"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 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.
The Right to Know Law has provisions concerning:
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.
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In rating the various materials in regard to their Health, Flammability, and Reactivity hazards, the guidelines presented in the HMIS Raw Materials Manual will be followed. In that manual, however, the Health rating system is rather vague, with the numerical rating applying only to acute, or, short term, effects. Another notation (an asterisk or a 0.1 appended to the health rating) is used to denote chronic or accumulated effects, including carcinogenicity and mutagenicity.
Based upon the information presented in the MSDS accorded to each chemical, the level of Health, Flammability, and Reactivity hazard will be rated on the HMIS scale of 0 - 4, with 4 being the highest degree of hazard. The HMIS labels will indicate this level of specific hazard, and will also indicate, by alphabetical code, the type(s) of personal safety equipment which must be used when handling the chemical.
Wall posters in the preparatory rooms of each department will display the code and the specific safety equipment indicated by each code letter. The HMIS labels will be affixed to each container except those which are used for temporary transfer of chemicals or those which are used for temporary laboratory use. A duplicate HMIS label will be affixed to the MSDS for each chemical so that when new shipments arrive, the same ratings can be easily given to the new containers. Following the initial labeling procedure in which all existing containers will be HMIS labeled, incoming new containers will be HMIS labeled before being placed on the shelves for use. By requiring such immediate HMIS labeling, unlabeled containers, and, thus, containers of unknown hazards, will not reach the shelves for general use.
Each department in the Science Division will be responsible for labeling their own chemical containers, based on the HMIS labels on the MSDS sheets. While all HMIS labels will be of the same appearance, different size labels will be used as appropriate for the size of the container.
0. MINIMAL HAZARD This material poses no significant risk to health. The materials are listed on the MSDS with the following minimal hazard warning: May be harmful by inhalation, ingestion, or skin absorption. May cause eye irritation. May cause skin irritation.1. SLIGHT HAZARD This material causes irritation or minor reversible injury on contact with eyes, skin, mucous membranes, or upper respiratory tract. This category includes materials which are listed on the MSDS as harmful only if swallowed.
2. MODERATE HAZARD This material causes temporary or minor, reversible injury. This category includes materials which are listed on the MSDS as harmful if swallowed, inhaled, or absorbed through the skin.
3. SERIOUS HAZARD This material causes major injury upon contact unless prompt remedial action is taken and medical treatment is given. This category includes materials which are listed on the MSDS as causing severe irritation, or extensive tissue damage.
4. SEVERE HAZARD This material causes permanent tissue damage, major tissue damage, or may be life threatening upon a single exposure or with repeated exposures. This category includes materials which are listed on MSDS as being extremely destructive to at least one type of tissue, or which may be fatal if swallowed, inhaled, or absorbed through the skin.
[ ]1 or [ ]* CHRONIC HEALTH EFFECTS This material may cause chronic (long term) health effects or may be carcinogenic (may cause cancer). This superscript designation is in addition to the number listing outlined above. In the Quattro Pro program, this is indicated by a .1 following the standard number rating.
(A higher rating is awarded material which is harmful through inhalation or skin contact than that which is harmful through oral ingestion - a type of exposure less likely to occur under routine working conditions. Note that ratings 1 and 2 apply to effects which are largely reversible, while ratings 3 and 4 indicate that exposure may cause permanent damage.)
FLAMMABILITY
0. MINIMAL HAZARD This material is normally stable and will not burn unless heated.1. SLIGHT HAZARD This material must be preheated before ignition will occur. Flammable liquids in the category will have flash points (the lowest temperature at which ignition will occur) at or above 200o F (NFPA Class IIIB).
2. MODERATE HAZARD This material must be moderately heated before ignition will occur. Flammable liquids in this category have flash points between 100o and 200o F (NFPA Class II & Class IIIA).
3. SERIOUS HAZARD This material is capable of ignition under almost all normal temperature conditions, and includes flammable liquids with flash points below 100o and boiling points above 100o F (NFPA Class IB & Class IC).
4. SEVERE HAZARD This category includes very flammable gases or very volatile liquids with flash points below 73o and boiling points below 100o F (NFPA Class IA).
REACTIVITY
0. MINIMAL HAZARD This material is normally stable, even under fire conditions, and will not react with water.1. SLIGHT HAZARD This material is normally stable, but can become unstable at high temperatures and pressures. This material may react with water, but it will not release energy violently. This category includes materials which are listed as being sensitive to moisture.
2. MODERATE HAZARD This material is normally unstable an will readily undergo violent chemical change, but will not detonate. This material may react violently with water or may form potentially explosive mixtures with water.
3. SERIOUS HAZARD This material is capable of detonation or explosive reaction but requires a strong initiating source or must be heated under confinement before initiation. The category also includes materials which react explosively with water.
4. SEVERE HAZARD This material is readily capable of detonation or explosive decomposition at normal temperatures and pressures.
[ ]1 SPECIFIC CONDITION EFFECTS This material may react violently or explosively under certain storage conditions or when used in combinations or mixtures with specific other materials. Consult the MSDS (including the footnotes found there) for details. This superscript designation is in addition to the number listing outlined above. In the Quattro Pro program, this is indicated by .1 in addition to the standard number rating.
PERSONAL PROTECTION
A -- Safety glasses should be worn when handling this material. This is the minimal rating given to any material.B -- Safety glasses and protective gloves should be worn when handling this material. This rating is given to materials which have the potential for skin irritation, or which may be harmful if absorbed through the skin.
C -- Goggles, protective gloves, and a laboratory apron should be worn when handling this material. This rating is given to materials which have the potential for splashing and which are listed as having a HEALTH HAZARD RATING of 2 or higher.
D -- A face shield, goggles, protective gloves, a laboratory apron, and an exhaust fume hood should be used when handling this material. This rating is given to materials which are capable of detonation or of explosive reaction. This rating would apply to all materials which receive a REACTIVITY HAZARD rating of 3 or 4.
E -- Safety glasses, protective gloves, and an exhaust fume hood should be used when handling this material. This rating is given to materials which have the potential for releasing harmful vapor, mist, or dust into the air.
H-- Splash goggles, a laboratory apron, protective gloves, and an exhaust fume hood should be used when handling this material. This rating is given to materials which, in addition to having the potential for releasing harmful vapor, mist, or dust into the air, also have the potential for splashing. Strong acids, strong bases, and strong organic solvents would fall into this category.
PLEASE NOTE: SOME PERTINENT INFORMATION ABOUT REACTIVITY WITH SPECIFIC MATERIALS MAY BE LISTED UNDER FOOTNOTES AT THE END OF EACH MSDS.
New chemical purchases will be accompanied by their own MSDS which must be filed if it is a new addition, or in place of the older MSDS if the chemical is a replacement of an existing one and there is updated information on the new sheet. All of the MSDSs in the Science Division will be filed and housed in the Science Division Office in 3-ring binders. MIOSHA requires that the MSDSs be readily available to employees on all shifts (Section 1910.1200g, Code of Federal Regulations, Title 29, Chapter XVII, Part 1910, Subpart Z), and that notices of new or updated MSDS be posted in the affected department within 5 days of receipt and kept posted for at least 10 days (Michigan Right to Know Law, Sec. 14k).
By posting the new MSDS for 10 days in the department which received the material, and by keeping all of the MSDS available in the Science Division Office, this mandate will be satisfied. Also, in Act No. 67 of the Public Acts of 1986, April 1, 1986, the information provision is extended to the chief of the organized fire department of the jurisdiction such that the quantity and location of any hazardous chemical specified by the chief should be provided within 10 working days (subject to an extension of 5 working days, upon request, at the discretion of the fire chief).
Since the MSDS will not be specific as to the location of each chemical, the Safety Committee will place a listing of all of the chemicals into a Quattro Pro program on floppy disc. The information will include the chemical name and the rating for each HMIS category. The Quattro Pro program will include a comprehensive list of all of the chemicals housed within the Science Division, and separate listings for the chemical inventory of each room in the Science Division. Any request for information will then be sorted out according to these criteria, as needed.
Each department is required to keep a listing of all of the chemicals located within its purview. This may be handled in conjunction with departmental inventory with the name of the chemical, the approximate amount in stock, and the location of the chemical indicated on separate papers or cards held in ring binders housed within each department. An inventory check should be performed once per year to insure maintenance of completeness of the listing. Any additions should be added as they arrive, and should also be added to the Hazardous Materials listing in the Quattro Pro program, if applicable.
Prescription drugs which may be used in laboratory applications should be kept in a locked cabinet. Several of the prescription drugs which are routinely used have a strong physical and/or psychological dependency liability and should be carefully monitored. A usage log should be maintained for each prescription drug. The log should indicate the amount and the person to whom the drug was dispensed. These log books should be carefully examined on a semiannual basis (e.g., end of each semester) to insure that they are accurate and that the usage patterns are reasonable.
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Last updated by Brian K. Dokter on May 12, 1997.