35.60 – Hazard Communication Program
October 9, 2015
A. General. The University of Idaho is committed to creating, maintaining, and promoting a safe and healthful environment for all students, employees, and visitors. A critical component of the university's environmental health and safety commitment is ensuring personnel are aware of, and know how to properly respond to, all hazards of their workplaces including chemical hazards, using practices such as those described in this Hazard Communication (HazCom) Program.
B. Scope. In order to comply with state regulations and protect employees, this policy statement concerning the Hazard Communication Program has been established for the University of Idaho. All campuses, colleges, schools, and administrative offices are incorporated within this program. This policy statement applies to all university employees at all university locations including the Moscow main campus and any branch campuses, Research and Extension Centers, all other university-owned property, university-leased space, and temporary field locations and field trips that are under the control of university operations and staff.
B-1. Exceptions. This policy statement does not apply to:
- Any chemical waste, including hazardous waste (see APM 35.40);
- Biological hazards (see APM 35.11);
- Ionizing or nonionizing radiation (see APM 35.81);
- Any consumer product that is used for its intended purpose, and the use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers;
- Labeling of any pesticide as defined in the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).
C. University of Idaho Compliance Responsibility. Unit administrators are responsible for the health and safety performance in their respective units (see APM 35.33). This responsibility can neither be transferred nor delegated.
C-1. Environmental Health and Safety. Environmental Health and Safety (EHS) is responsible for developing university-wide hazard communication policies and programs. Program requirements are described in the HazCom Program Guidance Manual on the EHS Web site. EHS maintains the necessary documentation and provides technical assistance to units in establishing procedures and conducting activities to comply with the HazCom Program.
C-2. Unit Administrators. All units must follow the compliance procedures in this policy and the supporting HazCom Program Guidance Manual on the EHS website. Units may document in writing their own methods for meeting the requirements of the HazCom Program but the methods must be approved by EHS. Responsible individuals through first-level supervisors in all units are responsible for implementing the required activities within their units, as described in the compliance guide. Critical components of the program include:
- Identifying and listing hazardous chemicals in use by employees;
- Preparing a written program;
- Ensuring chemical containers are labeled;
- Ensuring employees have access to SDSs;
- Informing and training employees; and
- Maintaining documentation.
C-3. Employee Responsibility. Employees are required to:
- Follow established policies and procedures regarding safe chemical handling;
- Participate in applicable training programs;
- Read and apply SDS information;
- Notify a supervisor if no SDS is available for a hazardous chemical or if an unlabeled chemical container is discovered.
C-4. Contracting with Non-University of Idaho Employers for Onsite Work. All University of Idaho units purchasing work or services from non-university employers must advise the employers (such as contractors performing work on university work sites) of any ongoing University of Idaho operations which cannot be stopped or remediated, and include a description of the hazardous chemicals to which the contractor’s employees may be exposed.
Non-university employers (contractors) shall be informed that they must provide a description of any hazardous chemicals brought into the workplace to which University of Idaho employees may be exposed. Contact EHS or email email@example.com if there are any questions about the potential risks that could be associated with these hazards.
D. Compliance Requirements. Procedures for complying with the university's Hazard Communication Program are described on the EHS website. This policy statement and the related procedures comply with requirements in Idaho Division of Building Safety General Safety & Health Standards, Hazard Communication 301 and Laboratories and Chemical Storage Safety Rules 111 requirements in chemical laboratory areas. Federal OSHA requirements are incorporated where it is helpful for clarification.
E. Additional Information. Questions regarding the Hazard Communication Program should be directed to EHS at (208) 885-6524 or by sending email to firstname.lastname@example.org. Various manuals, brochures, and other documents in support of the Hazard Communication Program are available on the EHS website.