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Right to Know



View the complete Hazardous Chemical Protection Communication (Right-To-Know) Plan

Purpose


The Hazardous Chemical Protection Communication Plan for Middle Georgia State University complies with the: (1) Federal Code-29 CFR 1910.1200, Hazard Communication plan; (2) Georgia Public Employees Hazardous Chemical Protection and Right to Know Act of 1988 as amended; (3) Georgia Department of Insurance Employee Chemical Protection and Right to Know Rules; and (4) The University System of Georgia Hazardous Chemical Protection Communication (Right to Know) Plan.

Note: This plan requires that seven areas be addressed:

  1. Written Implementation Program
  2. Hazard Determination
  3. Safety Data Sheets
  4. Chemical Labeling
  5. Employee Training
  6. Trade Secrets
  7. Contractors Requirements

The understanding and use of the following two documents are required:

  1. Safety Data Sheets (SDS): Relates needed information about the chemical.
  2. Labeling: Primary and Secondary: Relates manufactures and Chemicals identify and appropriate hazard warnings.

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Definitions


Right to Know (RTK) Coordinator - The individual who is assigned the responsibility associated with that title in this written Hazardous Chemical Protection Communication (RTK) Plan, and who is assigned the responsibilities of the Hazardous Chemical Protection Communication Coordinator in the Chapter 300-3-19 Rules.

Work Area: Means a room inside a building or structure, an outside area, or other defined space in a workplace where hazardous chemicals are produced, stored, or used and where employees are present in the course of their employment.

Workplace: Means an establishment or business of an employer at one geographic location at which work is performed by a state employee and which contains one or more work areas. In the case of an independent contractor or subcontractor, the workplace shall be defined as all work areas wholly owned or controlled by such independent contractor or subcontractor.

Hazardous Chemical: A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with the established scientific principles that acute or chronic health effects may occur in an exposed employee. This includes chemicals which are carcinogens, toxic or highly toxic, nephrotoxins, neurotoxins, agents which act on the hematopoietic (blood forming) systems, and agents which can damage the lungs, skin, eyes or mucous membranes.

Supervisor or Area Supervisor: Means the individual who is responsible for the supervision of the given work area. Supervisor may be used to denote division chair, department heads, directors, administrators, shift directors or leaders, etc.

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Policy


All work areas of MGA are included within this program. The written program is available for review at the MGA RTK Coordinator’s office (the Environmental Health & Occupational Safety Office) and can be found on-line on the Middle Georgia State University’s Environmental Health and Safety web site found here. All new employees are required to take RTK training prior to starting their position. All MGA employees are required to take RTK training annually thereafter. Supervisors are the most knowledgeable of conditions and situations in their work areas; therefore shall be responsible for assuring their units compliance with this RTK program.

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Responsibilities of Middle Georgia State University’s Right To Know Coordinator


  1. Act as liaison between The University System Right To Know Coordinator and MGA on hazardous chemical issues;
  2. Resolve questions regarding applicability of the Chapter 300-3-19 rules to individual workplaces and work areas of MGA;
  3. Make arrangements for and/or provide for appropriate and adequate Right To Know training (basic training) to all employees of MGA;
  4. Make arrangements for and/or provide for area supervisors, written specific hazard communication programs (specific training) for each workplace in MGA. The workplace specific program should include information concerning the hazardous chemicals used, stored, or manufactured in that particular workplace. The area supervisor is responsible for the availability of the workplace – specific training for all employees in his area.
  5. Acquires the hazardous chemical inventory information from the area supervisor in each department.
  6. Disseminate updated SDS information provided by area supervisors so that all employees of that particular will have access to current SDS’s for those hazardous chemicals used in their work;
  7. Coordinates information to the appropriate departments to assure that employees are made aware of and are properly trained in the uses and hazards associated with the chemicals to which they are exposed in their work area;
  8. Arranges information to appropriate departments for confirming that employee training on and notification of the use of hazardous chemicals in the work area are adequately documented;
  9. Organizes information to appropriate departments to insure that the supervisors provide employees with personal protective equipment appropriate to each work environment, and receive adequate training in the use and maintenance of this equipment;
  10. Review the hazardous chemical labeling practices of work areas which use secondary storage containers (at least annually).

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Responsibilities of Middle Georgia State University Area Supervisors


  1. Be knowledgeable of the hazard communication plan and its requirements.
  2. To make sure that every employee in their area attends one of the Hazard Communication Training sessions or completes the BOR online training.
  3. To assure the training records from each session are forwarded to the EHOS office for filing.
  4. To set up a Hazardous Communication Station in their work area, containing access to a copy of theMGA Hazard Communication Programand the SDS file containing all of the current hazardous materials in their area.
  5. Maintain a list of hazardous chemicals used or stored in their work area and report the updated inventory list each June and December to the EHOS office. Each chemical on the list must have a SDS on file.
  6. To assure that all employees have unrestricted access to this station during their work shift.
  7. To follow the correct hazardous material procurement procedure.

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Procurement of Hazardous Chemicals


The person requesting a chemical should determine if the chemical is:

  1. Presently being used or has been used in the department, or
  2. A new chemical having never been introduced to the campus.

Before the purchase of new chemicals determine:

  1. Is the name on the chemical inventory list? Yes_____ No_____
  2. Is an updated SDS in the department SDS file? Yes_____ No_____

Purchase of NEW chemicals:

It is the responsibility of the person requesting its purchase to ascertain that adequate research has been done to determine if the chemical is hazardous according to law, if safer to alternatives are available, or if any special requirements such as licenses are needed prior to the purchase.

It is the responsibility of the person approving the purchasing requisition to notify the purchasing department to request the SDS with the purchase order. (This may be done by writing upon the purchasing requisition – PLEASE REQUEST THE SDS FOR THIS PRODUCT.)

The Receiving Department supervisor shall send the SDS with the order to the Division requesting the chemical or product. The Division supervisor must place a copy of the SDS in the departmental SDS file and forward the original to the EHOS office for the Middle Georgia State University campus master file. The name of the chemical must be added to the chemical inventory files.

All employees (full time/part time/student workers) who will work with the new chemical must review the SDS and become familiar with the hazards associated with the chemical. The employee’s immediate supervisor is responsible for making sure they are familiar and comfortable with working with the new chemical. This process meets the Chemical Specific training requirement.

Failure to follow the above procedures will result in a “non-compliance” condition for the department and employees working with the new chemicals. If you have any questions regarding this procedure or need any assistance in training, please contact the EHOS office.

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Safety Data Sheets


Supervisors, in keeping with their obligation to ensure a safe work environment, are responsible for maintaining the SDS file in his/her department for the review by the employees in their work areas during their work shift. The supervisor is responsible for the employee training in SDS interpretation. Refer to SDS training information (Addendum 1).

A central file of SDS for chemicals used in various work areas for Middle Georgia State University will be maintained by the RTK Coordinator in the office of Environmental Health and Occupational Safety.

Supervisors will be responsible for sending the RTK Coordinator a copy of the SDS for any new chemical received in his/her work areas. The supervisors will review the incoming SDS for new significant health/safety information and will be responsible for the advising the affected employees of such changes. The RTK Coordinator may assist with this review.

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Hazard Chemical Inventory


It is the responsibility of the area supervisors of work areas using or storing chemicals to maintain the updated inventory of all chemicals in their work areas. [The SDS files must be inclusive of this list.]

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Hazardous Chemical Inventory Reporting


Each supervisor shall provide to the University’s RTK Coordinator each year on June 31st and each December 30th an updated list, by name, of all hazardous chemicals or products present at the department’s workplaces. This list shall include, but not be limited to, all chemicals labeled as:

  • Flammable or Combustible
  • Explosive
  • Combustible Liquid
  • Corrosive
  • Reactive
  • Oxidizer
  • Toxic
  • Water Reactive
  • Pyrophoric
  • Organic Peroxide
  • Compressed Gasses

This list shall include chemicals used in all science labs, allied health labs, all areas of plant operations (custodial, grounds, warehouse, water treatment, maintenance, etc.), art departments, drama departments, and dark room areas. Dark rooms are the responsibility of the assigned supervisor for its use otherwise it is the responsibility of the building supervisor of the building which houses the dark room. NOTE: Some office supplies are hazardous materials (liquid paper, toner cartridges, etc.) and need to be reported if they are stored in large quantities in one room (such as in the case of toner cartridges in a closet) but do not have to be reported if just a few items exist in a desk for one user’s supply.

The University’s RTK Coordinator will provide to the University System RTK Coordinator, as requested by the Ga. Department of Insurance, in July and January of each year the list of all hazardous chemicals present at the University’s workplaces.

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Chemical Labeling


  1. All hazardous chemicals introduced into the workplace by employers and used by employees shall be labeled in containers that meet the requirements of OSHA’s (Occupational Safety and Health Administration) Hazard Communication Standard (29 CFR 1910.1200).
  2. Primary/Secondary Labels
    It is important to understand two types of containers and labels: primary and secondary. A primary label is one that is prepared by the manufacturer. These labels are required to meet all of the requirements established by OSHA; therefore, employers/consumers would be in full compliance if they elect to rely on the primary labels supplied by the manufacturer.

    The primary containers label must include:

    • Identity of the chemical (same as SDS) Appropriate hazard warnings
    • Name and address of the manufacturer, distributer, or responsible party

    If an employee transfers a chemical from a primary container into another container which will be used only in that facility, that container is called a secondary container. The work shift supervisor must ensure that secondary container labels include:

    • Identity of the chemical (same as SDS) Appropriate hazard warnings
    • Name and address of the manufacturer, distributer, or responsible party

    Portable containers will be classified as secondary containers and must be labeled unless:

    • Only one person uses the material, AND the material is used entirely in one shift. If workers on different shifts use the same container then it must be labeled.

    If the secondary container is intended only for short term storage (one week or less), it shall be labeled with the name of the chemical and the date of filling vials and test tubes may have chemical labels affixed to the rack or container in which they are held, rather than on each vial or test tube, so long as every vial or test tube in the rack or container presents the same hazard. This type “temporary secondary containers” shall be labeled with the name of the chemical, the fill date, and initial of the preparer at a minimum.

  3. Unlabeled Containers
    If an employee finds an unlabeled or defaced labeled container in the workplace, it is considered to contain a hazardous chemical. The employee should immediately notify their supervisor. It is the responsibility of the supervisor to identify the contents. The supervisor should either request a label from the manufacturer, label the container using the SDS to transfer accurate information, or use a copy of a properly labeled container. If after exhausting all efforts to identify the contents, the supervisor shall call the RTK Coordinator for assistance in investigating and attempting to determine the contents. If such efforts fail to identify the contents, the supervisor will isolate the container from other chemicals; treat it as a container of hazardous chemicals whose properties are flammable, toxic and reactive. If the supervisor wishes to dispose of the container, it will be considered as hazardous waste and must be stored appropriately until disposal.

  4. Labeling Systems
    Labeling systems approved for use on the Middle Georgia State University Campuses are: the National Fire Protection Association (NFPA), and the Hazardous Material Identification Guide or System (HMIG or HMIS, respectively). Employees will be trained in these systems during their initial RTK training. Refer to the Labeling and Labeling Systems Information.

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Removal of Hazardous Chemicals


Supervisors are responsible for preparing an inventory of any chemicals they wish to be disposed. The list should include the name of the chemical, quantity to be disposed, and type, size and condition of container. Supervisors must report this to the RTK Coordinator who will contact vendors and start the process for removal of the hazardous chemicals.

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Close Out Policy


The Area Supervisor, in conjunction with the Coordinator of EHOS, is responsible for ensuring that all hazardous chemicals remaining on University property as a result of the departure of a faculty or staff member, or the vacating or reassignment of an assigned space, shall be managed in accordance with the following guidelines.

  • Ensure that all containers are properly labeled and no temporary containers or samples are left.
  • Ensure all unused, uncontaminated chemicals are disposed of properly or through an orphan chemical program.
  • Ensure all chemical waste is accounted for and disposed of properly and all microbiological waste is decontaminated and disposed of properly.
  • Ensure the transfer of ownership of all chemicals requiring a license to purchase and whom the chemical’s use has been transferred.
  • Ensure all gas cylinders are returned to suppliers.
  • Inspect labs, stockrooms, refrigerators, fume hoods, etc. for chemicals and cleanliness.

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Informing Contractors


It is possible for contractors doing work at MGA to:

  • Expose employees of the University to hazardous chemicals used by the contractor’s employees.
  • Expose employees and sub-contractors of the contractor to hazardous chemicals used by the contractor’s employees.
  • Expose employees and sub-contractors to hazardous chemicals used by the University.

Any and all contracts with MGA which may involve exposure to hazardous chemicals must require the contractor to:

  1. Notify the workplace supervisor at the worksite at least thirty days prior to the commencement of work, of any hazardous chemicals which will be used or stored at the work sites by the contractor or sub-contractor. (In emergency situations, the thirty day policy may be waived.)
    The workplace supervisor will then:
    • Disseminate this information to employees whose workplace is at the work site.
    • Upon request be provided with the chemical list and the SDS’s for those hazardous chemicals.
    • Supply the RTK Coordinator with the information about the contract work.
    • Request assistance with SDS’s etc. if needed.
  2. Provide documentation, upon request. To the workplace supervisor and RTK Coordinator, that employees of the contractor have been provided with the information and training on the hazardous chemicals being used by the contractor or sub-contractor, at the work site.
  3. Director of Plant Operations will be responsible for contacting each contractor before work is started in the University to obtain and disseminate any information concerning chemical hazards that the contractor is bringing to the University’s workplace.
  4. Prior to the commencement of work, the contractor must contact the EHOS office and provide written verification of satisfactory environmental data.

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  LAST MODIFIED: 6/29/2016