Hazard Communication Program

HAZARD COMMUNICATION PROGRAM Manual

Rev. August 2009

1. UCSB'S POLICY ON HAZARD COMMUNICATION PROGRAM (P-5430)
2. HAZARDOUS MATERIALS AND HAZARD REDUCTION
3. INTRODUCTION
4. ADMINISTRATION
5. DETERMINING HAZARD POTENTIAL
6. HAZARDOUS MATERIALS IN THE WORKPLACE
7. MATERIAL SAFETY DATA SHEETS
8. LABELING
9. EMPLOYEE AWARENESS AND TRAINING
10. RECORDKEEPING AND DOCUMENTATION
11. NON-ROUTINE TASKS
12. PIPING/CONTRACTORS/HAZARDOUS WASTE
APPENDICES

2. HAZARDOUS MATERIALS AND HAZARD REDUCTION

Purchase, Use, Storage and Disposal of Hazardous Materials

The use of hazardous materials in today's regulatory environment has enormous implications. There are extensive, costly and far-reaching requirements for seemingly even the simplest use and application of a hazardous material.

The Hazard Communication Program is but one of the many requirements related to hazardous materials use. Additionally, there may be requirements for storage (Business Plans, Fire Code, Risk Management and Prevention Plans, Superfund Amendments and Reauthorization Act, etc.), hazardous waste management (Resource Conservation and Recovery Act, Hazardous Waste Control Law), emissions and effluent controls (Air Pollution Control District, Sanitary Districts), and others too numerous and complex to describe here. This myriad of regulation reflects the high level of concern the general public has for the environment.

The regulatory message being delivered by the new laws and regulations is:

If you can avoid (or minimize) using a hazardous material, do so: It has become incumbent upon all managers and supervisors to not only use, store, handle, and dispose of all hazardous materials appropriately, but to first assess whether a less hazardous or even non-hazardous substitute exists. For instance, some industries have eliminated their use of organic solvents and returned to using soap and water for some processes.
Clearly, each instance must be evaluated individually to determine whether it is appropriate to substitute products. Just as clearly, however, it has become time to perform this evaluation.
It is, therefore, a goal of this Program to assure that all personnel responsible for selecting material for purchase have fully evaluated the relative hazards of and the necessity for using that specific material. Part of the intent of the Hazard Communication program is to train supervisors and employees in performing such an evaluation. This Program requires that this evaluation be routinely made as new information and products become available.
Reduce risk by reducing inventory: The basic concept underlying hazardous materials legislation and regulation is to reduce risk by minimizing inventory on hand. The elimination of hazardous materials involves not only substituting less hazardous products for more hazardous ones, but to also reduce stock. Cost savings achieved by bulk purchasing practices are more than lost by the costs associated with storing hazardous materials properly, or providing for their disposal due to outdated products.

3A. Program Description

UCSB has developed a Hazard Communication Program to help ensure the health and safety of all University employees working with or around chemical substances.

The Hazard Communication regulation, California Code of Regulations, Title 8, General Industry Safety Order 5194, requires all employers in California using hazardous materials to establish, implement and maintain a Hazard Communication Program. The Hazard Communication Program is intended to:

identify all hazardous materials used in a workplace;
determine those employees using or exposed to these materials; and
train these employees in the hazards of the materials and provide access to hazard summary sheets for each material (Material Safety Data Sheets).

Additionally,

all hazardous materials must be properly labeled; and
a written Hazard Communication Program must be maintained by each department and reviewed by all employees

3B. Approach

Health and safety goals are achieved by committed and comprehensive efforts that cut across the full range of employer and employee job duties. Everyone must participate in achieving these goals. Safety is not something that is done for the individual, but is rather done with and by everyone.

This well-established basis for successful health and safety units is the way the UCSB Hazard Communication Program and the Environmental Health and Safety Policy are designed. It clearly delineates the responsibility of personnel at all levels for this program as well as all health, safety and environmental units and issues. The intention of the Hazard Communication Program is to transfer knowledge and capabilities into each department-- where it must be in order to be effective.

UCSB has adopted an approach to implementing and maintaining the Hazard Communication Program by having each department head designate and support one individual in his/her department as the Department Safety Representative (DSR).

The Coordinator will be trained by EH&S to a degree that will enable them to conduct their responsibilities. The Coordinators are then responsible for developing the program within their departments under the direction of their department heads. Each Coordinator will design and implement the program based on the specific needs of the department. These needs will vary according to hazardous materials used, number of employees, resources, and other variables. Coordinators will also serve as key health and safety in their departments in their departments for other units and issues.

Each supervisor will bear the direct responsibility for compliance with the program requirements. Specific responsibilities are described in the next section of this document.

Environmental Health & Safety has oversight responsibility for the Program. In this role Environmental Health & Safety functions as a technical resource to the departments. They will advise the Coordinators, department heads and managers as to the requirements of the Hazard Communication Program and other health and safety units, interpret specific situations and problems, provide updates on information and legislation, and serve an oversight role in regards to general compliance issues. Departments requiring technical evaluations shall direct requests to Environmental Health & Safety by calling extension x3194.

4. ADMINISTRATION

A. Scope
B. Written Hazard Communication Program
C. Roles:
Department Heads
Managers
Supervisors
Coordinators
Employees
Environmental Health & Safety

4A. Scope

The Hazard Communication regulation (California Code of Regulations, Title 8, General Industry Safety Order 5194) applies to all California employers whose employees may be exposed to hazardous substances. Hazardous substances are defined by the regulation, and are detailed on page 14 of this program. All hazardous substances found in the workplace under normal or reasonably foreseeable emergency conditions (i.e., spill or release of a chemical) are included, with the following exceptions:

a. Hazardous waste;
b. Tobacco products;
c. wood products or wood dust);
d. Articles (manufactured items; not excluded are hazardous substances used in the articles);
e. Food, drugs and cosmetics used by employees;
f. Retail trade establishments (except for processing and repair work areas);
g. Pesticide use regulated by the California Department of Food and Agriculture (although similar requirements exist under the jurisdiction of the Agricultural Commissioner's Office);
h. Consumer products sold at retail, unless employee exposure is greater than exposure to the ordinary consumer (e.g., cleaning products in the workplace are regulated by Hazard Communication).

Also, additional labeling is not required on hazardous materials for:

a. Pesticides;
b. Food, drug and additive products;
c. Alcoholic beverages;
d. Consumer products.

Laboratories have a somewhat different responsibility under the law. The Hazard Communication Program regulation has been superseded by the Cal-OSHA regulation on Laboratory Safety. The basis of the program for laboratories will be the creation of a Chemical Hygiene Plan. This will allow for a somewhat different approach to chemical safety and employee training due to the uniqueness of the laboratory environment.

Those departments which maintain laboratories within their operations should contact Environmental Health & Safety at x4899 for direction.

4B. Written Hazard Communication Program

This document, the UCSB Hazard Communication Program, fulfills the requirement of the regulation for a written program, as well as serving as the overall program and policy document for the University.

It is the intent of this plan to assist and guide the DSR in their efforts to implement the program within their department, as well as to establish a consistent approach for all University departments in addressing this program.

Appendix A to this plan is a Model Departmental Hazard Communication Program, where specific detail relevant to each department can be inserted. The individual units are to be created, used and posted at each worksite.

The written program, both campus-wide and departmental "model" units, must include the following information:

An explanation of how the University will meet labeling, training, MSDS and documentation requirements.
A complete inventory of hazardous substances in the workplace.
A plan for training employees on potential hazards involved in non-routine tasks.
A plan for labeling unmarked pipes containing chemicals.
The method for making outside contractors aware of hazards posed in the areas in which they work.

It is the responsibility of the DSR to complete the written program, and to obtain all necessary departmental review and approval. Upon approval, the departmental program is to be posted at all Safety Corners within the department.

4C. Roles

The following chart ("Program Responsibility Flow Chart") graphically represents the responsibilities and relationships that have existed and been refined for the purposes of implementing this program.

DEPARTMENT HEADS:

Department heads are responsible and liable by law and by University policy for all health, safety and environmental management within their departments. This includes implementing the Injury and Illness Prevention Program (IIPP), the Hazard Communication Program and other relevant units throughout their entire department.

The specific means by which this implementation may be accomplished is dependent upon the scope of each department's specific operations. It is each department head's responsibility to clearly authorize and delegate program implementation to a department Coordinator; to allow the Coordinator and affected staff the time and resources to carry out the program; and to assure that all departmental supervisors recognize their mandate in carrying out this program.

The selection and support of an individual to serve as Coordinator are critical. The position carries substantial responsibility in regards to employee health and safety as well as to departmental and managerial liability. The qualifications for the Coordinator are as follows:

full-time career employee
concern for well-being of co-workers
experience and knowledge of the department
ability to research answers to questions and issues
communication skills
safety orientation
leadership abilities

Health and safety units require a strong management commitment to be successful. It is UCSB policy that all department heads will provide a high level of support and attention to employee health and safety units.

MANAGERS:

Managers have a dual role in the Hazard Communication Program. First, as a supervisor they must carry out all the responsibilities incumbent upon supervisors, as described below. Second, they are responsible to assure that all supervisors reporting to them are carrying out all of their responsibilities under the program.

SUPERVISORS:

Supervisors at all levels carry the primary responsibility for assuring that the Hazard Communication Program is implemented properly within the department. The program is for the benefit of the worker who has hands-on contact with or works near hazardous materials. Health and safety units must be conducted, however, by the front-line supervisor who has the most familiarity with operational and field procedures that require the use of hazardous materials. The support of the front-line supervisor by all higher level supervisors and managers is necessary and expected, and is University policy.

It is the responsibility of supervisors to assure completion of the following:

a.) Conducting an inventory of all products containing hazardous substances used within work areas for which they have responsibility, and posting the inventory.
b.) Labeling all products (product name, appropriate hazard warnings, and name and address of manufacturer). Use of all products containing hazardous materials is to be restricted by the supervisor until they are correctly labeled.
c.) Compiling Material Safety Data Sheets (MSDSs) for all products used within areas under their supervision, and making the MSDSs available to all workers in these areas during their work shift.
d.) Training all employees about specific hazards of all chemical products encountered in their workplace. Employee's performance should also be evaluated based on adherence to safe practices.
e.) Providing and maintaining appropriate personal protective equipment as required.
f.) Ensuring the proper usage of personal protective equipment by employees.
g.) Establishing Safety Corners in the primary worksite for every employee and providing a list of such safety corners to the Coordinator. The primary worksite is a location with the individual employee has cause to go to every day (e.g., timeclock, breakroom, etc.). See page 17 for details.

COORDINATORS:

Each department has a designated Hazard Communication Program Coordinator. The Coordinator's role in the Hazard Communication Program will vary depending on the needs of each department. However, for all departments it will be the Coordinator's responsibility to actively implement the program within the department, assess its status, delegate tasks, and advise departmental management on compliance. These Coordinator's tasks are to:

a.) Coordinate -- The Coordinator will integrate and coordinate all requirements from this program and other health, safety and environmental units throughout their department. The Coordinator will be the control point for all information flowing to or from a department. The Coordinator is responsible for obtaining information from EH&S and for providing this information to all individuals who need to know. The Coordinator will be responsible for identifying and providing this information to all individuals who need to know. A mechanism within the department for achieving this task will require development.
The Coordinators are not personally responsible for compliance, as that remains the department head's responsibility, but they are charged with making reasonable efforts to carry out the duties detailed in this program, assessing the department's compliance with program requirements and keeping the department head informed of the department's status.
b.) Implement -- The Coordinator will provide departments with ready access to a knowledgeable person regarding the program at a "local" level. This will allow for the program requirements described in this document to be integrated into departmental operations. The Coordinator will be required to have a comprehensive knowledge of program requirements, and should access EH&S staff as necessary.
c.) Delegate -- It is appropriate for the Coordinator to delegate tasks where this method is used selectively and judiciously. It does not relieve the Coordinators from their responsibility in seeing a task to completion, but does allow for assistance in completing the work.
d.) Train -- Most significantly, the Coordinator will work with departmental supervisors in identifying and addressing the training needs of all departmental employees.
The Coordinator will attend meetings regarding the Hazard Communication program or other units as necessary. They will also need to ensure that departmental meetings are held to provide training, and that program objectives within the department are promoted.
e.) Administrate -- The Coordinator will document departmental training, assist with inventories, maintain files of MSDSs, inventories, surveys, training records, fulfill requests for training and information, health & safety units and Safety Corner lists, etc.

EMPLOYEES:

It is the obligation of all employees to work according to the rules and procedures established to maintain safe conditions within their work area. This includes:

referring to the MSDS for specifics concerning the hazards associated with the chemicals used in their area;
routinely and properly utilizing all appropriate safety equipment and clothing;
actively participating in and completing all training required by the Hazard Communication Program.

ENVIRONMENTAL HEALTH & SAFETY:

Departments are encouraged to use the capabilities of Environmental Health & Safety (EH&S) to assist them in carrying out their responsibilities. Environmental Health & Safety shall provide to the departments:

program oversight;
program audits to ensure departmental compliance;
program coordination and technical guidance.

EH&S has the responsibility to assess each department's program and modify its direction as necessary.

5. DETERMINING HAZARD POTENTIAL

The Regulatory and Practical Perspective

The Hazard Communication regulation specifies certain materials as well as defines generic categories of materials which are included within the program. It is the responsibility of manufacturers and importers to assess the hazard of the products that they market, and to make this information available via the MSDS.

It then becomes the responsibility of the employer that uses the materials in the workplace to keep track of the materials (inventory), assess the potential hazard posed to their workers, and to train the workers in these hazards. The remainder of this section is devoted to describing how an employer, and specifically a department supervisor within UCSB, makes the determination of whether a product used by their employees is hazardous and requires inclusion within the program.

Hazardous substances, as defined by the regulation, include--

A. Those hazardous substances listed by:
1. The Director's List of Hazardous Substances, 8 CCR 339;
2. Toxic and Hazardous Substances List, 29 CFR 1910, Subpart Z;
3. Threshold Limit Values for Chemical Substances in the Work Environment, American Conference of Governmental Industrial Hygienists, 1996;
4. Seventh Annual Report on Carcinogens, National Toxicology Program, 1994;
5. Monographs, International Agency for Research on Cancer, Volumes 1-34.
B. Any other substances which present a personal hazard(s) as determined by scientific evidence.
The lists cited in section A are relatively static, and do not generally undergo significant or rapid change. Recognizing this, however, the regulation was written so as to incorporate advancing knowledge of what constitutes a hazardous chemical to workers, as evidenced by the generic description in section B. Given the difficulty of each supervisor individually determining the potential hazard of each chemical or product, it is clear that a simpler approach must be undertaken. In practical terms, therefore, essentially all chemicals used in the workplace must be regarded as potentially hazardous.
Considering all chemicals and products to be potentially hazardous simplifies the approach even though it may unnecessarily include a few materials which are essentially non-hazardous.

6. HAZARDOUS MATERIALS IN THE WORKPLACE

The Inventory

A. Reasons for the Inventory
B. Conducting the Annual Inventory

6A. Reasons for the Inventory

Inventory management is the cornerstone of the Hazard Communication Program because it is the basis for all training requirements. Complete, accurate and up-to-date inventories are essential to protect the worker from the hazardous properties of the chemical, as well as to protect the supervisor from potential liability by failing to warn and train the employee.

It is important to recognize that inventory management is a dynamic process. Hazardous materials inventories are necessary for many different regulatory purposes today, including the Uniform Fire Code requirements, Emergency Planning, and Hazard Communication. Therefore, the inventory form being used for this program requests information that extends beyond this specific regulation.

The basic concept of hazardous materials related legislation is to reduce risk by reducing inventory. Therefore, it should be emphasized at every opportunity by those either coordinating or conducting an inventory survey that elimination of materials from on-hand supplies is to be promoted. It is necessary to assure that any hazardous waste generated by reducing inventories is handled correctly.

6B. Conducting the Annual Inventory

The DSR is responsible for obtaining completed inventories from each work site in that department. It is the Coordinator's responsibility to assure that all sites have completed an inventory, but not necessarily for the Coordinator to have conducted the site survey himself.

The procedure to follow for completing inventories will be as follows:

Site personnel determine and segregate materials no longer needed by the department due to change in need, substitution of products, expired shelf life, etc.;
Supervisor arranges for proper hazardous waste disposal in conjunction with the Coordinator;
EH&S will conduct annual inventories, or will provide assistance and direction for a department conducting an internal inventory; (due to the dynamic process of developing inventory procedures check with EH&S for the latest requirements);
EH&S provides a computer-generated inventory for each area to the Coordinator; the Coordinator reviews list of all work sites, and disseminates copies to each area supervisor to be posted;
Supervisors (and assistants) conducts continuous updating of the inventory for each worksite, listing or deleting new or outdated materials as appropriate;
Coordinator assures that all sites are maintaining an updated inventory;
Coordinator spot checks sites for quality control purposes.

Distinction between the "annual" inventory and the "continuous" inventory:

Each department in conjunction with EH&S must perform an annual inventory of all chemical products on hand. This annual snapshot of chemicals fulfils a number of regulatory requirements. However, it does not provide for one major aspect of the Hazard Communication Program requirements.

The Hazard Communication program requires that employees must be trained in the hazards of a chemical prior to its usage. This in turns obligates the employer to be up-to-date at all times on the chemicals being utilized in the workplace, and that an MSDS be available in order to provide adequate training.

Therefore each department must have procedures in place to control the selection and purchase of materials, and the acquisition and distribution of the MSDSs PRIOR TO EMPLOYEE USAGE OF THE PRODUCT.

The flow chart on page 19 is one strategy which may be utilized to achieve this. Other options may be created by the department provided that the above-stated goal of acquisition, distribution and training prior to use is achieved.

7. MATERIAL SAFETY DATA SHEETS:

Managing the Flow of Information

A. MSDS Resources
B. MSDS Paper Flow
C. Computerized MSDS Database for Laboratories
D. Safety Corners
E. Purchasing

7B. MSDS Paper Flow

The completed inventory has two major implications:

the acquisition, dissemination, filing and accessibility of Material Safety Data Sheets, and
the training of all employees.

The handling of MSDSs can be difficult and complex depending on the number of materials used by a department and the rate of changeover from one material to another. In addition, as MSDSs are updated by the manufacturer they must be distributed in addition to the continued filing of the previously existing MSDS.

MSDSs shall be maintained in three separate types of locations:

Environmental Health & Safety has access to online MSDSs for hazardous materials;
the Coordinators shall maintain a master file of MSDSs for their department; and
each worksite supervisor shall maintain a file of MSDSs used within their area that is accessible to all employees at that worksite during their work shift.

The responsibility of the worksite supervisor requires further explanation. The law requires that an employee have access to MSDSs at their worksite during work hours. Therefore, every supervisor, in collaboration with the departmental DSR, must make a determination as to which sites will be designated so as to satisfy this requirement for all employees. Environmental Health & Safety will assist supervisors and Coordinators in this determination as requested.

7C. Computerized MSDS Database for Laboratories

MSDSs for laboratory chemicals are dealt with separately. Many laboratory reagent MSDSs (and some other products) from most of the major manufacturers are now available on-line 24 hours per day. The network may be accessed at UCSB by any computer terminal that is connected to PROFS or Bitnet (campus broadband network). Details on this evolving program will be routinely provided to all Coordinators in laboratory departments.

In the event that a lab reagent MSDS is not available through this network the user may follow the procedure described previously to acquire an MSDS.

7D. Safety Corners

A Safety Corner is to be established for each worksite by the supervisor in conjunction with the departmental Hazard Communication Program Coordinator. The purpose of Safety Corners/bulletin boards is to disseminate valuable health and safety information to department employees. Safety Corners/bulletin boards should be developed in convenient, accessible locations and, at a minimum, contain the following:

Appropriate MSDSs for work area
Listing of chemical hazards in workplace (inventory)
Emergency Notification Numbers (red/white placard)
Cal/OSHA poster "Safety and Health Protection on the Job"
Hazard Reporting forms (Appendix I of Injury and Illness Prevention Plan)
Pertinent environmental health and safety notifications, posters, information, etc.

The following material should be available to all employees in a close location:

Records of employee training and workplace inspections
Relevant environmental health and safety written units and manuals

The supervisor is responsible for maintaining a current list of all Safety Corner sites within the entire area for which they have responsibility. The sites are those which are necessary for meeting the MSDS availability requirement. This list will be provided to the department Coordinator, who shall maintain a master list.

The Hazard Communication Program Coordinator will collect annual or updated inventories as needed. As stated previously, the primary annual inventory will be conducted by EH&S. However, the responsibility for updating the inventory belongs to each supervisor, with the role of the Coordinator being to assure completion in each area.

The supervisor is responsible to assure that MSDSs are available for all products in use within their work area. For products currently in use MSDSs must be obtained immediately. For new products the MSDS must be obtained, and appropriate training provided prior to the use of the product by any employee, and it is the supervisor's responsibility to assure this.

The supervisor shall present a request for an MSDS of an existing product to the Coordinator. The Coordinator shall then be responsible for obtaining MSDSs for products presently in use for which no MSDS is on file. The Coordinator will then acquire the MSDS from Environmental Health & Safety.

THE CONTINUOUS INVENTORY -- As discussed on the previous page, it is essential that the department establish procedures for acquiring the MSDS and training the employee(s) in the hazards of a new product prior to its use. Therefore, it is the supervisors responsibility to maintain a current inventory of all products on hand or ordered, and to assure that the necessary training occurs.

7E. Purchasing

Purchasing practices and those responsible for implementing such procedures shall include requests for MSDSs for all chemical products obtained from manufacturers or distributors. No chemical products should be accepted or used until an initial MSDS has been received for the product.

8. LABELING

All hazardous materials used in the workplace must be properly labeled. Hazardous materials that are shipped in and used with their original container are generally properly labeled by the manufacturer or distributor. Some hazardous materials which are repacked by a distributor are less subject to regulatory scrutiny and therefore may not be accurate. It is advisable that the supervisor review these materials and determine if they are correctly labeled before allowing their use.

Hazardous materials which are dispensed into smaller containers than the original shipping container for distribution and use around the workplace must meet various labeling requirements. Specifically the label of all of these containers must now specify:

the material contained therein;
the correct hazard warning for the material;
the name and address of the manufacturer.

No hazardous materials shall be in use which are not labeled according to these criteria. It is the supervisor's responsibility to assure proper labeling and removal of any unlabeled materials from the work area.

Whenever available, commercially-prepared labels will be used for these secondary containers.

Environmental Health & Safety should be contacted for advice at extension 8787 on proper labeling when there is any uncertainty.

9. EMPLOYEE AWARENESS AND TRAINING

Another key component of the Hazard Communication Regulation is the training of employees. The training requirements for the Hazard Communication Program include the following:

A. When:
Information and training on a hazardous substance(s) must be provided--
1. at the time of initial assignment;
2. when a new hazardous substance is introduced into the workplace;
3. when new tasks are assigned.
B. Who:
All UCSB employees, career and general assistance, full-time and part-time, must be fully trained in all aspects of this program relative to their job assignment.
C. What:
Information and training to be provided includes:
1. Requirements imposed on the employer by the Hazard Communication regulation, including employee rights under the standard, such as the right of an employee to receive MSDSs on workplace substances, and access to medical and exposure records.
2. Identification of all departmental operations where hazardous substances are used or stored;
3. A complete explanation of the purpose and contents of Material Safety Data Sheets, including detail and guidance on interpreting the hazard information and technical terms included in the typical MSDS;
4. A description of the location and availability of the MSDS file and the departmental Hazard Communication program for each worksite (e.g., the departmental Safety Corner);
5. Methods and observations that can be used to detect the presence of hazardous materials, such as instrumentation, odor, appearance;
6. Protective measures for minimizing exposure and appropriate to the hazard, such as work practices, personal protective equipment, and emergency procedures;
7. Specific hazard information which covers the non-routine work assignments which are periodically performed by employees.
D. Effectiveness:
Under the regulation and its enforcement by Cal-OSHA, mere attendance at a training session does not meet the legal requirements. Understanding is required. In order to verify that an employee has come to understand the material, and that the training as offered is effective, a testing procedure is necessary. This procedure will be to offer a quiz following the completion of the training, which will then be scored and recorded. The test must be passed in order for the employee to work with the hazardous material. Repeat training will be offered as necessary to assist the employee in passing.
The EH&S Training Division will offer assistance in the training program. Information regarding types of available training, audiovisual materials, scheduling, etc., may be obtained by calling extension x3766.

10. RECORDKEEPING AND DOCUMENTATION

In order to document compliance with this program, all employee training, whether in a group, one-on-one, or self-instruction, shall be recorded. The following information shall be noted:

Name
Social Security Number
Place
Time
Subject
Training Method (e.g., videotapes, lecture, etc.)
Trainer
Test result (pass/no pass)

Environmental Health & Safety shall provide appropriate forms for the tracking of this and additional information. It is the responsibility of the supervisor, however, to assure that the information is recorded, that the DSR and EH&S receive a copy, and records are maintained.

See Appendices B, C, D & E of the Injury & Illness Prevention Program for training record forms.

11. NON-ROUTINE TASKS

Employees may periodically perform tasks which may potentially expose them to hazardous substances not ordinarily used in their normal work duties. Examples of non-routine tasks performed by the University may include: responding to emergency situations (e.g., repairs, spill cleanup, etc.), servicing of equipment, annual maintenance, etc. Prior to starting work on such projects, affected employees shall be given information by their supervisor about hazards to which they may be exposed during the activity.

Assessment of the workplace and work activities can be conducted with the assistance of EH&S. Contact the EH&S Hazardous Materials Division

This training must include the same level of detail and information necessary for routinely used hazardous materials. The training should, in fact, emphasize that the potential hazard of working with an unfamiliar material can be greater than with those that are handled routinely. As with all training it is necessary to document the completion and effectiveness of the training effort.

The obligation of this section of the regulation is to emphasize to the employer that frequency of assignment does not excuse or change the type, scope and detail of required training.

12. PIPING/CONTRACTORS/HAZARDOUS WASTE

A. Piping
B. Contractors
C. Hazardous Waste Management

12A. Piping

All piping used for hazardous materials shall be labeled with the same information included on any container of hazardous material (see section on labeling).

The responsibility for identifying piping containing hazardous materials rests with the supervisor. All potential work locations should be surveyed to identify piping requiring labeling.

Only authorized employees shall be allowed to work on unlabeled pipes. To ensure that these employees have been informed as to the hazardous substances contained within, the following policy has been established:

Prior to the start of work on unlabeled pipes, employees are to contact their supervisor for the following information:

the substance in the pipe;
potential hazards;
safety precautions which shall be necessary.

12B. Contractors

University responsibilities --

To ensure the safety of outside contractors working in UCSB facilities, it is the responsibility of the department head, their designee, or the contracting agent (e.g., project manager) to provide contractors with the following information before they begin work:

hazardous substances to which they may be exposed while on the job;
precautions and appropriate protective measures the workers may take to lessen the possibility of exposure.

Contractor responsibilities --

To protect University Employees from hazards posed by outside contractors' activities, each contractor must provide the project manager and/or the area supervisor with the following information:

hazardous substances which will be used on the job, to which exposure may occur;
precautions and appropriate measures employees should take to lessen the possibility of exposure.

In addition to the above noted requirements, the contractor will provide a MSDS to products used by the contractor within University facilities. These shall be presented to the University representative overseeing the project.

12C. Hazardous Waste Management

The disposal of outdated, substituted or otherwise unneeded hazardous materials potentially creates a hazardous waste. There are numerous regulations which establish complex parameters for the disposal of hazardous waste. Therefore, no employee shall dispose of a potential hazardous chemical material without verifying whether it is legally considered a hazardous waste.

It is the responsibility of each department head and all appropriate managers and supervisors to assure that legal handling, storage and disposal requirements are followed.

Material that is verified to be a hazardous waste must be disposed of properly. The requirements for safe and legal disposal change rapidly and require constant attention to detail. For guidance on the proper procedure to follow, follow Hazardous Waste Disposal Procedures or contact Environmental Health & Safety at extension x3293 or x8533, or your departmental Hazard Communication Program Coordinator.

APPENDICES

APPENDIX A. Departmental Model Program
APPENDIX B. Department Chemical Inventory
APPENDIX C. Department Coordinators Roster
APPENDIX D. MSDS (If you need assistance locating an MSDS for a product, please call x 8787 or x3743.