1. Tulane University - Office of Environmental Health & Safety (OEHS) OSHA HAZARD COMMUNICATION (HAZCOM) STANDARD 29 CFR 1910.1200 FOR TULANE LABORATORY OR FACILITY EMPLOYEES WHO WORK WITH OR AROUND CHEMICALS May 2012

2. Tulane University - Office of Environmental Health & Safety (OEHS) OBJECTIVES Employees shall learn about Tulane’s written Hazard Communication Plan Employees shall learn how to report and the reasons for reporting their chemical inventory Employees shall learn about proper container labeling Employees shall learn about Material Safety Data Sheets (MSDSs) and how to obtain them Employees shall learn how to find information on chemicals they may encounter on the job and how to protect themselves

3. Tulane University - Office of Environmental Health & Safety (OEHS) OSHA HAZARD COMMUNICATION STANDARD To view the OSHA HACOM Standard, see http://www.osha.gov/pls/oshaweb/owadisp.show_document ?p_table=STANDARDS&p_id=10099 http://www.osha.gov/pls/oshaweb/owadisp.show_document ?p_table=STANDARDS&p_id=10099 States You Have a “Right to Know” about Chemical Hazards in the Workplace and How to Protect Yourself Tulane has a Written Hazard Communication Plan located in Section 12 of the OEHS Policies and Procedures Manual (see http://tulane.edu/oehs/upload/PPMFullWebA.pdf).http://tulane.edu/oehs/upload/PPMFullWebA.pdf A Supervisor’s Guide to Hazard Communication is also available online for training and information purposes (see http://tulane.edu/oehs/safety/guidetohazcomm.cfm) http://tulane.edu/oehs/safety/guidetohazcomm.cfm

4. Tulane University - Office of Environmental Health & Safety (OEHS) OSHA HAZARD COMMUNICATION STANDARD Under the OSHA HAZCOM standard, manufacturers of chemicals are required to evaluate the hazards of the chemicals they produce and transmit that information to customers on labels and Material Safety Data Sheets (MSDSs)

5. Tulane University - Office of Environmental Health & Safety (OEHS) EXEMPTIONS FROM HAZCOM OSHA HAZCOM deals with chemical hazards. Other agencies such as the EPA or the FDA cover some of these other products. RADIATION BIOHAZARDS HAZARDOUS WASTE OVER-THE-COUNTER DRUGS DRUGS IN SOLID FORM FIRST AID SUPPLIES COSMETICS FOOD AND BEVERAGES WOOD PRODUCTS CONSUMER PRODUCTS (Depending on quantity or frequency of use – such as cleansers) ARTICLES (such as clothing)

6. Tulane University - Office of Environmental Health & Safety (OEHS) SUBMITTING ANNUAL CHEMICAL INVENTORIES As part of Tulane’s HAZCOM Plan, hazardous chemical inventories must be submitted annually to OEHS by the supervisor/principle investigator. Submit annual documentation that your hazardous chemical inventory has been reviewed and updated to: pfatlan@tulane.edu.pfatlan@tulane.edu In 2011 a new hazardous chemical inventory program will be implemented at Tulane. It is called EHS Assistant. Contact OEHS for information on registration and accessing this new system.

7. Tulane University - Office of Environmental Health & Safety (OEHS) CHEMICAL INVENTORY Required Information Supervisor/PI Department Campus/Bldg/Rm # Date of Inventory Product/Chemical Name Manufacturer CAS (Chemical Abstract Service) Number Product or Catalog Number Number of Containers Total amount of material & units (ml, g, lb) Container Type/Size (glass, plastic/ml, g, lb)

8. Tulane University - Office of Environmental Health & Safety (OEHS) CHEMICAL INVENTORY All information is important for regulatory reporting and must be submitted. If the amounts vary, simply indicate the amount of each material that is available on the day the inventory is taken. Each chemical has a unique CAS number. Mixtures will have a CAS number for each chemical in the mixture. Some materials are trade secrets and will not list the CAS numbers. Submit as much information as you can. Previously submitted inventories can be obtained from OEHS for updating. Contact Pam Fatland or Jay Folse.

9. Tulane University - Office of Environmental Health & Safety (OEHS) PURPOSE OF UPDATING CHEMICAL INVENTORY To verify that you have Material Safety Data Sheets (MSDSs) you need in the work area and that the OEHS library of MSDSs is complete Emergency Responders need inventory for emergencies, such as fires and spills, and for planning purposes To perform a hazard evaluation of the area, obtain appropriate PPE, verify proper storage and that containers are in good condition and not expired

10. Tulane University - Office of Environmental Health & Safety (OEHS) PURPOSE OF UPDATING CHEMICAL INVENTORY Tulane is required to report inventory to local, state, and federal agencies such as the EPA, the State Police, and the Fire Department Fees based on the inventory must be paid to regulatory agencies (Example: City of New Orleans Hazardous Materials Tax which helps to support the Fire Dept’s HAZMAT unit)

11. Tulane University - Office of Environmental Health & Safety (OEHS) CHEMICAL LABELS – Required Information Full Chemical Name Physical and Health Hazards (Flammable, Corrosive, Toxic) Manufacturer Name/Address/Phone Number (on incoming containers)

12. Tulane University - Office of Environmental Health & Safety (OEHS) CHEMICAL LABELS – Required Information Labels are required on all incoming containers, all transfer containers that will be left for a period of time, and on all containers that will be used by more than one person You can label an entire shelf instead of each individual container if all containers on the shelf contain the same thing (Ex. specimen containers of ethanol) Labels must be legible, in English with the full name of the chemical spelled out (no symbols or abbreviations)

13. Tulane University - Office of Environmental Health & Safety (OEHS) CHEMICAL LABELS – Required Information The purpose of labeling is to identify the material and to become aware of the hazards and the methods of protection Sometimes OSHA requires special wording to appear on the label of certain chemicals or at the entrance to a regulated area (Ex. Formaldehyde containers must say “Irritant and Potential Cancer Hazard”)

14. Tulane University - Office of Environmental Health & Safety (OEHS) More Chemical Label Information Sometimes labels contain other information that serve to enhance the hazard warnings and identify means of protection: Signal Word (e.g., Danger, Warning, Caution) First Aid Procedures Handling & Storage (e.g., Avoid contact with Acids) Special Instructions (e.g., Keep out of reach of children, Use with adequate ventilation)

15. Tulane University - Office of Environmental Health & Safety (OEHS) Chemical Labeling Systems Optional information which may be found on a container label: The National Fire Protection Association (NFPA) uses a color-coded diamond with a numerical rating system to identify the degree of health (blue), fire (red), or reactivity (yellow) hazards associated with a chemical in a fire situation. A zero means minimal hazards whereas a four indicates severe hazards (see http://www.nfpa.org/faq.asp?categoryID=928&cookie%5Ftest=1 ). http://www.nfpa.org/faq.asp?categoryID=928&cookie%5Ftest=1

16. Tulane University - Office of Environmental Health & Safety (OEHS) Chemical Labeling Systems Optional information which may be found on a container label: The National Paint and Coatings Association uses the Hazardous Materials Identification System (HMIS), a similar system of labeling which rates chemicals from zero to four on their health (blue), flammability (red), reactivity (yellow), and also gives personal protective equipment designations (see http://www.paint.org/hmis/index.cfm ). http://www.paint.org/hmis/index.cfm

17. Tulane University - Office of Environmental Health & Safety (OEHS) Chemical Labeling Systems Optional information which may be found on a container label: The Department of Transportation (DOT) uses a color-coded diamond in which there is a symbol and a term describing the major hazard of the material. This system is used during transportation of hazardous materials and is seen on shipping containers.

18. Tulane University - Office of Environmental Health & Safety (OEHS) Chemical Labeling Systems Optional information which may be found on a container label: The Globally Harmonized System (GHS) is currently being developed and approved. It is designed to protect health and the environment and to facilitate global trade in chemicals. It includes internationally agreed upon cautionary statements as well as symbols/pictograms for chemical properties. The United States is working towards adoption of this promising system at the present time (see http://www.osha.gov). http://www.osha.gov

19. Tulane University - Office of Environmental Health & Safety (OEHS) Chemical Labels OEHS has labels available for portable containers where you can write in the full name of the chemical and check off the physical and health hazards, as well as personal protective equipment. Use of these is optional. Contact Jay Folse of OEHS to request these: jfolse@tulane.edu.jfolse@tulane.edu OEHS also has Hazardous Waste Labels available for hazardous chemical waste. Contact Michael Kopaigorodsky of OEHS to request these: mkopaigo@tulane.edu. Hazardous Waste labels must contain the words “Hazardous Waste” and must also list the full name of the chemical and the associated hazards.mkopaigo@tulane.edu

20. Tulane University - Office of Environmental Health & Safety (OEHS) LABORATORY DOOR SIGNS Signage for laboratory doors stating the hazards found in the lab and emergency contact information are available from OEHS Door sign request forms available on OEHS website (see http://tulane.edu/oehs/safety/lab-door-labels.cfm). The form can also be used for updates of current signs http://tulane.edu/oehs/safety/lab-door-labels.cfm Signs contain stickers relating to hazards found in that laboratory (Example: Flammable, Corrosive, Water Reactive) Signs also contain authorized admittance/emergency contact information which should be used before entering a lab or during an emergency to contact appropriate personnel Copies of signage forms are kept in OEHS for emergency response purposes

21. Tulane University - Office of Environmental Health & Safety (OEHS) DEFINITIONS Familiarize yourself with terms found on chemical labels/MSDSs MSDS HyperGlossary – (See http://www.ilpi.com/msds/ref/)http://www.ilpi.com/msds/ref/

22. Tulane University - Office of Environmental Health & Safety (OEHS) COMMON DEFINITIONS CARCINOGEN - Can cause cancer CORROSIVE - Can cause destruction of living tissue (e.g., acids, caustics) EXPLOSIVE - Can cause release of pressure, gas, and heat FLAMMABLE - Can burn when ignition source and air are present

23. Tulane University - Office of Environmental Health & Safety (OEHS) COMMON DEFINITIONS IRRITANT - Can cause reversible inflammatory effect (e.g., eyes water, itching) OXIDIZER - Promotes combustion = oxygen SENSITIZER - Can cause an allergic reaction in some people TOXIC - Can cause health effect

24. Tulane University - Office of Environmental Health & Safety (OEHS) ROUTES OF ENTRY Chemicals can enter the body in a number of ways. Depending on how the chemical enters the body, you may need respiratory protection, skin protection such as gloves or aprons, or face and eye protection such as face shields and goggles. INHALATION = Nose INGESTION = Mouth SKIN CONTACT = Skin, Eyes INJECTION = Skin (subcutaneous vs. dermal)

25. Tulane University - Office of Environmental Health & Safety (OEHS) MATERIAL SAFETY DATA SHEETS (MSDSs) MSDSs are documents that inform you of the hazards associated with a chemical and how to protect yourself from those hazards MSDSs must be readily accessible to employees in the work area where the chemicals are used Each company publishes its own MSDSs with their address and emergency contact information. Thus if you have a chemical such as acetone from two different manufacturers, you will need an MSDS from each company

26. Tulane University - Office of Environmental Health & Safety (OEHS) MATERIAL SAFETY DATA SHEETS (MSDSs) (The following are types of information that can be found on an MSDS) Identity Ingredients Physical Properties Hazards *Physical *Health Precautions Storage Control Measures Disposal Spills Personal Protective Equipment (PPE)

27. Tulane University - Office of Environmental Health & Safety (OEHS) MATERIAL SAFETY DATA SHEETS - ACQUISITION Manufacturers are required to ship MSDSs to Tulane with the first shipment of a chemical OEHS maintains a hard-copy library of all MSDSs received from the manufacturers and all chemicals listed on the inventories that are submitted. The OEHS library of MSDSs is kept at the OEHS downtown office, 11 th floor of Tidewater MSDSs are also available on the OEHS website (See http://tulane.edu/oehs/safety/materialsafetydatasheets.cfm) http://tulane.edu/oehs/safety/materialsafetydatasheets.cfm The OEHS website/MSDS link also contains FAX numbers and web links for common chemical manufacturers Contact OEHS if you have trouble finding an MSDS that you need

28. Tulane University - Office of Environmental Health & Safety (OEHS) MATERIAL SAFETY DATA SHEETS – ACQUISITION Ways to Obtain MSDSs at Tulane: Go to the OEHS Website: http://tulane.edu/oehs/safety/materialsafety datasheets.cfm http://tulane.edu/oehs/safety/materialsafety datasheets.cfm –Online MSDS collections –Online Manufacturer Links –Manufacturer FAX numbers –Other University Websites OEHS Hard Copy Library of MSDSs: 11 th Floor Tidewater; contact OEHS at (504)988-5486

29. Tulane University - Office of Environmental Health & Safety (OEHS) ELECTRONIC MATERIAL SAFETY DATA SHEETS OSHA recognizes that MSDSs can be kept electronically in the work area, if all of these criteria are met: All employees must be trained on how to obtain MSDSs You must be able to print MSDSs You must have an alternative to obtaining MSDSs in the event of power loss or other emergency (Contact OEHS – hard copy library of MSDSs)

30. Tulane University - Office of Environmental Health & Safety (OEHS) GLOBAL MATERIAL SAFETY DATA SHEETS There are talks in progress for a global MSDS formal similar to the Globally Harmonized System (GHS) for labeling chemicals (see http://www.osha.gov) http://www.osha.gov International Chemical Safety Cards published by NIOSH are now available (see http://www.cdc.gov/niosh/ipcs/nicstart.html) http://www.cdc.gov/niosh/ipcs/nicstart.html

31. Tulane University - Office of Environmental Health & Safety (OEHS) TRADE SECRETS The OSHA HAZCOM standard provides for protection of trade secrets. The identity of a trade secret chemical must be given to health professionals, employees, or designated representatives in a medical emergency. The chemical manufacturer may require a written statement of need and confidentiality agreement as soon as circumstances permit. In a non-emergency, the health professional, employee, or designated representative may provide a written request for disclosure of a chemical’s identity. This written request may be denied but the manufacturer must explain how alternate information will satisfy the specific occupational or medical need. OSHA may be contacted to review the request and denial.

32. Tulane University - Office of Environmental Health & Safety (OEHS) TRAINING All who work with or around chemicals must be trained. All training must be documented. Training forms can be found at http://tulane.edu/oehs/training/trainingdocumentationold.cfm. http://tulane.edu/oehs/training/trainingdocumentationold.cfm Online quizzes for this OEHS Powerpoint presentation will go directly to OEHS and can serve as your training documentation for the OSHA HAZCOM Standard. Supervisors/principle investigators are responsible for providing training on specific chemical hazards in the work area, personal protective equipment (PPE) available, and/or work practices to use while doing your job.

33. Tulane University - Office of Environmental Health & Safety (OEHS) TRAINING All who work with or around chemicals must be trained. You must be able to show you understood the training. *Quiz *Random Interviews (Be able to answer questions) *Demonstrations (actually obtain an MSDS)

34. Tulane University - Office of Environmental Health & Safety (OEHS) OSHA REQUIRED TRAINING INFORMATION Employees must be familiar with the following: The requirements of the OSHA HAZCOM standard Any operations in their work area where hazardous chemicals are present The location and availability of Tulane’s written HAZCOM plan and how to obtain MSDSs

35. Tulane University - Office of Environmental Health & Safety (OEHS) OSHA REQUIRED TRAINING INFORMATION Employees must be familiar with the following: How to detect the presence or release of a hazardous chemical in the work area Physical and health hazards of chemicals present in the work area How to protect oneself from hazards Details of Tulane’s HAZCOM program including labeling and MSDSs

36. Tulane University - Office of Environmental Health & Safety (OEHS) OSHA REQUIRED TRAINING INFORMATION Employees must be familiar with the following: For hazards of non-routine tasks, check with your supervisor For specific emergency procedures for your area, check with your supervisor For hazards associated with unlabeled pipes in the work area, contact Facilities Services

37. Tulane University - Office of Environmental Health & Safety (OEHS) CONTRACTOR INFORMATION Contractors who could be exposed to chemicals at Tulane must be given the opportunity to review Tulane’s written HAZCOM Plan and must be told about particular hazards in the work areas in which they will be working Tulane and OEHS will provide MSDSs to contractors upon request

38. Tulane University - Office of Environmental Health & Safety (OEHS) CONTRACTOR INFORMATION Contractors who bring chemicals on Tulane property to be used in the course of their work must supply Tulane with a list of these chemicals, and must supply MSDSs and information to Tulane upon request See Section 12 of the OEHS Policies and Procedures Manual at http://tulane.edu/oehs/upload/PPMFullWebA.pdf for more information on contractors and HAZCOM http://tulane.edu/oehs/upload/PPMFullWebA.pdf

39. Tulane University - Office of Environmental Health & Safety (OEHS) SUMMARY - HAZCOM COMPLIANCE CHECKLIST Are you in compliance with HAZCOM? Annual chemical inventory submitted to OEHS Access to MSDSs available in the work area Training documentation forms/quizzes on HAZCOM topic sent to OEHS Proper container labeling for all containers in work area Up-to-date door labels for laboratories Familiarity with Tulane’s written Hazard Communication Plan available in Section 12 of the OEHS Policies & Procedures Manual (see http://tulane.edu/oehs/upload/PPMFullWebA.pdf) http://tulane.edu/oehs/upload/PPMFullWebA.pdf

40. Tulane University Office of Environmental Health & Safety (OEHS) Pam Fatland pfatlan@tulane.edu Manager, Chemical Safety (504) 988-2800 http://tulane.edu/oehs If unable to proceed to quiz, type the link below into your browser https://pandora.tcs.tulane.edu/ehs/enterssn.cfm?testnum=89pfatlan@tulane.eduhttp://tulane.edu/oehs Proceed to Quiz