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HAZARD COMMUNICATION. Safe Use, Handling & Storage of Chemicals and Other Affected Materials. The Engineering Program Texas A&M University. Topics to Review . The Texas Hazard Communication Act The TAMU HazCom Program Requirements for “Laboratory Departments” HazCom Implementation Plans

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HAZARD COMMUNICATION

Safe Use, Handling & Storage of Chemicals and Other Affected Materials

The Engineering Program

Texas A&M University


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Topics to Review

  • The Texas Hazard Communication Act

  • The TAMU HazCom Program

  • Requirements for “Laboratory Departments”

  • HazCom Implementation Plans

  • Supervisor Responsibility for Compliance

  • HazCom in:

    • Research Labs

    • Teaching Labs

    • Chemical Storerooms


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What is HazCom?

The Texas Hazard Communication Act is a

state law that requires public

employers to

provide employees with

specific information on the

hazards of chemicals to which they

may be exposed in the

workplace.


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Written Program (EHSD)

Duties & Responsibilities

Non-Routine Release

Training

Inventory

Labeling

MSDS

Supervision

Notice to Employees

Records

Reports

Implementation Plans

Workplace - Dept

*Work Area - Supervisor

*Optional

HazCom Requirements


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HazCom Facts

  • Texas is not an “OSHA State.”

  • HazCom for state agencies is under TDH.

  • Private employers are regulated by OSHA.

  • The Texas HazCom Act and TDH Rules are similar, but not identical with the OSHA Standard.

  • Texas does not have a “Lab Standard.”

  • TDH does recognize that research labs are different from other work places.


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Definitions

Employee: anyone (including students) who is on the payroll of TAMU or a TAMUS Agency and who may be exposed to hazardous chemicals in the workplace under normalworking conditions or foreseeable emergency.

Facility: Geographical location of one or more workplaces. TAMU and the Riverside Campus are facilities.

Workplace:Usually a single building (BioBio) or complex of buildings (Chemistry) where similar work activities are conducted.

Work Area: Room, lab or defined space within a workplace where hazardous chemicals are present, produced, used, or stored and where employees are present.


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HazCom at TAMU

Texas Hazard Communication Act: Enforced by TDH

TAMU HazCom Program: Administered by EHSD

Workplace Implementation Plan: Dept. or Administrative Unit

Work Area Implementation Plan: Room, lab or space


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HazCom in Research Departments

  • Appoint Hazard Communication Coordinator

  • Prepare a Workplace Implementation Plan

  • Post official TDH “NOTICE TO EMPLOYEES”

  • Urge supervisors to complete a Work Area Implementation Plan

  • Require supervisors to certify (at least annually) that all required training is complete and current.


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Workplace Implementation Plan

  • Name of Department or Unit

  • Responsible Person or Position

  • Location of Training Records

  • Location of MSDSs

  • “Notice to Employees” Location

  • Person Responsible for Inventory

  • Location of Inventory File

  • See “Fill-in-the-Blank” Form


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SPECIAL WORK AREAS

  • Teaching Labs

  • Chemical Stockrooms

  • Research Labs


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Hazardous Chemical Inventory

Workplace quantities: > 50 gal. or 500 lbs

Listed Extremely Hazardous Substances

Controlled Substances


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LABELS

  • PRIMARY CONTAINERS

  • Original label

    • Intact

    • Good condition

    • Not removed or defaced


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Labeling Requirements

Primary Containers

  • identity of material as on MSDS

  • health and physical hazards (including target organs.)

  • manufacturer’s name and address


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Other Work Places

Full label required on EVERY CONTAINER

Identity of material as on MSDS

Written hazard warnings

Target organs

LABELING Secondary Containers

  • Research Labs

    • Full label NOT required

    • Identify contents


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Container Labels

Primary containers must have Full Labels

Small 20containers may be labeled on rack or holder

Chemical Inventory

Incorporate into the Workplace Inventory.

Workplace must report > 50 gal or > 500 lb. (or > TPQ) for the Tier II Report

TEACHING LABS

  • Primary container labels must include:

    • identity of contents..same as on MSDS

    • hazard warnings (including target organs or systems)

    • Mfgr. name & address


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CHEMICAL STOCK ROOMS

  • Label all containers (unless for immediate use).

  • Include in Workplace Inventory. Workplace must report > 50 gal or 500 lb. or > TRQ.

  • NOTE:

    • A room or area that is connected to, and accessible ONLY through a research lab, is considered to be part of the lab.


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MSDS REQUIREMENTS

  • READILY ACCESSIBLE - within one work shift

  • CURRENT - most recent

  • EHSD Recommendation:

    • Maintain printed copy for:

      • hazardous materials in use

      • reasonable likelihood of exposure

      • highly hazardous substances present in the work area

    • Train employees on how to access MSDS

      • http://ehsd.tamu.edu--MSDS Search

      • Call EHSD 845-2132

      • Call manufacturer & request copy


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Required Training

  • General lab safety

    • Chemical safety training

    • Work site specific training


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Changes in Training Requirements

  • “New employee video” (aka “Category I Training) DOES NOT satisfy training requirements.

  • Training ONLY for employees who have “routine exposure to hazardous chemicals.

  • “Category II” Training now called “Hazard-Specific Training.”

  • There is no requirement to repeat training.


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TRAINING RECORDS

Date Training Provided

Name(s) of Instructors

AttendanceList - Names MUST be legible

SubjectsCovered


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GENERAL TRAINING

  • General Lab Safety

  • General Chemical Safety by Hazard Class

  • Labeling Requirements

  • General Ways to Access MSDS Information

  • Interpretation and Relationship of Labels & MSDS

  • Safe Handling Procedures

  • Proper Storage & Separation of Incompatible Chemicals

  • Minimizing Exposure -- PPE & Safety Equipment

  • General Emergency Procedures

  • Spill Response & Cleanup

  • Management & Disposal of Hazardous Chemical Waste

  • Can be provided by EHSD


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SPECIFIC TRAINING

Site-Specific

Chemical-Specific

Hazard-Specific

Supervisor Responsibility


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Specific Information and Training

  • Provide appropriate information and training to new or newly assigned employees before he/she work with or handles hazardous chemicals.

  • Additional training is required when:

    • a new or significantly increased hazard is introduced into the work area,

    • if the potential for exposure is significantly increased


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SITE-SPECIFIC TRAINING

  • Where hazardous materials are located and used.

  • Unusual or particularly hazardous materials or procedures

  • Location and access to MSDS & other safety information.

  • Location and use of safety equipment (including PPE)

  • Storage & labeling procedures in the lab

  • Emergency equipment & procedures, first aid

  • Exposure prevention and recognition

  • Proper storage of hazardous materials

  • Location and use of spill equipment

  • Specific hazard information on the chemicals in the lab


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MSDS INFORMATION

  • Chemical and Common Names

  • Hazardous Ingredients

  • Physical and Chemical Characteristics

  • Physical Hazards

  • Health Hazards

  • Primary Routes of Entry

  • Exposure Limits

  • Confirmed or Potential Carcinogen

  • Proper Handling and Storage

  • Control Measures

  • Emergency and First Aid Procedures

  • Date of Preparation or Latest Revision

  • Name, Address, Phone of Mfgr. or Responsible Party


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Hazard

Communication

Compliance

in Research

Laboratories


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CHARACTERISTICS OF A RESEARCH LABORATORY(According to TDH & OSHA)

  • Relatively small quantities of hazardous chemicals present and/or used.

  • Not for production

  • Containers, etc are designed for one person to easily and safely manipulate.

  • Multiple chemicals and procedures used.

  • Protective lab practices and equipment available and in common use.


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HazCom Requirements for RESEARCH LABS

  • Technically qualifiedSUPERVISION

  • “Ready” access to Material Safety Data Sheets

  • LABELING on primary containers

  • Employee TRAININGprior to potential exposure


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CONSEQUENCES of NON-COMPLIANCE

Loss of Research Lab Exemption

Fines

Personal & Employer Liability

Personal & Employer Aggravation

Paperwork


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WORK AREA IMPLEMENTATION PLAN

Not required,but HIGHLY RECOMMENDED

ADVANTAGES

Minimal effort

Proof of Training Compliance

Customized Lab Safety Manual

Reduction of Legal and Regulatory Liability


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OPTIONS FOR WORK AREA PLAN

  • Do nothing or “Do it yourself.”

  • Basic Plan

  • Basic Plan plus Lab-Specific Protocols


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OPTION IBASIC IMPLEMENTATION PLAN

  • Commitment to Safety & Health

  • Lab location

  • Responsible persons

  • Training documentation

  • Sketch of lab

  • MSDS Access - specific information

  • Hazard warnings

  • Hazard identification & labeling

  • Chemical inventory


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OPTION IILABORATORY SAFETY PLAN

Basic Plan plus:

  • Principles of Laboratory Safety

  • Strategies for Minimizing Exposure

    • Engineering controls

    • Administrative controls

    • Protective equipment

  • Laboratory Safety Rules and Procedures


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Prudent practices

Personal hygiene

Food & drinks in the lab

Personal protective equipment

Chemical fume hoods

Chemical storage

Hazardous waste

Housekeeping

Facility & equipment maintenance

Guards & shields

Glassware

Fire prevention

Cold traps & cryogenic hazards

Pressurized systems

Unattended operations

Working alone

Prior approval

Vigilance

Everyday hazards

Regulated/restricted areas or procedures

Accident reporting

Emergency information

Laboratory Safety Rules & Procedures


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Working With Hazardous Chemicals

  • Toxic Chemicals

    • High acute or unknown toxicity

    • High chronic toxicity

    • High chronic toxicity - animal use

    • Reproductive toxins

    • Chemicals produced in the lab

  • Physical hazards

    • Flammable solvents

    • Corrosive chemicals


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