Lewis & Clark College
Policy and Procedure
Subject: Chemical Safety/Hazardous Communication Training
Division: Business and Finance
Department: Facilities Services
Date: May 2012
To establish a safe working and learning environment by ensuring that “at risk” members of the entire College community are appropriately trained in the hazards associated with chemicals used in the operations of their departments. To ensure employees are informed of the presence of hazardous chemicals in the work place and to ensure compliance with the “employee right to know” provisions of the Oregon Occupational Safety and Health Code (OAR 437 Division 155).
Lewis & Clark College is committed to protecting the safety and health of all community members working in proximity to hazardous chemicals. It is their fundamental right to be accurately informed as to the hazards present, the degree of risk involved, and the control measures necessary to avoid hazardous exposures.
1. Departmental: The chairs or directors of departments at Lewis & Clark College shall be responsible for determining the potential for exposure to hazardous chemicals involved in the operations of their departments. The definition of “chemical” is:
Any element, compound, or mixture of elements or compounds existing as a gas, liquid, or solid and which does not meet the definition of an article. Examples: cleaners, detergents, sealants,paints, paint thinners, laboratory reagents, motor oils, and fuels.
Articles are exempt from this policy. The definition of “article” is:
Any manufactured item which is formed to a specific shape or design during manufacture, which does not release or otherwise result in exposure to a hazardous chemical under normal conditions of use, and which has end use functions dependent in whole or in part upon its shape or design during end use. Examples: furniture, hand tools, and structures.
The determination of hazard will be predicated on a review of the Material Safety Data Sheets of the chemicals used in that department as per the Chemical Labeling & Associated Documentation Policy. Where doubt exists as to whether a material should be classified as an article or as a chemical, or, whether a chemical is hazardous, the department chair or director will defer to the opinion of the Lewis & Clark Risk Management Coordinator (RMC).
2. Risk Management Coordinator (RMC): The RMC is responsible for the final determination of the presence or absence of hazardous chemicals in departmental operations based on:
- The opinion of department chairs and directors.
- A review of MSDS’s for a department.
- General observations of department activities.
- Requirements of federal, state, or local regulations.
Based on the above information, the RMC will direct that hazard communication and chemical safety training programs be set in place for departments when required.
B. Hazard Assessment:
The chairs or directors of departments shall assess potential risk of exposure to hazardous chemicals based on the information contained in MSDS’s. Material used in a department’s operations is to be considered hazardous if it possesses any of the following characteristics:
Flammability: the material has a flash point below 100 degrees F.
Explosive Potential: the ability to cause a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.
Reactivity: the material reacts in a way with other materials or with itself to produce a product that is inherently hazardous.
Hazardous Decomposition: the material, under special circumstances, will decompose to produce by-products that have the characteristics, of toxicity, carcenogenicity, reactivity, flammability, etc.
Toxicity: the ability of the material to cause adverse health effects in human beings.
Carcenogenicity: the ability of the material to produce malignancies (cancer) in human tissues.
Mutagenicity: the ability of the material to cause abnormal changes in the nuclei of human cells.
Teratogenicity: the ability of the material to cause adverse effects on human reproduction.
Corrosiveness: the material is either highly alkaline or acidic and capable of producing chemical burns of the skin, eyes, or mucous membranes on contact.
Compression: the material is stored in a closed vessel under an absolute pressure exceeding 40 psi at 70 degrees F., or 104 psi at 130 degrees F. regardless of the pressure at 70 degrees F., or the material is a liquid having a vapor pressure exceeding 40 psi at 100 degrees F.
C. Training Preparation:
Department chairs will identify which persons within their departments are at risk of hazardous chemical exposures prior to conducting training. This is done by associating MSDS’s with particular operations and identifying those persons involved in those operations. A binder of all MSDS’s shall be kept in a central location within the department where it is readily available to personnel. A written program outlining which operations are associated with which hazardous chemicals and an outline of the department training plan shall be placed in this binder.
D. Training Elements:
1. The general concepts of chemical safety:
a.Types of Hazards:
b. Impact of hazards on personnel:
Adverse health effects
Fire and explosion potential
Reactivity and decomposition
c. Hazard recognition:
Requesting work place monitoring by RMC.
d. Location of the departmental MSDS binder.
e. How to find a particular MSDS.
f. What information is contained in MSDS’s.
g. Concepts of Threshold Limit Value/Permissible Exposure Limits (TLV/PEL).
2. Specific chemical hazards and exposure control:
a. A discussion of each operation and associated chemical hazards.
b. Appropriate control measures for each hazard:
(1) Engineering controls (ventilation, isolation, etc.)
(2) Administrative controls (scheduling to avoid contact with personnel).
(3) Substitution of less hazardous materials.
(4) Personal Protective Equipment.