UPPS 04.05.05 - Hazard Communication Program

POLICY STATEMENT

Texas State University is committed to providing a safe environment for its employees.

1. BACKGROUND INFORMATION

   1. This policy establishes a Hazard Communication Program (HCP) for complying with federal, state, and local hazard communication regulations, standards, and practices.

   2. This policy establishes procedures for providing information to Texas State University employees and to members of the community who may be exposed to hazardous chemicals used or stored at Texas State.

   3. Throughout this policy, the term “hazardous chemicals” refers to any materials that may pose a physical hazard or a health hazard. This includes chemicals in all physical forms – liquid, solid, gas, vapor, fumes, and mist – without regard to whether they are contained.

   4. Due to security considerations, lists of hazardous chemicals and their Safety Data Sheet (SDS) information should not be posted on a university or departmental website without prior written approval of the Department of Environmental, Health, Safety, Risk and Emergency Management (EHSREM).

   5. Non-compliance with this policy can result in violations being charged against Texas State by regulatory agencies, as well as the assessment of fines and other costs. Disciplinary action may be taken against university employees who do not comply with this policy and associated regulations.

2. PROGRAM COMPONENTS

   1. Applicability – This policy applies to all university activities where individuals may be exposed to hazardous chemicals in the work area under normal operating conditions or in foreseeable emergencies.

   2. Workplace Chemical List (WPCL) – Texas State compiles and maintains a WPCL that contains information for each hazardous chemical that could be considered a health or physical hazard, and which is normally used or stored at the university. The WPCL is a composite of work area chemical lists (chemical inventories).

   3. Safety Data Sheets (SDS) – An SDS shall be readily available for each hazardous chemical used in a work area. SDSs can be hardcopies or can be available through an electronic database or through manufacturers’ web sites. The electronic copies must be made readily available via signage or weblinks to the SDS information in each work area.

   4. Container Labels – Original labels on incoming containers of hazardous chemicals must not be removed or defaced. Chemicals in original packaging transferred to other containers (i.e., workplace containers or secondary containers) except those for immediate use, must have labels affixed with at least the following information: chemical name and health or physical hazard warnings. No one may be required to work with a hazardous chemical which has been transferred to an unlabeled container unless that person made the transfer and will immediately use the chemical.

   5. Training – Education and training programs for individuals who use or handle hazardous chemicals must be provided. At a minimum, training should include applicable university policies, use information provided on the SDS and chemical container labels, the location of hazardous chemicals present in the work areas, the physical and health effects of exposure, proper use of personal protective equipment (PPE), safe handling of hazardous materials, first aid treatment for exposure to hazardous chemicals and safety instruction on clean-up and disposal of hazardous chemicals. Alternatively, departments can utilize the training provided by EHSREM through classroom setting and online training. Training records must be maintained and be available for review in the work area or central location.

3. RESPONSIBILITIES

   1. EHSREM is responsible for the following:

      1. developing policies for Texas State that follow federal, state, local regulations, standards, and practices related to hazard communication;

      2. compiling and reviewing the departmental Work Area Chemical Lists (WACL) to comprise Texas State’s WPCL. EHSREM will compile the WPCL at the end of the year as updated annual WACLs are submitted by each applicable laboratory and work area;

      3. preparing and submitting the annual Texas Tier Two Report to the Texas Commission on Environmental Quality;

      4. providing the Local Emergency Planning Committee (LEPC) and the San Marcos Fire Department (SMFD) with a copy of the Texas Tier Two Report;

      5. providing hazard communication training either in person or electronically; and

      6. disseminating the Notice to Employees to apprise them of their rights.

   2. University employees who are responsible for areas that use or store hazardous chemicals in areas other than laboratories are responsible for:

      1. following policies developed by EHSREM.

      2. developing a written HCP. EHSREM maintains a master copy of the written program, and it can be modified as needed for each department. The master copy may be obtained upon request from EHSREM;

      3. posting the Notice to Employees poster in the work area;

      4. maintaining and making available to employees an accurate WACL in the format designated by EHSREM;

      5. providing a work-area specific training session for new and newly assigned employees, including student workers before they can work with, or in, a work area containing hazardous chemicals

         1. Content of training programs must include the information set forth in Section 02.05.

         2. The employing department or office will maintain a record of training for five years and provide it to EHSREM upon request. EHSREM maintains records of training for personnel trained through EHSREM-led training (in-person).

         3. The supervisor must document the employee’s participation in the training. Documentation must include date of training, name of instructor, topics covered, name of the employee, and the employee’s signature attesting to their participation.

         4. The supervisor must provide annual refresher training on all hazardous chemicals used or stored in the work area. The supervisor must give training throughout the year to cover chemicals introduced into the work area that pose new hazards to employees.

      6. ensuring all containers are properly labeled;

      7. maintaining up-to-date SDS for each chemical in the work area. The SDSs can be hardcopies or available through an electronic database or through manufacturers’ websites;

      8. providing appropriate PPE for the hazardous chemicals in use; and

      9. budgeting funds to adequately support the availability of proper PPE for employees and students exposed to hazardous chemicals.

   3. University employees who are responsible for laboratories or supervise personnel who work in laboratories where hazardous chemicals are present must ensure compliance with all, applicable Texas State policies and with the Campus Chemical Hygiene Plan. In addition, they have the responsibility to:

      1. develop, maintain, and make available to employees an accurate chemical inventory in the format designated by EHSREM.

      2. maintain up to date SDSs for each chemical in the laboratory. The SDSs can be hardcopies or available through an electronic database or through manufacturers’ websites. The electronic copies must be made readily available via signage or weblinks to the SDS information in each work area.

      3. provide laboratory specific training in accordance with this policy (see 02.05 for more information).

   4. Additional resources include:

      1. Occupational Safety and Health Standards Act, 29 CFR, Part 1910, relating to working in areas with hazardous substances; provided by the Occupational Health and Safety Administration (OSHA); and

      2. Texas Hazard Communication Act (Worker Right-to-Know Program), Texas Health and Safety Code Chapter 502, relating to working in areas with hazardous substances in Texas, provided by the Texas Department of Health and Human Services.

4. REVIEWERS OF THIS UPPS

   1. Reviewers of this UPPS include the following:

      Position	Date
      Director of Environmental, Health, Safety, Risk and Emergency Management	October 1 E4Y
      Supervisor, Laboratory Safety Division	October 1 E4Y
      Chair, University Laboratory Safety Committee	October 1 E4Y
      Associate Vice President, Facilities	October 1 E4Y

5. CERTIFICATION STATEMENT

   This UPPS has been approved by the following individuals in their official capacities and represents Texas State policy and procedure from the date of this document until superseded.

   Director of Environmental, Health, Safety, Risk and Emergency Management; senior reviewer of this UPPS

   Vice President for Finance and Support Services

   President