Environmental Health & Safety

Hazard Communication Program

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Policy:

Yeshiva University (YU) and Albert Einstein College of Medicine (Albert Einstein College of Medicine) are committed to providing a safe and healthful work environment for all its employees, students, and visitors.

Employees have the right to know about the identities and hazards of the chemicals with which they work or may be exposed. In this way, they can reduce the incidence of chemically-related occupational illnesses and injuries.

YU and Albert Einstein College of Medicine provide information and training in an effort to reduce the possibility of accidental exposures and to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.

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Purpose

The Occupational Safety and Health Administration Hazard Communication Standard (29 CFR 1910.1200) requires that all employers develop and implement a written Hazard Communication Program which describes how the OSHA Hazard Communication Standard requirements are met at the University.

OSHA's primary intent in issuing this standard is to ensure that employees receive all necessary information concerning the potential hazards in their workplace, and that this information is presented to all employees prior to starting work, and when new chemical hazards are introduced into their work area.

The Hazard Communication Program is designed to:

  • Reduce the likelihood of injury or illness to employees by implementing specific procedures to identify and evaluate the chemical hazards in the workplace.
  • Inform and train employees on chemical hazards.
  • Ensure that all individuals at risk are adequately informed about the chemicals used and stored in their workplaces.
  • Outline procedures for all employees working with hazardous chemicals.

For our research laboratories, the Hazard Communication Program is superseded by OSHA's "Laboratory Standard". This is contained in our Chemical Hygiene Program.

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Responsiblities

Management
Management will ensure that the requirements of the Hazard Communication Program are fulfilled. Management will also receive information on the program from the Environmental Health and Safety Department.

Environmental Health and Safety Department (EH&S)
EH&S was created by Yeshiva University to protect the health and safety of the University's employees, students, and visitors. In cooperation with area supervisors, EH&S will:

  • Develop a Hazard Communication Program and make it available to all university employees.
  • Evaluate the chemical hazards which employees may encounter.
  • Assist management in maintaining a current hazardous chemical inventory by requiring all chemicals to be ordered through the Purchasing Department.
  • Ensure proper labeling of hazardous chemical containers through training.
  • Provide training in the Hazard Communication Program.
  • Maintain MSDSs for all chemicals used in the workplace.
  • Assure that all employees involved in non-routine tasks are informed of hazards associated with such tasks prior to assignment.
  • Assure that contractors and their employees are informed of hazards before performing work on University property.
  • Assure that contractors inform the University of all hazardous materials brought onto campus.
  • Assure that contractors inform the University of any hazards created by their activities.
  • Report to management the status of the Hazard Communication Program.

 

Supervisors
Supervisors are responsible to do the following:

  • Evaluate the hazards of the chemicals used in their workplace.
  • Provide training and supervision to workers who come in contact with hazardous chemicals.
  • Ensure that all chemical containers are properly labeled.
  • Ensure that MSDSs are available for all chemicals used in the workplace.
  • Ensure that all accidents and injuries involving hazardous chemicals are promptly reported to EH&S and to Occupational Health Service.

 

Employees
Employees are responsible to do the following:

  • Attend Hazard Communication Training classes.
  • Familiarize themselves with the MSDSs for the chemicals used in the workplace.
  • Know the protective measures for using hazardous chemicals safely.
  • Know how to recognize the signs and symptoms of exposure.
  • Know what to do in the event of an emergency or an exposure regarding hazardous chemicals.

 

Employee Rights  

Every employee has specific rights granted by state and federal agencies in the workplace. YU and Albert Einstein College of Medicine employees have the following rights under the Hazard Communication Standard:

  • The right to request and obtain information in writing on any hazardous chemicals with which they may come in contact.
  • The right to be informed of the hazardous chemicals used in their work area.
  • The right to have access to the YU and Albert Einstein College of Medicine written Hazard Communication Program upon request. This right is extended to include an employee's designated representative.
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    Chemicals Present in YU and Albert Einstein College of Medicine:

    The chemicals covered by the Hazard Communication Program, such as solvents, detergents and other cleaning agents, are typically used in the Engineering and Housekeeping Departments. Office workers may handle other hazardous chemicals which come under this program. The chemicals used in our laboratories fall under OSHA's "Laboratory Standard", which is contained in our Chemical Hygiene Program. A complete list of all of the specific chemicals on campus is maintained at the EH&S Department and is available for review at any time.

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    Hazard Determination:

    Since the University does not manufacture hazardous materials, the University will rely on the MSDSs received from manufacturers for information concerning hazardous chemicals used or stored at the University.

    Should hazard determination be required for a chemical for which there is no MSDS generated by the manufacturer, an outside source will be contacted to compile such information.

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    Labels and Other Forms of Warning:

    General Requirements
    Chemical manufacturers, importers, and distributors are required to label all containers of hazardous chemicals. The label must include:

    • The identity of the hazardous chemical.
    • The name and address of the manufacturer, importer, or other responsible party.
    • Appropriate hazard warnings, including:
      • Health hazards.
      • Physical hazards.
      • Listing of target organs, and effects.
      • Personal protective equipment required to use the chemical.
       

     

    All hazardous material containers delivered to the University must be labeled as above. These labels are not to be removed or defaced. Unlabeled containers will not be accepted.

    Suppliers of any solid metal material which may emit hazardous substances when worked upon, are required to supply labels with the first shipment of the material.

    In-House Labeling System:
    When materials are transferred from a labeled container to another container, the recipient container must be labeled. All labels developed in-house will derive their information from the labels of the incoming containers and the Material Safety Data Sheets. The following, at minimum, must be provided on all in-house labels:

    • The identity of the hazardous chemical contained therein.
    • Appropriate hazard warnings: Health hazards; Physical hazards

     

    Health Hazard - a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles, that acute or chronic health effects may occur in exposed employees. The term "Health Hazard" includes: chemical carcinogens, toxic or highly-toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatoxins, nephrotoxins, neurotoxins, agents which act on the hemolytic system, and agents which damage the lungs, skin, eyes, or mucous membranes.

    Physical Hazard - a chemical for which there is scientifically valid evidence of being: a combustible liquid, a compressed gas, an explosive, a flammable, an organic peroxide, a pyrophoric oxidant, or a substance which is reactive (unstable) with water.

    Labeling of Portable Containers
    Portable containers into which hazardous chemicals have been transferred, need not be labeled provided that the entire contents will be used within one day by the employee who performed the transfer.

    Consultants
    Upon request, all contractors will be instructed in the appropriate labeling system for the areas in which the work is taking place.

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    Material Safety Data Sheets (MSDSs):

    MSDSs are important documents which contain valuable information on the physical and chemical properties of a chemical. They also contain important safety information including:

    • Hazardous ingredients
    • Common names
    • Physical and chemical characteristics
    • Physical hazards including potential for fire, explosions, and reactivity
    • Health hazards
    • Primary routes of entry
    • OSHA Permissible Exposure Limits, ACGIH Threshold Limit Values.
    • Potential carcinogen notations
    • Precautions for safe handling
    • Control measures
    • Emergency and first aid procedures
    • Date of preparation
    • Name, address, and phone number of the chemical manufacturer.

     

    Locations:
    EH&S currently maintains MSDSs for every hazardous chemical present on campus. The MSDSs are available to all departments, and are available to employees 24 hours a day. They can be found at the following locations:

    • The EH&S Office, 800 Forchheimer
    • The Forchheimer Lobby
    • The 4th floor hallway of Forchheimer
    • The 9th floor hallway of the Kennedy Building.

     

    A file of MSDSs is currently maintained at the Occupational Health Service Department - Weiler Hospital, 7th floor.

    Upon request, all contractors will be provided with the appropriate MSDSs for the areas in which the work is taking place.

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    Employee Information and Training:

    Employees Requiring Training:
    Any employee, who either has actual or potential exposure to hazardous substances, will receive Hazard Communication Training. It is the intent of YU and Albert Einstein College of Medicine to ensure that employees receive information regarding all chemicals in their work area, and that they are prepared to deal with any unexpected releases or emergency situations, as well as exposures during the normal course of employment. Personnel who do not come in contact with hazardous materials are not required to receive this training.

    The Hazard Communication Standard has special training provisions for personnel who handle sealed containers of hazardous chemicals, for laboratory personnel, and for those personnel who may be exposed to hazardous substances used by a contractor on University property. Additional information for handling chemicals in laboratories can be found in the University's Chemical Hygiene Plan.

    Information
    It is the responsibility of EH&S and area supervisors to ensure that all:

    • Employees are informed of the Hazard Communication training requirements.
    • Employees are informed of any operations where hazardous chemicals are present.
    • Employees are aware of the ability to access appropriate MSDSs, the Hazard Communication Program, and the full list of hazardous chemicals on any work shift.
    • Contractors will be informed either verbally or in writing of any necessary measures which must be taken in the areas in which the work is taking place including situations of normal operation conditions and in any foreseeable emergencies.
    • Employees are aware that personal protective equipment is available and that they know its proper use.
    • Employees are aware that engineering controls, such as ventilation, are in place and operating properly.

     

    Training
    Training will be conducted by members of the Environmental Health and Safety Department or other suitable individuals. Training must be provided to all affected employees when:

    • The program is initially implemented
    • A new employee starts work.
    • An employee is transferred to a department that uses different hazardous materials.
    • A new hazard is introduced into the workplace.
    • New information becomes available for a substance already in use in the workplace.

     

    Elements of the University Training Program 

    • Methods of observation which may be used to detect the presence or release of a hazardous chemical in the work area.
    • Physical and health hazards of the chemicals in the work area.
    • Measures employees must take to protect themselves from exposure to hazards, including specific procedures such as appropriate work practices, emergency procedures, and personal protective equipment.
    • Requirements of the Hazard Communication Standard.
    • Location of the Hazard Communication Program.
    • Location of the Chemical Inventory Lists.
    • Instruction for using Material Safety Data Sheets.
    • Explanation of labeling systems.

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    Non-routine Tasks:

    This section applies to jobs that are not performed on a routine basis, but may involve contact with a hazardous substance.

    Supervisors are responsible to determine whether any hazards are present or may be created by the task.

    Supervisors are responsible to communicate information on all hazards presented by non-routine tasks to employees and to EH&S.

    Supervisors will ensure that special equipment, such as a portable ventilation system and/or personal protective equipment, is made available and is used properly during the task.

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    Contractor Notification Procedures:

    The Hazard Communication Standard requires that the University provide hazard information to on-site contract employers whose employees may be exposed to hazards while working at the University. (NOTE: Areas where contractors will work will be cleared of all hazards by EH&S prior to the commencement of the project. This is also true of in-house projects).

    The contractor must provide hazard information to the University when the contractor uses or stores hazardous materials on-site or exposes employees to them. This function will be coordinated by the Engineering Department or the Environmental Health and Safety Department. This information exchange must include: Material Safety Data Sheets; precautionary methods needed to protect workers during normal operating conditions and during foreseeable emergencies; the labeling system; and the emergency alarm system.

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    Special Exemptions and Provisions:

    There are several circumstances where the law is modified to address situations where a straight interpretation of the standard would not be applicable.

    Sealed Containers
    In operations such as warehousing and other materials management functions where employees only handle containers that are sealed, only the following aspects of the Hazard Communication Program apply:

    • Labels on in-coming containers must not be removed or defaced.
    • Material Safety Data Sheets must be made available and accessible to employees upon request.
    • Sufficient information and training must be provided to protect employees from hazards in the event of a spill or leak.

     

    Laboratories
    For laboratory operations, the following aspects of the Hazard Communication Program apply:

    • Labels on containers are not to be removed or defaced.
    • Material Safety Data Sheets are available and accessible to employees upon request to the YU Science Department (BH-1310) or the Albert Einstein College of Medicine EH&S Office (800 Forchh) or at Albert Einstein College of Medicine (Lobby and 4th floor Forchheimer and 3rd floor of Kennedy Building).
    • Employees are informed of the hazards of these chemicals through an appropriate information and training program.
    • Specific information and procedures for working with hazardous chemicals in laboratories can be found in the University's Chemical Hygiene Plan. Laboratory operations using hazardous chemicals are governed by OSHA's "Laboratory Standard".

     

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    Hazardous Chemical Exemptions:

    The following substances are exempt from the Hazard Communication Standard:

    • Hazardous waste regulated by the Environmental Protection Agency.
    • Tobacco or tobacco products.
    • Wood.
    • Articles which would not emit a hazardous substance if worked upon.
    • Food, drugs, cosmetics, or alcoholic beverages for personal consumption.
    • Consumer or hazardous substances used in the same manner, frequency and duration as they would be by a normal consumer. A Material Safety Data Sheet must be obtained if it is determined that these products are used more frequently than they would be by a normal consumer.
    • Solid drugs such as tablets, capsules, and pills.

     

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    Emergency Response: 

    IF YOU HAVE BEEN EXPOSED TO A HAZARDOUS CHEMICAL, WASH THE AFFECTED AREA WITH WATER FOR AT LEAST 15 MINUTES AND CONSULT A PHYSICIAN IMMEDIATELY.

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    Documentation: 

    The Environmental Health and Safety Office maintains records of each employee's attendance at training sessions.

    For additional information on th hazards in your work area, please contact your supervisor or the Environmental Health and Safety Department:
    (212) 960-0081 - at Yeshiva
    (718) 430-4150 - at Albert Einstein College of Medicine
    (718) 904-3051 - at Weiler Occupational Health Service

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