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Hazardous Chemical Communication Plan

Purpose
Definitions
Policy
Clayton State University Right to Know Coordinator
Procurement of Hazardous Laboratory Chemicals
Safety Data Sheets (SDS)
Container Labeling
Secondary Container Labeling
Unlabeled Containers
New Employees
Employees Handling Hazardous Chemicals
Documentation of Training
Training for Increased Hazard
Annual Retraining
Posters
Supervisory Responsibilities
Informing Contractors
Hazardous Chemical Inventory Lists

Purpose

In order to comply with the Georgia Public Employees Hazardous Chemical Protection and Right to Know Act of 1988 as amended, Georgia Department of Labor Chapter 300-3-19 Public Employee Hazardous Chemical Protection and Right to Know Rules, and the University System of Georgia Hazardous Chemical Protection Communication (Right to Know Plan), this written Hazardous Chemical Protection Communication Plan is established for Clayton State University.

This information is provided for compliance with the rules/regulations stated above to ensure the safety of all Clayton State University employees who work with hazardous chemicals in their work areas.

Definitions

MEMBER UNIT means any of the 35 colleges and universities governed by the Board of Regents of the University System of Georgia. For the purpose of this plan, it specifically refers to Clayton State University.
MEMBER RIGHT TO KNOW COORDINATOR means an individual who is assigned the responsibilities associated with that title in the written member unit Hazardous Chemical Communication Plan. For the purpose of this document, the Right to Know Coordinator for Clayton State University is Svetlana Soroka at (678) 466-4244.
UNIVERSITY SYSTEM RIGHT TO KNOW COORDINATOR means the individual who is assigned the responsibilities for all 35 colleges and universities governed by the Board of Regents of the University System of Georgia.
WORK AREA means a room inside a building or structure, an outside area, or other defined space in an area where hazardous chemicals are produced, stored, or used and where employees are present in the course of their employment.
WORKPLACE means an establishment or business of an employer at one geographic location at which work is performed by an employee and which contains one or more work areas. In the case of an independent contractor or subcontractor, the workplace shall be defined as all work areas wholly owned or controlled by such independent contractor or subcontractor. For the purpose of this plan, the term workplace refers to all property of Clayton State University
CONTRACTOR means any individual and/or company that will be conducting work on the property of Clayton State University. The term contractor includes all

Policy

All work units of Clayton State University are included within this program. The written program is available for review located at: View the Hazardous Chemical Plan.

Clayton State University Right to Know Coordinators

The HR Recruitment & Training Manager is responsible for:

Resolve questions regarding the applicability of the Georgia Department of Labor Chapter 300-3-19 rules to work areas at Clayton State University;
Make arrangements for and/or provide appropriate and adequate Right To Know training to all employees of Clayton State University, as well as additional Right To Know information provided in the employee handbook;
Ensure that employee training and notification of the use of hazardous chemicals in the work area(s) are adequately documented in each employee’s personnel file;

The EHS Coordinator is responsible for:

Act as liaison between the University System Right To Know Coordinator and Clayton State University on hazardous chemical issues;
Ensure that a written workplace-specific hazard communication plan be developed for Clayton State University that will include a list of hazardous chemicals used, stored or manufactured at Clayton State University and will be made available to all employees;
Disseminate updated information so that all employees of Clayton State University will have access to current Safety Data Sheets (SDS) for hazardous chemicals used in their work area, via their supervisors;
Ensure that employees are made aware of and are properly trained in the uses and hazards of the chemicals to which they are exposed in their work area(s);
Ensure that employees are provided with adequate personal protection equipment, and receive adequate training in the use and maintenance of this equipment for their hazardous chemicals in their work area(s);
Accumulate hazardous chemical inventory information for Clayton State University;
Annually review the hazardous chemical labeling practices of work areas that use secondary storage containers.

Procurement of Hazardous Laboratory Chemicals

Any person procuring a hazardous laboratory chemical must contact the Laboratory Manager(s) at (678) 466-4865 or 4868 prior to the purchase for her review and approval.

It is the responsibility of Laboratory Manager & Safety Officer to approve the purchase to determine whether a chemical product used is a hazardous chemical under the law.

Safety Data Sheets (SDS)

A central file of Safety Data Sheets (SDS) are maintained at the Department of Public Safety in the Student Center and are available to supervisors and employees 24 hours a day through the Department of Public Safety.

Container Labeling

Any person receiving hazardous chemicals will ensure that all containers:

Are clearly labeled as to the contents;
Display the appropriate hazard warnings;
List the name and address of manufacturer.

Secondary Container Labeling

The supervisor in each section will ensure that all secondary containers are labeled with either an extra copy of the original manufacturer’s label or with a label containing both the identity of the contents and, either an NFPA or GHS hazard warning label that is PROPERLY FILLED OUT.

If the secondary container is intended only for short-term storage (less than one week), it shall be labeled at minimum with the name of the contents and the date the container was last filled. Vials and test tubes may have hazard labels affixed to the rack or container in which they are held so long as every vial or test tube in the rack or container presents the same hazard.

Unlabeled Containers

If an employee finds a container in the work area that is unlabeled or carries a defaced label and is thought to contain a hazardous chemical, the employee will immediately notify a supervisor. If the supervisor is unable to identify the container/contents, the EHS Coordinator will contact the Laboratory Manager & Safety Officer for assistance.

New Employees

As a part of the new employee orientation, all new employees will receive Basic Right To Know training in basic hazardous chemical protection. This training provides an overview of the hazardous chemical protection laws, regulations, and policies in place in the University System, and a summary of employee rights in hazardous chemical protection. Basic training may include the online training program, Right to Know Basic Awareness Training, (currently at web address: http://www.usg.edu/ehs/) or viewing of the video Your Right To Know as approved by the Department of Labor for a hazardous chemical protection program. Any additional Right To Know policies for Clayton State University will be provided at this time. Clayton State University Director of Human Resources will ensure that acknowledgement of training is maintained in the employee’s personnel file located in the Office of Human Resources, Clayton State - East, 5823 Trammell Road, Morrow, GA 30260.

Employees Handling Hazardous Chemicals

Employees whose job functions will require routine exposure to any hazardous chemical must receive chemical specific training in addition to basic Right-To-Know training. This training must be provided at the time the employee is initially assigned to the workplace or job function requiring hazardous chemical exposure.

At a minimum, chemical specific training must include:

Any hazardous chemical present in the work area;
Information on the physical and health effects of the chemical(s);
Methods and observation techniques used to determine the presence or release of the chemicals in the work area;
How to lessen or prevent exposure to these chemicals by proper work practices and use of personal protection equipment;
Emergency procedures in the event of exposure;
Procedures for safe disposal of waste chemicals;
Proper notification procedures in the event of a spill or exposure

Documentation of Training

A record of BASIC TRAINING and/or CHEMICAL-SPECIFIC TRAINING will be maintained by the HR Recruitment and Training Manager. NOTE: Training completed via the web-based training is forwarded automatically via email to the HR Recruitment and Training Manager and is also maintained by the OIIT office, USG. Training records are required to be maintained for three years, 300-3-19-.03(4)(a).

Training for Increased Hazard

Prior to the introduction of any new chemical hazard or significant increase of an existing hazard in a work area, the supervisor of any affected employee must ensure that additional CHEMICAL-SPECIFIC TRAINING is completed and written documentation is completed. Written documentation for each employee completing the training will be forwarded by the supervisor to the Director of Human Resources.

Annual Retraining

Employees whose job functions require routine exposure to any hazardous chemicals must be retrained at least annually on the hazards associated with the chemicals to which they may be exposed.

Posters

Posters describing the employee’s right to know about hazardous chemicals should be prominently posted where they are visible to all employees on a routine basis.

The content of these posters is as specified in Chapter 300-3-19-.03(5)(b).

Supervisory Responsibilities

Department heads are responsible for ensuring that all employees are advised of any hazardous chemicals in their work area(s), are provided with the appropriate training by the employee’s immediate supervisor, and that proper documentation is filed.

The EHS Coordinator is responsible for ensuring that all hazardous chemicals remaining on Clayton State University property as a result of the departure of an employee or the vacating or reassignment of an assigned work area will be managed in accordance with appropriate procedures.

Informing Contractors

Any contract with Clayton State University which may involve hazardous chemical exposure WILL REQUIRE THE CONTRACTOR TO:

Notify the work area supervisor at Clayton State University at least 30 days prior to the commencement of work of any hazardous chemical that will be used or stored at the worksite by the contractor. The 30-day requirement will be waived in the event of an emergency or for work commencing in less than 30 days. Upon notification, the supervisor will:
- Disseminate this information to all Clayton State University employees whose work area is within the worksite;
- Obtain SDSs from the contractor for the hazardous chemical(s) to be used at the worksite and ensure that they are available to all employees during the contractor’s presence and forward a copy to the EHS Coordinator.
- Obtain documentation from the contractor that its employees have been provided with the proper information and training on hazardous chemicals being used by the contractor at the worksite;
- Notify the EHS Coordinator as to the specific location of the worksite, chemicals being used by the contractor, methods the contractor will use to secure the hazardous chemicals at the worksite, dates chemicals will be present on the property of Clayton State University, and the business address of the contractor performing the work.

Hazardous Chemical Inventory Lists

As a part of the Employee Right to Know Act of 1988, the maintenance of Safety Data Sheets (SDS) is required to ensure that basic chemical hazard information, initial first aid treatment and storage requirements for hazardous materials are immediately available. Catalogs of material data safety sheets are maintained in the Department of Public Safety for immediate access by Officers in the field and for all employees upon request.

Georgia law requires chemical inventories to be physically reconciled twice each year and submitted in June and December to the Board of Regents. Each department head will provide EH&S an inventory of chemicals present in their work areas. The inventory will include: a list denoting the name, manufacturer, quantity, exact location of the chemical, and denote each chemical as the following hazards; flammable, explosive, combustible liquid, corrosive, reactive, oxidizer, toxic, water reactive, pyrophoric or an organic peroxide.

The EHS Coordinator will provide an inventory of all hazardous chemicals present on the Clayton State University campus to the University System Right to Know Coordinator in January and July of each year. The EHS Coordinator will make this list available to all employees of Clayton State University upon request.

Availability of this list is required as part of this written Hazardous Chemical Protection Communication Plan.