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Right-To-Know Policy

Introduction

The Federal Occupational Safety and Health Administration (OSHA) 29 CFR 1910.1200 requires employers to provide information regarding hazardous chemicals to employees who may be exposed to such chemicals in the workplace. This policy and its accompanying procedures establish mechanisms to assure compliance with this regulation.

Policy
  1. Responsibility
    1. Program coordination and audit functions shall be provided by Environmental Health and Safety (EH&S).
    2. Responsibilities of departments, supervisors and instructors are as designated in specific sections of the policy.
  2. Hazardous Chemicals

    A hazardous chemical shall mean any element, chemical compound, or mixture of elements and/or compounds which is a physical hazard as defined by OSHA Standard in 29 CFR Section 1910.1200(c) or a hazardous substance as defined by the OSHA Standard in 29 CFR Section 1910.1200(d)(3).

  3. Employees and Students

    This policy applies to employees/students/visiting researchers, etc. who may be exposed to hazardous chemicals in the course of employment, education, or research through any route of entry (inhalation, ingestion, skin contact, or absorption, etc.) and includes potential (e.g., accidental or possible) exposure under normal operating conditions or foreseeable emergencies. Personnel are not included unless their job performance routinely involves potential exposure to hazardous chemicals.

  4. Exemptions

    This policy does not apply to:

    1. Any article which is formed to a specific shape or design during manufacturing and does not release or otherwise result in exposure to a hazardous chemical under normal conditions of use;
    2. Products intended for human consumption;
    3. Any food, food additive, color additive, drug or cosmetic, or distilled spirits, wines, or malt beverages;
    4. Laboratory operations regulated by the OSHA Standard "Occupational Exposures to Hazardous Chemicals in Laboratories, 29 CFR Section 1910.1200.
  5. Material Safety Data Sheets
    1. Material Safety Data Sheets (MSDSs) are documents containing chemical hazard and safe handling information prepared in accordance with requirements of the OSHA Standard for such document.
    2. Environmental Health and Safety (EH&S) shall serve as the central repository for MSDSs.
    3. Departments shall request from chemical manufacturers and distributors a MSDS for each hazardous chemical they have inventoried.
    4. Departments shall maintain copies of MSDSs for each chemical they possess and have them available for review by employees or their designated representatives and students.
    5. Departments shall bear the responsibility for providing MSDSs for a hazardous chemical distributed or sold interdepartmentally or outside the University.
    6. Employees or students who desire a copy of the MSDSs for hazardous chemicals to which they may be exposed should contact their supervisor, instructor, or Environmental Health and Safety (X84251). The EH&S website (a pull-down menu on Lehigh's home page) has several links to MSDS sites.
  6. Labels

    Existing labels on containers of hazardous chemicals shall not be defaced. When a hazardous chemical is transferred from the manufacturer's labeled container, the chemical users shall ensure that the new container is labeled using the Hazardous Materials Identification System (HMIS) labeling system.

  7. Chemical Inventories
    1. Departments shall compile and maintain a Chemical Inventory.
    2. The Chemical Inventory shall be updated annually and more often if necessary.
    3. The chemical inventory shall be readily available to employees and their representatives. New or newly assigned employees shall be made aware of the Chemical Inventory before working with hazardous chemicals or before working in an area containing hazardous chemicals.
    4. Chemical Inventories shall be submitted to EH&S in the format specified by EH&S each year and whenever updated.
    5. Chemical Inventories shall be retained by EH&S for 30 years.
  8. Emergency Information

    Each year and whenever updated, Departments, Centers and Institutes shall provide Environmental Health and Safety with the name(s) and the telephone numbers of knowledgeable representatives who can be contacted in case of emergency.

  9. Training
    1. Departments shall develop employee and student training programs for specific chemicals in their department.
    2. EH&S will offer generic training on classes of chemicals annually. (Graduate Student Orientation 2X/year) and periodically throughout each semester.
    3. Each department where any employee may be exposed to hazardous chemicals under normal operating conditions or foreseeable emergencies shall provide, at least annually, an education program for employees using hazardous chemicals. Additional information shall be provided whenever the potential for exposure to hazardous chemicals is altered or whenever new and significant information is received by the department concerning the hazard of a chemical. New or newly assigned employees shall be provided training before working with hazardous chemicals or before working in an area containing hazardous chemicals. Training shall be the responsibility of the supervisory staff.
    4. Undergraduate and graduate students registered in courses where they may be exposed to hazardous chemicals under normal operating conditions or foreseeable emergencies shall be provided training before working with hazardous chemicals. Training shall be the responsibility of the instructor. The use of hazardous materials shall be directly supervised by a technically qualified individual.
    5. Students assigned to research projects shall be trained in accordance with the requirements for employees.
    6. The training program shall include the following information, as appropriate: the location of the hazardous chemicals; information on interpreting labels and Material Safety Data Sheets and the relationship between these two methods of hazard communication; an explanation of the acute and chronic effects of the chemicals and instruction on their safe handling, including necessary protective equipment to be used and appropriate first aid treatment; and general safety instructions on handling, clean up procedures and disposal of hazardous chemicals. Generic training on classes of chemicals may be provided when numerous chemicals are involved.
  10. Rights of Employees and Students
    1. Employees and students who may be exposed to hazardous chemicals shall be informed of such exposures and shall have access to the Chemical Inventory and Material Safety Data Sheets for the hazardous chemicals. In addition, employees and students shall receive training on the hazards of the chemicals and on measures they can take to protect themselves from those hazards.
    2. Departments shall provide, at no expense to employees, appropriate personal protective equipment to protect employees from exposures to hazardous chemicals. Students may be required to purchase routine personal protective equipment (e.g., eye protection, lab coats, etc.); however, departments shall provide specialized personal protective equipment (e.g., respirator, face protection, gloves, barrier creams, etc.).
For more information regarding this policy, contact Environmental Health and Safety 610-758-4251.
F&A DEPARTMENTS


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