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HAZARD COMMUNICATION PROGRAM

HAZARD COMMUNICATION TOPICS:

I. GENERAL

The purpose of this document is to insure that the University of Pennsylvania is in compliance with the US Department of Labor's Occupational Safety & Health Administration's (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910.1200.

The Executive Director of the Office of Environmental Health and Radiation Safety is the overall coordinator of the University's program. Copies of the written program may be obtained from the Office of Environmental Health and Radiation Safety (EHRS) or from the EHRS website (www.ehrs.upenn.edu).

Each employee of the University of Pennsylvania must be apprised of the contents of the HCS, the hazardous properties of chemicals they work with, and measures to take to protect themselves from these chemicals. University employees working in research laboratories should consult PENN's Chemical Hygiene Plan for use and handling information for laboratory chemicals. The Chemical Hygiene Plan may be obtained from EHRS or from its website.

Whenever possible, the least hazardous substance will be procured.

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II. SAFETY DATA SHEETS (SDS's)

EHRS maintains an SDS library for hazardous chemicals used or stored at the University. SDS's were formerly known as MSDS's (Material Safety Data Sheets).  The SDS Library is located at EHRS, 3160 Chestnut Street, Suite 400/6287. SDS's 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.

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

SDS's 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 & 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.

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III. LABELS

All hazardous chemicals throughout Penn's campus must be properly labeled. Labels should list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer or other responsible party. Transfer containers must be labeled with this information. Immediate use containers (i.e., small containers into which materials are poured for use on that shift by the employee drawing the material) do not require labeling. To meet the labeling requirements of the Hazard Communication Standard for other in-house containers, refer to the label supplied by the manufacturer. All labels for in-house containers must be approved by EHRS prior to their use.

Supervisors must check on a monthly basis to ensure that all containers in the area are labeled and that the labels are complete.

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IV. TRAINING

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 KnowledgeLink.  Initial and refresher training can also be arranged by contacting EHRS at 215-898-4453 or via email. Additional training must be provided for employees whenever a new hazard is introduced into their work areas. Supervisors must ensure that training is complete before an employee begins working with a new hazardous substance.

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V. OSHA COMPLIANCE

All housekeeping and maintenance shops must post 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.

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VI. CONTRACTORS

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 SDS's for hazardous materials to be used in University Buildings to EHRS.

Pest control contractors must submit SDS's to EHRS for all pesticides used on campus. 

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NON-ROUTINE TASKS

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.

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VII. ADDITIONAL INFORMATION

Further information on this written program, the hazard communication standard, and applicable SDS's contact:

The Office of Environmental Health and Radiation Safety
3160 Chestnut Street, Suite 400
Philadelphia, PA 19104-6287
phone: 215-898-4453
email: ehrs@ehrs.upenn.edu
web site: www.ehrs.upenn.edu

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