Policy Name: Hazard Communication/Right to Know
Responsibility for Maintenance: Sustainability and
Environmental Health and Safety
Date of most recent changes: July 10, 2019
I. Policy Statement
Onondaga Community College employees have a right to be informed of potential hazards associated with chemicals they may use in their employment. This policy seeks to define College and employee responsibility, expectations and actions involving the safe handling of chemicals at the College.
II. Reason for Policy
The College is required to comply with applicable requirements of the New York State Right to Know Law and its implementing regulations and the Occupational Safety & Health Administration's (OSHA) Hazard Communication Standard (29 CFR 1910.1200).1 In general, these requirements address:
- Container labeling and other forms of warning
- Notification to Employees
- Material Safety Data Sheet and Safety Data Sheet requirements
- Training regarding Employee rights and properties of Chemicals they may be exposed to
- Implementation of appropriate measures to mitigate or prevent Chemical exposures
- Satisfaction of record keeping requirements by the College
This policy is the College’s Written
Hazard Communication Program, which meets the requirements outlined in 29 CFR
III. Applicability of the Policy
The policy applies in all departments and offices where Employees may be routinely exposed to Hazardous Chemicals. In addition, this policy imposes obligations on Department Heads and Management Services relating to procurement and provision of Safety Data Sheets.
IV. Related Documents
- 29 CFR Part 1910.1200 – Hazard Communication
- New York State Labor Law, Article 28 – Toxic Substances
- Title 12 of the New York Codes, Rules & Regulations, Part 820 – Toxic Substances – Information, Training and Education
- Onondaga Community College Laboratory Safety Program and Chemical Hygiene Plan
| Subject || Office Name || Telephone Number || Email/URL |
Evaluation of Exposure Incidents
Retention of Employee Exposure Records
Retention of Chemical Inventory Records
Acquiring and Updating Material Safety Data Sheets
and Environmental Health and Safety || (315) 498-2847 ||[email protected] |
| Term || Definition |
| Chemical || Any element, Chemical compound or mixture of elements and/or compounds. |
| Chemical Name || The scientific designation of a Chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the Chemical for the purpose of conducting a hazard evaluation. |
| Common Name || Any designation or identification such as code name, code number, trade name, brand name or generic name used to identify a Chemical other than by its Chemical Name. |
| Employee || A worker who may be Exposed to Hazardous Chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers who encounter Hazardous Chemicals only in non-routine, isolated instances are not covered. |
| Employer || A person engaged in a business where Chemicals are either used, distributed, or are produced for use or distribution, including a contractor or subcontractor. |
| Exposure/Exposed || That an Employee is subjected to, in the course of employment, a Chemical that is a physical or health hazard, and includes potential (e.g. accidental or possible) exposure. “Subjected” in terms of health hazards includes any route of entry (e.g. inhalation, ingestion, skin contact or absorption). |
| Hazardous Chemical || Any Chemical that is a physical hazard or a health hazard. |
| Health Hazard || A Chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in Exposed Employees. |
| Label || Any written, printed, or graphic material displayed on or affixed to containers of Hazardous Chemicals. |
| Material Safety Data Sheet (MSDS) || Written or printed material concerning a Hazardous Chemical. These are known as Safety Data Sheets (SDS)
under new OSHA regulations. |
| Physical Hazard || A Chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive. |
|Routine Exposure||Routine exposure means exposure which can be expected to occur in the course of employment as part of an employee's job duties. |
General: Any Chemical that appears in any of the following publications or has yielded evidence of acute or chronic health hazards in human, animal or other biological testing is considered to be a Health Hazard:
- CFR Part 1910: Subpart Z Toxic and Hazardous Substances (OSHA).
- Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment, American Conference of Governmental Industrial Hygienists (ACGIH) - latest edition.
- National Toxicology Program (NTP) Annual Report on Carcinogens - latest edition.
- International Agency for Research in Cancer (IARC) Monograms – latest edition.
- National Institute for Occupational Safety and Health's Registry of Toxic Effects of Chemical Substances (RTECS) - latest edition (applies to the New York State Right-To-Know Law only).
A record will be kept of those Employees who are exposed to Chemicals on the OSHA Subpart Z list. These Chemicals have known toxic effects and have had federal exposure limits, called Permissible Exposure Limits (PEL), established. The Employee records will be kept by the Office
of Sustainability and Environmental Health and Safety as required under applicable law. It is the responsibility of each Department Head to keep and maintain updated Employee and Chemical inventories for the department, and to forward updated lists to the Office
of Sustainability and Environmental Health and Safety. Signs will be posted to inform Employees that they have the right to know about the Hazardous Chemicals to which they are exposed.
List of Hazardous Chemicals: The Office
of Sustainability and Environmental Health and Safety will maintain lists of all Hazardous Chemicals used at the College and update the lists as new Chemicals come into the College. Each
department is responsible for providing a list of chemicals to the Office of
Sustainability and Environmental Health and Safety annually or when new
chemicals are acquired by the department. When purchasing new Chemicals, to the extent practicable, the least hazardous substance should be procured.
Safety Data Sheets (SDS): Management Services will obtain an SDS
for each new Chemical purchased. The Department Head or designee(s) will ensure
that each area maintains an SDS for the Hazardous Chemicals in that area.
Employee Access to SDS’s: Employees with Routine Exposure will be trained how to access
and read SDS’s. Employees will not need special authorization or permission to
access SDS’s. The supervisor of each operational area will ensure that all
employees under his or her supervision have access to the SDS’s for the
chemicals used in their work areas.
Safety Data Sheet File System
Office of Sustainability and Environmental Health and Safety will be the safety
data sheet (SDS) system manager responsible for compiling, maintaining, and
filing SDS’s for hazardous chemicals used or stored in work areas where
employees may be exposed to such chemicals. The primary location for all SDS
will be the online SDS database from the employee website.
SDS Records: An SDS for each hazardous chemical
will be kept in the SDS file or database system for as long as the hazardous
chemical is used in any work areas.
Transition from MSDS’s to SDS’s: OSHA is phasing out Material Safety
Data Sheets (MSDS) and transitioning to Safety Data Sheets (SDS). Both MSDS’s
and SDS’s will be utilized until MSDS’s are completely phased out. The older
material safety data sheet (MSDS) will be replaced with the new SDS for each
hazardous chemical as it is received with each new chemical shipment.
Labeling: Chemical manufacturers, importers, and distributors must label their containers of Hazardous Chemicals. Therefore, each container coming into the College should already be labeled, tagged, or marked with the following information:
- Identity of the Hazardous Chemical.
- Name and address of the Chemical manufacturer or responsible party.
- Appropriate hazard warnings including Health Hazards, Physical Hazards, target organs and effects, and personal protective equipment.
It is the responsibility of each Department Head, or designee(s) to ensure that each container in the department is labeled, tagged or marked with the identity of the Hazardous Chemical and the appropriate hazard warnings. This warning may be any type of message, words, pictures, or symbols which convey the hazards. Labels must be legible, in English, and prominently displayed. Any defaced or illegible Labels should be reported to the supervisor. Whenever a Chemical is transferred to a non-labeled container, a proper Label must be made-up and affixed to the new container.
The Hazard Communication Standard addresses certain exemptions for in-house labels:
- If a number of stationary containers within a work area have similar contents and hazards, signs or placards may be posted which conveys the hazard information.
- Various types of standard operating procedures, process sheets, batch tickets, blend tickets, and similar written materials may be substituted for container labels on stationary process equipment if they contain the same information as the container labels and if they are already available to the Employees in the work area throughout each work shift.
- If Hazardous Chemicals are transferred from a labeled container to a portable container for immediate use by the Employee who makes the transfer, labels are not required for the portable container.
- Warning labels are not required for pipes and piping systems. However, contents of such systems should be clearly identified.
Training: Each Employee with Routine Exposure to Hazardous Chemicals will receive initial training on
the Hazard Communication/Right-To-Know Law. Training will include the safe use
of Hazardous Chemicals before initial assignment, annually thereafter and
whenever a new hazard is introduced into their work areas. It is the
responsibility of the Department Head, or designee(s), to notify the Office of
Sustainability and Environmental Health and Safety before a new hazard is
introduced to Employees. A written log will be kept by the Office of
Sustainability and Environmental Health and Safety of all the Employees who
have received training. The Office of Sustainability and Environmental Health
and Safety will also maintain records of training needs of each department. The
content of the training will comply with OSHA 29 CFR 1910.1200 and NYS 12 CRR-NY
The determination of which Employees
are required to receive specific safety training will be based upon their
Routine Exposure. It is the intent of the College to ensure that Employees receive
information regarding all of the Chemicals in their work areas and that they
are prepared to deal with any unexpected releases or emergency situations, as
well as Routine Exposures encountered during the normal course of employment.
Non-routine tasks: These tasks are those which are not
performed on a routine basis and which may involve contact with a Hazardous
Chemical. The Department Head or designee(s) will determine what hazards are
present or may be created by a task. The Department Head or designee(s) is
(are) responsible for communicating this information and must inform the
Employees of any special equipment, such as portable ventilation systems and/or
personal protective equipment, that will be needed. The Department Head or
designee(s) should contact the Office of Sustainability and Environmental
Health and Safety for advice concerning non-routine tasks.
1 The OSHA Hazard Communication Standard has been adopted by
the New York State Commissioner of Labor as an applicable standard for the
health and safety of public Employees.
Approved by OCC Board of Trustees April
Updated and approved by the President
June 9, 2011
Updated and approved by the President
April 30, 2013
Updated and approved by the President
April 14, 2014
Updated and approved by the President
March 28, 2016
Updated and approved by the President July 10, 2019