Thomas Jefferson University

Jefferson's Written Hazard Communication Program

Introduction & General Statement

It is the policy of Jefferson to comply with the Occupational Health and Safety Administration ("OSHA") Hazard Communication Standard 29 CFR 1910. 1200 and to provide a safe working environment for employees, students, patients and their visitors. This policy specifies the procedures required to achieve this goal and the managerial responsibilities for ensuring compliance. This policy applies to all work operations at Jefferson where employees may be exposed to hazardous chemicals under normal working conditions or during an emergency situation

The Director of the Department of Environmental Health and Safety is the overall coordinator of the program. Department heads and chairs are responsible to ensure compliance with this program.

A hazardous substance is defined as any substance that is a physical hazard or a health hazard, i.e. compressed gases, explosives, flammables, oxidizers, corrosives, carcinogens, toxins, or irritants.

Copies of the written program may be obtained from the Department of Environmental Health and Safety in the Edison Building Suite 1630.

Container Labeling

The department head will verify that all containers received for use are clearly labeled as to the contents, note the appropriate hazard warning, and list the manufacture’s name and address.

The department head will ensure that all secondary containers are labeled with either an extra copy of the original manufacture’s label or with labels marked with the identity and the appropriate hazard warning.

The Department Head will ensure that all personnel (including contractors) will receive training on the labeling system used to identify hazardous chemicals.

Chemical Inventory

A Chemical Inventory List shall be created and maintained by each department that stores or uses hazardous materials. The list will contain the flowing information:

  1. Department Name
  2. Building and Room Location
  3. Contact Person and Contact Information
  4. Chemical Name
  5. Manufacture
  6. Total Quantities

The Chemical Inventory List must be kept on file in the department and a copy sent to the Department of Environmental Health and Safety. The list shall be updated annually and each time a hazardous material is added or removed from inventory.

Material Safety Data Sheets (MSDS)

Material Safety Data Sheets (MSDS’s) provide detailed information on a hazardous substance. The sheets include information such as:

  1. Identity of the substance
  2. Physical and chemical properties
  3. Physical hazards
  4. Health hazards
  5. Potential routes of entry
  6. Exposure limits
  7. Carcinogenicity
  8. Precautions for safe handling and use
  9. Emergency and first aid procedures
  10. Date of preparation of the MSDS

Department heads are responsible to obtain MSDS’s for all hazardous substances in their work places. Copies of MSDS’s are provided at the time of delivery by the chemical manufacture. They are also available via the TJUH Intranet. A binder containing copies of the MSDS’s must be kept in the department and be made readily accessible to employees during each work shift.

The Department of Environmental Health and Safety maintains an MSDS library for hazardous substances used or stored on campus. The MSDS Library is located at 130 S. Ninth Street, Suite 1630 Edison. 

Employee Training & Information

Every employee working with or potentially exposed to hazardous chemicals will receive initial training on the Hazard Communication Program at New Employee Orientation and than on an annual basis as part of Jefferson’s Health Stream Training Program. Department Heads are responsible for ensuring that employees are trained on the specific chemicals present in their workplace. This training must include the following elements:

  • An overview of the OSHA Hazard communication Standard
  • The hazardous chemicals present at his/her work area
  • The physical and health risks of the hazardous chemicals
  • Symptoms of overexposure
  • How to determine the presence or release of hazardous chemicals in the work area
  • How to reduce or prevent exposure to hazardous chemicals through use of control procedures, work practices and personal protective equipment
  • Hazardous chemical spill and leak procedures
  • Procedure to follow if employees are overexposed to hazardous chemicals
  • How to read labels and MSDS’s to obtain information
  • Location of MSDS's on file and written Hazard Communication Program

Department Heads must ensure that training is complete before an employee begins working with a hazardous chemical/substance.

Additional training must be provided for employees whenever a new hazard is introduced into their work areas.

Hazardous Non-routine Tasks

Periodically employees are required to perform non-routine tasks that require the use of a hazardous material(s). Prior to starting work on such projects, each affected employee will be given information about the chemical hazards associated with the performance of these tasks and appropriate protective measures to be taken. This information will be provided by the employee’s supervisor. The Department Head is responsible for listing examples of non-routine tasks.

Informing Outside Contractors

Any time a contractor is working on campus involving hazardous material(s) an MSDS(s) for the material(s) must be provided to Facilities Design and Construction, and the Department of Environmental Health. 4

It is the responsibility of Jefferson to provide contractors with information about hazardous chemicals that their employees may be exposed to on a job site and the recommended precautions their employees should implement to prevent injury/exposure. MSDS(s) are available to contract employees upon request by contacting the Department of Environmental Health and Safety.

Contractors are responsible for the training and education requirements of their employees outlined in Department of Labor's Occupational Safety & Health Administration's (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910. 1200

Contractors must comply with all of the provisions included in Jefferson’s Written Hazard Communication Program.

Chemicals in Pipes

Work activities are sometimes performed by employees in areas where chemicals are transferred through unlabeled pipes. Prior to starting work in these areas, the employee shall contact his/her supervisor for information regarding:

  • The chemical in the pipes
  • Potential hazards
  • Required safety precautions

Program Availability

A copy of this written program will be made available, upon request, to employees or contractors by contacting the Department of Environmental Health and Safety.