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Hazard Communication Program

Purpose

This Hazard Communication Program is intended to provide Western Michigan University (WMU) employees with information concerning the hazardous chemical(s) they may encounter during the course of their work.

Method

The Division of Environmental Safety and Emergency Management shall implement the Hazard Communication Program.

A copy of the written Hazard Communication Program shall be made available from the Division of Environmental Safety and Emergency Management to employees upon request. The written program will also be available for review at the University Police Station on a 24-hour basis and at specific locations on campus.

Program

• An inventory of all hazardous chemicals on campus shall be conducted and maintained by the Division of Environmental Safety and Emergency Management.
• Lists of hazardous chemicals for each university department shall be developed from the initial inventory, be updated periodically, and be available within that department.
• WMU shall rely on material safety data sheets from material suppliers to meet hazard determination requirements.

• MSDS for each hazardous chemical at the University shall be requested from the manufacturer or distributor and assigned an inventory number. Each MSDS shall be filed by this number and cross-referenced by product name on a computer database.
• Departments receiving an MSDS with an incoming chemical order shall submit a copy of that MSDS to the Department of Environmental Safety and Emergency Management.

• The Division of Environmental Safety and Emergency Management shall post and maintainin each work area the required MIOSHA “Right to Know” posters, and the “New or Revised MSDS” posters. Employees shall be notified within five (5) days of the receipt of any new or revised MSDS.
• MSDS shall be accessible to employees for review during their work shift.
• If the MSDS is not available in the work area, it can be reviewed at the WMU Police Station or requested from the Division of Environmental Safety and Emergency Management.
• Employees may verbally request to review and discuss hazardous material information, the written program, and the hazardous chemical lists with the Division of Environmental Safety and Emergency Management.

4. Labels and Other Warnings

• All incoming hazardous chemicals will be properly labeled. These labels shall be checked for the identity, hazard warning, and name and address of the manufacturer or responsible party.
• The Freight, Postal, and Delivery Department will be responsible for ensuring that incoming chemicals received at the University dock are properly labeled. If chemicals are not properly labeled, they will be refused/returned.
• Individual departments receiving hazardous chemicals shall ensure that the containers are properly labeled. If chemicals are not properly labeled they will be refused/returned.
• Each supervisor, lab director, and department head shall be responsible for ensuring that all temporary or refillable containers used in their work area are properly labeled with the name of the chemical and any hazard warnings.
• Piping systems containing any hazardous chemicals shall be painted every ten feet with the identity of the hazardous chemical and the appropriate warning.

• All employees shall be advised of the Western Michigan University Hazard Communication Program.
• Employees shall receive mandatory training regarding the hazardous nature of chemical materials that they may encounter during their work shift.
• Hazardous Material Training shall include:

1. The location and availability of the written Hazard Communication Program, the list of hazardous chemicals, and the MSDS.
2. The hazardous chemicals in the work area and their physical and health hazards.
3. The methods and observations used to detect the release or presence of hazardous chemicals in the work area.
4. The measures taken by WMU and the measures to be taken by each employee to prevent or lessen exposure.
5. Procedures to follow if exposure should occur.
6. The interpretation of labels and MSDS.

• Training shall be provided at the time of initial assignment and whenever a new chemical is introduced into the work area.
• Training records shall be maintained in the Department of Human Resources.

• The purpose of this requirement is to ensure that employees who perform non-routine tasks are informed and properly trained for the chemical hazards associated with non-routine tasks. Supervisors shall be responsible for contacting the Division of Environmental Safety and Emergency Management whenever employees will be performing non-routine tasks for which there is not already a standard operating procedure for that task and chemical.
• For instance, a non-routine task would occur when a chemical is to be used in a manner inconsistent with the directions on the label. Another example of a non-routine task is when an employee is to work with a chemical under conditions that arise infrequently.

• Before contractors begin work, the contract administrator (WMU employee in charge of the work) shall provide the contractor with the WMU Hazard Communication Program, and a list of hazardous chemicals that belong to WMU to which the contractor’s employees may be exposed.
• Contractors shall ensure their employees are provided any necessary personal protective equipment and the required information and training.
• Contractors shall inform their WMU contract administrator before bringing hazardous chemicals onto WMU property.
• Before contractors begin work on campus that may expose WMU employees or students to chemical materials, the contract administrator shall ensure that the MSDS for those materials have been provided to the Division of Environmental Safety and Emergency Management.

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