Jacksonville Center for Reproductive
Medicine
Hazardous Communication Policy
Introduction
The Hazard Communication Standard (HCS) addresses the right and needs of the
employees to be aware of the hazards and identities of the chemicals to which they
are exposed when working. Employees should also be aware of what protective
measures are available to prevent adverse affects. The HCS has been designed to
provide employees with this information. This standard deals with the issues of
evaluating and communicating hazards to employees. The evaluation of chemicals
is a highly technical process and required the analysis of experts. For this reason,
HCD has left that responsibility to the manufacturers and importers. In turn the
manufacturers, importers and distributors are left with the responsibility to provide
the consumer with their evaluations. The format that this information is provided
in is called a Material Safety Data Sheet or MSDS.
General Effects of Chemicals
Short-term (acute) effects may include:
Burns from flammable materials
Eyes, nose, throat, lung irriation or injury
Dry skin or dermatitis
Nausea (sick feeling)
Vomiting
Long-term (chronic) effects may include:
Sensitization
Death
Damage to liver, kidney, stomach, central
nervous system, muscles, brain, blood, bones,
and lungs
Policy
Fever
Unconsciousness
Death
Nervous system
effects
(i.e.
dizziness
headache, highs)
Cancer
Birth Defects
Reproductive effects
This practice has charged the Safety Officer with overall responsibility for the
Hazard Communication Program, in compliance with OSHA Hazard
Communication Standard, Title 29, Federal Regulations Code 1910.1200. The
Safety Officer has the full support and authority of the employer to ensure that
compliance is maintained in this office.
This practice will follow all guidelines in this section on hazardous chemicals. The
following policy explains in detail just how this practice will comply with the
Hazard Communication Standard, including instructions and other helpful
information.
The Hazard Communication Standard included in this section requires employees
and employers to come into compliance with its standards. This includes:
• Ensuring that all containers are properly labeled
• Establishing a list of hazardous chemical substances in the workplace
• Compiling a library of Material Safety Data Sheets
• Establishing workplace safety practices
• Providing necessary PPE and training for all employees at risk for exposure to
hazardous chemicals.
The Hazard Communications Program teaches the hazardous nature of the
substances with which you work, proper and safe handling procedures, and the
steps you must take to protect yourself from harm during normal working
conditions or in an emergency situation in the workplace.
This office provides written materials, including copies of the official standard and
written methods of compliance upon request from the Safety Officer. Initial and
annual training is provided for all employees.
Labeling and Other Forms of Warning
This practice will ensure that labels are presents on all chemicals that will provide
employees with the identity of the hazardous chemical and the appropriate
warnings. Labels must be legible and prominently displayed. There are so specific
requirement for size or color or any specific text. No label will be removed or
defaced unless immediately and appropriately relabeled. All labels on chemical
containers and any warning will be clearly written in English.
Chemical Inventory List
This practice maintains a chemical inventory list which is located in the MSDS
Manual. This is a list of hazardous chemicals used in this practice and includes the
chemical name, brand name and/or manufacturer, whether the chemical is
hazardous or non-hazardous and MSDS on file notation. If no MSDS is required,
that will be noted. This list will be maintained by the Safety Officer and will be
reviewed periodically. The chemical inventory list also serves as the index for the
MSDS.
Exemptions
The consumer product exemption applies when a product is defined as a
“consumer product” by the Consumer Safety Act . . . and “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 its use results in a duration and
frequency of exposure which is not greater than the range of exposures that could
reasonably be experience by consumers when used for the purpose intended (29
CFR 1910.1200 (b) (6) (ix)” . . . . The term “consumer product” means any article,
or component part thereof, produced or distributed for sale to a consumer for use
in or around a permanent or temporary household or residence, a school, in
recreation, or otherwise, or for the personal use, consumption, or enjoyment of a
consumer. . . . .
OSHA considers office chemicals such as White Out, cleaning chemicals, and
copier chemicals to be exempt under the provisions of the rule as consumer
products. Consumer products, which are hazardous chemicals as defined by the
HCS, fall under the provisions of the standard only when they are used with
greater frequency or duration than a normal consumer, or for “uses not intended by
the manufacturer . . . .”
The HCS also exempts:
• Hazardous waste and hazardous substances as a part of remedial or removal
action under the EPA
• Tobacco or tobacco products
• Wood or wood products if the only hazard is flammability or combustibility
• Articles (solids)
• Food for personal consumption by employees
• Drugs in solid, final form for administration to the patient
• Over-the-counter drugs or drugs for personal consumption by employees
• Cosmetics for personal use by employees
• Nuisance particles that do not pose any physical or health hazards covered by
the standard
• Biological hazards
Pharmaceuticals
Pharmaceutical products that are covered if they meet OSHA hazard criteria
include liquids, semi-solids (cream, ointments, lotions), powders and aerosols.
OSHA hazard classes cover both health hazards (e.g. highly toxic, sensitizer, etc.)
and physical hazards (e.g. flammable liquid, etc.) In particular, any drugs which
are in gel, powder, liquid or aerosol form require an MSDS sheet as well as drugs
which have been changed from their original solid form prior to patient
administration such as by crushing. (Ref: HazCom Standard 29 CFR 1910.1200
(g) (1)).
Exempted are pharmaceuticals which are received sealed, remain sealed, and go
home with the patient sealed (samples, dispensed products if sealed), tablets and
capsules which remain tablets and capsules (are not pulverized or broken apart for
administration in the practice).
Material Data Safety Sheets (MSDS)
The Material Data Safety Sheet is the document prepared by the manufacturer to
describe the chemical and to inform the use of any hazards and needed safety
precautions. The Safety Officer is responsible for obtaining MSDSs for all
hazardous chemicals and for making them available to all users.
All employees have access to our MSDSs at all times. Our MSDSs are stored in a
manual located in the laboratory.
Material Data Safety Sheets (MSDSs) Interpretation
Identity
This section identifies the product. The information recorded here will be used on
the corresponding label for the individual product.
Section I
Name, address, and phone number of the manufacturer or distributor of the
product is located here. The date the MSDS was prepared is also indicated in this
section.
Section II – Hazardous Ingredients
This section lists the hazardous components of the material identified in the
IDENTITY section. A brief description to identify the material is listed also.
OSHA PEL:
defines the permissible exposure level of the chemical.
ACGIH TLV:
defines the American Conference of Governmental
Industrial Hygienists Threshold Limit Value. TLV
means the airborne concentration of the substance that
represents conditions under which it is believed that
nearly all workers may be repeatedly exposed day after
day without adverse effects.
Section III – Physical/Chemical Characteristics
This section contains information on physical characteristics of the chemical: the
boiling point, appearance, melting point, solubility in water, vapor pressure, and
density.
Section IV – Fire and Explosion Hazard Data
This section contains information on the flash point of the chemical, how to
extinguish a fire involving the chemical, and any unusual hazards associated with
this chemical.
Section V – Reactivity Data
This will give the worker information that can aid in the storage and handling of
the chemical.
Section VI – Health Hazard Data
Information here must note the target organs that affected.
Routes of Entry
Carcinogenicity
NTP: National Toxicology Program report
IARC Monographs: International Agency for Research on Cancer
OSHA: does OSHA classify this chemical as a potential carcinogen?
Section VII – Precautions for Safe Handling and Use

In The Event Of A Spill: here is what is to be done in the event of a spill or
leak.

Waste Disposal Method: how to dispose of hazardous solids/liquids including
how to properly clean up after an accidental spill

Precaution To Be Taken: describes storage and handling so as not to cause a
hazardous reaction.
Section VIII – Control Measures
• Respiratory Protection: lists the types of PPE, type of ventilation and
precautions to be used when handling this material or when accidently
spilled
• Protective Gloves: gives the type of gloves needed to handle the hazardous
material or indicate if protection is needed
• Eye Protection: lists if goggles or face shield protection is needed
• Work / Hygiene / Maintenance Practices: notes what personal hygiene steps the
employee must take when handling this material.
Employee Information and Training
Employees at this facility shall be given information training regarding the
hazardous chemicals in the workplace when their job assignment begins and
whenever a new hazard exists.
Employees shall be informed of the requirements of 29 CFR 1910.1200, when and
where hazardous chemicals may be present and the location of the written hazard
communication program, hazardous chemical lists, and the Material Data Safety
Sheets.
Employees will be trained in methods of detecting the presence of hazardous
chemicals in their work area, the hazards of the workplace and measures that can
be taken to protect themselves from exposure to hazardous chemicals. In addition,
employees shall be informed of the specifics of this written hazard communication
program, including how to gain necessary hazard information, how the labeling
system operates, and how to use the Material Data Safety Sheets.
Work Practice Policy
Employees in the facility will use hazardous chemicals only in well-ventilated area
and while wearing PPE indicated by the MSDS. No eating, drinking, applying
cosmetics or contact lenses, or storing food or beverages will be allowed in area
where hazardous chemicals are stored or used.
All employees will clean the work surgaces and wash their hands following the
use of hazardous chemicals.
Spilled chemicals will be cleaned up according to our spill clean-up procedure or
the MSDS if the MSDS clean-up instructions are more stringent. The absorbed
material will be discarded according to information found in the MSDS.
Chemical Spill
Spill Clean-Up Procedures
1.Isolate the area and seek assistance
2.If the spill is chemical, get the MSDS and read how to clean up the spill
3.Retrieve the spill kit (which contains absorbent, PPE, small broom & dustpan,
bags for disposal, paper towels for cleaning and disinfectant)
4.Put on appropriate PPE: face protection, gown and heavy duty gloves
5.Pour absorbent on the spill, using enough that the spill becomes manageable in a
solid form. A special spill kit, or powdered sulfur, must be used to clean up
mercury
6.Using the broom and scoop in the chemical spill kit, sweep up the spill and
dispose it according to the MSDS directions or, if it is a biohazardous spill,
dispose of it in a red bag
7.Clean the area with soap and water
8.If the spill is potentially biohazardous, spray the area with a hospital grade
disinfectant using the spray-wipe-spray technique.
Mercury Spill
If you have a mercury spill:
1.Pick up silver beads with an eyedropper or syringe
2.Place in a plastic bag (preferably a Ziploc bag) and seal
3.Contact you local solid waste department or go to www.earth911.org. (Key in
your zip code and click on “mercury information”.)
Disposal
OSHA does not govern chemical disposal. The Envirnmental Protection Agency
(EPA) and the Presource Conservation and Recovery Act (RCRA) do. When
MSDSs are vague, contact eh wast removal service for guidance.
Many waste removal service recommend packaging chemicals separately from the
biohazardous waste, and labeling it “Chemical Waste”. The waste removal
company can then process it appropriately. This includes silver and mercury.
Storage and Handling of Hazardous Chemicals
Chemicals will be stored in cool, dry areas at temperatures between 67ºF and 94ºF,
unless the manufacturer notes otherwise. Storage areas should be constructed so
that shelving is fixed securely to the floor or wall and should be away from direct
sunlight, high heat and humidity, and ignition. Access to the storage area should
be limited to authorized personnel only.
Chemicals will be stored in properly labeled containers with special attention
given to hazard warning. These warning will alert employees using the chemicals
not to store incompatible materials in the same area. Chemicals need to be stored
by their potential hazard, not alphabetically. These hazard classes areas follow:
Health Hazard, Carcinogen, Compressed Gas, Corrosive, Flammable, Moderate
Poison, Non-Hazardous, Radioactive, Severe Poison, Water Reactive, and
Oxidizers.
Large volumes of flammables must be stored in special storage areas. Water
reactive chemicals need dry storage. Strong oxidizers will be separated from other
chemicals. Compressed gas cylinders will be secured and supported.
Each employee should read the manufacturer’s or supplier’s directions before
using any product, and note the possible hazards (both physical and health
hazards) of the product. The proper information should be on the label fro
products containing hazardous chemicals.
Eyewash Stations
Any employer who employs anyone to perform procedures that may cause
splashes or spills of hazardous chemicals to the eyes must have an eyewash
station. This includes any employer with x-ray equipment in use. See 1910.151
(c); 1926.50 (q).
The eyewash station must be “easily accessible” to the laboratory and must be
unobstructed for ease of use for employees who are performing those tasks that
may result in splashes of hazardous chemicals to the eye.
It must be located within 10 seconds from the potential hazard. It must be
approved by the ANSI. IT must be operational with one hand movement, provide
a continuous flow of clean, tepid water for at least 15 minutes, be continuously
operating while the employee holds both eye lids open, and be balanced on both
sides with sufficient force to meet in the middle.
This practice will install eyewash stations as needed. We will maintain proper use
by following the manufacturer’s instructions, checking for proper functioning
periodically and cleaning as needed.
Eyewash stations are located in the laboratory and instrument cleaning room.
Jacksonville Center for Reproductive
Medicine
Hazardous Communication Policy Review
This policy became effective on March 1, 2008.
It will be reviewed by the Safety Officer on an annual
basis unless otherwise necessary.
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