Hazardous Communication

arrow_circle_left Back to All Policies

Approved by: President's Cabinet

Original Date Effective: 2024-07-01

Last Modified:

Purpose:

The Jackson State Community College’s Hazardous Chemical Right-To-Know Program is modeled after the Tennessee Hazardous Chemical Right-To-Know Law passed by the General Assembly on May 23, 1985. The Tennessee Right-To-Know Law was enacted because of expressed concern relative to the proliferation and variety of chemicals present in our society and their effect on the safety, health, and welfare of persons living and working in Tennessee.

The intent and purpose of Jackson State Community College’s Right-To-Know Program is to provide necessary information that will enable college employees and students to become knowledgeable of the chemicals they work with and to which they may be exposed.

Policy/Procedure:

The college's Right-To-Know Program centers on the completion of the following:

  1. Assigning an individual responsible for implementing the program in each department, or, if necessary, in each work area.
  2. Making a list of all chemicals and by-products used, stored, or produced in each department or area.
  3. Obtain a current Safety Data Sheet (SDS) for each chemical, substance, or by-product listed.
  1. Understand how to determine which chemicals, by-products, or substances are hazardous.
  1. Preparing the Workplace Hazardous Chemical List.
  1. Submitting the hazardous chemical list to the Health and Safety Office for compilation and submission to local emergency response agencies. The hazardous chemical list is due on January 1 of each year.
  2. Ensuring that all containers are properly labeled.
  3. Training the employee
  4. Multi-employer workplaces (non-employees of Jackson State Community College who may have exposure while they are on any JSCC sites).

Notification 

The Occupational Safety Health Administration (OSHA) poster “You Have a Right to a Safe and Healthful Workplace” will be the means of informing employees about their rights under the Tennessee Hazardous Chemical Right- To-Know Act. These posters, available from the JSCC Campus Police Department, must be displayed in a conspicuous location for each area. 

Roles and Responsibilities 

The overall responsibility for the program lies with the Chief of Police. The Chief of Police will work with the Director of Physical Plant to: 

  1. Coordinate, audit, and determine compliance with JSCC’s Hazard Communication Program including annual updates and revisions.
  2. Maintain the library for Safety Data Sheets.
  3. Submit any required regulatory agency reports.
  4. Collect and keep records of chemical inventory reports.
  5. Work with local fire departments to provide chemical inventory, Material Safety Data Sheets / Safety Data sheets, and contact information for college personnel to be contacted during an emergency.
  6. Make available the necessary training to ensure compliance.
  7. Serve as a resource for questions and comments concerning JSCC’s Hazard Communication Program.
  8. Conduct routine inspections to assure compliance with safety processes that protect workers from the dangers of hazardous chemicals.

 Department Heads and Supervisors 

  1. Ensure that all employees who might have exposure to hazardous chemicals are trained and understand the Hazard Communication Program / Right to Know Law.
  2. Provide proper Personal Protective Equipment for employees.
  3. Assure that students, visitors, contractors, sub-contractors, vendors, and salesperson(s) are informed of where any hazardous chemicals are located and provide necessary precautions to ensure their safety.
  4. Assure that all containers are properly labeled
  5. Respond to emergency situations such as employee or student exposure, spills/leaks, and fires.

 Hazardous Determination   

The college is required by the Right-To-Know Law to maintain an inventory of all hazardous chemicals/materials in the workplace.  From this inventory, information is obtained to aid employee education and training, and data is compiled for submission to the Department of Labor if requested, and local emergency response agencies concerning the hazards on campus.  It is essential that all departments complete inventories as accurately as possible. Safety Data Sheets may be used to evaluate whether the listed chemicals are hazardous chemicals.

Hazardous chemicals are listed in the “Hazardous Ingredients” section of the Safety Data Sheets.             

Safety Data Sheets

Jackson State Community College is aligned with the Globally Harmonized System (GHS).  

All manufacturers and distributors supplying Jackson State Community College with products that contain hazardous chemicals must provide the college with a Safety Data Sheet (SDS) for that product. The SDS must be provided prior to or with the initial shipment of the product to the college. If an SDS is updated, a copy should be forwarded with the first shipment of chemicals after the occurrence of the update. If a product is not considered hazardous, the supplier must provide a statement to that effect. If an SDS is not shipped with the product or received within five (5) days after shipment, the department should request the SDS from the supplier.

Safety Data Sheets are not required for products that are: 

  1. Packaged in small containers (such as spray cans), and
  2. Used infrequently, and
  3. Obtained from general retail stores.

Note: The hazardous chemical must meet all three requirements to be exempt from the SDS rules. 

Each department will provide access to copies of the current Safety Data Sheets on each hazardous chemical in the workplace. 

The Chief of Police maintains the Safety Data Sheet library. 

Safety Data Sheets must be maintained on a current basis and must always be readily accessible to employees.

If an employee seeks a Safety Data Sheet and it is not available, they may submit a written request through their department head to the Chief of Police. The Chief of Police is required to furnish a copy within three (3) business days after receiving the written request. If the Safety Data is not available, the Chief of Police will notify the requestor that an effort has been made to obtain the SDS. If, after two weeks, the Chief of Police is still unable to obtain the requested Safety Data Sheet, the employee shall not be required to work with the hazardous chemical for which the SDS was requested. There shall be no penalty for not doing such work. Reassignment of the employee to other work, at equal pay and benefits, shall not be considered a penalty under this section.   

Container Labeling 

All containers of hazardous chemicals must be properly labeled, tagged, or marked.  Proper labels should indicate the following: 

  1. Identity of the hazardous chemical, i.e., the common and/or chemical name as well as any chemical ingredients.
  2. The name and address of its manufacturer, importer, or other party responsible.
  3. Its potential physical hazards (If not handled properly, it might burn, explode, react, etc.).
  4. Its potential health hazards (e.g., overexposure may irritate the skin, burn the eyes, cause dizziness, cause cancer, etc.).

Any container from a chemical manufacturer that has converted to the GHS system must have the following information: 

  1. Product Identifier;
  2. Signal Word;
  3. Hazard Statement(s);
  4. Pictogram(s);
  5. Precautionary Statement(s);
  6. Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

Note: Existing labels on containers must not be removed or defaced. 

Secondary Container Labeling Transfer  

Materials that are transferred from the original container to a secondary container must have a secondary container label.  Secondary container labeling must at least include the product identifier and words, pictures, symbols, or a combination thereof, which in combination with other information immediately available to employees, provide specific information regarding the hazards of the chemicals. Container labels may be obtained from the Director of Physical Plant. 

Education and Training Program 

The department supervisor, in conjunction with the Chief of Police and the Office of Human Resources, is responsible for coordinating and conducting training for new employees. The Chief of Police will provide the training program. The training may be conducted online or instructor-led in a classroom setting. Departmental supervisors are responsible for ensuring that all elements required of the training program are implemented within their respective departments. To comply with Tennessee law, refreshers must be provided on an annual basis. The training program shall include, as a minimum, the following: 

  • Defining the Hazard Communication Standard, the reasons why the standard was written, and the employees’ rights under the standard.
  • Explanation of the written plan and how each employee can access the plan.
  • Information on how to interpret container labels and Safety Data Sheets, and to understand the relationship between these two methods of hazard communication.
  • The location of the workplace chemical list and Safety Data Sheets file and employee rights of access to them. 
  • Places in an employee’s work area where hazardous chemicals are present.
  • The physical and health hazards of hazardous chemicals in the work area. The chemical’s long-term and short-term effects on the body and how the chemical can be detected if present.
  • Measures that employees may use to protect themselves from chemical hazards. These would include proper work practices, personal protective equipment, emergency procedures, etc.
  • General safety instructions on the handling, clean up, and disposal of hazardous chemicals. This would also include what to do in the event of a chemical spill.

Hazardous Chemical Inventory 

Each department must make a Workplace Hazardous Chemical List of all chemicals within their respective areas. When chemicals are added or deleted, the list must be updated. A copy of the current chemical lists must be forwarded to the Chief of Police upon request or when the list is updated. The chemical inventory list shall be kept on file for 30 years. 

Multi-Employer Workplace 

Anyone who is not an employee of Jackson State Community College but is conducting services at any of our sites where they could be exposed to hazardous chemicals shall be made aware of the elements of the Hazard Communication Program to ensure their safety. The Supervisor or Department Head that is responsible for the area that the non-employee of JSCC will be in shall: 

  1. Provide access to and ensure the understanding of Safety Data Sheets for the chemicals in their area.
  2. Assure that proper Personal Protective Equipment is used if required.
  3. Communicate procedures on how to react to exposure. This would include procedures for eyewash and shower stations, and evacuation in the event of a spill.