Table of Contents

5.1 Introduction

5.2 Controls to Reduce Exposures to Hazardous Materials

5.3 Chemical Procurement, Labeling, Storage, and Inventory

5.4 Chemical Labeling

5.5 Chemical Storage

5.6 Chemical Lists and Safety Data Sheets

5.7 Chemical Hazard Information and Training

5.8 Department Specific Supplemental Documents

Related Documents

Department Specific Hazcom Plan Details SDS Poster Revised SDS Poster

5.1 Introduction #

The purpose of a Hazard Communication Program is to inform employees of the hazards associated with chemicals in their workplace and ensure the safe use, handling, and disposal of hazardous chemicals. Overexposure to chemicals can result in adverse acute or chronic health effects. Routes of exposure to hazardous materials include contact with skin and eyes, inhalation, ingestion, and injection. Hazard Communication requires all employers to provide information to their employees about the hazardous chemicals to which they are exposed by completing a chemical inventory, ensuring labels are on containers, safety data sheets (SDSs) are available, and training is provided for workers.  

Reference Regulation: Hazard Communication (MIOSHA General Industry Part 42)

5.2 Controls to Reduce Exposures to Hazardous Materials #

As a general principle, all use of hazardous materials must be controlled to reduce exposures below permissible limits. The nature of a hazardous substance and its route of entry into the body determine the types of controls used to reduce exposures. Airborne hazards must be removed from the air and barriers must be provided to prevent contact and absorption hazards. Ingestion hazards are prevented by good hygiene practices and hand washing facilities.

There are three types of controls that are utilized: engineering, administrative, and personal protective equipment (PPE). Engineering controls are those that actually remove the hazardous material from the work environment. Administrative controls are procedures that reduce the amount of material, duration or extent of exposure to the material. PPE provides a barrier between the user and the material. Engineering controls will be used as the primary method to reduce exposures. Administrative and PPE will be used as secondary controls in most cases.

5.3 Chemical Procurement, Labeling, Storage, and Inventory #

Prior to procuring a chemical, it is important to consider all cost aspects during the life cycle of the chemical. Close attention must be paid to purchasing, handling and disposal costs to effectively manage chemical inventories and minimize accumulation of unused or unwanted chemicals.

Hazardous chemicals must be stored, labeled and inventoried properly to avoid confusion or mistaken identity of a chemical, to provide separation of incompatible materials, and to provide information for emergency response personnel.

5.4 Chemical Labeling #

The MIOSHA Hazard Communication Standard (HCS) is intended to ensure chemical safety in the workplace by requiring employers to provide information about the identities and hazards of chemicals that employees handle and use. The HCS is aligned with the Globally Harmonized System (GHS) of classification and labeling of chemicals. GHS provides a standardized approach to label elements and safety data sheets (SDS).  

All hazardous chemical containers will have:

• Primary label from the chemical manufacturer/supplier containing pictograms
• Signal word
• Hazard statements and precautionary statements
• Common product or chemical name 
• Supplier or manufacturer name, address and telephone number 

Small Containers (<100ml) where a pull out/fold back labels or tags are not feasible must contain a statement that the full label is provided on the immediate outer package

Very small containers (<3ml) must have all the label requirements on the outer packaging and contain a statement that the container must be kept in the outer packaging when not in use. The outer packaging must not be removed or damaged.

The pictogram is a symbol plus other graphic elements, such as a border, background pattern, or color that is intended to convey specific information about the hazards of a chemical. There are eight (8) required (as applicable) standardized pictograms and one (1) optional pictogram, under the GHS. Each pictogram consists of a different symbol on a white background within a red square frame set on a point, i.e. a red diamond. All pictograms are diamond shaped with a red border and black image. 

Figure 5.4.1 HCS Pictograms and Hazards

Signal words are used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The two signal words to be used are “Danger” and “Warning”. “Danger” is used for the more severe hazards, while “Warning” is used for less severe hazards. Only one signal word corresponding to the class of the most severe hazard should be used on a label.

A hazard statement is assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Examples:

• Flammable liquid and vapor
• Causes skin irritation
• May cause cancer
• May cause liver & kidney damage

GHS adds severity rankings to each of the hazard classifications. Categories range from 1 to 4; with “1” indicating the most severe and “4” indicating least severe. Note: This ranking system conflicts with the NFPA and HMIS systems where the number “4” indicates a severe hazard.  

Figure 5.4.2 Comparison of HMIS/NFPA and GHS Severity Rankings

A precautionary statement is a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling of a hazardous chemical.

Examples:

• Wear eye & face protection
• Avoid breathing fumes or mist
• Keep away from heat, sparks, open flames & other sources of ignition
• Store in well-ventilated space

Secondary containers of chemicals and any in-house dilutions or mixture made from purchased concentrations are required to be labeled with the full chemical name (no abbreviations), concentration, and primary health and/or physical hazard(s). Labels can be handwritten, printed, or obtained from the manufacturer. The Chemwatch Safety Data Sheet program, located on the EHS website, has the capability of creating and printing various size labels for use in the lab.

5.5 Chemical Storage #

To lessen risk of exposure to hazardous chemicals, trained personnel must separate and store all chemicals according to hazard category and compatibility. In the event of an accident involving a broken container or a chemical spill, incompatible chemicals that are stored in close proximity can mix to produce fires, hazardous fumes, and explosions. Staff must read the SDS and heed the precautions regarding the storage requirements of the chemicals. 

Incoming chemical shipments should be dated promptly upon receipt, and chemical stock should be rotated to ensure use of older chemicals. 

Basic Procedures for Chemical Storage:

• Storage areas should be cool, dry, ventilated, well lit and away from direct heat and sunlight.  
• Appropriate chemical spill kits and fire extinguishers should be kept near storage areas.  
• Containers must be sealed, capped and in good condition. 
• Outsides of the containers must be kept clean of chemical residue. 
• When storing chemicals on open shelves, always use sturdy shelves that are adequately supported.
• Do not store liquid chemicals above shoulder height. 
• Do not store chemicals within 18 inches of sprinkler heads. 
• Use secondary containment devices (i.e., chemical-resistant trays) where appropriate. 
• Do not store chemicals on the floor, in the aisles, in hallways, or in areas of egress. 
• Store chemicals by compatibility – not alphabetically.
• Quantities of flammable materials greater than 5 gallons must be stored in a flammable materials storage cabinet.

Cylinders must be stored in ventilated areas. Closets and lockers are not acceptable storage locations. Hallways, corridors, stairwells or near elevators are also unacceptable. Additionally, cylinders of oxygen and other oxidizers must not be stored within 20-feet of fuel-gas or other combustible materials unless separated by a specific barrier, e.g., a noncombustible wall, not less than 5-feet high, having a fire-resistance rating of ½-hour. Cylinders must be secured from tipping over. Securing devices can be purchased from any many safety supply companies, or Facilities Maintenance can develop a restraining system.

Additional Safety Procedures:

• Maintain small inventories of chemicals. Large inventories are more dangerous and usually result in more wastes being generated. 
• When applicable, handling and storage procedures outlined on the SDS should be incorporated into your Standard Operating Procedures (SOP). 
• Prior to working with chemicals, training on proper use and storage must be provided. If you are unsure of the correct safe handling procedures for any chemical, please contact EHS for assistance.

5.6 Chemical Lists and Safety Data Sheets #

Supervisors are required to maintain a current list and an SDS for all potentially hazardous chemicals stored, used, or produced within each work area that is under their responsibility. It is the responsibility of the supervisor to determine if chemicals in use or in storage present a potential hazard which must be identified on the chemical list and to provide to employees upon request. MIOSHA requires vendors or manufacturers to provide a specific Safety Data Sheet (SDS) for each hazardous product.  An SDS, contains physical and toxicological hazard information for the product. 

EHS manages a chemical inventory tracking system to maintain chemical lists and SDS called the MI Safety Portal. MI Safety Portal is a web-based, online, limited access database that is used to maintain chemical lists/inventories. More information on the MI SAFETY PORTAL system, including a summary of its capabilities and how to obtain access, is available on the EHS website. Other acceptable means of inventorying chemicals include excel sheets or physical binders for storing SDS. Because individuals may not show signs or symptoms of an exposure to a chemical until years later, individual departments must maintain and archive all SDS (current, revised, and obsolete) at U-M for 30 years.  Departments may use the MI Safety Portal or keep binders of paper copies of SDS for this purpose.

The chemical list must be updated on an annual basis, or more often if warranted. Unneeded materials should be discarded through EHS HMM. 

5.7 Chemical Hazard Information and Training #

EHS conducts classroom and online new hire safety training for staff on: Hazard Communication, Personal Protective Equipment (PPE), and many other safety topics. All staff that work with hazardous chemicals or use PPE are required to complete this training, as appropriate, shortly after being hired (before they actually begin work hazardous chemicals). Web based classes are available on MyLinc. 

Training will include the following:

• The requirements of the MIOSHA Hazard Communication Standard
• All operations in their work area where hazardous chemicals are present
• Location and availability of the written hazard communication program, the list of hazardous chemicals, and the SDS
• Methods and observations that can be used to detect the presence or release of hazardous chemicals in the work area;
• The physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area;
• Measures the employees should take to protect themselves from these hazards;
• Details of the hazard communication program– including an explanation of the new label elements [product identifier; signal word; hazard statement(s);  pictogram(s); and, precautionary statement(s)] on shipped containers and the workplace labeling system used by their employer; the new SDS format/sections; and,
• How employees can obtain and use hazard information
• The employer is prohibited from discharging, or discriminating against, an employee who exercises his/her rights to obtain information regarding hazardous chemicals used in the workplace.
• As an alternative to requesting a SDS from the employer, the employee can seek assistance from the MIOSHA Construction Safety and Health Division, at (517) 284-7680, or the MIOSHA General Industry Safety and Health Division at (517) 284-7750, to obtain the desired SDS.  A sign or MIOSHA poster will be posted with the address and telephone number of the MIOSHA Divisions responsible for such requests.
• Before any new physical or health hazard is introduced into the workplace, each employee who may be exposed to the substance will be given information in the same manner as during the hazard communication training.

Specific Training

In addition to the EHS training, each department must set up and implement a specific safety training program. This training must cover necessary work practices, procedures and policies to ensure that employees are protected from all potentially hazardous chemicals, biological pathogens, and dangerous equipment used in the workplace. The training must be conducted by someone thoroughly knowledgeable of all the specific hazards and proper safety techniques. 

In most cases, the Hazard Comzard Communication and PPE training available from EHS will be sufficient to address most of the typical safety training requirements for most departments. However, the specific activities and training requirements for each department should be discussed in detail with representatives from EHS to ensure no gaps or deficiencies are present.

5.8 Department Specific Supplemental Documents #

In order to comply with  governmental regulations, each department which has workers that fall under the requirements to have a hazard communication plan must complete and maintain the department specific Hazcom Plan for their departmental records. The department specific HazCom Plan is designed to ensure the department details are easily documented, available and kept up to date.

Specific department information that must be included in the HazCom Plan are:

• Department Name
• Areas covered by this specific HazCom Plan
• Chemical inventory
• Labeling of secondary containers
• Location(s) of SDSs for the hazardous chemicals used by the department
• Location(s) of the SDSs locator posters for the department
• Information on how hazard communication training will be conducted
• Training records of hazard communication training conducted
• Task specific training for new staff and/or new chemicals 
• Information on how contractors will be informed of hazards when they are working in the department’s areas
• Records of annual reviews of the HazCom Plan 
• Identifying hazardous non-routine tasks if applicable

• Assignment of a “Responsible Supervisor”, who will be responsible for:
  • Maintaining the HazCom Plan
  • Ensuring training is conducted and recorded
  • Maintaining SDSs
  • Ensuring hazardous chemicals are properly labeled
  • Maintaining the hazardous chemical inventory
  • Maintaining SOPs for routine and non-routine tasks

For additional guidance, view the Department Specific Hazcom Plan.