Hazardous Materials Procurement Program

I.  PURPOSE / SCOPE

• Purpose: To provide written guidance for CSUN Faculty and Staff on how to appropriately purchase hazardous chemicals and materials.
• Scope: To ensure that all applicable trainings, EH&S laws and regulations concerning environmental, facility and human life are recognized and addressed prior to the purchase and arrival of hazardous chemicals and materials here at California State University, Northridge (CSUN).

II.  DEFINITIONS

• Acutely Hazardous: A substance possessing toxic, reactive, flammable or explosive and specifically subject to threshold quantities listed in Appendix A to 29 CFR §1910.1200. 8 CCR § 5189. 
• Acute Toxicity: The ability of a chemical to cause a harmful effect after a single exposure.29 CFR § 1910.1200 Appendix A.
• Authorized End User: person within a department, college, area or shop who has ultimate responsibility for the overall management of the chemicals, personnel handling, and the assigned training within their allocated space or laboratory. In academic settings these individuals are referenced as Principal Investigators (P.I.) and in shop settings these individuals may be recognized as Shop Coordinators.
• CAS Registry Number® (CAS#): a universally recognized unique and unmistakable identifier for chemical substances assigned by CAS Registry, a division of the American Chemical Society.
• Carcinogen: see “Select Carcinogens”
• Consumer Product: products that are used in the workplace in the same manner that any general consumer would use them outside of campus buildings or facilities, i.e.; where the duration, volume and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience.
• DEA Controlled Substance: a drug or chemical whose manufacture, possession, or use is regulated by the jurisdiction of the United States DEA - Controlled Substances Act and the California Uniform Controlled Substances Act, including but not limited to those substances listed in 21 CFR §1308.11-1308.15.
• Explosive: any chemical compound, mixture, or device, the primary or common purpose of which is to function by explosion, i.e., with substantially instantaneous release of gas and heat, unless such compound, mixture, or device is otherwise specifically classified by the U.S. Department of Transportation; see 49 CFR chapter I. The term “explosives” shall include all material which is classified as Class A, Class B, and Class C explosives by the U.S. Department of Transportation, and includes, but is not limited to dynamite, black powder, pellet powders, initiating explosives, blasting caps, electric blasting caps, safety fuse, fuse lighters, fuse igniters, squibs, cordeau detonant fuse, instantaneous fuse, igniter cord, igniters, small arms ammunition, small arms ammunition primers, smokeless propellant, cartridges for propellant-actuated power devices, and cartridges for industrial guns. Commercial explosives are those explosives which are intended to be used in commercial or industrial operations. 29 CFR § 1910.109.
• Extremely Hazardous Substances: chemicals and compounds that could cause serious irreversible health effects from accidental releases, requiring documented emergency planning and notification as stated in 40 CFR § 355.
• Hazardous Materials: biological, chemical, compressed gases, or radiological substances, which if improperly stored, handled, used, or disposed may pose a threat to human health or the environment. 8 CCR § 5194.
• Health Hazard: A chemical that is classified as posing one of the following hazardous effects: Acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); aspiration hazard. The criteria for determining whether a chemical is classified as a health hazard are detailed in Appendix A of the Hazard Communications Standard (Section 5194) and Section 5194(c) (definition of “simple asphyxiant”). 8 CCR § 5191.
• Safety Data Sheet (SDS) formerly known as Material Safety Data Sheet (MSDS): product safety and handling information supplied by the product manufacturer. It is a requirement of the OSHA Hazard Communication Standard that a copy of each chemical's SDS be made available to any person working with or around a hazardous material.
• Occupational Safety and Health Administration (OSHA): federal and state agencies responsible for establishing and enforcing occupational safety and health regulations.
• Particularly Hazardous Substances: a select carcinogen, reproductive toxin, and/or a substance that has a high degree of acute toxicity. 29 CFR § 1910.1450(e)(3)(viii).
• Peroxide forming materials: a class of compounds that have the ability to form shock-sensitive explosive peroxide crystals.
• Procurement Card holder: person within a department, college or other administrative unit who has working knowledge of hazardous materials. This individual will also have working knowledge and understanding of all necessary campus specific documented training, and is authorized to review, and/or purchase hazardous materials including those using University procurement card (PCard) with an approved waiver.
• Procurement Card (PCard) Waiver: a written documented approval for a transaction that requires review by CSUN's Purchasing and Contracts Administration Department prior to purchase. CSUN Procurement Card Handbook.
• Pyrophoric Materials: a chemical in a gaseous state that will ignite spontaneously in air at a temperature of 130 degrees F (54.4 degrees C) or below. 8 CCR § 5194.
• Radioactive Materials: any class of chemical or material where the nucleus of the atom is unstable and emits ionizing radiation spontaneously. US Nuclear Regulatory Commission.
• Regulated Biological Select Agents: Biological agents and toxins that have been determined to have the potential to pose a severe threat to public health and safety, to animal and plant health, or to animal or plant products. Centers for Disease Control and Prevention (CDC).
• Reproductive Toxins: Chemicals which affect the reproductive capabilities including chromosomal damage (mutations), effects on fetuses (teratogenesis), adverse effects on sexual function and fertility in adult males and females, as well as adverse effects on the development of the offspring. 8 CFR § 5191.
• Risk Safety, and Solutions (RSS) Suite: – a system of applications for hazard assessment, hazard communication, chemical inventory and safety inspections of laboratory and shop areas. It was developed by the University of California and is now in use across the CSU system.
• Select Carcinogens: any substance which meets one of the following criteria:
  • It is regulated by Cal/OSHA as a carcinogen; or
  • It is listed under the category, “known to be carcinogens”, in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (1985 editions); or
  • It is listed under Group 1 (“carcinogenic to humans”) by the International Agency for Research on Cancer Monographs (IARC)(Volumes 1-48 and Supplements 1-8); or
  • It is listed in either Group 2A or 2B by IARC or under the category, “reasonable anticipated to be carcinogens” by NTP, and causes statistically significant tumor incidence in experimental animals in accordance with any of the following criteria:
    • After inhalation exposure of 6-7 hours per day, 5 days per week, for significant portion of a lifetime to dosages of less than 10 mg/m3;
    • After repeated skin application of less than 300mg/kg of body weight per week; or
    • After oral dosages of less than 50 mg/kg of body weight per day.

III.  RESPONSIBILITIES

Authorized End User: responsible for providing and documenting appropriate hazard communication training to all users of desired hazardous material, including but not limited to the following:

• Laboratory/Site specific documented training

• Safety Data Sheet review
• Spill response procedures
• Observing appropriate chemical hygiene
• Observing proper labeling, storage and segregation of hazardous materials
• Minimum PPE assignments and usage
• RSS Chemical Inventory uploading and re-certifications
• Hazardous waste generation
• Handling and disposal procedures to all laboratory personnel of hazardous materials before the hazardous materials are purchased.

Department PCard Holder: responsible for adhering to CSUN Purchasing Department Procurement Card Handbook. May assist Authorized End User (i.e., PI/Shop Coordinator) in verifying that all trainings and safety equipment are in place prior to the purchase of desired hazardous materials.

Environmental Health and Safety (EH&S): responsible for the development, implementation and monitoring of the Hazardous Materials Procurement Program.

Colleges and Departments: responsibility of deans, directors and department heads to ensure their respective Colleges and/or Departments comply with the Hazardous Materials Procurement Policy and Procedure, including but not limited to providing the necessary resources and personnel.

IV.  TRAINING

Authorized End Users are required to provide site specific training to all lab/shop personnel that area of the hazardous chemicals/materials. These trainings are to include the following but not limited to:

• Hazard Communication
• PPE Awareness
• Hazardous Material Handling
• Chemical Spill Response
• Hazardous Material Storage Requirements
• Hazardous Material Labeling Requirements
• CSUN Hazardous Waste Management Program
• Risk, Safety & Solutions (RSS) Suite
• CSUN Accident/Incident Procedures, and
• Campus Emergency Procedures

V.  QUALIFYING PURCHASES

Any requested quantities of the following items shall not be purchased on a PCard without prior EH&S consultation and acknowledgement.

• Substances listed on Cal-OSHA’s “The Hazardous Substance List” (See Cal-OSHA, Title 8 §339. The Hazardous Substances List)
• Radioactive Materials (radionuclides or isotopes; See CSUN Radiation Safety Manual)
• DEA Controlled Substances (Requires approval from Research and Sponsored Programs)
• Regulated Biological Toxins and/or Select Agents
• Explosives
• Carcinogens/Potential Human Carcinogens
• Extremely Hazardous Substances
• Pyrophoric materials and compounds
• Peroxides or peroxide forming materials
• Shock Sensitive materials and compounds
• Hazardous commercial products to be used in a laboratory or shop setting
• Radiation emitting equipment, including X-Ray generating devices (i.e., Scanning electron microscopes, DEXA scanners, etc.)
• Laser rated Class III or IV

VI.  PROCEDURES

Online Requisition / Purchase Order

When creating an Online Requisition, enter 10400 in the Class Code Chartfield to identify the expenditure used for internal campus reporting as Hazardous Materials. For additional reference, see CSUN Purchasing Department Creating Online Requisitions Guide.

PCard Purchasing Process via CSUN Purchasing Department

PCards may be used for the purchase of hazardous materials under the following conditions:

• the hazardous materials are infrequently needed, and
• the hazardous materials are available only from specialty vendors, and
• there are no established Blanket Purchase Orders in place with vendors who can supply the majority of a College’s or Department’s hazardous materials need, and
• an approved PCard Hazardous Materials Procurement Request for the hazardous items(s) in in place (see steps below), and
• a current PCard waiver approved by CSUN Purchasing via TopDesk

All hazardous materials requests initiated by Authorized End Users shall be routed to a College or Department PCard holder.

• Step 1 : Submit a PCard Hazardous Material Procurement Request (HMR) Form. **Please note**: Safety Data Sheet (SDS) must be uploaded to the Online Submittal Form.
• Step 2 : Authorized End User will receive an email from Smartsheet asking them to “Accept” or “Decline” the submittal request and to confirm training requirements for all end users. 
• Step 3 : Within 72 hours, EH&S will review the submission. Confirmation email is then sent to the Authorized End User/PI (and separately to the PCard holder, if applicable) with an "HMR" reference number (format: HMR-XX) assigned to the request. This reference number shall be retained by the Authorized End User/PI to include in all future communications regarding this request.
• Step 4: The Authorized End User/PI (or PCard holder, if applicable), may now move forward with the PCard purchasing process (e.g. submitting a TopDesk PCard Waiver request for state PCards). 

VII.  REFERNCES

CSUN Procurement Card Handbook

CSUN Chemical Hygiene Program

ATF, Title 18, USC, Chapter 40 – Importation, Manufacture, Distribution and Storage of Explosive Materials

Cal-OSHA, Title 8 §339. The Hazardous Substances List

Cal-OSHA, Title 8 §5189, Process Safety Management of Acutely Hazardous Materials

Cal-OSHA, Title 8 §5191. Occupational Exposure to Hazardous Chemicals in Laboratories

Cal-OSHA, Title 8 §5194. Hazard Communication

EPA, Title 40 CFR Part 355, Emergency Planning and Notification

EPA, Title 40 CFR Part 355 Appendix A, List of Extremely Hazardous Substances and Their Threshold Planning Quantities

OSHA, 29 CFR, 1910.1200 OSHA Standards, Toxic and Hazardous Substances

OSHA, 29 CFR, 1910.109 OSHA Standards, Explosives and blasting agents

VIII.  FORM / ATTACHMENTS

PCard HAZARDOUS MATERIALS PROCUREMENT REQUEST (HMR) FORM

LIST OF MATERIALS REQUIRING EH&S ACKNOWLEDGEMENT 

IX.  REVISION RECORD