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Hazard Communication Program

(Approved by the President by authority of Executive Order No. 1)

The Washington Industrial Safety and Health Act (WISHA) code, WAC 296–62–054 through –05425, Hazard Communication Standard, requires chemical manufacturers or importers to assess the hazards of all chemicals they produce or import and transmit that information to affected employers and employees. The standard requires the University to provide employee information about the potential of hazardous chemical exposure under normal use conditions or in a foreseeable emergency; and the transmittal of this information by means of a comprehensive Hazard Communication Program which includes container labeling and other forms of warning, Material Safety Data Sheets, and employee training.

In order to comply with the Hazard Communication Standard, this Hazard Communication Program has been established for the University of Washington. All schools, colleges, and administrative offices including University of Washington and Harborview Medical Centers are incorporated within this program.

Primary responsibility for compliance with the Hazard Communication Program lies with the department or organizational unit. Each dean, director, chair, and supervisor is responsible for safety performance and hazard communication within their respective units. With the advice of the chemical Hazards Advisory Committee, the Environmental Health and Safety Department (EH&S) is responsible development and coordination of University-wide policies and procedures. EH&S also provides technical assistance in establishing procedures and monitoring performance in activities involving the Hazard Communication Program.

The University of Washington is committed to creating, maintaining and promoting a safe and healthful environment for all associated individuals including students, faculty, staff employees, hospital patients, and visitors. A critical component of the University's environmental health and safety commitment is integrating information concerning chemical hazards into all academic and operational activities by means of this Hazard Communication Program.

The container labeling portion of the Hazard Communication Standard requires manufacturers, distributors and importers to label, tag or mark hazardous chemical containers with the identity of the hazardous chemicals, the appropriate hazard warnings, and the name and address of the manufacturer, importer or other responsible party. The purpose of the labeling requirements is to provide employees with an immediate warning of hazard in the workplace and to direct the handler of the chemical to the appropriate Material Safety Data Sheet (MSDS). Labels should act as visual reminders of information presented during training and of information found in more detailed form on the MSDS.

Some exemptions from the labeling portion of this standard by the chemical manufacturers exist in the following situations:

Supervisors in each University department or organizational unit, including laboratories, shall verify that all hazardous material containers received for use:

Note:  It is University policy that no container will be accepted for use until the above data is verified.

Manufacturers, distributors, and importers are required to provide this information on their container labels. For containers not properly labeled, containers with obscure/defaced labels, or unlabeled secondary containers where a chemical is transferred for storage, the supervisor shall ensure that an extra copy of the original manufacturer's label or a generic self-adhesive label (available from University Stores) is filled out with the appropriate information and affixed to the container immediately. The information for completing the generic label may be obtained from a copy of the original label, the MSDS, or by calling EH&S, 206–543–7262.

The University Chemical Hazards Advisory Committee will review the labeling system annually and update as required.

The Material Safety Data Sheet (MSDS), or equivalent, is the primary written means to convey information concerning the hazards of chemicals to employers and employees. In most cases the manufacturer, importer or formulator who introduces the product into commerce or the workplace will prepare and send the MSDS or equivalent. The contents of the MSDS will be based upon a chemical hazard determination made by them.

The EH&S Occupational Health and Safety Office is responsible for obtaining and maintaining a comprehensive MSDS collection for the University. Incoming MSDS will be reviewed for new and significant health/safety information to be passed on to affected employee work areas. A MSDS central repository will be located in EH&S, located in Hall Health Center, for review by any interested employee. Copies of specific MSDS may be obtained by calling EH&S, 206–543–7262.

Since MSDS must be readily accessible to employees in their work areas on all shifts, individual departments or operational units may also be required to have a collection of MSDS for those hazardous chemicals used in their work areas. EH&S will assist in compiling these individual MSDS collections and will request a MSDS from the manufacturer for those chemicals with no MSDS on file in the central repository. The Hazard Communication Standard [WAC 296–62–05403(3)(b)] states that laboratory units must maintain any MSDS received with incoming shipments of hazardous chemicals.

Supervisors in each University department or operational unit, including laboratories, will be required to send copies of initial MSDS received from manufacturer to the EH&S central repository for MSDS.

The Chemical Hazards Advisory Committee will review the MSDS system annually and update as required.

University of Washington employees must be made aware of the hazardous chemicals that are used in their work areas and the requirements of the Hazard Communication Standard. Employees must also be informed of the availability and location of the written program, the MSDS, and the List of Hazardous Substances.

The Standard requires the University to train employees in the methods and observations for detecting the presence or release of hazardous chemicals, the physical and health hazards of these chemicals, the measures for protection from these hazards, and the specific details of the Hazard Communication Program which includes the labeling and MSDS information systems.

During the University process of new employee orientation, the various personnel services will:  be responsible for presenting a health/safety orientation pamphlet to acquaint new employees with the Hazard Communication requirements, and inform them of the availability and location of the written program, the MSDS, and the List of Hazardous Substances. This material will also be used to inform current employees.

The EH&S Training and Occupational Health and Safety Offices will assist with the provision of adequate programs for more detailed training and information in the Hazard Communication Standard (WAC 296–62–054 through –05425). EH&S will aid in providing and making available multimedia training materials, speakers and technical support for individual department or organizational unit supervisors.

With the cooperation of EH&S, the supervisors in each University department or organizational unit will be responsible for their employees receiving training and information which includes the following content:

After completing the training and information session, the supervisors will be responsible for verifying that Hazard Communication Training was conducted for each employee.

Before a new hazardous chemical is introduced into any individual department or organizational unit, each employee in the affected work area will be given information as outlined above.

The Chemical Hazards Advisory Committee will review the employee training and information systems annually and update as required.

A list of all know hazardous chemicals which may be used by University of Washington employees is available from EH&S. This List of Hazardous Substances has been compiled using the best available information from industrial experience and from both human and animal research studies. Some listed substances are included that may be hazardous only under specialized situations (e.g., aspirin, ethanol, starch). The EH&S Occupational Health and Safety Office is responsible for maintaining the List of Hazardous Substances. Further information on the listed chemicals may be obtained by reviewing the MSDS available at EH&S, located at the Hall Health Center, 206–543–7262, or within individual department collections.

The Chemical Hazards Advisory Committee will review the List of Hazardous Substances annually and update as required.

Periodically, University employees may be required to perform hazardous nonroutine tasks such as confined space entry or repair/maintenance operations. Prior to starting work on such projects, individual departments or organizational units must consult with EH&S, review documented procedures, and provide information for involved employees. Information will cover specific chemical hazards, protective/safety measures to be taken by employees, and the steps which have been taken to lessen the hazard potential of the operation.

7.   Informing Contractors

Contractor employees must be informed of the hazardous chemicals which may result in exposures while on a University job site and the appropriate protective measures to be taken to lessen these possible exposures. The University is responsible for those hazardous chemicals existing at the job site, but not those brought to the job by the contractor.

With the assistance of EH&S, the Facilities Management Office will provide the necessary hazard communication information to the contractor through contract and purchase specifications. The affected department or organizational unit will provide more specific hazard communication information as it relates to on-site activities.

For service contracts where vendor personnel are required to work in areas with possible hazardous chemical exposures, the requesting University department or organizational unit must indicate on the Purchase Requisition form that these potential exposures exist, and must provide the name of a contact person for further information. The University Purchasing Department will notify the vendor that hazard communication information is available when placing service contracts.

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