Hazard Communication Policy
Purpose:
In order to comply with the Michigan Hazard Communication Standard MIOSHA-STD-1600, 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 & visitors.
Policy:
It is the policy of Northern Michigan University to comply with the requirements of the Michigan Hazard Communication Standard and Michigan's Right To Know Law, as they pertain to; Hazardous Material Inventory, Purchasing, Labeling, Portable Containers, Waste, Safety Data Sheets, Employee Training, Firefighters Right To Know and Contractor Responsibilities.
References:
MIOSHA-STD-1600 Part 92 and Part 430
Training:
All NMU Employees are required to take Hazardous Communication: The Right to Understand. This training is available through the NMU Safety Departments Safe Colleges online training system. It can be accessed through your MyNMU or this link.
The goal of this course is to provide an understanding of hazardous chemicals and their specific dangers, as well as actions you can take to protect yourself and others.
Hazardous Materials on Campus, Procedure
Purpose:
In order to comply with regulatory requirements, including the MIOSHA General Industry Hazardous Communication Standard and MIOSHA Hazardous Work In Laboratories, an annual inventory identifying hazardous materials on campus is required. The purpose is to ensure that the hazards of chemicals on campus are evaluated, and that information concerning their hazards is available to employees, students and visitors.
Compliance:
Northern Michigan University is committed to inventorying hazardous materials on site annually. The NMU Safety Department maintains the safety data sheet repository for all chemicals on campus. These are available at Safe Colleges SDS Repository.
To access the NMU Chemical Repository go to NMU Safe Colleges SDS Repository OR Scan the QR Code located in 'Form' below. From the main page of the repository you can easily locate all campus buildings and the rooms within each building.
This QR code and web address are available on the Michigan Right to Know Law posters that are posted in all NMU Buildings.
Reporting your Chemical Inventory
Consumer products are not inventoried if used for personal use, but if purchased in bulk to be used as part of your daily job it will need to be inventoried. For example, if you use Windex once a week to clean a window in your office (or as you would at home) it does not need to be put on the inventory. But if you use Windex daily to clean, as part of your job, this would need to be put on the inventory.
Any, but not limited to, chemical containers that have a manufacture label which denote physical hazards or health hazards, or whose SDS denotes hazards, are to be included in the NMU chemical inventory. In general, laboratory chemicals and reagents are inventoried even if the hazard is considered low. If you are unsure if something should be put on the inventory, put it on the inventory.
For further guidance and examples, you can go to: Chemical Inventory Guidelines
How to find your specific building and room in the SDS Repository
There are two ways to do this.
1. Go to the NMU Safe Colleges SDS Repository find your building and room to view the inventory of that room.
OR
2. Each Department’s main office has been provided with a QR Code system that will allow you to scan the QR Code of an individual room.
3. Once you have your list you can fill out the ADDITIONS or DELETIONS form as necessary.
New Product
When you purchase a new chemical, you are required to fill out the Hazardous Materials Addition form at the time the chemical is delivered to campus. You will need to have the Safety Data Sheet from the company. This form can be accessed through this link:
If the new chemical you are purchasing is listed on the EPA Toxic Release Inventory (TRI) you must have permission to order the product. Follow the steps below:
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Provide the Safety Data Sheet (SDS) to the Safety Department, your Department Head and Dean.
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Provide the reason for the requested chemical.
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If your request is approved you must follow these next steps.
a. Notify your stockroom manager
b. Notify the NMU Purchasing Department and arrange for prompt delivery.
Annual Inventory
On an annual basis Departments are required to review and update their complete chemical inventory. If you find chemicals in your active chemical inventory that are no longer in that space they are to be archived in the repository. To have specific chemicals archived please fill out the Hazardous Chemical Deletion form found here: Inventory Deletions Sheet
Container Labeling for Hazardous Substances
All containers must have a proper label on them that is legible. Original containers shall follow the GHS from the manufacturer and must contain the following:
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Product Identifier
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Signal word
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Hazard Statement
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Pictograms
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Precautionary statement(s)
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Name, Address, & telephone number of the chemical manufacturer, importer or other responsible party.
Reference MIOSHA Hazardous Communication 1910.1200(f) Labels and other forms of warning.
Secondary Containers
Definition: A secondary container is defined as any container holding a product which is not the original container supplied by the manufacturer.
Secondary container labels are required when operations in a work-place setting includes the transferring of smaller amounts from the original container to a secondary container such as a beaker, flask, or bottle.
The secondary container label must include, at minimum, the full name of the chemical, the hazard, the date transferred and the expiration date.
Hazardous Waste
NMU disposes of hazardous waste on a scheduled basis. Some departments may have a monthly removal while others may be on a six month removal cycle. If you have hazardous waste in your area please fill out the Hazardous Waste Disposal form.
Chemistry and Biology Departments do NOT use this form. Please contact your stockroom manager.
For information regarding waste types please go to NMU Waste Disposal Guidelines
Contractor Owned Substances
All contractors who work on campus are required to comply with MIOSHA and NMU Rules and Regulations. All hazardous chemical safety data sheets are submitted to the NMU Safety Department and Facilities Department prior to work commencing.
Fire Fighters Right to Know
The Marquette City Fire Department has the QR code to the NMU Chemical Repository. In the event there is no internet available NMU Dispatch has a catalog of the repository.
For more information or clarification contact safety@nmu.edu or 906-227-2151
Date Approved: | 10-5-2005 |
Last Revision: | 7-18-2023 |
Last Reviewed: | 7-18-2023 |
Approved By: | President |
Oversight Unit: | SAFETY DEPARTMENT |
Attached form file: | Safety Data Sheet Poster QR Code for Hazard Comm.Policy.pdf |