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Hazardous Materials Management

A. Policy 

The University, in accordance with its overall Environmental Health and Safety Policy, recognizes the significant safety concerns posed by the handling, storage and disposal of hazardous materials. The University requires each department to comply with federal, state, and local safety laws and regulations, in addition to generally accepted safety procedures and practices. Departmental safety procedures and programs are subject to review, coordination, and inspection by Environmental Health and Safety and/or federal and state agencies

B. Hazardous Materials Defined 

A hazardous material, as defined IHMM (Institute of Hazardous Materials Management) is any item or agent (biological, chemical, radiological, and/or physical), which has the potential to cause harm to humans, animals, or the environment, either by itself or through interaction with other factors. In addition, the University shall follow generally accepted standards established by the American Conference of Governmental Industrial Hygienists in its annual publication Threshold Limit Values and Biological Exposure Indexes. 

C. Authority and Responsibility 

Environmental Health and Safety

  • Environmental Health and Safety will distribute applicable federal, state, and local laws, regulations and ordinances to each Department.
  • The Director of Environmental Health and Safety shall serve as the Chemical Hygiene Officer who will be responsible for the development and implementation of a laboratory safety and hazardous materials management policy within the Science Departments.
  • The Director of Environmental Health and Safety shall coordinate compliance with these laws, regulations and ordinances and shall act as liaison with outside agencies in conjunction with appropriate University departments.
  • Environmental Health and Safety shall conduct regular inspections and audits of areas, and shall forward deficiency reports to the Principal Investigator Responsible Official, Chair of appropriate department, or to the University Safety, Security and Health Committee. 

Physical Plant Office 

  • The Physical Plant Office shall identify personnel responsible for developing and implementing safety and hazardous materials management policies within their department and to coordinate these activities with Environmental Health and Safety.
  • The Physical Plant Office should develop a self-inspection program to document its Safety Data Sheets (SDS) and Personal Protective Equipment (PPE) to be easily accessible to personnel. An outline of the inspection program is to be filed with Environmental Health and Safety. 

Science Departments (Chemistry, Biology, Geo-Sciences, Physics, & Engineering)

  • The Science Departments shall identify a Radiation Safety Officer responsible for the development and implementation of a radiation safety program. A copy of the management program shall be filed with the Environmental Health and Safety Office. 
  • The Science Departments should develop a self-inspection program to document its activities.  An outline of the inspection program is to be filed with the Environmental Health and Safety Office.

Art/Art History Department 

  • The Art/Art History Department shall identify personnel responsible for developing and implementing safety and hazardous materials management policies within the Art/Art History Department, and to coordinate these activities with the Environmental Health and Safety Office. 
  • The Art/Art History should develop a self-inspection program for the Art/Art History Department to document their activities. An outline of the inspection program is to be filed with the Environmental Health and Safety Office. 

Human Resources 

  • The Human Resources Office shall incorporate Environmental Health and Safety policies and procedures within the University Personnel Manual. 
  • The Human Resources Office shall identify those personnel classifications exposed to hazardous materials and include this information in the position description for those classifications. 

Other Departments

  • Each Department chairperson or director shall be responsible for developing and implementing a safety and hazardous materials management program within their assigned departments as appropriate and for coordinating these activities with Environmental Health and Safety. 
  • Each Department chairperson or director should develop a site-specific program as appropriate to document their activities. An outline of the inspection program is to be filed with Environmental Health and Safety. 

D.  Inspection Procedures

  • Environmental Health and Safety shall develop a system of general inspection practices (e.g. laboratories and facilities) and procedures appropriate to all university areas. 
  • Department heads shall develop their own inspection system that includes practices and procedures. 
  • Faculty members should conduct routine inspections where appropriate in offices, laboratories, research shops and storage areas. 
  • The Physical Plant Office and Environmental Health and Safety personnel should conduct regular inspections in their respective areas of responsibility, 
  • Periodic audit inspections may be conducted by Environmental Health and Safety personnel. 
  • Inspection discrepancies will be corrected on a timely basis and reviewed by Environmental Health and Safety.

E. Purchasing Procedures

  • When purchasing equipment, it is the responsibility of the department, in consultation with the Purchasing Office and the Physical Plant Office, to review those items for safety consideration and to notify Environmental Health and Safety of potential hazards. The following steps should be taken. 
  • Review the equipment before purchasing regarding special maintenance problems, guarding, training needs and the need for protective equipment. 
  • Review the equipment for human factor engineering such as, but not limited to, ventilation, heat and space. 
  • Review the purchase of hazardous chemicals and toxic materials for: (i) possible substitution; (ii) potential storage problems; (iii) potential handling problems and procedures for use; (iv) disposal methods (i.e. explosion proof refrigerator) Equipment requiring unusual or new electrical service should be reviewed by the Physical Plant Office before purchase. 
  • A department safety review should be attached to the Department Purchase Order at the time the item is purchased to insure that a complete record is maintained. 
  • A Safety Data Sheet (SDS) is to be requested for each chemical ordered. A copy of the DPO as well as a copy of any new SDS is to be kept on file within each department and ne easily accessible.

F. Storage Procedures

  • Each department shall implement storage practices and procedures appropriate for the chemicals or hazardous materials being utilized. 
  • Fire-resistant cabinets and safety containers are to be utilized for highly flammable chemicals and materials. 
  • Designated storage areas are to be utilized for those items requiring special handling and segregation. 
  • Containers of all chemicals and hazardous materials are to be labeled properly in accordance with federal, state, local and University standards. 
  • Storage areas are to be marked clearly with warning signs and shall be posted with those notices and licenses required in accordance with federal, state, local and University regulations. 
  • Each department shall maintain complete and accurate inventories of chemicals and hazardous materials on hand annually.

G. Procedures for the Use of Chemicals and Hazardous Materials 

  • Each department as appropriate shall develop written safety procedures concerning the use of chemicals and hazardous materials. The departments documented safety procedures will be a site-specific chemical hygiene plan.
  • The Chemical Hygiene Plan shall:
  • Be incorporated into the training program for new employees and students, and for in-service training for existing staff. 
  • Include information concerning the collection and disposal of chemicals and hazardous materials. 
  • Include information concerning emergency procedures to be followed in the event of an accident or chemical spill. 
  • A copy of the Chemical Hygiene Plan shall be filed with Environmental Health and Safety.
  • Laboratories, workshops and work site areas shall be under the direct supervision or guidance of a technically qualified individual. Generally accepted safety procedures shall be followed in addition to appropriate federal, state, and local laws and regulations. 
  • Emergency and personal protective equipment shall be available during the use of chemicals and hazardous materials. 
  • Safety Data Sheets (SDS) shall be available as a resource convenient to all areas where chemicals and hazardous materials are being used.

H. Procedures for Hazardous Materials Spills

  • Hazardous Materials Spills shall be reported to University Police and Environmental Health and Safety
  • The following steps shall be taken by Personnel if unable to safely contain or clean hazardous material.
  1. Identify the type of spill
  2. Inform supervisor and others in the area about the spill
  3. Call University Police and provide the following information:
    1. Type of spill
    2. Quantity of spill
    3. Building and Room Number
  4. University Police shall contact Environmental Health and Safety and provide aforementioned information about the spill
  • Environmental Health and Safety may contact “outside agency” if hazardous spill is outside their scope of hazardous materials training.
  • Refer to Chemical Hygiene Plan for further information.

I. Procedures for the Disposal of Chemicals and Hazardous Materials

  • Chemical and hazardous material waste disposal shall be conducted in accordance with federal, state, local, and University regulations. Generally accepted laboratory procedures should be followed except where there is conflict with these regulations.
  • Licensing and permits for the disposal of chemicals and hazardous materials shall be coordinated with Environmental Health & Safety. 
  • Contracts with chemical and hazardous material disposal companies shall be coordinated with Environmental Health and Safety. 
  • Each department as appropriate shall identify those materials that require special collection and disposal. 
  • Each department is responsible for the disposal of chemicals and hazardous material waste that it generates. 
  • Chemical and hazardous material waste identified for disposal shall be stored and labeled properly.
  • Departments requiring assistance in identifying, collecting or disposing of chemicals or hazardous material waste shall contact Environmental Health and Safety. 
  • Environmental Health and Safety shall maintain a record of disposal of chemicals and hazardous material waste as required by federal, state, local, and University regulations.
  • Please see Chemical Hygiene Plan for further information on the disposal of chemical and hazardous materials

J. Records and Licensing Procedures 

  • Departments holding federal, state, or local licenses or permits for chemical or hazardous material storage, disposal or use shall file a copy of their license/permit with Environmental Health and Safety. 
  • Departments applying for renewal or termination of licenses or permits for chemicals or hazardous material storage, disposal or use shall coordinate their activities with Environmental Health and Safety. 
  • Each department holding a license or permit requiring the submission of reports showing compliance with the conditions of the licensing or permit shall submit a copy of that report to Environmental Health and Safety. 
  • Annual chemical and hazardous material inventories are to be conducted using the University Chemical Tracking program (aka ChemSW).
  • Safety Data Sheets (SDS) shall be maintained by each department for the chemicals and hazardous materials used or stored in their areas. 
  • Copies of SDSs are to be forwarded to Environmental Health and Safety 
  • SDSs are to be made available upon request to personnel exposed to chemicals or hazardous materials. 
  • Training records shall be kept on all personnel who use chemicals or hazardous materials. These records must include the type of training, dates, name of instructor and signature of the employee.
  • Copies of training records for classified staff are to be stored with Environmental Health and Safety
  • Copies of training records that may be required for faculty or contract employees are to be stored with Environmental Health and Safety. 
  • Copies of Department Purchase Orders (DPOs) for chemicals or hazardous materials are to be stored with Environmental Health and Safety. 
  • Departments shall maintain appropriate medical records for personnel who use chemicals or hazardous materials. 
  • Copies of appropriate medical records that may be required of classified staff are to be forwarded to Environmental Health and Safety and to the Human Resources Office. 
  • Copies of appropriate medical records that may be required of faculty or contract employees are to be forwarded to the appropriate vice president and Environmental Health and Safety. 

K. Training Requirement 

  • Site-specific training for personnel exposed to or utilizing chemicals or hazardous materials shall be included in each department's new employee training. 
  • Environmental Health and Safety shall conduct annual training programs for personnel exposed to chemicals or hazardous materials. 
  • Departments introducing a new chemical or hazardous material category in the workplace shall conduct employee training consistent with the type of hazard. 
  • Faculty shall incorporate safe practices and procedures for the use, storage, and disposal of chemicals and hazardous materials into their curricular or research activities where appropriate. 

L. Emergency Procedures

  • Each department storing or utilizing chemicals or hazardous materials shall develop emergency procedures in conjunction with Environmental Health and Safety. 
  • Each department storing or utilizing chemicals or hazardous materials shall have personnel available to assist in dealing with emergencies, and shall maintain equipment and supplies appropriate to deal with potential accidents or problems. Refer to procedures of hazardous material spills for further information in the Chemical Hygiene Plan