Hazard Communication

This program is designed to reduce the risk of CSUN employees’ exposure to a wide variety of hazardous substances that may be encountered during their normal job duties.

I. Purpose/Scope

Purpose:  This program is intended to reduce the risk of occupational exposure to hazardous substances and comply with the requirements specified in California Code of Regulations, Title 8, §5194 “Hazard Communication”.

Scope:  The Hazard Communication Program applies to all University employees who have potential for occupational exposures to hazardous substances during their normal job duties.

Exemptions & Exceptions:  This program does not apply to hazardous waste; tobacco or tobacco products; wood or wood products; foods, drugs, or cosmetics intended for personal consumption by employees while in the workplace; retail food sale establishments; and consumer products packaged for distribution.

II. Definitions

Acute:  acute effects usually occur rapidly as a result of short-term exposures, and are of short duration.

Carcinogen:  a substance is considered to be a carcinogen if:

• It has been evaluated by the International Agency for Research on Cancer (IARC) Monographs, Vols. 1-53 and Supplements 1-8, and found to be a carcinogen or potential carcinogen; or,
• It is listed as a carcinogen or potential carcinogen in the Sixth Annual Report on Carcinogens published by the National Toxicology Program (NTP) or,
• It is regulated by OSHA as a carcinogen.

Chronic:  chronic effects generally occur as a result of long-term exposure, and are of long duration.

Corrosive: a substance that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact.

Exposure or Exposed:  Any situation arising from work operation where an employee may ingest, inhale, absorb through the skin or eyes, or otherwise come into contact with a hazardous substance.

Flammable:  A substance that falls into one of the following categories:

• Flammable aerosol:  An aerosol that, when tested, yields a flame or a flashback.
• Flammable gas:  A gas that forms a flammable mixture with air.
• Flammable liquid:  Any liquid having a flashpoint below 100 degrees F (37.8 degrees C) or higher.
• Flammable solid:  Any solid liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard.

Flashpoint:  The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite when tested using approved methods.

Globally Harmonized System of Classification and Labeling of Chemicals (GHS):  Standardized system for classifying and labeling hazardous chemicals.

Hazard Warning:  Any words, pictures, symbols, or combination thereof, appearing on a label or other appropriate form of warning which convey the health hazards and physical hazards of the substance(s) in the container(s).

Hazardous Substance:  Any substance, which is a physical hazard or a health hazard or is included in the List of Hazardous Substances prepared by the Director pursuant to Labor Code section 6382.

Health Hazard:  A substance 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 substances which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system and agents which damage the lungs, skin, eyes, or mucous membranes.

Highly Toxic:  A substance falling within any of the following categories:

• A substance that has a median lethal dose (LD50) of 50 milligrams or less per kilogram of body weight when administered orally.
• A substance that has a median lethal dose (LD50) of 200 milligrams or less per kilogram of body weight when administered by continuous contact for 24 hours with the bare skin.
• A substance that has a median lethal concentration (LC50) in air of 200 parts per million by volume or less of gas or vapor, or 2 milligrams per liter or less of mist, fume, or dust, when administered by continuous inhalation for one hour.

Immediate Use:  The hazardous substance will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred.

Label:   Any written, printed, or graphic material displayed on or affixed to containers of hazardous substances.

Organic Peroxide:  An organic compound that contains the bivalent-O-O- structure and which may be considered to be a structural derivative of hydrogen peroxide where one or both of the hydrogen atoms has been replaced by an organic radical.

Oxidizer:  A substance other than a blasting agent or explosive as defined in section 5237(a), that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.

Physical Hazard: A substance for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.

Pictogram:  A composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category.

Product Identifier:  The name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS.

Pyrophoric: A substance that will ignite spontaneously in air at a temperature of 130 degrees F (54.4 degrees C) or below.

Safety Data Sheet (SDS):  Written or printed material concerning a hazardous substance, which is prepared in accordance with section 5194(g)

Sensitizer: A substance that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the substance.

Signal Word:  A word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in this section are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for the less severe.

Toxic: A substance falling within any of the following categories:

• A substance that has a median lethal dose (LD50) of more than 50 milligrams per kilogram but not more than 500 milligrams per kilogram of body weight when administered orally.
• A substance that has a median lethal dose (LD50) of more than 200 milligrams per kilogram but not more than 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours with the bare skin.
• A substance that has a median lethal concentration (LC50) in air of more than 200 parts per million but not more than 2,000 parts per million by volume of gas or vapor, or more than two milligrams per liter but not more than 20 milligrams per liter of mist, fume, or dust, when administered by continuous inhalation for one hour.

Trade Secret:  Any confidential formula, pattern, process, device, information, or compilation of information which gives its user an opportunity to obtain a business advantage over competitors who do not know or use it.  A trade secret shall not include chemical identity information, which is readily discoverable through qualitative analysis.

Unstable (reactive):  A substance which in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shocks, pressure or temperature.

III. Responsibilities

Environmental Health & Safety (EH&S):

• Establish and update the written “Hazard Communication Program”.
• Advise and assist departments in complying with the program requirements including labeling, Safety Data Sheets (SDS), employee information and training, and record keeping.
• Provide consultation, monitoring, and training support services on matters related to chemical safety.
• Arrange for employee exposure monitoring (as required).
• Provide regular, formal audits for compliance with this Hazard Communication Program.
• Maintain a chemical inventory of hazardous substances on campus using RSS Chemicals.
• Maintain environmental and employee exposure monitoring records.
• Provide employees with exposure records.
• Maintain training records.

Department/College:

• Ensure that all requirements of the Hazard Communication Program have been met before employees are exposed to hazardous substances under normal conditions of use or in a foreseeable emergency.
• Develop procedures to ensure effective compliance with requirements of this standard.
• Provide the resources necessary to ensure that Personal Protective Equipment (PPE) is available for affected employees.
• Develop and maintain a chemical inventory of hazardous substances present in all work areas within the department using RSS Chemicals.
• Share the chemical inventory of hazardous substances present with EH&S using RSS Chemicals.
• If a hard copy of the SDS is not available in the department, ensure employees have online or internet access to the manufacturer's website or generic SDS's for that material.
• Examples include:
• Fischer Scientific Safety Data Sheets
• VWR Scientific Safety Data Sheets
• RSS Chemicals (available to CSUN students & employees)
• Inform employees of the hazards of non-routine tasks.
• Inform outside contractor’s employees who work in areas under department jurisdiction of the hazardous substances to which those employees may be exposed.
• Ensure that all exposure incidents are documented on the Employee Injury and Supervisors Accident Investigation Report, Form 620, and reported to the Environmental Health and Safety Office.
• Ensure that all employees working with or around hazardous materials are trained in methods to detect the presence or release of a hazardous material in the work area. These methods may include reading monitors, interpreting alarms, or observing the appearance or odor of hazardous chemicals when released.

Purchasing & Contracts Administration:

• Purchasing will receive on-line requisitions for hazardous materials created by an “Authorized Individual”.
• If an SDS is required for the product (as noted in a text field) the purchasing agent will ensure the requirement is communicated to the vendor.
• When the SDS is received, Purchasing will forward original SDS to the creator of the requisition.

Employees:

• Understand the applicable components of the Hazard Communication Program.      
• Report any accident, injury or illness, exposure, or spill to their supervisor or EH&S.
• Understand the hazards of the chemical they work with and how to protect themselves (e.g. PPE). 
• Spill/hazard Identification - If continuous monitoring (e.g. oxygen monitor) or other monitoring devices are not present be observant for spilled liquids or powders and unusual odors.
• If a chemical spill occurs, immediately contact Environmental Health and Safety at extension 2401 or Department of Police Services at 911.  Employees should not attempt to clean up a hazardous materials spill unless they have been appropriately trained.
• Use personal protective equipment, including eye protection, gloves, coveralls, respirators, and other protective equipment, as the job requires and as specified by the SDS.
• Post warning signs when hazards, such as ionizing radiation, lasers, flammable materials, biological hazards, mechanical hazards, or when other special hazards exist.

Chemical Manufacturers and Suppliers:

• The manufacturer or supplier is responsible for providing appropriately labeled chemical containers (section IV) and for providing SDSs for all chemicals supplied. 

IV. Labels & Safety Data Sheets

Labels

The manufacturer, importer, or distributor shall ensure that each container of hazardous chemicals is labeled, tagged or marked with the following information:

• Product identifier
• Signal word
• Hazard statement(s)
• Pictogram(s);
• Precautionary statement(s); and,
• Name, address, and telephone number of the manufacturer, importer, or other responsible party.
• If hazardous substances are transferred from the original container to a secondary portable container the secondary container must be labeled with the following information, at a minimum:
• Identify of the hazardous substance using the full name (in English) of the substance. Chemical symbols or abbreviations are not sufficient.
• Hazard Statement providing the primary health and/or physical hazard(s) of the hazardous chemical through the use of words, pictures, symbols, or any combination of these elements.
• Secondary portable containers are not required to be labeled if it is intended for immediate use by the employee who performs the transfer.  (OSHA Quick Facts - Laboratory Safety Labeling and Transfer of Chemicals) 
• Labels shall not be removed or intentionally defaced.

Safety Data Sheets (SDS)

Each area shall maintain copies or have access to the required safety data sheets for each hazardous chemical in the workplace, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s).  Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.

Each safety data sheet shall be in English and shall contain the following information (using the specified section numbers and headings):

Section 1, Identification

Section 2, Hazard(s) identification

Section 3, Composition/information on ingredients

Section 4, First-aid measures

Section 5, Fire-fighting measures

Section 6, Accidental release measures

Section 7, Handling and storage

Section 8, Exposure controls/personal protection

Section 9, Physical and chemical properties

Section 10, Stability and reactivity

Section 11, Toxicological information

Section 12, Ecological information

Section 13, Disposal considerations

Section 14, Transport information

Section 15, Regulatory information

 Section 16, Other information, including date of preparation or last revision.

V. Training & Employee Procedures

Information and training on hazardous chemicals in the work area shall be provided at the time of their initial assignment, and whenever a new hazard is introduced into the work area.  Information and training may relate to general classes of hazardous substances to the extent appropriate and related to reasonably foreseeable exposures of the job.

Information and training shall consist of at least the following topics:

• The requirements of this section.
• Any operations in their work area where hazardous substances are present.
• Physical and health hazards of the substances in the work area, and the measures they can take to protect themselves from these hazards.  This includes specific procedures the employer has implemented to protect employees from exposure to hazardous substances, such as appropriate work practices, emergency procedures, and personal protective equipment to be used.
• The hazard communication program developed by the employer, including an explanation of the labeling system and the safety data sheet, and how employees can obtain and use the appropriate hazard information.
• Employees shall be informed of their right:
• To personally receive information regarding hazardous substances to which they may be exposed;
• For their physician or collective bargaining agent to receive information regarding hazardous substances to which the employee may be exposed;
• Against discharge or other discrimination due to the employee’s exercise of rights afforded pursuant to the provisions of the Hazardous Substances Information and Training Act.
• Whenever employer receives a new or revised material safety data sheet, such information shall be provided to employees on a timely basis not to exceed 30 days after receipt.

VI.   Resources/References

• California Code of Regulations Title 8, Section 5194
• OSHA Quick Facts - Laboratory Safety Labeling and Transfer of Chemicals
• Fischer Scientific Safety Data Sheets
• VWR Scientific Safety Data Sheets
• RSS Chemicals (available to CSUN students & employees)

VII. Revision Record

REVISION	CHANGES	DATE
4.0	Add SDS and new labeling requirements.	December 2013
4.1	Format changes, migrate to web one.	January 2014
4.2	II Definition, Environmental Health & Safety (EH&S), Employees, Safety Data Sheet (SDS) and V. Training and Employee Procedures format update.	June 2018
4.3	Minor revisions and add online SDS links.	February 2019
4.4	Reference to the Campus chemical inventory, secondary portable container labeling, spill detection.	August 2019
4.5	Minor revision and links updated.	October 2022
4.6	Added RSS Chemicals information, added exposure monitoring training to department/college responsibilities, and updated secondary container labelling requirements	December 2023