Hazardous Communication Program

Hazardous Chemical Identification and Classification

Hazardous chemicals include, but are not limited to, the following:

• "The Hazardous Substance List," commonly known as the Directors List of Hazardous Substances, 8 CCR §339;
• "Toxic and Hazardous Substances, Air Contaminants," 8 CCR §5155;
• "Threshold Limit Values for Chemical Substances in the Work Environment," American Conference of Governmental Industrial Hygienists, updated annually;
• "12th Report on Carcinogens," National Toxicology Program, 2011;
• "Monographs," International Agency for Research on Cancer, World Health Organization;
• SDSs for reproductive toxins and cancer causing substances; and
• Any other substance that may present a physical or health hazard as determined by scientific evidence.

Hazardous chemicals can be identified by the hazard classifications noted on manufacturer labels and SDSs. Common hazard classifications include flammable, corrosive, toxic and carcinogen

General Requirements

All departments that use, handle or store hazardous chemicals must maintain an inventory of the hazardous chemicals present in their work areas. Inventories must be entered in the Cal Maritime CIS, the online inventory system managed by SRM.

Consumer Products

Consumer products must be included in the chemical inventory if the employee exposure to the product is significantly greater than the consumer exposure occurring during the principal consumer use of the product. However, certain minimal inventory thresholds are required for other reporting agencies such as Certified Unified Program Agency (CUPA).

Chemical Inventory System (CIS)

The following CIS links is available on the Safety & Risk Management webpage by simply selecting the MSDS icon

General Requirements

Departments must maintain copies of any SDS received with incoming shipments of hazardous chemicals, obtain SDS of hazardous chemicals if received without an SDS, and shall ensure that SDSs are readily accessible during each work shift. SDSs may be maintained in electronic form so long as there are no barriers to employee access.

Obtaining SDSs

SDSs can be obtained by:

• Requesting copies from your supervisor
• Contacting the vendor directly
• Performing an internet search by entering the product name followed by MSDS
• Contacting SRM for assistance

By June 2015, all SDSs must be GHS-compliant. SDSs will have a consistent 16-section format with the following sections:

• Section 1: Identification
• Section 2: Hazard(s) Identification
• Section 3: Composition/Information on Ingredients
• Section4: First Aid Measures
• Section 5: Fire-Fighting Measures
• Section 6: Accidental Release Measures
• Section 7: Handling and Storage
• Section 8: Exposure Control/Personal Protection
• Section 9: Physical and Chemical properties
• Section 10: Stability and Reactivity
• Section 11: Toxicological Information
• Section 12: Ecological Information (non-mandatory)
• Section 13: Disposal Considerations (non-mandatory)
• Section 14: Transportation Information (non-mandatory)
• Section 15: Regulatory Information (non-mandatory)
• Section 16: Other Information

Manufacturers and importers may withhold the specific chemical identity of a hazardous chemical with certain "trade secret" provisions. Contact SRM for assistance with addressing "trade secret" information

General Requirements

Every container of a hazardous chemical, except containers that will contain chemicals for immediate use, must be labeled, tagged, or marked to identify the substance and appropriate hazard warnings.

Manufacturer Labels

The manufacturer's original label shall provide:

• Identity of the hazardous substance;
• Signal word;
• Hazard statement(s);
• Pictograms;
• Precautionary statement(s); and
• Name and address of the manufacturer, importer or responsible party.

Labels shall be:

• Legible;
• In English; and
• Prominently displayed on the container.

• The original label shall not be removed or defaced unless the container is immediately marked with the required information.

Workplace Labels

Minimum Requirements

• Every container of a hazardous chemical must be labeled, tagged, or marked, in English, to identify the chemical and to provide appropriate hazard warnings;
• Portable secondary (workplace) containers used immediately by the person performing the transfer do not need labels; and
• Non-hazardous substances (e.g., distilled water) should be labeled in order to avoid confusion.

Acceptable labeling conventions

Best practice is to include all information that is provided on the manufacturer's label.

If a set of abbreviations is used routinely in the work area, definitions of the abbreviations must be posted in a prominent place in the work area and available to all employees.

• Alternative methods such as signs, placards, process sheets, and operating procedures are acceptable for individual stationary process containers, provided that the information is conveyed to all affected persons. Commonly used labeling systems include Department of Transportation, National Fire Protection Association and Hazardous Materials Identification System.
• Examples of acceptable labeling conventions include:

Small volume containers such as micro-scale test tubes and vials can be placed in a rack and the rack can be labeled with the name of the hazardous chemical and the appropriate hazard;

• Containers are labeled with a symbol and a sign is posted defining the meaning of the symbol; the posted information must include the name of the hazardous chemical and the appropriate hazard; and
• Secondary container labeled with unique product or common name must also contain the appropriate hazard warning; example "concentrated Accel-corrosive."

The poster "Safety Data Sheets, Labels, and Hazardous Chemical Emergencies," must be displayed in all areas where hazardous chemicals are used, handled or stored. Departments must fill in all blank spaces (e.g., location of SDSs) on the poster.

Aboveground pipes transporting hazardous substances (gases, vapors, liquids, semi- liquids, or plastics) shall be labeled in accordance to 8 CCR §3321, "Identification of Piping."

Employees shall not work on any unlabeled pipes until:

• The contents of the pipe are determined; and
• Appropriate safety precautions have been determined for the work.

All off campus shipments of hazardous chemicals must comply with the current U.S. Department of Transportation (DOT) requirements and the Cal Maritime Hazardous Chemicals Use, Storage, Transportation and Disposal policy. Hazardous Materials shipment information can be found on the Safety & Risk Management webpage.

Hazard information, which includes access to SDS, must be made available to contractors and contract workers if the work is to be performed in the presence of hazardous chemicals. Contractors and contract workers must also disclose hazard information for hazardous chemicals that are brought into the work area that may affect campus employees.

Employees shall follow emergency procedures covered in their department-specific Emergency Action Plan and Injury and Illness Prevention Program. Emergency response procedures are also covered in the SDSs, labels, and Cal Maritime Emergency Response Guide.