Hazard Communications Policy

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 https://www.nmu.edu/policedepartment/msds-binder-view
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.

(sent 9/19/2018)

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 has committed to inventorying hazardous materials on site annually as described below (see items required to be inventoried).  By providing the NMU Safety Department a chemical inventory list annually, the safety data sheets for all chemicals on campus are provided on MSDS Online.  Included below is a list of items that may be required to be inventoried as well as items not required to be inventoried.

Procedure – Report Chemical Inventory to NMU Safety Department:

To view and print the current inventory for each department, follow these instructions:

1. Go to NMU MSDS Online:
   • https://www.nmu.edu/publicsafety/msds-binder-view
   • Click on eBinder on MSDSOnline
     • Username:nmumsds
     • Password:msds
2. Edit Memory (top right)
3. Select department and room number, Save
4. Select additional list if provided
5. Print Inventory List
   • Right click on the page
   • Select Print Preview
   • Change margins  to print pertinent information
   • Click Print
6. Cross out any chemicals you no longer have on this list
7. For additional products, use the Hazardous Materials Additions and Deletions worksheet.
8. This list must be provided to the NMU Safety Department in a manner that is easy to decipher.
9. If your department has no changes to the inventory, please check the box on the bottom of the Hazardous Material Additions and Deletions form.
10. Sign the Hazardous Material Inventory Additions and Deletions Worksheet and forward it the NMU Police Department, Lori Pelkola.The inventory list printed from the eBinder must also be included with the submitted materials.
11. The information submitted by your department will be updated on the MSDS eBinder via the NMU Safety Department

Consumer products are not inventoried if used for personal use, but if purchased in bulk to be used as part of your daily job 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 used Windex daily to clean, as part of your job, this would need to be put on the inventory. 

Items Required to be Inventoried

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 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. 

Examples include:

• Abrasive Blasting Agents
• Activated Charcoal
• Alumina
• Biological Toxins - http://www.selectagents.gov/SelectAgentsandToxinsList.html
• Cements Powder Form (Establish as Static Inventory)
• Chemicals Contained in Process, Storage, and Supply Tanks (see section below)
• Chemical Kits – Can be inventoried under the kit name
• Chemicals or Toxins that are derived from plants or animals
• Commercial Cleaners, Degreasers, Lubricants as Stock (Establish as Static Inventory)
• Corrosive cleaning agents (e.g. strong base/acid solutions, RNASE away,etc.)
• DEA scheduled materials - http://www.deadiversion.usdoj.gov/schedules/index.html
• Degreasers
• Desiccants
• DHS Chemicals of Interest - https://www.dhs.gov/appendix-a-chemicals-interest-list
• Dyes and Stains
• Epoxy Resin/Hardener
• Flammable Solvents
• Gas Cylinders – Lecture cylinders, small compressed gas cylinders, small propane cyliners
• Janitorial Stock Supplies
• Laboratory Chemicals and Reagents (including Amino Acids, Sodium Chloride, Sucrose, Glycerin, Glycerol, Powdered Metals)
• Laser Dyes and Solvents
• Layout Fluids
• Lecture Bottle Compressed Gas Cylinders
• Metal Plating Solutions
• Molecular Sieves
• Oils, Lubricants and Greases including Vacuum Pump Fluid, Bleach Mineral Spirits (used for maintenance, repair or cleaning)
• Organic solvents, including liquid scintillation counting cocktail
• Paints and Lacquers
• Pesticides
• Photographic Chemicals
• Pool Chemicals
• Propane Tanks (e.g. for forklifts, BBQs, heaters, etc.)
• Research drugs and therapeutics
• Shock sensitive and potentially explosive mixtures produced by the lab must be inventoried
• Small Compressed Gas Cylinders
• Small Propane Cylinders
• Solvents
• Spray Paint and Flammable Aerosols
• Water Treatment Chemicals

Items that may be required to be inventoried – depends on quantity and usage

Chemicals that can be exempted from the NMU chemical inventory are usually found in consumer quantities and used in a consumer fashion. The list below lists items that may be exempted from the NMU inventory if the chemicals are normally available as a consumer product and are of a quantity that a consumer would use. The list below provides some examples of consumer products that can be excluded. Next to each product is a quantity that in most cases will be considered a consumer quantity.

Examples include:

• 5-Minute Epoxies, super glue and other Tube Glues (consumer quantity 1-2 per room/area)
• 5 in 1 Oil (consumer quantity 1-2 per room/area)
• PVC Pipe Primers and Cements (consumer quantity 1-2 per room/area)
• Rubber Cement (consumer quantity 1-2 per room/area)
• "ZEP"- and other cleaning type products (consumer quantity 1-2 per room/area)
• Soldering Pastes and Fluxes (consumer quantity 1-2 per room/area)
• Hand Sanitizer (consumer quantity 1-2 per room/area)
• WD-40 (consumer quantity 1-2 per room/area)

Items not required to be inventoried

These chemicals are normally available as a consumer product and are of a quantity that a consumer would use. Even though some items may not be entered into the inventory, the user is still responsible to obtain a current SDS for the product. The list below provides some examples of common materials that do not need to be inventoried.

Examples include:

• Alkali Vapor Sources (Very small quantities)
• Activated Charcoal in small pre-packaged laboratory scale cartridges
• Batteries
• Biological Material
  • Plant or animal tissue
  • Reproducing biological organisms, bacteria, viruses, fungi, or yeast
  • Enzymes, antibodies, proteins, peptides, nucleic acids o Conjugated antibodies and
• Blood or Blood Products
• Bloodborne Pathogen Kit
• Buffer Solutions for Growth Media
• Buffer Solutions for pH Probes
• Calcium Chloride Ice/Snow Melt Products Working Quantities (Storage areas require static posting)
• Cements Premixed Deliveries
• Chemical Waste
• Chemical containers with incomplete or illegible information
• Chemical Spill Kits (includes wipes for chemical cleanup)
• Consumer products when ordered/present in consumer quantities and used as appropriate
• Custom DNA Sequencing
• Dilutions
• Empty Chemical Containers
• Enzymes
• Fire Extinguishers
• First Aid Kit (may include calcium gluconate as a first aid for hydrofluoric acid burns)
• Food or Food Additives (unless it will be used for R&D or operational purposes)
• Gelatin
• Growth Media
• Hand Sanitizer
• Hormones
• Lead bricks, sheets, piping
• Lotion
• Office Supplies (appropriate quantities for office administrative purposes)
• Cooking oil
• Non-chemical diagnostic materials that contain a film on any surface (e.g. 96-well plate)
• Non-Hazardous Metals such as Foils, Bars, and Rods
• Perlite for gardening/greenhouse type work
• Personal Items for Personal Use
• Pharmaceuticals, Medication, including veterinary medicine when it is in solid, final form for direct administration to the patient
• Photographic Film
• Plasmids (when not combined with other hazardous chemicals)
• Polymer Spheres (non-hazardous/low hazard or as non-hazardous suspensions)
• Precious Metals (Platinum, silver, gold)
• Potting Soil and Mulch
• Radiological Sources, Chemicals, and Waste
• Sand/Polishing Paper, Buffing Compounds
• Secondary chemical container that is produced in the lab from a primary chemical container(s) that is already inventoried (e.g.)
  • 1N NaOH that is made from a commercially available 10N NaOH solution or solid NaOH.
  • Squirt bottles and spray bottle
  • Conical and “Falcon” tubes with chemicals or samples in them
• Solder
• Special Nuclear Materials
• Structural Material and Articles (example of Articles: beryllium tool, single crystal substrates, ammunition)
• Synthetic Thermoplastic Polymer
• Test strips (pH, Peroxide, Water Hardness, Iron, Phosphate, etc.)
• Thermal Compounds available as a consumer product (e.g. for computers, silver based)
• Tissue culture media or other growth media
• Water, Demineralized Water
• Welding Rod
• White Out
• Working Solutions

Note: Each designated person(s) will be responsible for the proper hazard determination for all mixtures that are commonly made and used in the research lab. For hazard classification guidance concerning mixtures and solutions, the Hazard Communication Standard (29 CFR 1910.1200) states that a mixture (or solution) will be considered as having the same health hazards as the components that comprise ≥1% of the mixture (≥0.1% for known carcinogens in the mixture). If the designated person(s) is not comfortable with making hazard determinations or is unsure about the hazard classification of a particular solution, they should consult with Public Safety. In order to fully comply with OSHA Hazcom, please review Labeling Chemicals or Reagents in Secondary Containers Protocol (Quick Facts Link).

Regulations:

OSHA 29 CFT 1910.1200 Guidance for Hazard Determination  

OSHA 29 CFR 1910.1200 "Hazard Communication Regulation"  

OSHA 29 CFR 1910.1450 "Occupational Exposure to Hazardous Chemicals in the Laboratory"

Michigan Facilities' Guide to SARA Title III, Emergency Planning and Release Reporting - 14th Edition - January 2016

Definitions:

Chemical - any element, chemical compound or mixture of elements and/or compounds.

Chemical name - the scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation.

Consumer Product - any consumer product or hazardous substance, as those terms are defined in the Consumer Product Safety Act (15 U.S.C. 2051 et seq.) and Federal Hazardous Substances Act (15 U.S.C. 1261 et seq.) respectively, where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended.

Consumer Quantity - a quantity typically found in the home. This is generally considered to be 1 to 2 containers, but, may be more.

Hazardous chemical - any chemical that is a physical hazard or a health hazard.

Health hazard - a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes chemicals which act on the hematopoietic system and damage the lungs, skin, eyes, or mucous membranes.

Physical hazard - a chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.

Safety data sheet (SDS) - A document that contains information on the potential hazards (health, fire, reactivity and environmental) and how to work safely with the chemical product. It also contains information on the use, storage, handling and emergency procedures all related to the hazards of the material. It is intended to tell what the hazards of the product are, how to use the product safely, what to expect if the recommendations are not followed, what to do if accidents occur, how to recognize symptoms of overexposure, and what to do if such incidents occur.

Please contact the NMU Safety Department, Occupational and Environmental Health Specialist for more information at 227-2151.