UAMS ADMINISTRATIVE GUIDE

NUMBER: 11.4.02
DATE: 1/15/1997
REVISION: 10/11/2004, 9/1/2007

(1)     The Department of Occupational Health and Safety (OH&S) will be responsible for the following:

1. Conducting introductory Hazard Communication training sessions.
2. Ensuring that each department using “hazardous” chemicals has access to current Material Safety Data Sheets (MSDS). 
3. Determining whether chemicals used are “hazardous” within the meaning of the definition established by Occupational Safety and Health Administration (OSHA).
4. Reviewing MSDS for compliance with OSHA guidelines.
5. Maintaining the UAMS central file for MSDS.
6. Ensuring review and compliance with the Joint Commission on Accreditation of Healthcare Organizations (JCAHO) standards which require that hazardous chemicals be handled safely, and training be conducted.

(2)     Department Managers are responsible for the following:

          a)      Providing specific training and information on Material Safety Data Sheets (MSDS) to their

                    employees and contractors as required by the standard (page 3).     

          b)      Maintenance and review of applicable MSDS.

          c)      Ensuring proper labeling on containers.

          d)      Establishing written departmental specific procedures.

          e)      Documenting employee training conducted within the department.

(3)     The UAMS Procurement Services Department will be responsible for ensuring that all chemical purchase orders have the words “MSDS REQUIRED” clearly labeled on the purchase request.  

PROCEDURES (REQUIREMENTS)

(4)     Original chemical containers must remain properly labeled, tagged, or marked at all times with the appropriate required information, including the identity of the hazardous chemical, appropriate hazard warnings and the name and address of the chemical manufacturer, importer, or other responsible party.

(5)     Containers received without appropriate forms of warning must be properly labeled.  The receiving department should contact Occupational Health and Safety for assistance.                 

(6)     Portable containers do not have to be labeled if they are intended for immediate use (on that shift), by the employee who transferred it from a labeled container.

(7)     Material Safety Data Sheets (MSDS) must be available and easily accessible to employees, OSHA and designated employee representatives during any shift, at any time; and must meet the requirements of the OSHA Hazard Communication Standard on form 174 or the equivalent.

PROCEDURES (EMPLOYEE INFORMATION AND TRAINING)

(8)     Introductory Hazard Communication Training is conducted during new employee orientation and open sessions.  Additional sessions are available upon request.  This training is conducted by Occupational Health and Safety.  Training will be conducted at the time of an employee’s initial assignment, and whenever a new hazard is introduced into their work area.

(9)     Employees will receive training in the following areas:

            *  Methods to detect hazardous chemicals

            *  Physical and health hazards of chemicals

            *  Protective measures

            *  Details of the Hazard Communication program

(10)    Employees will be provided the following information:

            *  Requirements of the OSHA Hazard Communication standard

            *  Operations with hazardous chemicals present

            *  Location and availability of the written hazard communication program

            *  Location and availability of MSDS

(11)    Contractors will be informed of the hazards of chemicals in their work area and of measures to protect their employees.

(12)    The specific chemical hazards and protective measures applicable to each department are not covered in the introductory hazard communication training (each department will be responsible for providing this training).

PROCEDURE (DEPARTMENTAL HAZARD COMMUNICATION TRAINING)

(13)    Employees are to be trained at the time they are assigned to work with a hazardous chemical.  Retraining is to be done when a new hazard (not just a new chemical) is introduced into the work area.  For example, if a new solvent is brought into the work place and it has hazards similar to existing chemicals for which training has already been done, no new training is required.  Of course, the MSDS’s must be available and the product must be properly labeled.  However, if the solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the work place before, new training on the carcinogenic hazard must be provided to employees working in the areas where it may be exposed.

(14)    Employees should complete, with documentation, the introductory Hazard Communication training prior to departmental training.  Department training should concentrate on the following areas:

a)    Operations in the work area where hazardous chemicals are present

b)    The location and availability of the written departmental specific procedures

c)    The location and availability of material safety data sheets

d)    Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.)

e)    The physical and health hazards of the chemicals in the work area

f)     The measures which employees can take to protect themselves from these hazards, including specific procedures the department has implemented, such as appropriate work practices, personal protective equipment to be used, and emergency procedures.

PROCEDURE (RECORDKEEPING)          

(15)    Department specific procedures will be updated annually or as new hazards enter the work place.

(16)    A copy of all MSDS will be forwarded to the Department of Occupational Health and Safety, for maintenance of a central file.

REFERENCES

OSHA 29 CFR 1910.1200

JCAHO, Plant, Technology, and Safety Management Standard PL.6 Hazardous Material and Wastes

Chemical Guide to the OSHA Hazard Communication Standard, Roytech Publications, 1986.

SIGNATURE: ________________________________  DATE: _________________________

NOTE:  This form may be used to simplify or summarize MSDS information and is available from OH&S.