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Environmental Health and Safety

Hazard communication program

Introduction

The purpose of this Hazard Communication Standard (HazCom) Program is to provide Kansas State University (KSU) employees with the necessary information to protect their health and well-being from chemical hazards. The KSU Department of Environmental Health and Safety (EHS) has developed this written HazCom Program detailing the methods used at KSU to provide necessary chemical hazard information to employees. These methods include an inventory of every hazardous chemical on campus, proper chemical labels, collections of Safety Data Sheets with Right-to-Know access, training, and this written document. These hazard communication methods will reduce injuries and illnesses resulting from exposure to hazardous chemicals. All university laboratories should have a copy of this written program. 

Hazard Communication Standard

The Occupational Safety and Health Administration (OSHA) released an updated Hazard Communication Standard (HCS) in 2012 which aligned the document with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals (GHS). GHS is a standardized international format of communicating chemical hazard information intended to improve the quality and consistency of such information. The GHS system includes requirements for chemical labels, pictograms, and Safety Data Sheets.
This written HazCom Program complies with OSHA's HCS 29 CFR 1910.1200 and is to be enforced throughout the university.
OSHA defines a hazardous chemical or chemical product as one that poses a physical and/or health hazard to the user. Typical hazards include:

a. Physical: compressed gases, explosives, flammables, oxidizers
b. Health: carcinogens, poisons, irritants

Thousands of chemicals are used daily throughout the campus and new ones are routinely introduced into the work environment. This program applies to all chemicals or chemical products that are known to be present in the workplace and which employees may be exposed under normal use conditions or in a foreseeable emergency. The chemicals covered by this program include but are not limited to laboratory chemicals, cleaning agents, floor strippers and waxes, maintenance solvents and oils, compressed gas, printing inks and solvents and paint.

This standard does not apply to:

a. Food, drugs, cosmetics, tobacco or tobacco products, or alcoholic beverages packaged for sale to consumers or intended for personal consumption by employees in the workplace.
b. Any consumer product or hazardous substance where it can be demonstrated that it is used in the workplace in the same manner as normal consumer use, and which use results in a duration and frequency of exposure which is not greater than consumer exposure.
c. Any drug as defined by the Federal Food, Drug, and Cosmetic Act that is used in its final form for administration to the patient such as a dispensing pharmacy or hospital.
d. Wood or wood products, including lumber which will not be processed, where the chemical manufacturer or importer can establish that the only hazard they pose to employees is the potential for flammability or combustibility. Wood or wood products which have been treated with a hazardous chemical covered by this standard, and wood which may be subsequently sawed or cut, generating dust, are not exempted.
e. Hazardous waste.
f. Nuisance particulates where the chemical manufacturer or importer can establish that they do not pose any physical or health hazard covered under this section.
g. Ionizing and non-ionizing radiation.
h. Biological hazards.

The HazCom Program is distinct from the University’s Chemical Hygiene Plan (CHP). The CHP is primarily to inform the safe use of chemicals in the workplace, and so contains standard operating procedures, criteria for selecting safety controls, and measures to maintain safety controls present in the laboratory. The purpose of the HazCom Program is to ensure effective communication about the chemical/physical hazards in the workplace, and so has requirements for container labels, Safety Data Sheets, training, and inventory control. The two programs work hand in hand.