4.0 General

4.1 Hazard Determination

4.1.1 Since OHIO does not manufacture chemical intermediates or compounds. OHIO shall rely on Material Safety Data Sheets (MSDS) from its suppliers to meet the chemical hazard determination requirements of the PERRP Hazard Communication Standard.

4.2 Chemical Inventory, Book, or File

4.2.1 A chemical inventory shall be maintained for each department where hazard communication applies (SEE APPENDIX 1).

4.2.2 A MSDS book (or file) shall be maintained for each department where hazard communication applies.

4.3 Ordering Hazardous Chemicals

4.3.1 No chemical shall be introduced into OHIO facilities without an MSDS for it. MSDS information should be evaluated before the decision to purchase the chemical is made and provisions for safe handling made before purchase.

4.3.2 It is the responsibility of the person ordering the chemical to review the affected department’s MSDS book to insure that there is a current MSDS for the material being ordered.

4.3.3 If no MSDS is found in the department MSDS book then the employee requesting the chemical purchase shall obtain an MSDS from the manufacturer or supplier prior to ordering the hazardous material, place a copy in the MSDS book and supply a copy to EHS for the master MSDS file.

4.3.4 Vendors shall be required to provide an MSDS for the sample product and the receiving party must place the MSDS in the MSDS book where the product is tested prior to permitting the sample into OHIO facilities.

4.3.5 If the product is added to the inventory a copy of the MSDS shall be sent to EHS. Write on it the date and the OHIO Department using the material.

4.3.6 If the sample product is not added to the inventory it's MSDS shall be removed from the departmental MSDS book and archived (add date of use and location of use).

4.3.7 Any supervisor who finds a chemical in non-laboratory inventory but no MSDS must immediately request an MSDS from the manufacturer or supplier by phone or in writing. Once the MSDS is received, a copy shall be sent to EHS Office in order that the master MSDS book and master MSDS list may be updated. The Department Chairman, Supervisor, or Designate shall update the department chemical inventory and MSDS book.

4.3.8 Employees who find that the department MSDS book is not accurate shall immediately notify their Department Chairman, Supervisor, or Designate.

4.4 Receipt of New MSDS

4.4.1 Each product for which a new MSDS is received shall be added to the affected department MSDS book and master MSDS file.

4.4.2 The master chemical inventory shall also be updated immediately.

4.5 Chemicals No Longer In Use, On-Site, or Purchased.

4.5.1 MSDS for chemicals which are no longer purchased, in use, or in OU facilities shall be archived.

4.5.2 The Department Chairman, Supervisor, or Designate shall mark its location of use and date when replaced (see section 4.5.3) on the MSDS and send it to EHS Office to be archived.

4.5.3 If a department phases out a hazardous chemical, it is the department's Chairman, Supervision, or Designate responsibility to remove the MSDS from the department MSDS book and line through the name of the chemical on the departments' inventory list.

4.5.4 The removed MSDS shall be submitted to EHS requesting that the removed MSDS be archived.

4.5.5 EHS shall ensure that all archived MSDS have the location of use noted, date when archived and that they are maintained for at least 30 years.

4.6 Contractors or Other Outside Employers Working in OHIO Facilities.

4.6.1 Any contractor or other outside employer who must bring hazardous materials into OHIO facilities for completion of their work must have copies of their MSDS’s on site, and provide a copy to the affected department chairman or supervision where the work is to take place through their OHIO contact, if requested to do so.

4.6.2 All OHIO project managers shall include the following information for contractors or service employers in their project specifications and/or documents:

  • Where MSD Sheets may be found for chemicals which are in use in specific areas where the work is being done by the contractor.
  • How an MSDS may be obtained if requested by a contractors employee.
  • Information concerning how the OHIO labeling system works, as described in section 4.7.
  • Provide MSDS to contractors supervision for areas in which contractor employees have potential exposure to hazardous chemicals during work activities.
  • Emergency evacuation information from the area in which the contractor’s personnel work.
  • Specific information concerning how hazardous chemicals may be detected if contractor employees become exposed.
  • Hazards associated with unlabeled piping in the area which inadvertently may leak or be punctured from contractors activities.

4.6.3 The above information shall be provided to the contractor prior to commencement of contracted work, by the OHIO Project Manager.

4.6.4 All prime contractors will provide this information to all their sub- contractors.

4.6.5 It is recommended that this information be relayed to each other at the first project meeting at the start of the project.

4.7 Labeling

4.7.1 It is the responsibility of the person who purchased and received the chemical to determine the adequacy of the hazardous chemicals label according to the following criteria:

  • The identity of the hazardous chemical must be on the label.
  • Appropriate hazard warnings, for example:
    • Health Hazard rating
    • Fire Hazard rating
    • Reactivity rating Specific Rating
    • Target organ (primary)
  • Suggested Personal Protective Equipment
  • Symptoms of exposure
  • The name and address of the chemical manufacturer, importer or other responsible party.

4.7.2 NFPA, HMIS, and DOT labeling systems are used on campus. See appendix 4 for overview information on NFPA and HMIS systems.

4.7.3 The person who purchased and received the chemical shall ensure that the MSDS is included in the Department MSDS Book, update the inventory, and forward a copy of the MSDS to the EHS if this had not been accomplished when the material was ordered.

4.8 Labeling Requirements of Articles

4.8.1 "Articles" (see definition section 3.2) received need not be labeled as long as they are not rendered hazardous through manipulation of the article such as welding, grinding or other actions which affect the article and cause it to become hazardous to employees.

Example: A steel I beam is considered an article until it is welded into place. The I beam and welding rod will give off toxic materials through the action of welding. If the end use of an article will render it hazardous then the article must be labeled. OSHA requires, however, that only one label need be provided with the first steel shipment under these conditions.

4.9 Portable Containers

4.9.1 All portable containers are to be labeled. See Appendix 3 for labeling recommendations.

4.9.2 Portable containers of solvent or other chemicals need not be labeled if their contents are fully used by the employee(s) who dispensed it during the shift within which it was dispensed, and if the portable container is under the direct control of the employee(s) at all times.

4.10 Training

4.10.1 Basic training for all employees potentially exposed to hazardous chemicals shall be conducted when they are hired. Records of this training shall be maintained by the employees supervisor/department. This training shall address the following:

  • Material Safety Data Sheets usage, location, availability, and terminology.
  • Hazards associated with the chemicals within the area they work.
  • Specific chemical handling procedures for chemicals employees personally work with.
  • The requirements of the "Hazard Communication Program" (29 CFR 1910.1200).
  • The hazards of non-routine jobs (such as certain maintenance operations).
  • The labeling system and its interpretation.
  • The methods an employee may use to detect the presence of a hazardous chemical or the spill of such a chemical and the measures an employee may take to protect himself from these hazards (i.e. personal protective equipment, work practices, and emergency procedures).
  • Also any methods that OHIO has used to evaluate employee exposures during normal working conditions, such as exposure monitoring or other pertinent methods.
  • Procedures for conducting “non-routine” tasks safely.

4.11 Transferred Employees

4.11.1 An employee who transfers to a new department shall be trained using the training outline found in section 4.10.

4.12 Periodic Re-Training

Periodic retraining is recommended by EHS and required if new materials are brought into the workplace.