IV. Hazard Identification
Purpose : This procedure outlines a method for determining the health hazards of a particular chemical that will be used by the laboratory. For any chemical that is purchased from any outside supplier, the manufacturer's or supplier's MSDS and label will be the principal source of hazardous information. Any chemical produced in the laboratory, or produced as a by-product, will be assumed to be hazardous unless, or until, its identity can be determined and a specific hazard analysis is performed.
Scope : This procedure will cover all hazardous chemicals used in the laboratory, whether brought into the laboratory from an outside manufacturer or supplier, or produced in the laboratory as a product, intermediate or byproduct. This procedure also details the acquisition and maintenance of MSDS's and container labeling.
Procedures :
1. The CHO will review each new or revised MSDS when it is received from a manufacturer or supplier. The review will be conducted to assure that it is complete and that it provides information concerning the health hazards, special procedures or practices for handling and storage, emergency procedures and disposal methods. In conjunction with the appropriate laboratory supervisor, the CHO will determine if special procedures or practices need to be implemented to assure safe handling.
2. The Purchaser of a given chemical substance will be responsible for forwarding MSDS's from all hazardous materials suppliers to the CHO for review. If available, suppliers' samples must include a Material Safety Data Sheet for the use of operating personnel in evaluating the product. The Purchasing Department will assist a laboratory manager in the development and maintenance of a chemical inventory. An example inventory form for a given lab can be found in Appendix II of this CHP.
3. If a Material Safety Data Sheet is missing, the purchaser will secure it by contacting the manufacturer. This allows the person in most immediate need to get the information first. Suppliers who fail to cooperate in providing MSDS's will be identified to the appropriate management personnel for disposition. This may also the include cessation of all future purchasing.
4. All labels affixed to incoming chemicals containers must be maintained. Contact your supervisor or the CHO if any container labels are missing or defaced.
5. The container with missing or defaced labels will be removed by the CHO from stock and not returned until the condition has been rectified.
6. If any laboratory procedure will result in the production of a by-product that is unknown, it will be considered hazardous and handled accordingly to the SOP for work with particularly hazardous substance.
7. If any laboratory procedure results in an intermediate or final product whose composition is known, a literature search will be conducted to determine the hazardous nature of the chemical. Following this hazard evaluation, the CHO in conjunction with other members of the management staff, as needed, will develop appropriate practices and procedures to assure safe handling, use, storage and disposal of the chemical. These procedures will be included with the SOP's for work with hazardous chemicals to ensure employee protection.
8. In addition to the MSDS's, other information concerning the hazards, safe handling, storage, and disposal can be found in the library. A list of reference materials is provided in Appendix II.
9. Material Safety Date Sheets. Since such a wide variety of substances is utilized in our facilities, one central record keeping area will be used for storage of MSDS's for the entire university. In this way, everyone will know where to obtain MSDS information. The following procedures cover record keeping and filing of MSDS's for chemicals used in the laboratories.
a. Upon placing verbal and written orders for chemical reagents, a request will be issued for shipment of a MSDS to the orderer's attention, arriving either before or with the product.
b. A master file and cross reference list of MSDS's by trade name, chemical's names, supplier and user will be developed and maintained by the CHO, and located in a file.
c. A file of MSDS's for chemicals used in each laboratory will be located in the laboratory.
d. The laboratory file of MSDS's should be used for employee training purposes and must be available for employee access. The CHO will give the lab supervisor a copy of each MSDS for hazardous chemicals used in their areas.
e. The CHO will make MSDS's available to any outside medical provider or public service agency that has a need for the information.
10. We will rely exclusively on the information supplied by the product vendor or distributor of the Material Safety Date Sheet to properly determine the hazards of any particular chemical used in the laboratories. MSDS's that are incomplete or appear to be in error will be referred back to the vendor or distributor by the purchasing agent for information update or change. If you notice any missing information or information which appears to be inaccurate, please contact your lab supervisor or the CHO.
a. MSDS's should be maintained in accordance with 1910.20-Subpart C-General Safety and Health Provisions - "Access to Employee Exposure and Medical Records." Paragraph (d) Preservations of Records; (1) (11) (A) & (B), Material Safety Data Sheets: and paragraph (c) (5) (iv). Records Concerning the Identity of a Substance or Agent need not be retained for any specific period, as long as some record of the identity of the substance or agent, where it is used, and when it was used is retained for at least thirty years. MSDS's for products that are not currently used or that have been changed will be maintained in an inactive file for a minimum of 30 years.
11. Labels are designed to provide information to employees concerning the hazards of various chemicals. Therefore, it is important the hazardous chemicals remain in properly labeled containers. The following procedures apply to all manufacturers' labels.
a. All manufacturers' labels will be left on the containers. If any container labels are missing or defaced, please contact your supervisor.
b. As a minimum, each label should contain the following:
1. Identification of the material in the container;
2. Appropriate hazard warnings, such as health, fire, and reactivity;
3. Name and address of chemical manufacturer, importer, or the responsible party.
c. If you are unfamiliar with the contents of the label, please see the lab supervisor for a further explanation.
12. In the laboratory, storage, reaction or processing containers should be labeled with:
a. Identification of material in the container, such as product or chemical name.
b. Possible appropriate hazard warnings such as health, fire, or reactivity, taken from the Material Safety Data Sheets or other hazards identification reference.
c. Date of initiation
d. Name of initiator
13. The CHO will ensure containers of chemical produced in-house will be labeled with appropriate hazard information.