WESTERN NEW MEXICO UNIVERSITY

STUDENT HEALTH SERVICES
HAZARD COMMUNICATION/RIGHT TO KNOW PROGRAM

POLICY: The Student Health Services will maintain an effective “Hazard Communication Program” in accordance with the current New Mexico Occupational Health and Safety Act (Regulation 29 CFR 1910.1200).

PURPOSE: The above noted Regulation was established “to ensure that the hazards of chemicals produced or imported by chemical manufacturers or importers are evaluated, and that information concerning their hazards is transmitted to affected employers and employees. The transmittal of information is to be accomplished by means of comprehensive hazard communication programs, which are to include container labeling and other forms of warning, material safety data sheets (MSDS), and personnel training.”

GUIDELINES: This Program, as well as the Regulation, is otherwise referred to as the “Right to Know Law,” which effect is designed to provide knowledge, warning, protection and training to employees who may be exposed to the hazards of chemical and other materials.

This information is available to employees, designated representatives, Assistant Secretary of OSHA and the Director of NIOSH.

I. RESPONSIBILITY

  1. The Director of the Student Health Services (SHS) designates the Safety Committee Chairperson as having the prime responsibility for the administration of the “Hazard Communication Program.” This individual will be considered the Safety, Infection Control & Quality Improvement (SICQI) Coordinator.
  2. All personnel (staff, student employees and volunteers) will fully participate in the program as it may apply to their work area and work responsibility.
  3. The “Hazard Communication Program” will consist of five basic components:
    1. Inventory and audit of hazardous chemicals and materials.
    2. Labels and labeling of hazardous chemicals and materials containers.
    3. Material Safety Data Sheets (MSDS) maintenance, distribution, availability, and locations.
    4. Personnel training and information (general and specific).
    5. A written “Hazard Communication Program,” as herewith prescribed.
  4. The written “Hazard Communication Program” for the Student Health Services with its associated inventory list, records, materials, etc., will be maintained by the Coordinator of SICQI, and is located in the Nurse’s Office. Personnel may review the program, MSDS and chemical listing at this location.

II. MATERIALS, INVENTORY, AUDITS

  1. An initial inventory of all chemicals and materials will be made of all work areas and facilities. An annual audit will be conducted thereafter. All hazardous chemicals and materials will be identified and listed. The listing will note at least the following information:
    1. The name of the chemical.
    2. Identification of manufacturer or supplier.
    3. Location(s) where the chemical or material is used.
  2. A system will be maintained to add any newly introduced hazardous chemicals or materials to the list.

III. MATERIAL SAFETY DATA SHEETS (MSDS)

  1. An MSDS will be provided for all required chemicals and materials used within the SHS.
  2. There will be a Master MSDS File and Index of all required chemicals and materials, which will be located in the Nurse’s Office. The original inventory listing and audits will be used to ascertain that there is an MSDS as may be required for each chemical or material item, and that all containers are properly labeled and stored.
  3. An MSDS with associated Index will be available to personnel during their work period.
  4. The MSDS will be available for all required chemicals and materials used in a specific work area, or for a specific work assignment. Such locations will be:

    Laboratory
    Nurse’s Office
    Janitorial Closet

    In the event an MSDS is not available, or should a new chemical or material be introduced for use without a required MSDS, the SICQI Coordinator should be promptly notified in writing. The Coordinator will see that the matter is corrected.

IV. LABELS AND LABELING

  1. All hazardous chemicals or materials on hand or received must have a label that will specify at least:

    1. the chemical name
    2. any specific warning or other hazard information
    3. identification of the manufacturer or supplier and address
  2. A hazardous chemical or material label will not be removed from its container, nor will such a label be defaced.
  3. Any hazardous material introduced into a secondary container must be labeled.
  4. Should it become necessary for a label to be introduced by the SHS, or replaced on ahazardous chemical or material container, such a label will display the information noted in Paragraph A above. The SICQI Coordinator must be notified in writing of any such need.
  5. The Physical Plant Department Director or SICQI Coordinator will have a label affixed on each and every container having hazardous chemicals or materials.
  6. It will be the responsibility of the Physical Plant Department Director or SICQI Coordinator to ensure that all secondary containers are properly labeled with a duplicate of the manufacturer's label or a SHS or PPD label, as noted in Part IV (A) and (C) above.

V. INFORMATION AND TRAINING

  1. All personnel will be informed of the "Hazard Awareness Program"/"Right to Know Law" annually, and/or at time of initial assignment, and annually thereafter. This will include asbestos awareness information.
  2. Personnel will sign a form or list that they attended a general or specific training session indicating they received any written material, understood the SHS's policy on Hazard Communication, or received any technical or specific training relative to hazardous chemicals or materials.
  3. All personnel involved with any new or significantly changed material will be trained prior to the material being used.
  4. A short quiz will be given by the SICQI Coordinator as an indicator of the employee's retention of “Hazard Communication”/”Right to Know” basics.
  5. Retraining or refresher training will be conducted if an employee indicates a lack of knowledge regarding specific materials or “Right to Know” basics, or requests retraining. Refresher training will be provided annually.
  6. General program information and training will be accomplished by lecture, photo slides, movie, video, or literature, or a combination thereof, and will cover the contents of this program to include a review of the following:
    1. Department's policy statement (ref. POLICY)
    2. The basic definition of the Regulation (ref. PURPOSE)
    3. Statements of responsibility, both program and personnel (ref. Part I)
    4. Description of MSDS, and how to read, all sections
    5. Location and availability of the written Hazard Communication Program, MSDS masters and locations, and chemical listing (ref. Part III)
    6. Definitions (see attached):
      1. Hazardous chemicals
      2. Health hazards
      3. Physical hazards
    7. Steps that SHS personnel can take to lessen or prevent exposure to hazardous chemicals or materials, i.e., knowledge of chemicals, storage, posting, personal protective equipment, administrative controls, training, etc.
    8. Methods and observation techniques use to determine the presence or release of hazardous chemicals or materials in a work area, i.e., flame or fire, smell or odor, fumes, itching, color, irritation, etc.
    9. Follow the recommendations of the MSDS guides in the event there is an exposure to a hazardous chemical. The Emergency Action Plan should be followed in the case of building-wide possible hazardous chemical exposure.
    10. Notice of hazardous chemicals or materials that are in an individual's work area.
  7. INFORMING CONTRACTORS
    1. Student Health Services will notify Physical Plant Department of any known non-structural related hazards the contractors will be exposed to. This will include the location of the MSDS.
    2. It will be responsibility of the Physical Plant Department to provide contractors with the following information:
      1. Any hazardous chemicals to which they may be exposed while on the job site.
      2. Precautions and controls to be taken to lessen or prevent possible exposure by use of appropriate protective measures.
    3. Physical Plant Department will also be responsible for contacting each and all contractors before work is started to gather and disseminate any information concerning chemical hazards that the contractor may be bringing onto the work site.
    4. It will be the responsibility of any WNMU department official initiating a work or construction contract to notify the SICQI Coordinator of such contract, name of the contractor, date, and type of work to be performed at SHS.

VIII. PROGRAM MAINTENANCE -- OTHER FUNCTIONS

  1. Purchasing/MSDS Supply: A standard statement will be applied to all Purchase Orders on request in order to obtain applicable MSDS on all required chemicals or materials.

    "Suppliers must furnish the Student Health Services and the WNMU Safety Office (PO Box 680, Silver City, NM 88062) a "Material Safety Data Sheet" applicable to any item on this purchase request."
  2. No chemical or material requiring a MSDS will be introduced into the SHS or any work area of the SHS by petty cash purchase, supplier samples or other means without notifying the SICQI Coordinator in writing.

Reviewed and
approved _______________________________.