In accordance with the Federal and Michigan Occupational Safety and Health Acts, (OSHA and MIOSHA) P.A. 154 of 1974 as amended by Act No. 80 of 1986 in Michigan, Lake Superior State University has established a written hazard communication program to safeguard employees in the handling of hazardous chemicals and other materials in the work place. This written program meets all requirements of the law, and is available in each department office and the Human Resources Office, in the assigned Procedures Manual, for review by all employees.
Overall responsibility for implementing and coordinating this program is vested in the Director of Physical Plant.
Under The Right to Know Law, P.A. 80 of 1986, the University's Written Hazard Communication Program includes the following elements.
- Hazard Determination:
The University will be relying on Material Safety Data Sheets (MSDS) obtained from material suppliers or manufacturers, to meet the hazard determination requirements. It is the responsibility of department supervisors to determine the hazardous materials used in their areas. If questions arise, the supervisor may request the local Health Department or Physical Plant department to assist in determining hazardous materials.
The Shipping and Receiving Clerk will be responsible for seeing that all containers coming into the University are properly labeled, as indicated in the Material Safety Data Sheets. Materials not properly labeled will not be issued.
All incoming labels shall be checked for: identity, hazard warning, and the name and address of the supplier/ manufacturer.
Each supervisor/department head shall be responsible for ensuring that all secondary and portable containers used in their work area are properly labeled with identity of the material and hazard warning, as indicated in the Material Safety Data Sheets.
Each supervisor/department head shall be responsible for ensuring that all stocks are inventoried, that old stocks of hazardous materials are properly labeled in a visible manner, and out-dated stocks are discarded through the hazardous waste disposal program of the Physical Plant.
Piping systems on campus will be labeled and painted at access points and every 10 feet where the piping is 8 feet or closer to employee contact. Piping will be painted as follows: OXYGEN - GREEN; ACETYLENE - ORANGE; NATURAL GAS - BLUE, and labeled with the proper hazard warning.
- Material Safety Data Sheets (MSDS):
Material Safety Data Sheets are developed by chemical manufacturers or importers for each chemical supplied, to record available scientific evidence used in making hazard determination, and provide the following information for the consumer: chemical and common name(s) of the material(s); physical and chemical characteristics of the material; physical and health hazards of the materials; signs and symptoms of exposure; medical conditions aggravated by exposure; primary route(s) of entry; permissible exposure limits; precautions for safe handling and use; applicable control measures; emergency and first aid procedures; name, address and telephone number of party responsible for preparing the MSDS, and other related information regarding the hazardous material.
The Director of Physical Plant will be responsible for compiling the master MSDS files. They will be kept in the Physical Plant Office and in the Security Office. Individual Material Safety Data Sheets will be kept on file for 30 years.
Copies of MSDSs for all hazardous chemicals to which department employees may be exposed will be kept on file in the office to which employees report directly. MSDSs will be available for review to all employees. Copies will be available upon request from the immediate supervisor, or from the Physical Plant Office.
Any department head or purchasing officer ordering a hazardous chemical(s) must inform the manufacturer/reseller of such chemical(s) to insure there are two copies of a proper MSDS sheet with each shipment of chemicals. Upon receipt of chemical(s), the receiving supervisor will keep one copy of the MSDS sheet for the Master MSDS file. The other copy of the MSDS will go with the chemical(s) to the department head. Department heads directly receiving hazardous chemicals must ensure a copy of the MSDS (s) are immediately given to the Physical Plant department.
Employees purchasing items locally for the University must request an MSDS for purchased items requiring an MSDS. If an MSDS is not readily available, the department head must obtain one for the file as soon as possible.
- Employee Information and Training:
The Human Resources Office shall coordinate and maintain records of general and specific Hazardous Materials Communication training required for all employees of the University.
Each new employee will be give a copy of the written Hazardous Communication Policy, and will receive general chemical hazard training from the Human Resources Office. Department heads will then train employees on the specific hazards inherent to their respective jobs regarding:
- a list of health and physical hazards in the specific work site
- chemicals and their specific hazards in their work site
- how to detect hazards at the work site
- how to lessen or prevent exposure to hazardous materials
- what preventative measures and safety equipment are provided by the University
- procedures to follow if exposed to hazardous chemicals
- how to read and interpret labels and the MSDSs.
The department head will make record of Hazardous Materials Communication training and written materials given each employee and will forward a copy of the record to Human Resources Office for retention in the training file.
Employees will sign a list indicating they have received training and written material and the date received, with a copy being sent to the Human Resources Office.
Before any new hazardous materials are introduced into a department, or work area, each employee will be given information regarding proper handling of such material. Supervisors will be responsible for seeing that MSDSs on the new material are available to employees upon request.
Department supervisors will conduct periodic safety meetings to update employees on hazardous materials used in their areas, and will send record of this to the Human Resources Office, showing date of training, names of those attending, and hazardous materials discussed.
Notices will be posted on the department bulletin boards that provide the location of the written hazard communication program and MSDSs available for the hazardous materials in their work location.
Video cassettes concerning the subject of Hazardous Materials Communication will be located in the Human Resources Office for training and may be viewed by employees when their respective department heads make arrangements with the Human Resources Office.
- Outside Contractors:
Applicable department heads must obtain and evaluate the MSDSs for any chemical(s), be they purchased, manufactured, or brought on-site by contractors or employees. These department heads will require a list of chemicals that a contractor may use prior to the chemicals being brought onto the work site. Contractors will be requested to provide and post lists of MSDS's for whatever hazardous materials they may bring to campus work sites.
- Inventory List:
Each department is responsible for compiling and maintaining a list of hazardous chemicals/materials used in their operations, and for maintaining an updated MSDS file available for inspection at the request of employees. Master files will be kept in the Physical Plant Office and Security Office, and will be available for the local fire department upon request.
It will be the responsibility of the Director of Physical Plant to make periodic inspections of labels, MSDS forms, and to interview employees to determine if the above procedures are being followed. A report to the supervisor with copies to the appropriate vice president and the President, will detail the findings with recommendations for any corrective actions deemed necessary.