Multi-Employer Workplace Program

Multi-Employer Workplace Program Table of Contents

• Policy Statement
• Program Description
• Definitions
• General Procedure for Outside Employers
• Outside Employer and Sub-Contactor Responsibilities
• Work Area Department Responsibilities
• Procuring Department Responsibilities
• Program Forms

Multi-Employer Workplace Policy Statement

It is the policy of Syracuse University to establish and maintain procedures to facilitate the exchange of hazard communication information with outside employers in a multi-employer work environment. This policy was established in accordance with 29 CFR 1910.1200(e)(2) of the Hazard Communication Standard and will be updated as the standard is amended. Outside employers are defined as employers, who are not employees of Syracuse University, yet perform a job or a service on University-operated property (on-site).

Multi-Employer Program Description

In accordance with the Hazard Communication Standard, each outside employer working on Syracuse University operated property (on-site) is responsible for developing, implementing and informing the other on-site employers of hazard communication related information. Under the Multi-Employer Program, each outside employer must provide Syracuse University, and other employer(s) working on-site, with unrestricted, on-site access to material safety data sheets (MSDSs) for all hazardous materials used, handled or stored on-site to which an employee may potentially be exposed to during their normal course of work. Each outside employer working on-site must also ensure that the hazards of chemicals or materials used, handled and/or stored on-site are identified and that information regarding precautionary measures necessary to limit the potential exposure of employees working in the area is exchanged. The Program also defines the labeling system which must be utilized for hazardous materials used, handled and/or stored on-site at Syracuse University.

Definitions

Senior Occupant: The highest ranking member of an organization residing in a work area whose job classification includes overall management, administration and supervision of that work area.

Hazardous Materials: Any material or substance which in normal use can be damaging to the health and well-being of humans. Such materials cover a broad range which may be classified as:

1. Toxic agents including drugs, chemicals, and natural or synthetic products that in normal use are in any way harmful, ranging from poisons to skin irritants and allergens. When improperly used, all materials can be hazardous to man
2. Corrosive chemicals such as sodium hydroxide or sulfuric acid that destroy or otherwise damage the skin and mucous membranes upon external contact or inhalation
3. Flammable materials including:
   • organic solvents
   • finely divided metals or powders
   • some classes of fibers, textiles or plastics
   • chemicals that either evolve or absorb oxygen during storage, thus constituting a fire risk in contact with organic materials
4. Explosives and strong oxidizers such as peroxides and nitrates
5. Materials in which dangerous heat build-up occurs during storage, either by oxidation or microbiological action. Examples are fish meal, wet cellulosics, and other organic waste materials
6. Materials that emit ionizing radiation
7. Biohazards including viruses, bacteria, fungi, parasites or any living organism that can cause a disease in human beings

Precautionary Measures: Control methods prescribed by a specific product's Material Safety Data Sheet, (MSDS), to minimize the hazards related to the use, handling and storage or the material in a work area.

Labels: All hazardous material containers used in this Multi-Employer workplace, whether they are original or reusable, must be appropriately labeled, tagged or marked. If a container is not labeled, tagged or marked, then a generic label, tag or marking must be affixed to the container. The generic label, tag or marking must include:

1. Identity of the hazardous material
2. Name and address of the manufacturer, importer, or other responsible party.
3. Appropriate hazard warnings to include: health hazards, physical hazards, target organs and affects and personal protective equipment.

Labels, tags and markings must be in English, but can be in other languages in addition to English. Labels, tags or marking on hazardous materials must not be removed or defaced.

General Procedure for Outside Employers

Follow these steps to meet program requirements:

STEP 1. Read the Outside Employer and Sub-Contractor Responsibilities.

STEP 2. Complete and submit the Notification of Hazardous Use Form and the Hazard Identification Form to the procuring department at least 72 hours before the start of a project. Ensure completion of all sub-contractor's and contract agent's forms and submit, also.

STEP 3. Establish an accessible on-site depository of material safety data sheets and maintain the Hazardous Materials Log for actual daily usage.

STEP 4. Conspicuously post a Precautionary Measures Bulletin in the on-site work place and fax or courier a copy to the procuring department, as early as possible, but no less than 24 hours before using any material without a specific use date listed on the Hazard Identification Form.

STEP 5. Submit the Hazardous Materials Log for actual materials used to the Environmental Health Office following the completion of the project.

Any change or revision to the information provided must be submitted in writing to the procuring department, as soon as possible. Copies of the completed Hazardous Materials Log will be maintained in the University's Environmental Health Office, (EHO), 029 Lyman Hall in accordance with the Hazard Communication Standard and under the supervision of the Director of EHO.

Outside Employer and Sub-Contractor Responsibilities

1. Obtain information concerning the Multi-Employer Workplace Policy from the Syracuse University procuring department when performing a job or a service on-site at Syracuse University.
2. Ensure that information concerning the Multi-Employer Workplace Policy is conveyed to all of it's sub-contractors and contract agents who will perform a job or a service on-site at Syracuse University.
3. Complete and submit the following forms to the Syracuse University procuring department 72 hours prior to the start of a project:
   • Notification Of Hazardous Materials Use Form
   • Hazard Identification Form(when applicable)
4. Ensure the completion of by it's sub-contractor's or contract agents of all necessary forms and their submission to the Syracuse University procuring department.
5. Maintain an on-site inventory of Material Safety Data Sheets (MSDSs) for the hazardous materials used on-site. Ensure that this location is accessible in the event of an emergency involving the hazardous materials used during the job.
6. Ensure that precautionary measures are taken to ensure that exposures to hazardous materials are controlled as recommended/required by the material's MSDS. Additionally, control of strong or unpleasant odors (which may induce nausea, dizziness, headache or other symptoms of illness and/or affect the well-being, safety or performance of an exposed) is necessary.
7. Post a Precautionary Measures Bulletin as early as possible, but no less than 24 hours before using a hazardous material without a specific use date listed on the Hazard Identification Form. This form must be conspicuously posted in the work area. Additionally, a copy of the Bulletin must be couriered or faxed to the procuring department no less than 24 hours prior to use.
8. Maintain a daily Hazardous Materials Log to record the use and/or storage of any hazardous materials and associated precautionary measures taken. This log must be available on-site for inspection by Syracuse University officials and submitted to the University's Environmental Health Office at the completion of the project.
9. Use manufacturers' labels (or the label format described in the definitions section of this program) on all hazardous materials containers including secondary/temporary containers.
10. Record and maintain MSDSs for all materials used on-site for a minimum of 30 years and provide the depository's location on the Hazardous Materials Log.
11. Inform the Syracuse University procuring department of any changes and/or variations in the above information as soon as reasonably possible.
    

Work Area Department Responsibilities

1. Obtain forms from the procuring department and conduct a Hazard Assessment Form to identify the hazardous materials used, handled and stored in the area prior to the commencement of a project. Submit the proof of assessment to the procuring department.
2. Remove, whenever possible, all hazardous materials which could expose or potentially expose an employee during the course of the project.
3. Complete and submit to the procuring department, the Hazard Identification Form for the hazardous materials that will remain in the area where work is to be performed. Include precautionary measures which must be taken to ensure that exposures to hazardous materials are controlled as recommended/required by the material's MSDS.
4. Inform the procuring department of the location of the MSDS binder for hazardous materials which will remain in the work area and the method of access to the MSDSs. Ensure that the method used eliminates all barriers to access of the information by exposed workers or other employees with possible exposure.
   

Procuring Department Responsibilities

1. Convey information concerning the Multi-Employer Workplace Policy to outside employers hired to perform a job or a service on-site at Syracuse University.
   
2. Inform the outside employers of their responsibility to ensure that exposures to hazardous materials are controlled as recommended/required by the material's MSDS.
3. Ensure the outside employers submit, (prior to the start of the project), the required Multi - Employer Workplace Program Forms including:
   
   
   • Notification Of Hazardous Materials Use Form
   • Hazard Identification Form (when applicable)
   • Precautionary Measures Bulletin
   • Hazardous Materials Log

   
   

4. Ensure that the proper documentation is maintained regarding the exchange of hazard communication information between employers. To facilitate documentation, ensure that a Hazard Assessment Form is completed and subsequently reviewed by the "Senior Occupant" who is responsible for the area where the job or service is to be performed. Ensure that a Hazard Identification Form is completed by the work area department for hazardous materials remaining in the area. Inform the Senior Occupant of their responsibility to ensure that exposures to hazardous materials are controlled as recommended/required by the material's MSDS.
5. Ensure that an exchange of information regarding precautionary measures provided by the outside employers and the department where the work is to be performed takes place when appropriate. A copy of the Hazard Identification Form can be used to provide this information to on-site employers.

Multi-Employer Program Forms

• Notification of Hazardous Materials Use Form: This form must be completed by any outside employer contracted by Syracuse University or sub-contractor hired by an outside employer.
• Hazard Identification Form: This form must be completed by any outside employer or sub-contractor using, handling or storing hazardous materials on-site.
• Precautionary Measures Bulletin: must be conspicuously posted.
• Hazardous Materials Log: This form is a daily record of the on-site use and/or storage of any hazardous materials and their associated precautionary measures.
• Hazard Assessment Form:This form must be completed by the Senior Occupant of the work area to identify hazardous materials used, handled and stored in the work area prior to the commencement of the project.

Last modified on October 25, 2002

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