials needed to perform the task and their specific hazards
  - Safety measures to be implemented
  - 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
  These procedures also apply to areas that may have work performed by outside contractors.
  
  Potential hazardous non-routine tasks at Reynolds shall be identified by each respective department and documented on Appendix C. Each department will maintain Appendix C in the department with a copy forwarded to the Safety Officer.
10. 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 Department of Facilities Management and Planning will work collaboratively to have any and all reasonably accessible unlabeled pipes, that have been identified to carry hazard chemical/material, inspected semiannually for leaks, worn parts, etc.
11. ON-SITE CONTRACTORS
  The college has designated specific employees on each campus, to serve as the college's first point-of-contact (POCs) for its on-site contractors (Please contact The Department of Facilities Management and Planning for further information). Prior to the contractors starting work, the POC(s) will:
  - Inform on-site contractors of the college's hazard communication program (HCP)
  - Request any SDS from the contractors for any hazardous materials that will be used.
  - Work with the Department of Facilities Management and Planning and/or the Safety Officer to provide the contractors with:
    - Provide copies of all relevant SDS with respect to the contractor's work area
    - Inform on any precautionary measures that need to be taken to protect their employees
    - Share 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. The Safety Officer is to be made aware of any external and internal Safety Audits in addition to any inquires pertaining to the Hazard Communication Plan.
12. PROGRAM REVIEW
  This written Hazard Communication Program (HCP) for Reynolds will be reviewed in a collaborative effort by the college Safety Officer on a biannual basis and updated as necessary. All updates to the college's written Hazard Communication Plan 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)
  - Researching, developing and implementing, a college-wide communication mechanism to address Safety issues that include, but are not limited to the scope of this HCP

Appendix A
CHEMICAL INVENTORY

Please see the Safety Officer for this information.

General Information

Reynolds Community College
Campus Locations
(804) 371-3000