Hazard Communication for Supervisors

University of Idaho employees are covered under the worker protection requirements of the Idaho Division of Building Safety (DBS) Hazard Communication Program. This standard requires that employers provide their employees with information on the hazards of the chemicals used in their work areas and ensure the employees understand the information.

What is the Globally Harmonized System (GHS)?

In 2012, the United States adopted a United Nations standard pertaining to labeling of chemical containers, classification of chemical hazards, and the distribution of the information in a standardized manner, known as the Globally Harmonized System (GHS). Included in this change are new pictograms that indicate the hazard(s) of a chemical, a new format for Safety Data Sheets (SDSs, formerly called Material Safety Data Sheets or MSDSs), and a simplification of the signal words used in labeling. Additional information about these new requirements can be found in the Resources section below.

Does this program apply to my employees?

The program applies to all university employees who may handle or be exposed to hazardous chemicals except for the following exempt or conditionally-exempt situations.

Office use of any consumer product that is used for its intended purpose, provided it is used in a manner consistent with reasonable consumer use. For example, office use of products such as printer toner, glass cleaner, disinfectants, furniture polish, etc., is exempt as long as the frequency and duration of use is comparable to home use. An employee that uses glass cleaner all day long every day would not be exempt from this program.
Warehouse and shipping/receiving operations where employees only handle chemicals in sealed containers, which are not opened under normal conditions of use by these employees, are conditionally exempt. They must be provided with the information necessary to protect them in the event of a spill or a leaking hazardous chemical container.

Additionally, certain substances are exempt from this program. Please refer to the Hazard Communication Written Program for a list of specific exemptions.

What are the major program components?

The Hazard Communication Program is simple in concept: employees have the right to know and understand the chemical hazards they may be exposed to in the workplace. To accomplish this goal, the program has some basic requirements.

A written plan, specific to each work area, must be available to employees.
A list of hazardous chemicals in the specific work area must be maintained.
Safety Data Sheets (SDSs) for these chemicals must be readily available to employees.
All chemical containers must be properly labeled.
All employees must complete training at the time of initial hire and at any time a new chemical hazard is introduced into the workplace.

What are the responsibilities for supervisors under this program?

Supervisors play a key role in the effectiveness of the Hazard Communication Program. Major responsibilities in the implementation of this program include:

completing the unit-specific Written Program Template and maintaining a copy in the work area;
identifying and listing all hazardous chemicals in use by employees;
obtaining Safety Data Sheets (SDSs) and ensuring employees have access to them (electronic or paper copies may be used; however, a binder of organized paper copies is considered best practice);
ensuring all chemical containers are labeled;
completing job hazard analyses (JHAs) and SOPs as necessary;
identifying the hazards of non-routine tasks;
informing and training employees;
ensuring proper personal protective equipment (PPE) is available and properly used;
maintaining documentation (SOPs, employee training, etc.); and
adequately informing non-university personnel (such as contractors, USDA employees, etc.) sharing the same work area of the hazardous substances to which their employees may be exposed while performing their work.