Hazardous Materials Management Policy

Initiated: June 18, 1987
Revised:  September 7, 2005 Approved:  October 5, 2005

Purpose

To manage hazardous materials that presents a physical or health hazard, on the campus of Northern Michigan University.

Applicability

All University employees, full time, part time, temporary, casual labor, students.

Policy

It is the Policy of Northern Michigan University that all hazardous materials will be managed in accordance with the Federal Hazard Communication Standard and Michigan's Right To Know Law, as they apply to: Acquisition of Hazardous Materials, Storage and Transportation, Health Assessment, and Disposal of Hazardous Waste.

References

Federal Hazard Communication Standard (HCS), 29 CFR 1910.1200 as amended and Michigan's Right To Know Law, Act 80, of Public Acts of 1986 as amended.

Initiating Department/Division

Public Safety and Police Services, 227-2152.

Preface of the Hazardous Materials Management Plan

This Hazardous Material Management Plan has been established as guidelines for managing hazardous materials on the campus of Northern Michigan University.

  1. Hazardous material is defined as any material that presents a physical or health hazard.
  2. University Policy
    1. Regulatory Compliance: The University will comply with the Federal Hazard Communication Standard (HCS), 29 CFR 1819.1200 and Michigan's Right To Know Law.
    2. Excluded Materials: Any substance regulated by separate Federal or State regulations or law such as: asbestos-related materials, PCBs and nuclear wastes are excluded.

Responsibilities Of Hazard Material Management

  1. President: Promote safe living through an effective Safety Program in all phases of our operation: education, research, student service, public service, and employee and community relations.
  2. Director of Purchasing: Will purchase materials based solely on need, and not in bulk.
  3. Director of Human Resources: Will ensure that all employees are aware of the requirement of the plan.
  4. Academicians: Are required to brief students on safety policies and to insure that said policies are complied with in their classes.
  5. Administrators/Supervisors: Will be held responsible for insuring that subordinates comply with safety policies and will be accountable if subordinates do not comply.
  6. Staff Employees and University Employed Students: Compliance with safety policies is mandatory and failure to comply is grounds for disciplinary action.
  7. Safety Director: Shall implement the Hazardous Materials Management Plan.
    1. The Safety Director shall determine the presence of hazardous materials (as defined by Federal or Michigan statutes) in facilities owned, operated or controlled by the University and to evaluate necessary actions to comply with all statutory requirements.
      1. Each department will complete an annual inventory of all hazardous substances and provide the inventory to Public Safety.
      2. The Public Safety Department shall maintain a complete listing of all hazardous substances and Material Data Safety Sheets for those substances.
    2. The Safety Director shall chair the University Safety Committee which will serve as the central clearinghouse for all issues related to safety. The Committee will meet on a regular basis to review compliance with current rules, codes, and regulations; to discuss accident prevention, methods, safety education and training; to evaluate compliance inspections and with Michigan's Right To Know Law. The committee, through the Chair, will act as an advisory group to the University administration apprising them of potentially unsafe procedures, practices, conditions or violations. The Committee will then develop practical recommendations for controlling or correcting them. The committee, through the chair, will present these recommendations to the University administration on various safety related issues brought to the attention of Committee members.
    3. The Safety Director will inform all on-site contractors of the hazards their employees may face while performing work at Northern Michigan University. Upon request, the contractor will be provided with copies of the Material Safety Data Sheet (MSDS) for the substances to which employees may be exposed.  Contractors will not be permitted to begin work until this process has been completed.
      1. Each contractor shall sign a statement acknowledging the receipt of the specific MSDS. Prior to starting work, each contractor shall sign a statement acknowledging that they have trained their employees about the hazardous substances they may be exposed to while working at the University.
      2. Prior to beginning work, each contractor shall provide the Safety Director with MSDSs and a list of all substances that will be used and supplied by the contractor's employees while working at the University.
      3. The list of substances and MSDSs will be evaluated by the Safety Director to determine if they pose any new or significant risk to University employees. The University will reserve the right to refuse to let a contractor use or manufacture a specific substance if it poses an excessive risk or would necessitate additional training of University employees.
      4. When bringing hazardous substances onto the University, contractors will be required to properly label each container in accordance with the requirements of the Hazard Communication Standard.
      5. The Safety Director is responsible for periodically checking labels on contractor-supplied containers to assure that the contractor is adequately performing his labeling function.
      6. It will be the responsibility of the contractor to remove all hazardous materials from the work site upon completion of the project.
      7. During the construction project, the contractor will be responsible for proper storage of hazardous materials at the work site. Upon completion of the project the Safety Director will inspect the site to insure that all containers of hazardous substances have been removed.

Acquisition Of Hazardous Materials

  1. Chemicals on the most current EPA Toxic Release Inventory (TRI) List may not be purchased by any department without prior approval of the Dean of the College and the Safety Director.  Departments will be provided current EPA TRI List by the Safety Director.
  2. Departments utilizing toxic chemicals shall develop internal policies and procedures for the acquisition and use of these products.  The policies and procedures will be recommended by the department head and approved by the Dean of the College and Safety Director.   The policies will be attached to this policy and reviewed on an annual basis.
  3. The individual initiating the purchase has the following responsibilities:
    1. Notification to the department head and approval of the Dean.
    2. Notification to the appropriate stock room manager. 
    3. Notification to Purchasing Department that the item is on the EPA TRI List.
    4. Notification and arrangements for immediate delivery of the substance once received at Central Receiving.
  4. Department using material shall comply with the requirements of this policy and all internal department policies and procedures.
  5. The University Safety Director will coordinate with the Director of Purchasing to insure the following:
    1. Purchasing should not process any purchase requisition for chemicals without checking to determine if the chemical is on the most current EPA TRI List.
    2. When Purchasing receives any requests for the purchase of chemicals on the EPA TRI List, they must be approved by the Dean of the College and Safety Director.
  6. Director of Purchasing
    1. All purchase orders for substances will carry a stamped or typed imprint which states: "Under the following two laws the OSHA Hazard Communication Standard and MIOSHA Employee Right To Know, you are requested to furnish to the University Material Safety Data Sheets (MSDS) on the items requested on this Purchase Order. The MSDS should be sent to: Northern Michigan University, Public Safety Department, ATTN: Safety Director, Marquette MI 49855."
      1. Copies of all purchase orders for substances will be sent to the Safety Director and will be held on file pending receipt of the requested MSDS.
      2. Purchasing and Central Receiving will send all MSDS received by their offices to the Safety Director.
      3. The Safety Director will inspect all MSDS for purchased substances to assure that they are dated, complete, "not obviously unacceptable", and contain the information specified in Section 1910.1200(g) of the Hazardous Communication Standard. The Safety Department will send a copy of the MSDS to the individual initiating the order. The University will rely "in good faith" on the hazard determination performed by the manufacturer when the MSDS is received. Should the MSDS prove to be deficient, the University shall inform the manufacturer of the deficiency and attempt to secure an updated MSDS which meets the requirements of the Hazardous Communication Standard. In the interim, the University will rely on the information as provided by the manufacturer for substances already in stock.
      4. Should a manufacturer prove unable or unwilling to provide the University with an adequate MSDS, the University will cease using the substance as supplied by the manufacturer and dispose of existing inventories in accordance with local, state, and federal regulations.

Central Receiving And Warehousing Of Hazardous Material

  1. Receiving inspections
    1. It is the responsibility of Central Receiving to perform the following when a shipment is received and is possibly damaged:
      1. Check the packing slip for MSDS before opening package.
      2. Follow safety procedures listed on the MSDS for personal protection before opening package.
      3. If the material is damaged, a joint inspection or examination of the contents by the Carriers' representative and a Central Receiving representative should be arranged as soon as possible.  Public Safety should be notified of the damaged shipment.
    2. It is the responsibility of the department receiving packages to perform the following when a shipment is received with potential concealed damage:
      1. Check the invoice for a MSDS before opening package.
      2. Packages will be opened as soon as possible and inspected for concealed damage of materials.
      3. If damage is discovered, procedures for personal safety will be followed as listed on the MSDS.
      4. Arrangements must be made with Public Safety to have the product stored in an appropriate containment area.
      5. Public Safety and Central Receiving must be notified immediately.
      6. As proof of receipt of goods, all packaging material and cartons in which the goods were received must be retained, unless immediate disposal is necessary to avoid a threat to health and safety.
    3. Central Receiving forwards to the Purchasing Department all related documents to be assembled and transmitted with the claim to the Vendor or the Carrier responsible for the loss incurred from the damage. Interstate Commerce Regulations require that any damage of this nature must be reported to the Carrier within 15 days after delivery of the goods.
  2. Long term storage of chemicals
    1. The facility must be secured to prevent incidental exposures.
    2. The facility must meet safety standards with regard to construction, emergency systems, ventilation, and equipment.
      1. Employees must be trained in what actions should be taken in the event of a hazardous material accident.
      2. Employees must be trained in order to prevent placement together of reactive chemicals.
    3. Labeling for hazardous substances
      1. Delivery will be refused for all unlabeled containers, containers bearing illegible labels, and inadequately labeled containers.
      2. All portable containers used on the University, as defined by the Hazardous Communication Standard, will be labeled with the contents' identity and appropriate hazard warnings.
      3. All stationary tanks will be labeled with the identity of the contents and appropriate hazard warnings.

On-campus Transportation or Delivery of Hazardous Materials

  1. Warehouse personnel will deliver hazardous material to user locations.
    1. Prior to delivery, the MSDS will be reviewed and appropriate safety equipment utilized.
    2. No damaged hazardous waste containers will be moved on campus.
  2. Any on-route damage should be reported immediately to the Safety Director and the vehicle evacuated and secured.
  3. If damage occurs outdoors or in a building, the Safety Director should be notified immediately.

Health Assessment And Medical Information

  1. Personnel who are working with designated hazardous materials will comply with appropriate MIOSHA standards and receive any required specialized training.
    1. Pre-assignment physical exams. Notification of the health examiner as to the nature of the possible exposure. The employee and the supervisor will consult with a health advisor to set-up pre-established schedules for exams.
    2. Periodic physical exams or monitoring. Notification of the health examiner as to the nature of the possible exposure. The employee and the supervisor will consult with a health advisor to set-up pre-established schedules for exams.
    3. Special physical exams for accidental exposure. Notification of the health examiner as to the nature of the possible exposure. The employee and the supervisor will consult with a health advisor to pre-establish an examination schedule.
  2. Use of personal safety monitoring and protective equipment for students, guests and visitors required by MSDS, MIOSHA regulations and individual department policy.
  3. Special personnel considerations
    1. Pregnancy exclusions
    2. Individual requested medical exclusions, i.e. pacemakers, allergies, physical limitations

Safety And Training

  1. Development of Safety Rules.
    1. The person at the time of ordering any hazardous materials and prior to their receipt should develop safety rules regarding the material.
    2. These rules should be reviewed and approved by the immediate supervisor with a copy forwarded to the Safety Director.
  2. Initial employee training required by the Hazard Communication Law will be arranged by the Safety Director.
    1. All employees will be trained on the potential hazards of the substances used at their respective work stations.
      1. The training format will be a combination of written, lecture and audio-visual materials.
      2. All employees will be given the opportunity to ask questions and receive answers. \
      3. Written reference handouts will be distributed to employees. \
      4. An outline of each training session will be kept on file by the Safety Director.
    2. Initial training will include:
      1. An overview of the requirements contained in the federal Hazard Communication Standard and Michigan's Right to Know Law.
      2. Location and availability of the University's list of substances, copies of the MSDSs, and our Written Hazard Substances Communication Plan.
      3. Physical and health effects of the hazardous substances.
      4. Methods and observation techniques that can be used to determine the presence or the release of hazardous substances in the work place.
      5. How to reduce or prevent exposure to these hazardous substances through use of equipment, work practices, and the use of personal protective equipment.
      6. Steps the University has taken to lessen or prevent exposure to these hazardous substances.
      7. Emergency procedures to follow in the event of an exposure to these hazardous substances.
      8. How to read labels and MSDS to obtain appropriate hazard information.
      9. A question and answer session.
      10. Distribution of any appropriate handouts.
      11. Information concerning employee responsibilities as they relate to hazardous substances.
    3. A short quiz will be given at the end of the session and will be kept on file with the "Employee Training Record." Employees who do not satisfactorily master the material will be scheduled for another training session.
    4. Each Employee will sign a copy of an "Employee Training Record" to verify that he/she attended the training and received written handout materials, including the University Policy on Hazard Communication.
  3. Training up-date or continuous training, additional training.
    1. In addition, all employees will receive additional information from their supervisors regarding the identities and locations of hazardous substances used in their specific work areas. Supervisors will also inform employees of the potential hazards of substances in pipes and/or ventilation systems in their work areas and explain the pipe identification system used by Northern Michigan University.
    2. Prior to a new substance or physical hazard being introduced into any work area at Northern Michigan University, all employees in the affected work area will be trained on the new hazard as outlined above. A written training record will be signed by the employee.
    3. In the event that a physical hazard is discovered for a substance currently being used, employees in the affected work area will be notified. If the substance or physical hazard is totally new, all employees will be informed and trained as specified above.
  4. New Employee Training
    1. New employees of Northern Michigan University will receive a health and safety orientation and will receive information and training on the above mentioned items. This new employee training will be conducted or arranged by the Safety Director. At the end of the session, new employees will have an opportunity to have any questions answered by the presenter.
    2. Each new employee will sign a training record to verify that he/she attended the training and received written handout materials including the University policy on the Hazard Communication and Michigan's Right to Know La
    3. New employees will receive additional information from their supervisors regarding the identities and locations of hazardous substances used in their specific work area. Supervisors will also inform new employees of the potential hazards of substances in pipes and/or ventilation systems in their work areas and explain the pipe identification system.
  5. All employee training records will be maintained in the Safety Department.
  6. Safety equipment to be used will be governed by the most current MIOSHA, Northern Michigan University policy, and other state standards.
    1. It is the role of the Safety Department to promote the use of safety principles, provide technical services to assist supervisors in their application, and insure compliance with the requirements of the University Safety Program.
    2. Individual responsibilities of
      1. Supervisors/academicians. It is the policy of Northern Michigan University to promote safe living and working through an effective safety program in all phases of our operation: education, research, student service, public service, and employee and community relations. All supervisors are responsible for applying sound safety practices and safety education principles to students and employees within their jurisdiction.
      2. Employees/students. It is their responsibility to cooperate with the University Safety Program by observing all safe practices, policies, and standards, and by observing all safety laws and regulations.
      3. Guests, visitors or vendors. It is their responsibility to cooperate with the University Safety Program by observing all safe practices, policies, and standards, and by observing all safety laws and regulations.
  7. At use locations
    1. Specific safety procedures. Safety equipment to be used will be governed by the most current MIOSHA, MSDS recommendations, departmental or university policy.
    2. Storage and dispensing. Safety equipment to be used will be governed by the most current MIOSHA, MSDS recommendation, departmental or university policy.
    3. Emergency procedures will comply with Northern Michigan University's Emergency Management Plan.

Disposal Of Hazardous Waste

  1. University employees who work with hazardous materials shall reduce present and future risks of hazardous materials to the environment and the health of employees, staff, visitors, and the community. Employees shall comply with federal, state, local and University laws or regulations pertaining to hazardous materials.
  2. Users of hazardous materials must coordinate with their department heads for appropriate disposal.
    1. The Department heads will coordinate with the Safety Director for annual disposal of hazardous materials.
    2. The department heads will be required to submit an inventory of all hazardous materials to be disposed of when notified by Public Safety of a disposal date