- Program Coordination
- Material Safety Data Sheets
- Hazardous Substance Inventory
- Factor Explanations
- Labels and Warnings
- Contractor Policy
- Infrequent Tasks and Unlabeled Pipes
This Written Plan has been prepared by St. Olaf College to describe our efforts regarding compliance with the requirements outlined in the Minnesota Right-To-Know Standard (MN Rules Chapter 5206).
Information is provided on the following subjects:
- Methods the College will use to compile and maintain a current inventory of hazardous substances.
- How the MSDS will be obtained and organized.
- How labels will be maintained and/or provided.
- How employees will be trained and informed about hazardous substances.
- How contractors will be informed of the hazards associated with their job activities at St. Olaf College.
St. Olaf College is committed tp providing a comprehensive program that will provide each employee with information about the substances they use or encounter in their work environment. In addition to the information found in this Written Program Plan, employees and/or their designated representatives have access to further information and resources which are also part of our employee Right-To-Know Program.
Overall coordination or the program for St. Olaf College will be handled by the Coordinator of Environmental Health and Safety.
A Material Safety Data Sheet will be kept for every material that appears on our Hazardous Substance Inventory List. The Master MSDS file will be maintained by the Coordinator of Environmental Health and Safety, and located in the Environmental Health and Safety Office, Ytterboe 224. In addition, the Biology and Chemistry departments have subscribed to a standardized collection of data sheets for laboratory materials, and these are available in the reference section of the Science Library, located in the Science Center.
Each department and/or work area where hazardous substances are used will maintain a file of MSDS for the work area(s), and will be responsible for assuring that the MSDS are accessible to employees during all work hours. Employees have the right to review the MSDS, and the employee or his/her designated representative must receive a copy within twenty four (24) hours of a request.
The College will maintain both a Master Inventory List, and Departmental Inventory Lists. The Master List will be maintained by the Physical Plant Office, and will be on file there. The Chemistry and Biology lists will be maintained with the departments. Hazardous substances used by other departments will be included in the Master List, and maintained in a computer database at the Physical Plant Office.
The inventory consists of a collection of summarized MSDS, alphabetical by trade name, for each substance we use. We have also printed these summaries so that they can be used as a quick reference. Since the MSDS books are sorted by manufacturer’s name, this summary will also act as an index for the MSDS book. This summary is not intended to replace the MSDS at all. Ideally, if there is a question regarding a product, the summary could be checked initially. If any questions remain, or protective gear is indicated, employees should refer to the MSDS for specifics.
The fields in the summary are set up as follows:
- Trade Name – This is the name of the product as it appears on the label.
- Substance – This is the type of product, possibilities might be detergent, stripper, etc.
- Manufacturer – This will most often be the firm that actually made the product, in some cases it will be a supplier.
- Emergency Phone – This is the number to call for emergency handling or treatment information. Use it only in case of real emergency, not for technical or use information.
- Ingredients – We have included all ingredients listed on the MSDS. Many of these are not hazardous, but many are. Most look very nasty because of the technical appearance of the names. Always read this section completely before becoming alarmed.
- Factor – This field list specific problems associated with the substance. Detailed explanations of each factor follow. Any time a factor is listed you should refer to the MSDS.
Corrosives are materials that will severely irritate or eat away body tissues. For the purposes of St. Olaf College, no materials are included that indicated that they were mild irritants or that they might irritate. Corrosives are acidic or caustic, that is, they have low or high Ph values. They are especially dangerous because they are also REACTIVE and may give off TOXIC fumes if they are engaged in reactions or exposed to fire.
Acids have many uses and are among our most valuable chemicals, but they need to be handled and stored properly. Proper protective equipment is a must for safe handling. Various products have different strengths, and some may require minimal equipment, that is splash-proof goggles and gloves. Other products may require full body protection and respiratory equipment. Acids are extremely reactive, and need to be stored away from caustics. Chlorine and ammonia products should especially be avoided as very harmful gasses will result from interaction between acids and these chemicals. Some work areas should be ventilated to avoid concentrations of harmful mists.
Caustics are used in a variety of ways, for us, most commonly as cleaners and disinfectants. They are also very reactive, and need to be handled very carefully. Contact with acids and oxidizers should be avoided.
Water should never be added to acids or caustics. When necessary to mix water with these chemicals, the acid or caustic should be added to the larger volume of water to avoid a violent reaction.
In the event of splashing or spilling, remove the worker to emergency eyewash or shower immediately. Follow directions. If the MSDS state to flush for fifteen (15) minutes, make sure that you do. Remove contaminated clothing, and get qualified medical attention. Do not attempt to stop leaks or perform cleanup without proper training and equipment. Hydrofluoric acid requires specialized care, be sure to report that hydrofluoric acid is involved to emergency responders.
Flammables for these purposes are essentially anything that will burn. Most flammables fall into one of three categories: Solvents, Flammable gasses, and Explosive dusts.
Solvents and solvent based mixtures are probably our biggest exposures. These take forms such as cleaners of many types, degreasers, thinners and fuels. Solvents are generally quite volatile. This means that they change form readily and will evaporate at low temperatures, often creating hazardous conditions. Most of these substances will also be classified as:
- Toxic – Flammable gases are used in many ways, but most often as fuels for various processes. Natural gas, propane and acetylene are used around us every day. Propane, acetylene and other compressed pose additional hazards because of the high pressure they are stored under. If a valve breaks on one of these bottles it can react very much like a rocket. Proper storage and handling is very important.Explosives dusts are often generated from relatively benign materials. Dusts from metals, grains food substances, plastics, soaps and wood products can all be dangerous. They present special problems if large areas become contaminated. A small dust explosion can form a chain reaction as the initial blast raised other dusts in the presence of these other substances may enhance the possibility of ignition taking place. Dusts may also be REACTIVE, CORROSIVE or TOXIC depending on the source material.It is most important to avoid conditions which might start a fire around any of these materials. Smoking or any type of open flame must not be allowed in an area in which solvents, flammable gases or explosive dusts are used or stored. Electrical equipment must be properly grounded and in excellent condition when used to pump or transfer materials or to ventilate storage and work areas. In some work and storage areas wiring should be explosion proof. Generally, we should try top eliminate any conditions which might start a fire.One of the best ways we can help maintain safe conditions is to do what we can to keep airborne concentrations as low as possible Solvents and liquid fuels must be kept in approved air-tight safety containers. Areas in which liquids are used must be kept properly ventilated. Systems that use flammable gases need to be kept in excellent condition, and valves and connections monitored regularly to protect against leaks.Spills of liquids need to be cleaned up properly and quickly. Many of these liquids generate heavier than air vapors which will seek the lowest level available to them. These areas often have electrical equipment or pilot lights which set off an explosion. Contaminated rags need to be stored and disposed of properly at the end of each shift so that spontaneous combustion or vapor problems do not occur. Dusts should not be allowed to build up in work or storage areas. High places, ledges and etc. need to be monitored. Dust collection systems need to be in place and working properly when called for.
- Flammable liquids and solvents should be stored properly in special cabinets or rooms designed for this use. Flammables must be stored well away from oxidizers The presence of oxidizers may make the materials more readily ignitible and will make a fire far more intense by supplying more oxygen to the material than otherwise available.
- If a spill or other emergency involving these types of substances occurs, remove all ignition sources and leave the area. Pilot lights and electrical equipment should be shut down. Flush eyes and exposed skin with large amounts of water. Remove contaminated clothing. Get to fresh air.
- If you are going to attempt to stop a leak, perform a clean up or fight a fire, make sure that you are familiar with the proper methods and have the equipment you need before you start the work. Many of these materials require special training .
- Reactives – Reactives are materials that are unstable, and will react with air, water or other chemicals to produce heat or dangerous gases. While some are fairly stable, they have incompatibilities with other materials that may result in harmful situations. We have broadened this category somewhat to include materials whose MSDS describes as stable, but are incompatible with oxidizers. Oxidizers may contribute free oxygen in a reaction, drastically lowering flashpoints. Many materials will burn at room temperature when exposed to oxygen. Other substances may burn when exposed to water, so it is important to note a material’s incompatibilities.Proper storage of reactives is probably the most important consideration for us in their handling. Reactives should never be stored in the presence of incompatible materials. In our daily work we should never mix chemicals. Probably the most common injury in physical plant work occurs through the mixing of acid and bleach or bleach and ammonia. The substances we use are designed to be handled according to their directions. Making solutions stronger than called for will often compromise their ability to do the job properly, and could result in dangerous situations. Water should never be added to solutions of acids or caustics, the corrosive should always be added to the larger volume of water.If a dangerous reaction is occurring in your workplace it should be treated as a dangerous gas or fire problem. Do not try to neutralize the reaction unless you have been trained properly. never re-enter a space until you have received a clearance. If flammables are involved, shut down electrical equipment as you exit.
- Toxic Chemicals – Toxic chemicals are those substances that affect the internal systems of the body. That is, they are actually poisonous or destructive to the tissues. Toxics can have acute or chronic effects. Acute toxic effects are apparent after a short exposure to a TOXIC substance. Many acute effects disappear after the victim is removed to fresh air, but some may cause permanent damage or death. Chronic effects appear after long term exposures to toxic chemicals. Toxics enter the body three ways: inhalation, skin absorption, and ingestion.
- Inhalation – When chemical vapors become airborne, people in the area will be subject to them through inhalation. As you breath, whatever substances are in the air enter your lungs, and are then distributed throughout your body. When using chemicals which are listed as toxic, always handle them so that airborne concentrations are held to a minimum.Concentrations can be held down by use of safety cans and cabinets, disposing of contaminated rags and other materials properly, and use of adequate ventilation. If vapors accumulate to the point that Threshold Limit Value, or Permissible Exposure Limit on the MSDS are likely to be exceeded, be sure to use proper protective equipment, have adequate ventilation available or cease the process you are using and leave the area.
- Skin Absorption – The skin is good protection for our bodies, but it is permeable, that is, substances can pass through it and enter the body. Skin absorption can be managed by safe handling practices, and proper use of safety equipment such as gloves, boots, face shields, and protective clothing. A key factor in minimizing the possibility of skin absorption is good hygiene. Do not leave substances on your skin, wash thoroughly, following directions. clean clothes properly before wearing them again.
- Ingestion – Toxic chemicals are most often ingested while eating drinking or smoking. Good hygiene practices are especially important. Wash thoroughly before taking breaks or meals if you have been using toxic substances which might be ingested in this way. It is also important to keep food and drink away from these materials so that they do not become contaminated. Solvents, petroleum products, metals, gases, pesticides, dusts and plastics and the materials associated with them are often TOXICs.Solvents present handling problems because they are very volatile, that is, they change form readily. Most will evaporate at low temperatures and become airborne. They enter the body most readily through inhalation, but may also be absorbed. Children may ingest them, but this is unlikely for a worker unless she or he fails to wash hands before eating.Solvent exposures may cause fatigue, dizziness, nausea, unconsciousness, dermatitis, irritation of skin and eyes, and chronic effects ranging from liver and kidney damage to cancer and birth defects.Petroleum products such as lubricants and machine oils can cause problems because they are often handled in processes or encountered as mists. Exposures can be limited by proper handling, ventilation, protective equipment, and frequent changes of work clothing. Irritations of the lungs, skin and eyes are among the most common problems encountered with these materials, most can be easily avoided with proper use and handling.Metals are usually inhaled as dusts, but may be ingested with food or drinks. Dusts are common in metal working situations such as machine or welding shops. Some metals are relatively harmless, such as iron, while others can be very toxic. These include materials such as lead and cadmium.
- Risks can be minimized by using proper ventilation, especially in situations involving molten metals and spray painting. it is also important to control metal dusts as some, especially aluminum can be explosive. Appropriate personal protective equipment is essential to avoid heat and TOXIC injuries. Respiratory protection is a must for some situations. Exposures to lead and cadmium must be carefully monitored. Again, good hygiene practices can be very helpful.
- Toxic effects can range from dermatitis, or skin irritations, to kidney and nervous system damage. Metal fume fever is a possibility when exposed to fumes of zinc, brass and copper. This produces flu like symptoms with a metallic taste in the mouth.
- Gases may be toxic in different ways. Some are actually poisonous to the body. Carbon monoxide and hydrogen sulfide are examples of materials that will actually kill you through their toxic properties. Other gases may not harm you in low concentrations, but in large volumes will displace oxygen so that you cannot get enough to live. Gases as seemingly safe as nitrogen and carbon dioxide fall in this category. They are often referred to in MSDS as simple asphyxiants. Still other gases are corrosive, and will burn if inhaled. Chlorine, ammonia and formaldehyde are the most common of this type.
- We can protect ourselves by using gases appropriately and in well ventilated areas. Respirators or self-contained breathing equipment may be necessary in some situations. Goggles and gloves may be important when using gases that are considered corrosive.
- Never attempt to stop or repairs leaks involving toxic gases, or rescue persons overcome by gases unless you have self-contained equipment and proper training. Each year people die while trying to rescue friends or co-workers who have been overcome by toxic gases. Your friend and you will be best served if you can give responding personnel details of the substances and circumstances involved in an accident of this type. Dusts of all types present problems, but mineral dusts are most often toxic. Asbestos is probably the most recognized, but silica, talc, graphite, coal, clay, limestone, fiberglass and rock wool can all cause problems.
- Although inhalation is the primary vehicle for entering the body in a harmful way, skin irritation may result from prolonged contact with dusts. Lung diseases such as asbestosis, silicosis and black lung can result from chronic exposures to dusts. Cancers are also associated with exposure to asbestos.
- Dusts can be managed through proper handling and cleanup procedures. Use adequate ventilation and protective equipment when working with dusts in confined spaces. Wet processes generally work better for cleanup. If you work with toxic dusts during the day with protective equipment, do not disregard your dusty work clothes at the end of the day. It is important to thoroughly clean your self and your clothes to minimize exposure to family members and others.
- Comment – This field will give a brief explanation of handling procedures when appropriate. Other considerations that a user should be aware of will also be listed in many cases. Again, this is intended as a quick reference. Always refer to the MSDS for very specific information if you have any questions.
- Protective Equipment – The bottom line of the summary lists protective equipment associated with the use of the substance. Use is definitely recommended if the item is marked YES with a “Y”. “O” indicates that use is optional or required only in certain circumstances. If any of these fields is marked “Y” or “O”, refer to the MSDS.
No incoming containers of hazardous substances may be accepted unless properly labeled with the following information:
- Identity of the hazardous chemical(s).
- Appropriate hazard warnings.
- Name and address of the manufacturer, importer, or other responsible party.
No label or incoming container is to be defaced or removed, and no product may be accepted from shipment if labels have been damaged, obscured or removed. Each department head listed earlier will be responsible for this requirement, and should be contacted if damaged or incomplete labels are found. Each department head or foreman will also be responsible for ensuring that label information is kept current, and that it corresponds with the information on the matching MSDS.
Materials should not be transferred from bulk to unlabeled transfer containers, unless the entire amount is used in the current shift by the person performing the transfer. If the transfer container is used longer than the current shift, it must be marked with the following information:
- Identity of the hazardous chemical(s).
- Appropriate hazard warnings.
Each employee will receive training and information before they are assigned to a work area where they may be working with, or be exposed to, a hazardous substance. Annual formal training will be conducted by, or under the direction of, the Director of Facilities. Department supervisors will also conduct training on an as needed basis. The Assistant Director of Personnel, will maintain the Right-to-Know training records, and advise the departments regarding additional training needs.
Training sessions will include the following information:
- The requirements of the Right-to-Know Program, and the contents and location of the Written Program Plan.
- Information about the types of hazardous substances that employees are working with and/or exposed to.
- Training on how to read and use labels and MSDS
- Training on the use of protective equipment, proper work practices and emergency procedures.
- Information about the rights of the employee and the employer under the Right-to-Know Law.
- Information on how to obtain and use additional information on hazardous substances in the employee’s work place.
In order to inform outside contractors of the hazardous substances they may encounter while working at St. Olaf, the Director of Facilities will serve as the contractor contact for the College.
The contractors will be notified by the Director of the applicable hazards and provided with appropriate information so that the contractor(s) may train their people.
Non-routine activities will be coordinated through the Physical Plant Office to make sure that employees are informed of the hazardous substance exposures, and provided with the necessary training and personal protective equipment needed to safely complete the job. Before activities in questionable areas begin, the Director, or applicable department supervisors should meet with employees to discuss the potential hazards they may encounter.
Under the supervision of the Director, department supervisors will inform employees of the dangers associated with any hazardous substances located in unlabeled pipes within their work areas.