Hazard Communication Program

EHRS maintains a library of Safety Data Sheets (SDSs) for hazardous chemicals used or stored at the University. SDSs were formerly known as MSDSs (Material Safety Data Sheets).  The SDS Library is located at EHRS, 3160 Chestnut Street, Suite 400/6287. SDSs for many products are available on the EHRS website. All University employees may also obtain a copy of a Safety Data Sheet via a written, verbal (215-898-4453) or email (ehrs@ehrs.upenn.edu) request to EHRS. The SDS will consist of the fully completed OSHA required form. 

SDSs must be readily available to all employees. Facilities Services (FRES), Penn's housekeeping vendor, Aramark, and dining services vendor, Bon Appetit, must ensure that SDSs for hazardous materials used by their employees are maintained in the offices where the employees are based. FRES, Aramark and Bon Appetit must supply EHRS with a copy of an SDS for all products used by their employees on Penn's campus. A binder of SDSs for all housekeeping and maintenance products must be located in each stockroom and in each housekeeping zone office. A binder of SDSs for all housekeeping products must also be located in Aramark's main office on Penn's campus.

All products used by Penn maintenance and housekeeping staff must be reviewed by an industrial hygienist prior to its use. A recommendation for need of a substitution or personal protective equipment (PPE) will be made by the industrial hygienist. Facilities Services must supply the necessary PPE.

SDSs that meet the requirements of the Hazard Communication Standard must be fully completed and received at the University either prior to, or at the time of receipt of the first shipment of any potentially hazardous chemical purchased from a vendor. It may be necessary to discontinue procurements from vendors failing to provide approved SDS's in a timely manner.

New Bolton Center, Morris Arboretum & Gardens & School/Center Shops

SDS's are maintained at each facility where hazardous chemicals are stored and/or used.  SDS's are typically found in a yellow SDS binder in a conspicuous location at each facility.

All hazardous chemicals throughout Penn’s campus must be properly labeled.  The existing manufacturer's label must not be removed, altered or defaced.  If the original label must be replaced, it must contain the same information as the original label.  Labels, as required by the Occupational Safety and Health Act (OSHA) Hazard Communication standard 1910.1200, must contain the following information:

• Manufacturer name, address and phone number
• Product identifier
• Signal word (“Warning”, “Danger”)
• Hazard statement(s)
• Pictogram(s) (https://www.osha.gov/sites/default/files/publications/OSHA3491QuickCardPictogram.pdf)
• Precautionary statement(s)

When chemicals are transferred to other containers in the workplace, the OSHA required label elements must be on the new label, or the product identifier and words, pictures, symbols, or a combination thereof, in combination with other information (such as safety data sheets), can be used to provide the specific information on the hazards of the chemical. 

The labeling of containers in a laboratory is specified by the OSHA laboratory standard, 1910.1450.  Manufacturer chemical labels must still contain the elements listed above and must not be removed or defaced. If chemicals are transferred to a secondary container in lab, the new container must have the chemical name (chemical formulas are not appropriate) and, if possible, the physical or health hazard in words or symbols.  Safety data sheets (SDS) for the chemicals must be available to the laboratory employees. 

If an employee transfers hazardous chemicals from a labeled container to a portable container that is only intended for immediate use by the employee who performs the transfer, no labels are required for the portable container.  For more information, see the "Researcher-Created Labels" section under heading Section IV: Chemical Container Labeling in Penn's Chemical Hygiene Plan. 

Each employee working with or potentially exposed to hazardous chemicals must receive initial training on the Hazard Communication Standard and the safe use of these chemicals. The training will emphasize the following:

• A summary of the standard and this written program;
• Hazardous chemical properties including visual appearance, odor and the methods that can be used to detect the presence or release of hazardous chemicals;
• Physical and health hazards associated with potential exposure to workplace chemicals;
• Procedures to protect against hazards including the use of personal protective equipment, work practices, and emergency procedures;
• Hazardous chemical spill and leak procedures;
• Where SDS's are located, how to understand their content, and how employees may obtain and use appropriate hazard information.

Initial training is available on Workday Learning. Initial and refresher training can also be arranged by contacting EHRS at 215-898-4453 or via email. Additional training will be provided for employees whenever a new chemical hazard is introduced into the work area. Supervisors will ensure that training is complete before an employee begins working with a new hazardous substance.

All housekeeping and maintenance shops must post the OSHA Safety & Health poster where maintenance staff gathers. See https://www.osha.gov/Publications/poster.html In addition, EHRS's phone number (215-898-4453) must also be posted.

EHRS, upon notification from a supervisor or Project Manager, will advise outside contractors of any chemical hazards which may be encountered in the normal course of their work on the premises. Project Managers are responsible to supply SDSs for hazardous materials to be used in University Buildings to EHRS.  Contractors should take the following training: Hazard Communications for Contractors

Pest control contractors must submit SDSs to EHRS for all pesticides used on campus.

Supervisors contemplating a non-routine task, must consult with EHRS and ensure that employees are informed of chemical hazards associated with the performance of these tasks and appropriate protective measures. This will be accomplished by a meeting of supervisors and EHRS with affected employees before such work is begun.

Reviewed: 1/25/2019; revised 10/26/2021