OHS#12-221
HAZARD COMMUNICATION PROGRAM
1.0
INTRODUCTION
2.0
APPLICATION OF THIS PROGRAM
3.0
RESPONSIBILITIES
3.1
3.2
3.3
4.0
LABELING
4.1
4.2
4.3
4.4
5.0
General Requirements
Life Safety Boxes (LSBs)
HAZARD COMMUNICATION INFORMATION AND TRAINING
7.1
7.2
8.0
General Requirements
Obtaining SDSs
Stanford University-Produced Hazardous Substances
Trade Secrets
HAZARDOUS CHEMICAL INVENTORY
6.1
6.2
7.0
General Requirements
Labeling Containers Leaving Campus
Proposition 65 Warning Labels
Unlabeled Pipes
SAFETY DATA SHEETS
5.1
5.2
5.3
5.4
6.0
Supervisors, Laboratory Directors and Principal Investigators
Employees
Department of Environmental Health and Safety (EH&S)
Hazard Communication Training
Other Required Hazard Communication Training
INFORMING CONTRACTORS AND CONTRACT WORKERS
APPENDIX A: DEFINITIONS
APPENDIX B: GLOBALLY HARMONIZED SYSTEM (GHS) PICTOGRAMS GUIDE
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1.0
INTRODUCTION
“Stanford University makes all reasonable efforts to:
1. Protect the health and safety of Stanford University faculty, staff, and students.
2. Provide safe work practices - academic, research, and administrative - for faculty,
staff and students.
3. Provide information to faculty, staff, and students about health and safety hazards.
4. Identify and correct health and safety hazards and encourage faculty, staff, and
students to report hazards.
5. Provide information and safeguards for those on campus and in the surrounding
community regarding environmental hazards arising from operations at Stanford
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University.”
To fulfill this University policy and to comply with the Cal/OSHA Hazard Communication
Standard (California Code of Regulations, Title 8, Section 5194), this Hazard
Communication Program has been developed. Components of the program include
adequate labeling of hazardous substances in the workplace, providing information
such as Safety Data Sheets (SDSs) for hazardous substances, and training employees on
chemical hazards in the workplace.
Requirements outlined in this manual are mandatory by the Cal-OSHA regulation where
the word “shall” is used, and are advisory in nature where the word “should” is used.
2.0
APPLICATION OF THIS PROGRAM
The purpose of the Hazard Communication Program is to establish a written program
that provides for and supports the methods to inform employees about hazardous
substances they may be exposed to in the workplace, potential harmful effects of these
substances and appropriate control measures.
2.1
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Covered Employees, Operations, and Substances
This Hazard Communication Program applies to:
a. All non-research University employees;
b. Laboratories that primarily provide quality control analyses for manufacturing
processes or that produce hazardous substances for commercial purposes; and
c. Hazardous substances purchased and used by Stanford employees for non-research
uses.
Health and Safety at Stanford University - Principles, Responsibilities, and Practices.
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2.2
Exempted or Partially Exempted Operations and Substances
The following operations are exempted or partially exempted from the Hazard
Communication Program:
2.2.1 Research Laboratory Operations
a. Research Laboratory operations are exempted from the provisions of the Hazard
Communication Program and are addressed under the Stanford University Chemical
Hygiene Plan (CHP). Such research laboratory operations shall;
i. Ensure that labels are not removed or defaced (see Section 5.0), and
ii. Maintain SDSs and ensure SDSs are available to employees (see Section 6.0).
b. Refer to the Stanford University Chemical Hygiene Plan for specific requirements
affecting laboratory employees. This plan is available at:
chemtoolkit.stanford.edu/docs/Chemical_Hygiene_Plan.pdf.
2.2.2 Warehouse Operations
a. Warehouse operations where chemicals are only handled in sealed containers are
exempted from the provisions of the Hazard Communication Program. Such
warehouse operations shall:
i. Ensure that labels are not removed or defaced (see Section 5.0);
ii. Maintain SDSs and ensure SDSs are available to employees (see Section 6.0); and
iii. Provide Hazard Communication training (EH-4300) and job-specific Hazard
Communication training to employees.
b. Such operations include:
i. Warehouses;
ii. Stockrooms; and
iii. Shipping/receiving.
2.3
Exempted Substances
The following substances are exempt from the requirements of this program:
a. Hazardous waste;
b. Tobacco or tobacco products;
c. Wood or wood products, including lumber which will not be processed and the only
hazard they pose to employees is the potential for flammability or combustibility;
d. Articles (see definition in Appendix A);
e. Food, drugs or cosmetics intended for personal use; and
f. Consumer products used in the workplace when used as a normal consumer would
use (i.e. White-Out, spray paint used for short, one-time applications).
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3.0
RESPONSIBILITIES
3.1
Supervisors
Supervisors are responsible for implementing the Hazard Communication Program at
the local operational level and ensuring the safe use of hazardous substances for all
areas under their supervision. Responsibilities include:
a. Identifying hazardous substances present in the work area.
b. Maintaining an inventory list of hazardous substances present in the work area.
c. Ensuring hazardous substances are appropriately labeled or posted.
i. Ensuring pipes carrying hazardous substances are labeled.
d. Obtaining SDSs for hazardous substances used in the work area and ensuring SDSs
are available to employees.
e. Ensuring employees are trained on Hazard Communication (course EHS-4300) and
on physical hazards, health hazards, safe handling procedures, and emergency
procedures for hazardous substances used in the work area.
f. Ensuring that employees follow established safety procedures.
g. Adequately informing any non-University personnel sharing the same work area of
the hazardous substances to which their employees may be exposed while
performing their work.
h. Maintaining a copy of this written program available in the workplace. The program
is also available online at: www.stanford.edu/dept/EHS/prod/general/hazcom.html.
3.2
Employees
Employees are responsible for:
a. Knowing the hazards and precautionary procedures for the hazardous substances
used in their work area.
b. Completing Hazard Communication training (course EHS-4300) and job-specific
training before working with hazardous substances.
c. Planning and conducting operations in accordance with established procedures and
good safety practices.
d. Using personal protective equipment and clothing in accordance with prescribed
training.
e. Notifying the supervisor whenever work involves disturbing unlabeled pipes.
3.3
Department of Environmental Health and Safety (EH&S)
EH&S’s Occupational Health and Safety Program is responsible for providing resources
(i.e., reference materials) and technical support to ensure employees are protected
from hazardous substances. Specific responsibilities include:
a. Developing, implementing and evaluating the Hazard Communication Program.
b. Assisting supervisors in identifying hazardous substances present in the work area
and evaluating potential hazards of operations.
c. Providing Hazard Communication training (EHS-4300) to all employees covered
under the Hazard Communication Program.
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d. Assisting supervisors with job-specific employee training for all employees covered
under the Hazard Communication Program.
e. Recommending appropriate engineering controls, administrative controls and
personal protective equipment.
4.0
LABELING
4.1
General Requirements for Containers
The following requirements are for labeling hazardous substances:
a. Every container of a hazardous substance must be labeled, tagged, or marked to
identify the substance and to provide appropriate warnings.
i. Detailed information on labels and label requirements can be found online:
http://www.osha.gov/dsg/hazcom/appendix_c.pdf
b. The manufacturer’s original label shall provide:
i. Identity of the hazardous substance;
ii. Signal word;
iii. Hazard statement(s);
iv. Pictograms (see Appendix B);
v. Precautionary statement(s); and
vi. Name and address of the manufacturer, importer or responsible party.
c. Labels shall be:
i. Legible,
ii. In English,
iii. Prominently displayed on the container.
d. The original label shall not be removed or defaced unless the container is
immediately marked with the required information.
e. Synthesized substances developed at Stanford University for non-laboratory use
which do not leave the University must be labeled with their reactants and possible
products (e.g., Grignard reagent) or by a useful generic description (e.g., long-chain
ketone) and their probable hazardous properties.
f. Non-hazardous substances (e.g., distilled water) should be labeled in order to avoid
confusion.
g. Alternative methods such as signs, placards, process sheets, and operating
procedures are acceptable for individual stationary process containers, provided
that the information is conveyed to all affected persons.
h. Portable secondary containers used immediately by the person performing the
transfer do not need labels.
4.2
Labeling Containers Leaving University Facilities
Hazardous substances covered under this program (see Section 2.0) that leave
university facilities shall be labeled as described in Section 4.1 above.
a. Guidance on labeling requirements for shipping hazardous substances is provided in
the “Excepted Quantities” training (EHS-2650).
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b. More detailed explanations on hazard classification and label requirements for
shipping hazardous substances can be found online:
www.stanford.edu/dept/EHS/prod/enviro/waste/DOT_Haz_Mat_Tool_Jun_2010.html.
4.3
Proposition 65 Warning Notices
a. Required notification/notices shall be posted, as required by Proposition 65, when
employees and/or the public are exposed to substances that are listed as being
known to the State to cause cancer or reproductive toxicity.
b. At Stanford, Proposition 65 notices are posted on the cover of the Life Safety Boxes
wherever Proposition 65 substances are present (see Section 6.2).
c. Most current list of Prop 65 chemicals can be found online:
oehha.ca.gov/prop65/prop65_list/newlist.html
4.4
Unlabeled Pipes
a. Aboveground pipes transporting hazardous substances (gases, vapors, liquids, semiliquids, or plastics) shall be labeled in accordance to 8 CCR Section 3321,
“Identification of Piping.”
b. Employees shall not work on any unlabeled pipes until:
i. The contents of the pipe are determined; and
ii. Appropriate safety precautions have been determined for the work.
5.0
SAFETY DATA SHEETS
The purpose of a SDS is to provide health and safety data about a specific hazardous
substance. The SDS discloses the chemical composition, physical hazards, health
hazards, and other information about a hazardous substance or material as specified by
OSHA.
5.1
General Requirements
a. A SDS shall be available for every hazardous substance used in a work area and shall
be accessible to employees.
b. A SDS shall be provided by the manufacturer/importer/distributor with or before
the initial shipment of the hazardous substance(s) and with or before the first
shipment after an SDS is updated.
c. If the SDS is not provided with the shipment, the purchaser (e.g., laboratory/shop
supervisor) shall obtain one from the manufacturer, importer or distributor prior to
use of the purchased material.
d. SDSs shall be in English and contain the following information as specified in:
www.osha.gov/dsg/hazcom/appendix_d.pdf.
e. If employees travel between workplaces, the SDSs may be kept at a central location
(e.g., shop). However, employees shall be able to obtain the required information in
an emergency.
5.2
Obtaining SDSs
Supervisors shall ensure employees can obtain SDSs from the following sources:
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a. Supervisor
b. Online: msds.stanford.edu
c. EH&S (650) 723-0448
5.3
Stanford University-Synthesized Substances
SDS and labeling requirements apply to hazardous substances synthesized at Stanford
University and sent offsite. Contact EH&S Occupational Health and Safety Program (x30448) for assistance and further details on these requirements.
5.4
Trade Secrets
Manufacturers and importers may withhold the specific chemical identity of a
hazardous substance with certain “trade secret” provisions. Work with EH&S if
information in SDS is withheld as a “trade secret.”
6.0
HAZARDOUS CHEMICAL INVENTORY
6.1
General Requirements
a. University laboratories, departments and shops shall maintain an inventory of
hazardous substances present in their areas.
i. At Stanford, inventories must be maintained using ChemTracker, the online
inventory system provided by EH&S. More information can be found online:
www.stanford.edu/dept/EHS/prod/researchlab/chem/inven/index.html or
chemtracker.stanford.edu.
6.2
Life Safety Boxes (LSBs)
a. Life Safety Boxes, located outside of each room containing hazardous chemicals,
provide room-specific chemical hazard information to emergency response
personnel.
b. Hazard labels on the front of the Life Safety Boxes represent the different types of
hazards that may be present within the lab.
c. Information in the Life Safety Boxes include:
i. Cover page with hazard symbols representing the different types of hazards
within the lab;
ii. SU’s Emergency contact form (or School of Medicine Emergency contact form);
iii. Chemical storage map; and
iv. The room’s chemical inventory printout (provided annually by EH&S).
7.0
HAZARD COMMUNICATION INFORMATION AND TRAINING
All faculty, staff and students who may come into contact with hazardous chemicals
shall be trained in safe handling procedures, health and safety hazards, labeling, SDSs
and personal protective equipment.
7.1
Hazard Communication Training
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Employees shall complete the following trainings:
a. Hazard Communication Training (EHS-4300) and
b. Job-specific Hazard Communication Training provided by their supervisor.
7.1.1 Frequency of Training
Employees shall be trained on hazardous substances in their work area:
a. Upon initial assignment and
b. Whenever a new hazard is introduced into the work area.
7.1.2 Recordkeeping of Training
Training records shall be maintained by the Supervisor for at least one year.
7.2
Other Required Hazard Communication Training – Non-Routine Operations
Supervisors shall inform employees of the hazards and safety procedures for nonroutine tasks and operations involving substances contained in unlabeled pipes in their
work area.
8.0
INFORMING CONTRACTOR AND CONTRACT WORKERS
This section applies to non-University personnel working on the Stanford University
campus (i.e., contractors, consultants, and visitors). The primary University contact (i.e.,
supervisor) shall inform contractor and contract workers of chemical hazards by
providing SDSs, communicating precautionary measures and explaining labeling systems
in place at Stanford University.
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Appendix A: Definitions
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Stanford University Hazard Communication Program
Definitions
Article:
A manufactured item (1) Which is formed to a specific shape or design during
manufacture; (2) which has end use functions(s) dependent in whole or in part upon
its shape or design during end use; and (3) which does not release, or otherwise
result in exposure to a hazardous substance under normal conditions of use or in a
reasonably foreseeable emergency resulting from workplace operations.
Classification: To identify the relevant data regarding the hazards of a chemical; review those
data to ascertain hazards associated with the chemical; and decide whether the
chemical will be classified as hazardous, and the degree of hazard where
appropriate, by comparing the data with the criteria for health and physics hazards.
Container: Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, tank
truck or the like that contains a hazardous substance. For purposes of this section,
pipes or piping systems are not considered to be containers.
Emergency: Any potential occurrence such as, but not limited to, equipment failure, rupture of
containers, or failure of control equipment, which may or does result in a release of a
hazardous substance into the workplace.
Exposure or exposed: Any situation arising from work operation where an employee may
ingest, inhale, absorb through the skin or eyes, or otherwise come into contact with
a hazardous substance.
Hazard category: The division of criteria within each hazard class.
Hazard class: The nature of the physical, health or environmental hazard.
Hazard classification: An evaluation of chemicals to determine the hazard classes, and where
appropriate, the category of each class that applies to the chemical being classified.
Hazard statement: A statement assigned to a hazard class and category that describes the
nature of the hazards of a hazardous product, including, where appropriate, the
degree of hazard.
Hazard warning: Any words, pictures, symbols, or combination thereof appearing on a label or
other appropriate form of warning which convey the health hazards and physical
hazards of the substance(s) in the container(s).
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Hazardous substance: Any substance which is a physical hazard or a health hazard or is
included in the List of Hazardous Substances prepared by the Director pursuant to
Labor Code section 6382.
Health hazard: A chemical which is classified as posing one of the following hazardous effects:
acute toxicity (any route of exposure); skin corrosion or irritation; serious eye
damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity;
carcinogenicity; reproductive toxicity; specific target organ toxicity (single or
repeated exposure); or aspiration hazard. Detailed explanations of health hazards
classifications
can
be
found
online:
http://www.osha.gov/dsg/hazcom/appendix_a.pdf.
Immediate use: The hazardous substance will be under the control of and used only by the
person who transfers it from a labeled container and only within the work shift in
which it is transferred.
Physical hazard: A chemical that is classified as posing one of the following hazardous effects:
explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas);
self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to
metal; gas under pressure; or in contact with water emits flammable gas. Detailed
explanations of physical hazards classifications can be found online:
http://www.osha.gov/dsg/hazcom/appendix_b.pdf.
Pictogram: A composition that may include a symbol plus other graphic elements, such as a
border, background pattern, or color, that is intended to convey specific information
about the hazards of a chemical.
Precautionary statement: A phrase (and/or pictogram) that describes recommended
measures that should be taken to minimize or prevent adverse effects resulting from
exposure to a hazardous product, or improper storage or handling of a hazardous
product.
Proposition 65: Also known as the Safe Drinking Water and Toxic Enforcement Act of 1986,
this law requires the state to publish a list of chemicals known to cause cancer, birth
defects, or other reproductive harm.
Signal word: A word used to indicate the relative level of severity of hazard and alert the
reader to a potential hazard on the label. The words 'Danger' and 'Warning' are used
as signal words.
Trade secret: Any confidential formula, pattern, process, device, information, or compilation
of information which gives its user an opportunity to obtain a business advantage
over competitors who do not know or use it. A trade secret shall not include
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chemical identity information which is readily discoverable through qualitative
analysis.
Work area: A room or defined space in a workplace where hazardous substances are produced
or used, and where employees are present.
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Appendix B: Globally Harmonized System (GHS) Pictograms Guide
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 Explosives
 Self-reactives
 Organic peroxides





Flammables
Self-reactives
Pyrophorics
Self-heating
Emits flammable gas
 Organic peroxides
 Oxidizers
 Gas under pressure
 Carcinogen
 Respiratory
sensitizer
 Reproductive
toxicity
 Target organ toxicity
 Mutagenicity
 Aspiration toxicity
 Acute toxicity
 Irritant
 Dermal sensitizer
 Acute toxicity
(harmful)
 Respiratory tract
irritant
 Narcotic effects
 Corrosives
 Environmental
toxicity
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(severe)
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