Hazard Communication
(Phone: 443-4132)

SU's Hazard Communication Program

Hazard Communication Training

Hazardous Materials Inventories
- Registering a New Inventory with EHO
- Maintaining an Existing Inventory
- Re-locating an Existing Inventory

Material Safety Data Sheets

Multi-Employer Program

Asbestos Management Program
- Asbestos Awareness - Phase 2 - On-line Training Presentation

Hazard Communication Program

The purpose of Syracuse University's Hazard Communication Program (HCP) is to ensure that employees of the University are provided with information and training on the physical and health hazards associated with hazardous chemicals with which they work or may be exposed to in the normal course of their employment or in a foreseeable emergency.

The Occupational Safety and Health Administration (OSHA) defines a "Chemical" as any element, chemical compound, or mixture of elements and/or compounds." OSHA further defines a “Hazardous Chemical” as any chemical which presents a physical hazard or a health hazard. The University's HCP is the means of conveying this information to its employees. The Environmental Health Office (EHO) is responsible for overseeing and maintaining the University's HCP.

The University's HCP includes training programs to enable supervisors and their employees to determine the hazards of "hazardous chemicals"; and appropriate implementation of protective measures. The HCP consists of a written hazard communication program; a comprehensive inventory of the University's hazardous chemicals; associated Material Safety Data sheets (MSDS); container labeling requirements and other forms of warning.

Hazard Communication Training

Employees of the University who may be exposed to hazardous chemicals during the normal course of employment or in a reasonably foreseeable emergency are expected to fulfill the Basic Hazard Communication training requirement in accordance with the University's Hazard Communication Policy. Because potential exposures to hazardous chemicals are sometimes difficult to identify, University Policy requires all new employees (exempt, non-exempt, temporary, faculty, teaching assistants, graduate assistants, post-doctoral staff paid by the University, work-study students, etc.) to complete Basic hazard Communication Training. Initial employee information and training is provided by the Environmental Health Office. Additional training is provided and documented by the supervisor regarding pertinent and specific information on hazardous chemicals related to the employee's job duties, during a reasonably foreseeable emergency or whenever an associated hazard changes (i.e. MSDS change, job task modification resulting in a greater exposure, etc.). All training should be completed prior to potential exposure to hazardous chemicals.

As new employees are hired, they are assigned a Basic Hazard Communication training date and time by the Office of Human Resources (HR) as part of their New Employee Orientation. The assigned training date can be found with the Orientation Packet distributed by HR, or by consulting Human Resources. Should a schedule conflict arise, other sessions are available. New employees can register for alternate sessions by completing the on-line Hazard Communication Training Registration Form.

Department Heads/Chairs are responsible for ensuring that their employees complete the initial and supervisor level required Hazard Communication training. This also includes any employees who are not hired directly through HR and/or did not participate in HR's new employee orientation process. Departments are responsible for informing employees of a hazardous chemical with which they may work or may be exposed to during the normal course of their employment and review MSDSs and other pertinent information whenever a change in a chemical's hazardous constituent(s) has occurred or whenever there is a change in the health hazard data for a hazardous chemical.

Refresher Training: Employees who use hazardous chemicals on a frequent basis are required to attend annual Hazard Communication training refresher sessions provided by EHO. EHO coordinates these refresher training events.

EHO-provided Hazard Communication Training covers the following information:

• The written Hazard Communication Program
• How to identify chemical(s) containing hazardous constituents
• How to make a physical/health hazard identification
• The role of Material Safety Data Sheets (MSDS)
• How to obtain, use and understand Material Safety Data Sheets (MSDS)
• Labeling Requirements
• Employee Information and Training

Sessions are approximately 45 minutes in length.

Material Safety Data Sheets

One of the requirements of the University's Hazard Communication program is to ensure that, for any hazardous chemical, there is an associated Material Safety Data Sheet (MSDS) readily available to employees and emergency response personnel. An MSDS is an employee's primary source of information on chemical properties, physiological and physical hazards of a product containing hazardous constituents. An MSDS must be "readily available" to an employee prior to use of a hazardous chemical. ("Readily available" is explained in the next paragraph.)

As noted above, if a chemical presents physical and/or health hazards to an employee, an MSDS is required. Reading a container label or packaging material and looking for signal words such as "Danger", "Caution", "Warning", "Toxic", "Hazard", or "Hazardous" signifies that the chemical may present a hazard and that a corresponding MSDS is required in the workplace.

The Environmental Health Office (EHO) is responsible for facilitating the maintenance of a University wide comprehensive inventory and a depository of associated MSDSs for all department registered hazardous chemicals. EHO distributes copies of MSDSs to specific work areas, offices and laboratories for placement in dedicated MSDS binders where these chemicals are used, handled and/or stored. MSDS binders shall be located in an area that is readily accessible and available to an employee during their work shift. Factors that may be appropriate to consider when determining if MSDSs are readily accessible and available may include: Must employees ask a superior or other management representative for the MSDS? Are the sheets maintained at a location that is locked or under conditions where employees cannot refer to them during each work shift?

On going maintenance of the MSDS binder is essential for ensuring safety and compliance in the workplace and is disscussed further in the section below, "Hazardous Chemical Inventories".

Hazardous Chemical Inventories

Registering an Inventory with EHO

Departments are responsible to ensure all senior level individuals (Professors, Principal Investigators, Supervisors, etc.), referred herein as "Senior Occupants" register and maintain an accurate hazardous chemical inventory with EHO in areas under their purview. For inventories that are not currently registered, Senior Occupants will need to complete a New MSDS Inventory Registration Form. As required by OSHA, the University's Hazard Communication Program, in conjunction with its mandatory training, provides employees with pertinent information on any substance containing chemical constituents with which they may work or may be exposed to during the normal course of their employment.

Important Notice to Laboratories: If you are a Principal Investigator responsible for hazardous chemical(s) in a new or existing research/teaching lab and registering your inventory for the first time, it can be done by filling out the Laboratory Registration Form for Principal Investigators.

In either of the above instances, registering a new hazardous chemical inventory is a 2 step process.

Step 1. Once the initial registration form is filled out and submitted, EHO will send out a packet with forms and instructions to the Senior Occupant.

Step 2. Senior Occupants must perform a physical inventory of chemicals in the work area in order to identify which chemicals need to be registered. The following information must be listed on the form provided for each hazardous chemical; the Product Name, Manufacturer's Name and .contact information.

Maintaining an Existing Inventory

For Minor Revisions:

Since hazardous chemical inventories are likely to change, registered inventories must be amended each time a new or different hazardous chemical is introduced into an area. Responsibility is assigned to the Senior Occupant of the area. These small changes are referred to as Minor Revisions. An on-line form (MSDS Inventory - Add Items Form) or a printout of a MS Word version is available to easily facilitate any minor revision.

Annual Review & Update:

Senior Occupants are also required to "audit" their chemical inventories at least annually. The annual review and update is facilitated by EHO by either an email or hardcopy request. Senior Occupants wanting to use the email method should contact the Hazard Communication Coordinator.

Re-Locating an Existing Inventory

Senior Occupants relocating their registered hazardous chemical inventories to another location must inform EHO by submitting a Hazardous Chemical Inventory - Change in Location Form prior to the relocation. A new MSDS binder and associated contents will be created and sent to the new location.

Important Notice to Laboratories: If you are a Principal Investigator of a laboratory and responsible for hazardous chemical(s) in a research/teaching lab, a change in location can be accomplished by updating your information via the Laboratory Registration Form for Principal Investigators.

Multi-Employer Program

The Multi-Employer Workplace Program is a program facilitating the exchange of pertinent hazard communication information in a multi-employer setting at the University. Contracting Department personnel who hire outside employers must provide a Multi-Employer packet to all contractor and subcontractors, advising them of their obligations. Multi-Employer forms regarding hazard communication, procurement and hazard assessments are available on-line at (http://bfasweb.syr.edu/env_hlth/hc/mepinfo.htm#forms). For questions and concerns call 443-9131 or email Garrett Moll at gjmoll@syr.edu.

Syracuse University's Asbestos Management Program

Syracuse University developed and maintains an Asbestos Management Program. The policy is to maintain asbestos found in Syracuse University owned buildings in good condition (not damaged) thru daily inspections. The program's management of asbestos includes the identification of asbestos contain building material, (ACBM) found in a building, labeling ACBM, daily inspection of ACBM, a method of reporting any damaged ACBM for repair, the implementation of specific procedures for floor care and training.

Syracuse University's Asbestos Awareness Training Program has 2 phases. Phase 1 is included in the New Employee Orientation Training Program. Phase 2 is an on-line training program provided by the employee's supervisor to identify ACBM in the buildings where they may work. Phase 2 can be found at the following web site: Asbestos Awareness - Phase 2 - On-line Training Presentation.