Hazard Communications



Originator:  Edmund Sullivan 
June 1995

Reviewed:     July 2006


Section:                        Page:

1.0        Scope and Purpose               2
2.0        Availability                   2
3.0        Material Safety Data Sheets           3
4.0        Container Labeling               5
5.0        Employee Information and Training      5
6.0        Hazards on Non-Routine Task           6
7.0        Contractor Information               7
8.0        Contractor Hazard Communication           7
9.0        Applicable Documents             11

Appendix  A    29 CFR 1910.1200 Hazard Communication
Appendix  B        Inventory List

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1.0    Scope and Purpose

1.1    In November 1983, OSHA Regulation 29 CFR 1910.1200 was
promulgated to ensure that the hazards of all chemicals
produced or imported by chemical manufacturers or importers
are evaluated, and that information concerning their hazards
is transmitted to employers and employees.

1.2    Department Chairs/Managers whose operations involve the use of hazardous
chemicals are required to establish a program to communicate
these hazards to their employees.  The communication is to be
accomplished by:

1.2.1    Developing a written program that is available to all
employees who may be exposed to hazardous chemicals as
part of their normal job function or in a foreseeable

1.2.2    Obtaining Material Safety Data Sheets (MSDS's) for the
hazardous chemicals used and making them available to

1.2.3    Labeling all chemical containers so as to identify the
contents and provide appropriate hazard warnings.

1.2.4    Providing information and training to employees
concerning the potential health and physical hazards
of the chemicals they work with or are otherwise
exposed to.   Environmental, Health & Safety  (EH&S)
can assist you with compliance.
1.2.5      Students should also be made aware of the hazards associated
with working with chemicals and instructed in what appropriate
personal protective equipment is appropriate for the work being performed.

1.3    This document outlines the procedures that will be followed at
Middlebury College to comply with these provisions.  See Appendices A
for the full text of  29 CFR 1910.1200.

2.0    Availability

2.1    Copies of the written program, the Middlebury College hazardous chemical
list, and all MSDS's are available for review in the appropriate departments.
MSDS's not available for hazardous chemicals shall be reported to EH&S
so appropriate action can be taken to obtain the MSDS.

2.2    Copies of the MSDS's for the chemicals in a given work area
Should be available in that area.  Department Chairs/Managers and supervisors are
responsible for ensuring that all MSDS's are on file.

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3.0    Material Safety Data Sheets

3.1    All new chemical purchases must include an MSDS with the delivery
of the new chemical.  Any individual wanting to order a new chemical, including  
samples for evaluation must:

3.1.1    Obtain an MSDS from the product manufacturer,
distributor or vendor.

3.1.2    Make sure that all safety precaution relating to the chemical
have been met.  Refer any problems to EH&S.

3.1.3    If appropriate, EH&S can review the MSDS for completeness and
evaluate the potential hazards of the chemical as proposed for use.

3.1.4       The Chemical Hygiene Officer may perform these duties in  Bicentennial        

3.2            The department chair/manager or /designee is responsible for reviewing for 
completeness  all MSDS's under their control.  EH&S may assist with this   
procedure  which includes:

The review any MSDS  sheets for the department. 
The reviewer will rely upon health and physical 
hazard determination performed by the chemical manufacturer
or importer.  The reviewer will evaluate potential hazards of
the chemical as proposed for use and specify any necessary control measures.

3.3 The reviewer will review all MSDS's for compliance with VOSHA requirements. 
If a MSDS is found to be incomplete, another  must be requested from the supplier of the  
product.  MSDS's are not to be altered by any college  personnel.  As a minimum,
all MSDS's must provide the following information.

3.3.1    The identity of the product as used on the label.

3.3.2    The chemical or common name of each constituent which
pose a health hazard or comprises at least 1.0% or
more of the mixture with the corresponding chemical
abstracts service (CAS) number.

3.3.3    The chemical or common name of any constituent known
to be a carcinogen if it comprises  .1% or more of the

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3.3.4    Provide the chemical or common name of each constituent
which poses a physical hazard.

3.3.5    The physical and chemical characteristics of the

3.3.6    The physical hazards of the chemical.

3.3.7    The health hazards of the hazardous chemical including
signs and symptoms of exposure and any medical
conditions which may be aggravated by exposure.

3.3.8    The primary routes of entry.

3.3.9    The OSHA Permissible Exposure Limit (PEL), the American
Conference of Governmental Industrial Hygienists
Threshold Limit Value (TLV) or any other exposure
limit recommended by the manufacturer or importer
preparing the MSDS.

3.3.10    Whether the hazardous chemical is listed in the
National Toxicology Program (NTP) Annual Report on
Carcinogens or has been found to be a potential
carcinogen in the International Agency for Research
on Cancer (IARC) Monographs, or by OSHA.

3.3.11    Any applicable precautions for safe handling and use
including information pertaining to hygiene practices
and procedures for clean up of spills and leaks.

3.3.12    Any applicable control measures including appropriate
engineering controls, work practices and personal
protective equipment.

3.3.13    Emergency and first aid procedures.

3.3.14    Date of preparation of the MSDS or last revision to
the MSDS.

3.3.15    The name, address, and telephone number of the
preparer of the MSDS who can provide additional
information on the hazardous chemical and appropriate
emergency procedures.

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4.0    Container Labeling

4.1    All containers of hazardous chemicals received from the vendor
must be labeled as to clearly identify the contents, provide
an appropriate hazard warning, and list the name and address
of the manufacturer.

4.2    Manufacturer labels on containers of hazardous chemicals shall
not be removed or defaced.

4.3    All in-house secondary containers must be labeled with the
product or chemical name, appropriate hazard warnings, and
first aid information.  Managers and supervisors in each work
area are responsible for ensuring that all secondary
containers are labeled.

4.4    All stationary equipment, degreasers, storage tanks etc., must be labeled to identify the
hazardous chemical(s) contained therein and provide appropriate
hazard warnings.  Managers and supervisors in each work area
are responsible for ensuring that all stationary process equipment is labeled.

4.5    Each department will be responsible for providing all the appropriate
labels for in-house containers and stationary process equipment.  EH&S
can provide assistance in obtaining these labels.

5.0    Employee Information and Training

5.1    Department Chairs/Managers are responsible for seeing their employee receive hazard
communication training and  retraining when required.   Initial training will be 
conducted at new employee safety orientation.   Managers must make arrangements
with EH&S for any employee(s) not currently trained.

This training and information will be provided in cooperation with area supervisors. 
The program will vary depending upon the employee groups being trained, but will, as  
a minimum, consist of the following:

5.1.1    An overview of the hazard communication requirements as
contained in 29  CFR 1910.1200 and the location and
availability of the written program and MSDS's.

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5.1.2    An explanation of the physical and health hazards
associated with chemicals use and how to locate the information on theMSDS.

5.1.3    Methods and observation workers can use to detect the
presence of a hazardous chemical.

5.1.4    Specific procedures that are used to reduce or prevent exposure
to hazardous chemicals.

5.1.5    An explanation of the labeling system used at the college,
how to read and interpret MSDS, and how employees can
obtain and use the appropriate hazard communication

5.2    Department Chairs/Managers and supervisors in each work area are responsible for
seeing that initial training  is conducted for their employees, and retraining
when new hazardous chemicals are introduced into the workplace.

5.3    Employees and contract workers shall receive hazard
communication training and information at the time of initial
assignment and whenever a new hazard is introduced into the
work area.

5.4    MSDS's shall be retained in each department.  Copies shall also be kept in
a central location in Public Safety.

5.5    Department Chairs/Managers and supervisors in each work area are responsible for
ensuring that all employees in that area have received hazard
communications training.

6.0    Hazards of Non-Routine Tasks

6.1    Employees required to perform non-routine tasks involving the
use of hazardous chemicals or potential exposures to hazardous
chemicals will be provided necessary information and training
prior to performing the task by a qualified individual approved
by the supervisor or EH&S..

6.2    It is the responsibility of the manager and supervisor
arranging for the non-routine task to inform EH&S prior to
performance of the work if additional employee training is needed.

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6.3    Non-routine tasks include, but are not limited to, such
activities as degreaser cleaning, exhaust duct removal, boiler
cleaning, etc.

7.0    Contractors Information

7.1    All contractor employers with employees working at the college
will be provided information regarding the chemicals they may
encounter while in the facility. 

7.2    The manager or supervisor arranging for the contractor services
is responsible for providing the contractor with a copy
of  appropriate MSDS's or bringing the contractor to EH&S
for this information prior to the start work.

7.3    A copy of the information in Section 8.0 has also been included
as an exhibit to the Contractor Agreement and is thereby                   (for future use)
available to the contracting employer.

8.0    Contractor Hazard Communication

8.1    This information is provided in compliance with the VOSHA Hazard
Communication Standard 29 CFR 1910.1200.  It provides a
description of any hazardous chemicals that contractor
employees may be exposed to throughout  Middlebury College's
operations and recommendations or campus rules regarding appropriate protective 
measures.  For the purpose of this attachment, contractor employees shall
include any contract workers and/or temporary workers.

8.2    It is the responsibility of the contractor to inform and train
his employees assigned to Middlebury College as to the contents of this Exhibit.

8.3    Contractors are required to submit to their College host or Purchasing
Agent, Material Safety Data Sheets and amounts for each
hazardous material to be utilized by the contractor.  This
information must be submitted before work begins.  Hazardous
materials shall include any solid, liquid, or gaseous substance,
including paints and oils for which an MSDS is required under
state or federal regulations.

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8.4    The Middlebury College EH&S is the designated contact
for any issues surrounding this Exhibit.

8.5    Certain areas within the college require the use of
personal protective equipment.  Contractors are required to
provide their employees with any necessary personal protective
equipment.  The areas and the required equipment are listed

8.5.1    General Campus                                   Appropriate PPE when working with 
chemicals (safety glasses, gloves).

8.5.2    Bicentennial Hall                                      Safety glasses, hand protection. See
work area supervisor prior to 
starting work for specific PPE.

8.5.3    Respiratory protective equipment is neither required
nor recommended in the chemical use areas under normal
operating conditions.

8.6    Working on certain equipment or materials in the Bicentennial Hall
may present special potential hazards.  Examples are
exhaust ducts and fans, waste chemical plumbing,
and gas lines.  The nature of the potential hazard will vary
but may involve exposures to corrosives, solvents, gases
metals and/or unspecified reaction products.  Potential fire
and explosion hazards may also exist when performing such work.

8.7    All work involving these special potential hazards must first
be cleared through the EH&S and work area supervisor
for determination of the appropriate precautions,
controls and/or personal protective equipment that may be
necessary for the particular job.

8.8    Listed below are the areas in the college where
chemicals are used or stored and the class of chemicals that
may be found in those areas:

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8.8.1    Service Building (Facilities)- Shipping/Receiving, Model
Shop, Stockroom, Plumbing & Electricians Room, Custodian Dept.

Class            Examples

Acids            Sulfuric Acid
Bases            Sodium Hydroxide
Metals            Aluminum, Stainless Steel
Solvents                        Isopropyl Alcohol
Oils                                         Lube

8.8.2    Bicentennial Hall - Labs,  Chemical Storage

Class            Examples

Acids            Hydrochloric Acid, Nitric Acid
Bases            Sodium Hydroxide, Potassium Hydroxide
Compressed Gases    Nitrogen, Hydrogen, Oxygen
Cryogenic Liquids    Nitrogen, Helium
Solvent            Acetone, Isopropyl Alcohol

8.9    Material Safety Data Sheets for all hazardous chemicals used at
the college are filed and available in each department and DPS.

8.10    Potential Health and Physical Hazards of chemicals uses at
Middlebury College.

8.10.1    Acids & Bases - acids and bases are primarily corrosive
substances.  A corrosive chemical is
one that causes visible destruction or
irreversible alterations in living
tissue.  Exposure to corrosive mists
may cause eye and respiratory tract

8.10.2    Metals - overexposure to metals may cause a variety of
adverse health effects depending on the metal
species involved.  Inhalation or ingestion of
metals may affect the skin, respiratory system,
central nervous system and reproductive system.
Some metals may also be carcinogenic.

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8.10.3    Organic Solvents - an organic solvent is a substance
that is used to remove or dissolve
another substance.  There are many
different types of organic solvents
all capable of producing a variety
of adverse health affects. 
Generally, most organic solvents
will produce headaches, dizziness,
irritation and nausea upon acute
over exposures.  Chronic over
exposures may cause liver and kidney
damage or disorders of the central
nervous system.  Some organic
solvents may be carcinogens.  Many
organic solvents also present fire
or explosion hazards.

8.10.4    Compressed Gases - all compressed gases can be
hazardous due to high pressures. 
Rupture of the compressed gas
cylinder or system can cause a
sudden, intense release of energy
presenting serious hazards to life
and property.  Compressed gases may
also be hazardous due to the
flammable, reactive, toxic or
asphyxiant nature of the gas.

8.10.5    Cryogenic Liquids - these liquids are extremely cold
and can cause severe burns upon
contact with skin.  Also, the very
high volume of gas and liquid upon
vaporization (rupture) can cause
an asphyxiation hazard in an
enclosed area.

8.11    Refer to the MSDS for specific hazardous chemical(s) for
detailed physical and health hazard information.

9.0    Applicable Documents

9.1    29 CFR 1910.1200 Hazard Communication

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