The 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 web site (www.ehrs.upenn.edu).

Each employee of the University of Pennsylvania must be apprised of the content 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. MATERIAL SAFETY DATA SHEETS (MSDS'S)

EHRS maintains an MSDS library for hazardous chemicals used or stored at the University. The MSDS Library is located at EHRS, 3160 Chestnut Street, Suite 400/6287. MSDS's for many products are available on the EHRS website. All University employees may also obtain a copy of a Material Safety Data Sheet via a written, verbal (215-898-4453) or email (ehrs@ehrs.upenn.edu) request to EHRS. The MSDS will consist of a fully completed OSHA form 174 or equivalent.

MSDS's must be readily available to all employees. Facilities Services and UNICCO must ensure that MSDS's for hazardous materials used by their employees are maintained in the offices where the employees are based. Facilities Services and UNICCO must supply EHRS with a copy of an MSDS 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 MSDS's for all housekeeping products must also be located in UNICCO'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.

MSDS's that meet the requirements of HCS 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 MSDS's in a timely manner.

New Bolton Center

MSDS for any chemicals used or stored out at New Bolton Center can be found in the following locations:

Housekeeping: All MSDS for chemicals used by the Housekeeping Staff can be found in yellow MSDS binders both at the Admissions desk of Widener Hospital and in the Housekeeping Office in the Pathology Building.

Farm Crew: All MSDS for chemicals used by the Farm Staff can be found in a yellow MSDS binder in the breakroom of the Farm Headquarters. MSDS specific to the Machine Shop can be found in a yellow MSDS binder hanging on the wall in the Machine Shop.

Facilities Services: All MSDS for chemicals used by Facilities can be found in yellow MSDS binders in the Facilities/Maintenance Office. Contact the Maintenance Office for any needed MSDS.

EHRS also keeps copies of MSDS for all chemicals used and stored at NBC in the MSDS Library in the EHRS office on the main campus. MSDS's for typical cleaning chemicals used in NBC can be found on our website.

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 drained for use on that shift by the employee drawing the material) do not require labeling. To meet the labeling requirements of HCS 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 HCS 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 MSDS's are located, how to understand their content, and how employees may obtain and use appropriate hazard information.

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V. OSHA COMPLIANCE

All zones must post OSHA safety & health information at the zone office where maintenance staff gathers. In addition, EHRS's phone number (215-898-4453) must be posted.

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VI. CONTRACTOR EMPLOYEES

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

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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 MSDS'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