Policy 1100: Employee Right-to-Know Program

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University Policy #1100

Section 1. Policy

This program is established in accordance with the Minnesota Employee Right to Know Act of 1983.  The purpose of the act is:

  • Reduction and prevention of injuries and illnesses arising out of the work place.
  • Creation of safe and healthful working conditions.
  • Preservation of human resources.

Section 2. Authority

This policy is issued pursuant to the authority granted under Section 1.1, subdivision 2 (a) and (b) of the Minnesota State Colleges and Universities (MnSCU) Regulations.

Section 3. Effective Date

This policy shall become effective upon signature by the President and the Vice President for Administration and Finance, and shall remain in effect until modified or expressly revoked.

Section 4. Responsibility

The responsibility for implementation of this regulation is assigned to the Vice President for Administration and Finance.

Section 6. Implementation

In order to promote a safer and more healthful work place, and to comply with the Minnesota Right to Know Act, we will maintain a list of hazardous chemicals used in the workplace; maintain appropriate Material Safety Data Sheets (MSDS); ensure containers are labeled according to the act and provide appropriate employee training.

This program applies to all work operations in our company where employees may be exposed to hazardous substances or harmful physical agents under normal working conditions or during an emergency situation.

The Director of Facilities is the program coordinator and has overall responsibility for the program.  The Director of Facilities will review and update the program as necessary.  Copies of the written program may be obtained from the Facilities office.

Under this program, employees will be informed of the contents of the Employee Right to Know Standards, the hazardous properties of chemicals with which they work, safe handling procedures and measures to take to protect themselves from such chemicals.  Employees will also be informed of the hazards associated with non-routine tasks and the hazards associated with chemicals in unlabeled pipes.

LIST OF HAZARDOUS CHEMICALS

The Facilities Director will maintain a list of all hazardous chemicals and related work practices used in the work place and will update this list as necessary.  Where appropriate, a separate list will be made for special work areas.  Each list will also identify corresponding Material Safety Data Sheets (MSDS) for each chemical.  The master list with Material Safety Data Sheets will be maintained at the office of the Facilities Director.

LIST OF HARMFUL PHYSICAL AGENTS

The Facilities Director will maintain a list of harmful physical agents when present in the work place and workers may be exposed to the agents through equipment use, product handling or other work related activities.  Heat, noise, ionizing and non-ionizing radiation sources will be identified for each work area.  Lists will also identify the corresponding physical agent fact sheet (PAFS) for each source. 

MATERIAL SAFETY DATA SHEETS (MSDS)

MSDSs provides the employee with specific information on the chemicals used in the work place.  The Facilities Director will maintain a binder in the office with a MSDS on every substance on the list of Hazardous Chemicals that are present in the work place.  The MSDS will be a fully completed OSHA Form 174 (previously OSHA 20) or equivalent.  Each supervisor will ensure that each work site maintains a MSDS for hazardous materials in their area.  MSDSs will be made readily available to employees and other individuals required to be in such areas.

The Facilities Director is responsible for acquiring and updating MSDSs.  All persons purchasing or ordering products will obtain appropriate MSDSs and deliver such MSDSs to the Facilities Director.  All supervisors will verify that employees have received appropriate training prior to allowing employees to using chemical products.  All products used must be on the list of Hazardous Chemicals, if appropriate.  All new procurements must be approved by the Facilities Director.

LABELS & OTHER WARNING FORMS

The Facilities Director will ensure that all hazardous chemicals in the facilities are properly labeled and update such as necessary.  Labels will list the chemical identify; appropriate hazard warnings; and the name and address of the manufacturer, importer or other responsible party.  MSDSs will be used to verify label warnings.  Containers received at the facilities to be used by facility workers will be inspected by an appropriate supervisor to make certain all containers are properly labeled.

If there are a number of stationary containers within a work area that have similar contents and hazards, then signs may be posted on them to convey the hazard information.  When applicable, process sheets, batch tickets, blend tickets and similar written materials may be substituted for container labels when they contain the same information as labels.  These written materials will be made readily available to employees in the same manner as labels and MSDSs.

If chemicals from a labeled container are transferred to a portable container that is intended only for immediate use, no labels are required on the portable container.  Pipes or piping systems do not have to be labeled, but the contents will be described in the training sessions.

NON-ROUTINE TASKS

When employees are required to perform hazardous non-routine tasks (i.e., cleaning tanks, entering confined spaces that contain hazardous chemicals, etc.) a special training session will be conducted to inform them of the hazardous chemicals that may be encountered and proper precautions to be taken to reduce or avoid exposure.

TRAINING

Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training on the Employee Right to Know Standard and the safe use of those hazardous chemicals by an appropriate supervisor or the Facilities Director.  The attached program has been prepared for this purpose.

Whenever a new hazard is introduced, additional training will be provided.  Safety meetings will be used to review the information presented in the initial training.  All supervisors and managers will be trained regarding hazards and appropriate protective measures so all information will be available for employees and to provide daily monitoring of safe work practices. 

The training plan will emphasize these items:

Summary of the standard and this written program

  • Chemical and physical properties of hazardous materials and methods that can be used to detect the presence or release of chemicals (including chemicals in unlabeled pipes).
  • Physical hazards of chemicals (e.g., potential of fire, explosions, etc.).
  • Health hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical.
  • Procedures to protect against hazards (e.g., personal protective equipment required, proper use and maintenance; work practices or methods to assure proper use and handling of chemicals; and procedures for emergency response).
  • Work procedures to follow to assure protection when cleaning hazardous chemical spills and leaks.
  • Where MSDSs are located, how to read and interpret the information on both labels and MSDSs, and how employees may obtain additional hazard information.

The Facilities Director will review the employee training program and advise on initial training or annual retraining needs.  Retraining is also required when the hazard changes or when a new hazard is introduced into the work place.  As part of the assessment of the training program, the Facilities Director will obtain input from employees regarding the training they have received and their suggestions for improving it.

CONTRACTOR EMPLOYEES

The Facilities Director will advise outside contractors of any chemical hazards that may be encountered in the normal course of their work on the premises, the labeling system in use, the protective measures to be taken and the safe handling procedures to be used.  In addition, each company supervisor will notify these individuals of the location and availability of MSDSs.  Each contractor bringing substances in the company facilities will submit complete information on such substances.  As a minimum, the information will include MSDSs, labeling system used and precautionary measures to be taken in working with these substances.

All university employees or their designated representatives, may obtain further information on this written program, the Employee Right to Know standards, applicable MSDSs and chemical information lists by contacting the Director of Facilities.

Supplement #1 - List of Hazardous Chemicals

Supplement #2 - List of Harmful Physical Agents

Supplement #3 - AIDS Information

Supplement #4 - Safety Briefing

Supplement #5 - Asbestos Fact Sheet