The College shall develop and implement procedures for the proper handling, disposal, labeling, inventorying, and communication of hazardous substances in compliance with state and federal statutes.  The Board delegates to the president or designee responsibility for these procedures.

520.001 COMPLIANCE

Purpose and Administration

1. Purpose

The purpose of the hazard communication procedure is to ensure that College employees are aware of the hazards associated with substances they may be using.

This procedure details responsibilities, training, labeling requirements, documentation, accessing information, accountability, and auditing.

2. Ad Hoc Hazard Review Groups

These groups will meet as needed to review concerns regarding the use of hazardous substances in units/divisions/departments, work areas, special projects, and faculty research projects.

The Ad Hoc Hazard Review Groups will consist of the following membership: 

a. Department supervisor/division chair where hazardous substances are used

b. Unit dean where hazardous substances are used

c. Director of facilities services

d. Associate vice president of human resources

e. Concerned faculty/staff, and/or their representatives

f. Associate director of environmental health and safety

3. Associate Director of Environmental Health and Safety

The associate director of environmental health and safety is the College employee assigned to coordinate specific aspects of this program.

Labeling/Signs

1. Supervisor Responsibilities

The unit dean/division chair/department supervisor is responsible for:

a. Ensuring all original chemical containers entering the division/department are labeled with an intact, original label or labeled as secondary container.

b. Appointing specific employee(s) to be responsible for chemical labeling in each department/ division.

c. Directing employees to check containers for incomplete or defaced labels.

d. Directing employees to label all secondary containers.

2. Secondary Container Labeling

The labeling of secondary containers must include:

a. A copy of the original manufacturer’s label.

b. In lieu of original label:

(1)     Name of the chemical/product.*

(2)     Appropriate hazard warning.**

(3)     Manufacturer, importer, or other responsible party.

* The identity of the potentially hazardous substance(s) may be any chemical or common name that is indicated on the material safety data sheet (MSDS), which will permit cross-reference among the chemical inventory, the label, and the MSDS.

** The hazard warning must convey the specific health or physical hazard(s) that may be produced by the substance.

c. The date transferred or prepared.

d. The preparer’s initials.

3. Stationary Container Labeling

Label stationary containers:

a. As a secondary container.

b. Or use area signs/placards instead of container labels to identify potentially hazardous substance(s)/hazard(s) present.

4. Labeling Chemicals Generated in the Laboratory

Chemicals generated in the laboratory include mixtures, solutions, reaction products, and research chemical products or by-products. Unless existence of chemical(s) mixture or solution is momentary, mark container with:

a. Name of chemical(s) generated.

b. Known hazard(s) associated with chemical(s) generated.

c. Name of person who generated chemical.

d. Date made.

5. Hazardous Waste Container Labeling

Hazardous waste labels may be obtained from the associate director of environmental health and safety.  The labeling of hazardous waste containers must include: 

a. ClarkCollege’s name and address.

b. ClarkCollege’s WashingtonState dangerous waste generator’s identification number: WAD134978048.

c. Words “Hazardous Waste.”

d. Name of the waste.

e. Major hazard represented by the waste.

f. Washington State Department of Ecology designated dangerous waste code(s).

g. Accumulation start date unless the container is a satellite waste storage container, then mark the date when accumulation limits are met.

6. Area Labeling/Signs

The unit/division/department's safety and hazard sign system needs to enable a person unfamiliar with the usual routine of the laboratory to escape in an emergency, locate emergency equipment, and recognize hazardous chemical storage and handling areas.  Area labeling/signs are needed in the following circumstances:

a. Specific area hazards (such as carcinogenic, flammable, or radioactive).

b. Designated handling and storage area(s).

c. Access doors to the laboratory.

d. Safety showers, eyewash stations, first aid kits, fire extinguishers and exits.

e. Emergency posters with telephone numbers (on-campus and off-campus numbers).

f. Allowable eating areas.

g. Required personal protective equipment for an area (e.g., goggles, etc.).

7. Chemicals Requiring Specific Labeling

Certain chemicals require specific labeling:

a. Confirmed Carcinogens	WAC 296-62-07310
b. Lead	WAC 296-62-07521
c. Vinyl Chloride	WAC 296-62-07329
d. Acrylonitrile	WAC 296-62-07336
e. 1,2-dibromo-3-chloropropane	WAC 296-62-07342
f. Inorganic Arsenic	WAC 296-62-07347
g. Ethyl Oxide	WAC 296-62-07371
h. Cadmium	WAC 296-62-07425
i. Benzene	WAC 296-62-07523
j. Formaldehyde	WAC 296-62-07540
k. Methylenedianiline (MDA)	WAC 296-62-07621
l. Asbestos	WAC 296-62-07721
m. Methylene Chloride	WAC 296-62-07470
n. Thorium	WAC 296-62-07519
o. 1,3-Butadione	WAC 296-62-07460
p. Hydrogen, Oxygen and Anhydrous Ammonia	WAC 296-24 parts E&F

Recycled Materials Labeling

Containers marked with the symbol shown below contain materials recycled by the College. Products marked with this symbol indicate recycled material content.

Biohazard Warning Label

Label materials potentially containing Bloodborne Pathogens and other biohazardous materials with the words “Biohazard,” the Biohazard

Material Safety Data Sheets (MSDS) Procedures

1. Purpose of the MSDS

The MSDS is used to relay chemical hazard information from the manufacturer/importer to the College and the employee. The MSDS contains information to educate employees on the safe use of hazardous chemicals in the workplace. The MSDS provides a quick reference of the health effects and physical properties of hazardous substances to aid in special handling, storage, spills, and personal protective devices.

2. MSDS Responsibilities

The College is required to maintain an MSDS for all potentially hazardous substances on campus. MSDS responsibilities are as follows:

a. The associate director of environmental health and safety maintains a master MSDS file of potentially hazardous substances on campus.

b. Department supervisors/division chairs are responsible for ensuring that employees:

(1) Obtain an MSDS for every potentially hazardous substance present in department/ division areas.

(2) Forward a copy of MSDS's received to the associate director of environmental health and safety. (Mark with Purchase Order number and/or the name of appropriate division/department before forwarding.)

(3) Know the location of the MSDS's on the College Intranet site (ClarkNet).

(4) Read the MSDS and product label on chemicals prior to using/handling.

(5) Follow handling procedures found on the MSDS and product label.

(6) Audit MSDS and chemical inventories periodically for completeness.

c. Employees are responsible for knowing the location of the MSDS on the ClarkNet, reading the MSDS and label for a chemical prior to handling, and following chemical handling instructions found on the MSDS and product label.

3. To Obtain an MSDS

Choose one of the following options to obtain an MSDS:

a. Mark “yes” in the MSDS required section on the Purchase Request.

b. In the computerized purchasing program, note “MSDS Required” in the line notes.

c. Request MSDS from business supplying the product (the customer service desk usually has a request form or the MSDS). 

d. Complete an MSDS request form for the product and send to the associate director of environmental health and safety GHL 206.

e. Contact the associate director of environmental health and safety for assistance.

4. Purchasing Services and MSDS Procurement

Purchasing Services will procure an MSDS for each hazardous substance purchased for use at the College, if requested by the unit/division/department placing the order. Payments to vendors may be withheld until acceptable MSDS is obtained. (This does not include blanket orders, will call, credit card purchases, and petty cash.) Bid proposals will be non-responsive unless MSDS’s are provided.

5. MSDS’s for Blanket Orders, Will Call Orders, Credit Card, or Petty Cash Purchases

For blanket orders, will call orders, credit card, or petty cash purchases of chemicals, it is the responsibility of the division/department originating the purchase to obtain the MSDS for the purchase and forward a copy to the associate director of environmental health and safety.

6. MSDS Locations

The master file for all campus MSDS's is located in the office of the associate director of environmental health and safety. The chemical inventory and all MSDS’s are available on the ClarkNet. It is located in the Environmental Health and Safety section.

Employee Information and Training

1. Human Resources will provide information about the College’s hazard communication policy contained with the chemical hygiene procedure to employees in New Employee Success Training. For employees working directly with hazardous materials, there will be an additional training requirement. This training will be provided by Environmental Health and Safety. In addition, the department supervisor/division chair is responsible for the adequacy of training of employees new to their work area. Training shall include the following:

a. An explanation of the provisions, requirements, and location of the College hazard communication procedure on the ClarkNet.

b. The presence of hazardous substances in the work area.

c. The location of the MSDS on the ClarkNet and the purpose and content of MSDS forms.

d. Methods of identifying hazardous substances and procedures for safe handling and proper disposal.

e. The physical and health hazards associated with hazardous substances, including the likely physical symptoms or effects of overexposure and measures employees can take to protect themselves from hazardous substances, including specific College procedures and practices, emergency procedures, and personal protective equipment to be used.

f. The requirements of the chemical hygiene procedure.

2. The associate director of environmental health and safety will assist the department supervisor/division chair with training materials.

3. The associate director of environmental health and safety, in conjunction with the department supervisor/division chair, will periodically audit training records to ensure compliance with this procedure.  The department supervisor/division chair is responsible for correcting deficiencies that are identified.

Contractors/Vendors

1. Contractors'/vendors' employees working on campus are a special concern. They are not familiar with the hazardous substances the College has in use and are usually on campus only a short time.
   
   
2. Before contractors and/or their employees commence work on campus, the contractors must sign an agreement that they acknowledge the College's hazard communication procedure and have communicated it to their employees.
   
   
3. The College may not authorize the work or continued work of a contractor who does not have the necessary training on these procedures.
   
   
4. Before commencing work at the College, contractors/vendors will be required to provide to the College a list of potentially hazardous substances they are bringing to campus. An MSDS must accompany any substances brought onto campus. All containers must be labeled in accordance with this section.
   
   
5. Contractors/vendors are responsible for proper labeling, handling, storage, and disposal of hazardous wastes created by their activities.

Hazardous Substances Inventory

The associate director of environmental health and safety maintains an inventory of potentially hazardous substances for the campus. This list may be reviewed on the ClarkNet. Department supervisors/ division chairs are responsible for working with Environmental Health and Safety to maintain inventories for division/department work areas.

Chemicals Developed in the Laboratory

Chemicals developed in the laboratory are governed by the chemical hygiene procedure and the provisions stated in WAC 296-62-40015 (2).

Revised Policy and Procedure Approved by Executive Cabinet
June 15, 2010

520.005 DISPOSAL OF HAZARDOUS MATERIALS

Disposal of hazardous waste must be approved by the associate director of environmental health and safety.  Unit deans, division chairs, and department supervisors are responsible for ensuring that hazardous materials are properly collected, segregated, identified, packaged, and held prior to disposal pick-up. The cost of hazardous waste disposal is charged to the unit, division, or department producing the waste. Cost of disposal can be reduced by participating in hazardous waste disposal pick-ups scheduled by the associate director of environmental health and safety.

To properly dispose of hazardous waste:

1. Contact the associate director of environmental health and safety to set up initial hazardous waste disposal procedures for each waste stream generated.
   
   
2. Notify the associate director of environmental health and safety of addition or change of a waste stream.
   
   
3. Contact the associate director of environmental health and safety to arrange disposal of hazardous waste.
   
   
4. Dispose of all waste according to federal and state regulations.
   
   
5. Use the disposal firm contracted by the State of Washington for hazardous waste disposal. (Any exceptions must be authorized by the associate director of environmental health and safety.)
   
   
6. Document shipment of hazardous waste on a Hazardous Waste Manifest.
   
   
7. Contact the associate director of environmental health and safety for the firms the College approves to recycle spent chemical products such as oils/lubricants, antifreeze, oil filters, parts cleaner, photography fixer, etc.
   
   
8. Contact the associate director of environmental health and safety before giving away unwanted chemicals.
   
   
9. Prohibit the use of the sanitary or storm sewer systems for hazardous chemical disposal.
   
   
10. Prohibit the use of trash containers for hazardous chemical disposal.
    
    
11. Prohibit evaporation of volatile compounds as a means of hazardous chemical disposal.
    
    
12. Obtain prior approval from the Washington State Department of Ecology, through the associate director of environmental health and safety, for any treatment of hazardous waste such as, precipitation, volume reduction, chemical change, filtration, distillation, etc.
    
    
13. Consider unlabeled or unwanted chemicals as waste. Contact the associate director of environmental health and safety prior to declaring unlabeled or unwanted chemicals as waste.

Hazardous Waste Shipping Manifests

It is the responsibility of unit deans, division chairs, and department supervisors to:

1. Ensure a Hazardous Waste Manifest accompanies shipments of hazardous waste.
   
   
2. Forward all hazardous waste shipping manifests to the associate director of environmental health and safety.
   
   
3. Maintain hazardous waste manifests on file for 5 years.
   
   
4. Ensure Hazardous Waste Manifests have the College’s hazardous waste generator number, the transporter ID number, and are signed by a College representative and the transporter.
   
   
5. Contact disposal facility if a copy of the manifest with a handwritten signature of the owner/operator of the designated disposal facility is not received within 35 days.
   
   
6. File an exception report with the Washington State Department of Ecology within 45 days if a copy of the manifest with a handwritten signature of the owner/operator of the designated disposal facility is not received.

Revised Policy and Procedure Approved by Executive Cabinet
June 15, 2010