MSDSs
Hazard Communication Program
2.0 RESPONSIBILITIES
Northwestern University is committed to providing a safe and healthful environment for the pursuit of teaching, research, and public service. The University is further committed to complying with federal, state, and local regulations relating to employee health and safety and to protection of the environment.
This policy and related regulations and guidelines apply equally to all faculty, staff, students, and visitors.
The senior vice president for business and finance and the vice president for research have assigned direct responsibility for compliance with the University's Hazard Communication Program to deans and department heads.
The deans are responsible for ensuring that department heads, principal investigators, and other supervisory personnel fulfill their obligation to adequately and regularly instruct persons under their supervision in proper safety procedures. Deans are also responsible for ensuring that department heads, principal investigators, and other supervisory personnel comply with all related government regulations and University rules and policies.
The term department head will be used in this text to include academic and administrative directors.
The department head is responsible for providing a safe workplace for faculty, staff, and students within the department's facilities. The department head is responsible for ensuring training of departmental faculty, staff, and students in the proper procedures necessary to maintain the general safety of the day-to-day operations. The department head may delegate safety and health-related responsibilities to a department safety representative or to principal investigators and other supervisors, but it is the department head's responsibility to see that the requirements are met.
Department heads must provide safety training to faculty, staff, and students whose work potentially exposes them to hazardous chemicals during normal operations or in foreseeable emergencies. Additional training must be provided whenever a new health or physical hazard not covered in previous training is introduced into their work area.
The department must maintain a training record and forward a copy to the Evanston ORS office. Contact ORS for training materials, guidelines, and advice on training. See section 4.0 for detailed training information.
2.2.2 Material Safety Data Sheets
Department heads must ensure that an MSDS is obtained for each chemical used or stored in the workplace and made readily accessible to faculty, staff, students, and emergency response personnel. See section 5.0 for more information on MSDSs.
2.2.3 Container Labeling and Other Forms of Warning
Department heads are responsible for ensuring that all chemical containers in their workplace bear labels with the appropriate chemical identity and hazard warnings. See section 6.0 for complete information on labeling and hazard warnings.
2.2.4 Workplace Hazardous Chemical List
Department heads are required to compile a list of hazardous chemicals used in their department and make it available to faculty, staff, and students. See section 7.0 for complete information regarding a list of hazardous chemicals.
2.2.5 Hazards of Nonroutine Tasks
Department heads are required to inform faculty, staff, and students of the hazards of nonroutine tasks and of the hazards associated with chemicals contained in unlabeled pipes in the workplace. See section 8.0 for information on the hazards of nonroutine tasks and the hazards of chemicals contained in unlabeled pipes.
2.2.6 Hazardous Materials Information for Contractors
Department heads must ensure that information regarding chemical hazards present in their workplace is shared with contractors. For more information on this subject, see section 9.0 and Appendix D.
Department heads must be aware of and implement the special requirements under the Hazard Communication Program that apply to laboratories. For more information on laboratory requirements, see section 10.0.
Department heads are responsible for compiling the annual inventory of hazardous chemicals as required under SARA Title III. See section 11.0 for more information on the annual inventory.
Department heads are responsible for assembling a Safety Desk Book. See section 12.0 for a list of the documents and other information required.
2.3 Principal Investigators and Other Supervisory Personnel
Principal investigators and other supervisory personnel are responsible to the department head for implementing the departmental safety programs, policies, and procedures. The principal investigator and other supervisory personnel shall be familiar with and understand the University safety policies and procedures pertaining to the workplace. These encompass but are not limited to employee training, record keeping, MSDS maintenance, labeling of chemicals, posting of warnings, medical surveillance, inventory reporting, engineering controls, safe work practices, and provision of personal protective clothing and equipment. Principal investigators and other supervisory personnel may not delegate their responsibilities.
2.4 Department Safety Representative
Department heads may appoint a department safety representative to perform designated safety functions. The department safety representative
- contacts University safety personnel on safety-related problems
- corresponds with other department safety representatives in the building
- knows the emergency procedures for the department and the University
- coordinates the department's program of accident prevention, safety training, annual inventory of hazardous chemicals, and emergency response
The Office of Risk Management inspects the public and service areas of the building and reports safety violations to the department head and/or Facilities Management for correction. The Department investigates accidents and handles Workers' Compensation claims for occupational injuries and illnesses. The Division will assist in developing safety policies and procedures as well as general safety training programs. Division staff will provide advice on local and national codes pertaining to facilities, materials handling, storage, and fire protection.
UP responds to alarms and emergency calls to provide assistance and control the site of the emergency. The communications officer summons the fire department or ambulance when needed. The responding UP officer may provide emergency first aid and arrange for transportation to the emergency room in cases where paramedics are not required.
2.7 Office for Research Safety (ORS)
ORS is responsible for coordinating the University's overall compliance with the Hazard Communication Program. ORS responsibilities, as they relate to the Hazard Communication Program, include
- maintaining the central repository for MSDSs
- compiling the annual inventory of hazardous chemical information and submitting reports to federal, state, and local agencies
- surveying laboratory facilities and offering recommendations for improved work practices
- coordinating the the Integrated Safety Information System (ISIS) compliance program
- training and advising personnel in safe work practices, personal protective clothing and equipment, engineering controls, and regulatory requirements
- conducting or arranging for environmental monitoring
- inspecting laboratory equipment such as chemical fume hoods
- recommending policies and procedures for the safe conduct of work with chemicals
ORS representatives are authorized to enter University facilities within their jurisdiction at any time to observe working conditions, monitor equipment, and sample for contaminants. The ORS director and the designated chemical hygiene and biohazards safety officers are authorized to close a facility or stop a process or procedure that poses an imminent danger to life or property.
Facilities Management maintains the basic building facilities including fire extinguishers and fire hoses in public and service areas, building fire alarm systems, ventilation systems, and electrical and piping systems. Facilities Management personnel respond to emergencies to help handle building services and equipment.
Safety requirements are well documented and available for most basic work procedures. Employees must accept the responsibility for knowing the safety requirements and putting them into practice in the workplace. Safety considerations should always be included in the planning and performing of work, which includes learning in advance about the properties, hazards, and safety measures pertinent to the materials and equipment to be used. Employees must know the established emergency procedures and the location and proper use of emergency equipment and supplies.
Although the OSHA standards apply only to employers and employees (including student employees), it is the policy of Northwestern University to ensure that all students who might be exposed to hazardous materials in the course of their academic activities are adequately protected and trained. Students shall receive instruction in the appropriate safety precautions for their specific research/teaching labs and will be expected to follow the given rules.
Internal ORS Links: What's New | Emergency Response | Administration | Biological Safety | Chemical Safety | Hazard Communication | Laboratory Safety | New to NU? | Radiation Safety
External ORS Links: Northwestern Home | Vice President for Research | Big 10 EH&S Links | Risk Management | Employee Safety Handbook
ORS - Evanston • 2145 Sheridan Road • Tech NG71
• Evanston, IL 60208
ORS - Chicago • 303 E. Chicago Avenue • Ward B106 W223 •
Chicago, IL 60611
Phone 847/491-5581 or 312/503-8300 • FAX 847/467-2797 or 312/503-0547
e-mail researchsafety@northwestern.edu
Last Revision 05/16/2007
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