Calvin College Hazcom Plan

Introduction

THE RIGHT TO KNOW LAW

The Michigan Occupational Health and Safety Act (MIOSHA) stipulates the requirements of employers for the safety and health of their employees. Act No. 154 of the Public Acts of 1974 was amended by Act No. 80 of the Public Acts of 1986, with the amended title reading as follows:

"An act to prescribe and regulate working conditions; to prescribe the duties of employers and employees as to places and conditions of employment; to create certain boards, commissions, committees, and divisions relative to occupational and construction health and safety; to prescribe their powers and duties of the directors of the departments of labor, public health, and agriculture; to impose an annual levy to provide revenue for the safety education and training division; to provide remedies and penalties; and to repeal certain acts and parts of acts."

This MIOSHA mandate is often referred to as The Right to Know Law (RTK) or Hazcom since it emphasizes the requirements of employers to educate the employees as to the specific hazards of the chemicals with which they come into contact during their duties as employees. The Right to Know Law initially (effective May 25, 1986) was applied to certain standard industrial classifications. Beginning February 25, 1987, the law was expanded to include educational institutions, among others.

Calvin College, in order to comply with the Michigan Right to Know Law, is required to train its employees about potential chemical hazards in the workplace. The RTK is a "performance" oriented law. This means that there are no established guidelines to follow in terms of how we as a college comply with the law. This flexibility provides us with the freedom to design a program that both appeals to the population who are affected by it, and to initiate a program in the manner most advantageous for the College. In order to guarantee that no stones are left unturned and that all possible hazard situations are addressed, all employees will be eligible for the training and any employee wishing to attend is not only welcome, but encouraged to do so. Any employee specifically asked to attend a session by his or her supervisor is under obligation to attend. The Right to Know Law has provisions concerning:

the safety labeling of containers of hazardous chemicals
the keeping of Material Safety Data Sheets (MSDS) for each hazardous chemical used or generated on the premises
a training program to educate the employees about the hazard labeling procedure and the safety equipment required when handling specific hazardous chemicals.
an institutional written program for implementation of the law

A hazardous chemical is defined as "any chemical which is a physical hazard or a health hazard" but which does not fall into the category of pesticides, food or food additives, distilled spirits which are intended for non-industrial use, or consumer product as defined in the Consumer Product Safety Act (15 U.S.C. 2051 et. seq) or hazardous substance which is subject to a consumer product safety standard (15 U.S.C. 1261 et seq.). A physical hazard is "a chemical for which there is a scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive."

A health hazard is less specific, given the difficulties in distinguishing hazards which may take prolonged exposure before displaying an effect. "The term 'health hazard' includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins (toxic to the liver), nephrotoxins (toxic to the kidney), agents which act on the hematopoietic (blood cell producing) system, and agents which damage the lungs, skin, eyes, or mucous membranes." (Code of Federal Regulations, Title 29 Part 1910.1200 - Hazard Communication). Since the health hazard definitions are rather loose, all chemicals will be considered hazardous chemicals in the context of proper labeling and handling. All chemicals will thus receive a hazard label, and a MSDS will be filed for each type of chemical in inventory.

LABELING

Labels are the most useful source of information on the hazards of a chemical because of the availability. There may be two types of labels available:

Manufacturers Label - The content of theses are generally mandated by federal or state law. They should not be defaced or removed for any reason.
User Label - These are labels added by the user to quickly deliver a summary of the hazards. The labels generally denote the relative hazard with the use of a numerical system(0-4); the higher the number, the higher the hazard. See the Science Division Hazcom Plan for a common example.

TRAINING

Generally, employees or students only have to be trained once during their career at Calvin. However, there are circumstances that necessitate retraining.

Anytime an employee is transferred to a new job were the employee is potentially exposed to a new hazardous chemical having significantly different chemical characteristics than any previously worked with.
Anytime a new hazardous chemical with significantly different chemical characteristics is introduced to the workplace.
Anytime a new hazardous or potentially hazardous effect of a chemical, that is already being used, is discovered. For example, an updated Material Safety Data Sheet is received, stating that a chemical already classified as a sensitizer has also been found to be carcinogenic.

General Training

There are two parts to the training procedure. First is the general chemical hazard training session. The second part is specific training, which all employees who work with hazardous chemicals must receive. The area supervisor, with the assistance of the Environmental Health and Safety Officer, will determine whether it is necessary for an employee to attend the chemical safety training inherent to a particular job.

The Environmental Health and Safety Office will offer periodic training sessions at locations and times to be announced. All area supervisors are required to attend a training session.

In addition, the following must be trained:

any employee or student whose job involves the routine handling or use of any hazardous chemical(s),
any employee or student whose job may result in his/her having contact with or exposure to a hazardous chemical for any reason, or
any employee or student who could be exposed to hazardous chemicals during any foreseeable emergency.

Specific Employee Training

All employees should be thoroughly briefed by their supervisors on how the Michigan Right to Know law effects them and their rights and responsibilities under the law. Employees must be trained on specific "operations in their work area where hazardous chemicals are present," "the hazards of chemicals in unlabeled pipes," and the location of the hazard communication program (this document), the required list of hazardous chemicals and Material Safety Data Sheets. Finally, the RTK requires that employee training include:

"Methods and observations that may be used to detect the presence or releases of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released),
"the physical and health hazards of the chemicals in the work area,
"the measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used, and
"the details of the hazard communication program (this document), including an explanation of the labeling system (procedure) and Material Safety Data Sheet, as well as how employees can obtain and use the appropriate hazard information."

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Send comments or questions to Brian K. Dokter, CHMM, the maintainer of this page. It was last updated on October 9, 1996.