Hazard Communications Policy

Initiated: June 18, 1986
Revised:  September 7, 2005
Approved:  October 5, 2005

Purpose

In order to comply with the Federal Hazard Communication Standard (HCS), 29 CFR 1910.1200 and Michigan's Right To Know Law, a written Hazardous Substances Communication Plan (HSCP) has been established for Northern Michigan University.

Applicability

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

Policy

It is the policy of Northern Michigan University to comply with the requirements of the Federal Hazard Communication Standard and Michigan's Right To Know Law, as they pertain to; Hazardous Material Inventory, Purchase Orders, Employee Owned Hazardous Materials, Labeling, Portable Containers, Material Safety Data Sheets, Employee Training, Firefighters Right To Know and Contractor Responsibilities.

References

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

Initiating Department/Division

Public Safety & Police Services, 227-2152

Inventory Process

Annually, the Public Safety Department will provide a copy of each department previous years inventory of hazardous materials.  Each department is responsible to reconcile the inventory against the information provided.  The new inventory must be submitted to Public Safety.

Purchase Of Hazardous Substances

Purchase of hazardous substances shall comply with the requirements of the Hazardous Material Management Policy of Northern Michigan University.

Employee Possessed Hazardous Substances

The University has adopted a strict policy covering employee possessed substances. Any employee who wishes to bring a substance covered by this act, including consumer products, into the work place must first complete a request listing the name of the substance, the manufacturer's name, the manufacturer's address, and the reason for the request.

  1. Completed request forms will be submitted to the Safety Director by the employee's supervisor. The Safety Director will attempt to secure the MSDS from the manufacturer.
  2. If it is determined that the substance the employee wishes to bring into the work place poses no risks, the employee will be allowed to bring the substance into the work place. A list of all approved employee possessed substances will be posted on the bulletin board for view and use by all employees in the affected area.
  3. These rules do not apply to the following employee possessed substances which are totally exempted from regulation under the Hazard Communication Standard:
    1. Tobacco and tobacco products.
    2. Food, prescription drugs, personal medication, and cosmetics intended for the personal consumption or use of the employee.
  4. Employees will be advised of these requirements during orientation training. Any employee found in possession of an unauthorized substance will be subject to disciplinary action.

Container Labeling For Hazardous Substances

All containers used for hazardous materials shall be labeled in accordance with the Hazardous Material Management Policy of Northern Michigan University.

Material Safety Data Sheets (MSDS)

  1. The Safety Director will obtain MSDS for substances purchased by the University and employee possessed substances located on campus. To assure the integrity of the University MSDS system, all purchases should be routed through the Purchasing Department. For any purchase made by a department that does not go through Purchasing, such as those made with petty cash or NMU Purchasing Card, it will be the responsibility of the department head to ensure that an appropriate MSDS is submitted to the Safety Director, prior to purchase.
  2. No substance shall be purchased or otherwise brought onto University property, unless a MSDS has been received, reviewed and approved for the product. The Safety Director will review incoming MSDS to ensure that they contain the information specified in the Hazard Communication Standard. A MSDS Evaluation Form will be used for this purpose.
  3. A master set of manufacturer MSDS and the MSDS evaluation form will be maintained by the Safety Director at the Department of Public Safety and Police Services, 102 Services Building, Northern Michigan University.
  4. Should a MSDS be found to be deficient during the evaluation process, a copy will be returned to the manufacturer with a letter of explanation.
  5. If the warehouse attendant or requesting department receives a shipment of a substance for which there is no approved MSDS in the data base, it will be assumed that no MSDS has been received and delivery of the shipment to the requesting department will be delayed until an approved MSDS is received.
  6. As updated Material Safety Data Sheets are received, they will be evaluated as outlined above by the Safety Director. Copies of the updated MSDS forms will be distributed to all individuals having a set of MSDS forms. Those individuals will be responsible for removing any outdated MSDS and replacing it with the new MSDS. The MSDS files will be periodically checked for accuracy and completeness by the Safety Director.

Employee Access To Material Safety Data Sheets

  1. A master set of Material Safety Data Sheets shall be maintained by the Safety Director at the Department of Public Safety and Police Services, 102 Services Building. A partial selection of MSDS may be maintained at selected work areas of the University as determined by the Safety Director.
  2. Material Safety Data Sheets will be available at all times to any employee who wishes to review the MSDS for a particular substance.  MSDS information may be viewed on line by any employee at http://aditweb.nmu.edu/public_safety/msds-db/index.php.
  3. Employees will be made aware of the location of MSDS forms by the posting of a MIOSHA "Right To Know Information" poster throughout the University.
  4. The Safety Director will be immediately contacted if an MSDS is not available for a substance an employee may have to use. An employee will not be required to work with any hazardous substance for which an MSDS is not available.
  5. Any employee can request a copy of the manufacturer's original MSDS by submitting a written request to the Safety Director on an approved form. A photocopy of the MSDS forms will be supplied to the requesting employee within 15 days of receipt of the request as specified by 29 CFR 1910.20(e).
  6. Within five working days of the receipt of a new or revised MSDS for a substance, the Safety Director shall post a notice of the existence of, and location of, new or revised MSDS forms. This notice shall be posted next to the MIOSHA "Right To Know Information Poster." These notices shall be posted for a minimum of ten working days. The notice shall be posted on the MIOSHA "New or Revised MSDS" form.

Employee Training And Information

  1. All initial employees training required by the Hazard Communication Law will be conducted or arranged by the Safety Director. The format will be a combination of written, lecture and audiovisual materials. All employees will be given the opportunity to ask questions and receive answers. Written reference handouts will be distributed to employees. All employees will be trained on all of the potential hazards of the substances used at their respective work stations. An outline of each training session will be kept on file by the Safety Director. 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 MSDS forms, and its written Hazard Communication Plan.
    3. Hysical 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 forms 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.
    12. 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 an additional training session.
  2. Each employee will sign a copy of an "Employee Training Record" to verify that he attended the program, understood the training, received written handout materials, and understood the University policy on Hazard Communication.
  3. 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 located in their work areas and explain the pipe identification system used by Northern Michigan University.
  4. 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.
  5. Each new employee will sign a training record to verify that he attended the training, received written handout materials, and understood the University policy on the Hazard Communication and Michigan's Right To Know Law.
  6. 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 in their work areas and explain the pipe identification system.
  7. 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.
  8. In the event that a new substance or 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.
  9. All employee training records will be maintained in the Safety Department.

List Of Hazardous Substances

A list of all hazardous substances known to be present at Northern Michigan University will be maintained by the Safety Director. Information on each listed substance can be obtained by reviewing the MSDS forms available at the Department of Public Safety and Police Services.

Hazards Of Non-routine Tasks

  1. Periodically, employees will be required to perform non-routine tasks which could result in an exposure to hazardous substances.
  2. Prior to starting work on such projects, each affected employee will be informed by his supervisor about the hazard of all known substances to which he might be exposed and protective measures he can take to minimize potential exposure. This will only include hazardous substance known to be present. This information will include:
    1. Specific substance identities.
    2. Physical and health hazards posed by these substances.
    3. Protective measures that the employee will take to minimize potential exposure, personal protective equipment, and emergency procedures.

Contractor Owned Substances

Contractors are required to comply with the provisions of the Hazardous Material Management Policy of Northern Michigan University.

Fire Fighters Right To Know

The Safety Director will be responsible for providing the Marquette Fire Chief with an inventory of all hazardous substances and copies of MSDS forms for all hazardous substances used on the campus of Northern Michigan University. This report will be updated on a regular basis.

Annual Hazard Communications Review

Annually, the Safety Director will review the entire Hazard Communication Program plan for Northern Michigan University to determine its completeness and effectiveness.

Hazard Communication Plan for Northern Michigan University Prepared May 7, 1987.
Updated 3/20/90
Updated 4/92
Updated 8/96
Updated 9/05