The Right to Know (Hazard Communication) Policy

Purpose and Application

This policy document is written to ensure that employees and students are alerted and properly trained in the safe use of hazardous substances with which they may come in contact. We will accomplish this by compiling lists of hazardous substance, harmful physical agents and infectious agents, maintaining and using Material Safety Data Sheets (MSDS), ensuring proper container labeling, and by providing employee training.

This policy document applies to all College of Saint Benedict and Order of Saint Benedict (CSB|OSB employees and students who may work with hazardous substances.

Definitions and Scope

“Hazardous Substances” include a wide range of chemicals such as cleaning products, pesticides, and even toner for copiers, as well as many compounds used in instructional and research laboratories. Hazardous waste (medical, biological, radioactive, and other).

“Material Safety Data Sheets (MSDSs)” provide safety information about specific hazardous substances including the hazards and control measures.

Employees and students have a “right to know” about the hazardous substances they work with and how to handle them safely. All employees are responsible for following safety instructions on labels and MSDSs and complying with safety procedures.

Roles and Responsibilities

The Environmental Health and Safety (EHS) is responsible for:

  • Assisting departments with general Right-To-Know information and training guidelines and
  • Maintaining an up-to-date written Right-To-Know (hazard communication) program.

Each department is responsible for maintaining up-to-date inventories of hazardous substances and making MSDSs readily available. Each department purchasing or using hazardous chemicals is to assign a person responsible to coordinate the purchasing, inventory, dispensing, and forwarding of MSDSs as appropriate.

Copies of the MSDSs for all new procurements must be sent to the EHS. Departments shipping hazardous materials are to make sure that all containers shipped from CSB|OSB facilities are properly labeled and that the transporter is authorized and aware of the nature of shipment.

Supervisors are responsible for providing job-specific training to all their employees, including a discussion of how to safely handle hazardous substances in their work area. Supervisors are responsible for identifying any new hazardous substance before it is introduced into the workplace and informing employees in the work area about the dangers of such hazardous substances. EHS will assist supervisors in the identification and information.

Procedures

Training
All new employees who may work with hazardous substances will at minimum receive Right-To-Know training during new employee orientation. Individual departments will provide job-specific training on the safe use of hazardous substances in their work area. Additional training is provided whenever a new hazard is introduced into a work area. The training method must provide an opportunity for the employee to ask questions. The individual department may hold safety meetings to review the initial and/or additional training materials

Written Plan
Copies of the comprehensive written Right-To-Know (Hazard Communication) is primarily available on the EHS website. The plan may be obtained from EHS office.

Warning Labels
Hazardous substances must be labeled with the main hazard name, the hazard warning and measures to protect the user against exposure risks. All employees and students are expected to read labels and follow instructions and warnings. Detailed labeling requirements are specified in the Right-To-Know Plan.

Material Safety Data Sheets
The purpose of the Material Safety Data Sheets (MSDS) is to describe the physical and chemical properties of hazardous substances as well as their health hazards, routes of exposure, precautions for safe handling and use, emergency and first aid procedures, and control measures. MSDSs must be available in the immediate work area. EHS will provide assistance in obtaining MSDSs.

Record Keeping
The Environmental Health and Safety will maintain copies of records of all employees who are provided with the Right-To-Know training. Each department must maintain a record of individual department training and forward a copy to EHS.

Hazardous Chemicals Lists
Each department is responsible for maintaining an up-to-date list of hazardous substances present. This list should be readily available to EHS.

Contractors
The CSB|OSB will inform all contractors of known hazards contract employees may encounter while performing work at our facilities. Contractors similarly must disclose anticipated hazardous operations and observe our safety procedures. The College/Corporate project manager may contact EHS to develop job-specific safety information as appropriate.

Key References and Resources

The documents listed below may be obtained from the Environmental Health and Safety Office.