Staff HR Policy D-746.00
Institutional Effectiveness Criterion: Culture

Hazard Communication Program

The Hazard Communication Program has been created for compliance with the Occupational Safety and Health Administration (OSHA) and Michigan Occupational Safety and Health Administration (MIOSHA) guidelines. The Michigan Right-to-Know Law was enacted to ensure that necessary information is provided to employers and employees who could be exposed to hazardous chemicals in their workplace. It requires a communication program designed to safeguard the handling of hazardous chemicals through container labeling, the availability of Safety Data Sheets (SDS), employee training and a written hazard communication program. 

The law also provides for specific employee rights, including:

1. The right to be notified (by employer posting) of the location of SDSs
2. The right to be notified (by employer posting) of new or revised SDSs no later than five working days after receipt.
3. The right to request SDSs from their employers.

Employees are protected from any discrimination or discharge resulting from the request for information regarding hazardous chemicals under the Right-to-Know Law. The following written hazard communication program has been established for Northwestern Michigan College:

1. Hazard Determination RequirementsNMC will rely on SDSs from material suppliers to meet hazard determination requirements.
2. Labeling
   1. Incoming Containers:The employee ordering a chemical must ensure that all incoming containers are properly labeled before entering an NMC facility.  labels must be verified for compliance with OSHA Globally Harmonized (GHS) standards, ensuring they clearly display the product identity, manufacturer information, signal word, pictograms, and hazard/precautionary statement(s)
   2. Portable Containers: Each employee  must ensure that any portable (secondary) containers used in their work area are labeled with the chemical identity and appropriate hazard warnings. (Note: Labels are not required if a secondary container is intended only for the immediate use of the employee who filled it during that specific work shift.)
3. Safety Data Sheets (SDS)
   1. The Campus Safety and Security office  is responsible for maintaining the master campus-wide SDS file.
   2. Copies of SDS for all hazardous chemicals to which departmental employees may be exposed will be kept on file by a designated department official and accessible to everyone.
   3. The employee purchasing  the chemical will request SDS with all purchases and ensure SDS are published to NMC’s SDS Google Drive within 5 days of purchase. MIOSHA Right-to-Know posters will be posted on each campus by Human Resources in highly visible areas.Posters will include the exact location and access instructions for the digital SDS Google Drive. Notices of new SDSs must be added to the poster within 5 working days of receipt and must remain for a minimum of 10 days.
4. Employee Information and Training 
   1. A department supervisor or their designee shall coordinate and maintain records of Hazard Communication/Right-to-Know training conducted in their area.
   2. As part of new employee orientation, before handling chemicals, each new employee will receive information and training from their supervisor on:
      1. Chemicals and hazards in the work areas
      2. How to lessen or prevent exposure to these hazardous chemicals
      3. What the College has done to lessen or prevent worker's exposure to these chemicals
      4. Procedures to follow if exposed to these chemicals.
   3. Specific hazards, labeling, and handling protocols for "Chemicals Under Pressure." Employees working with or around pressurized chemical systems—including liquids or solids contained in a pressure vessel with a compressed propellant gas—must be trained on how to identify the Gas Cylinder pictogram on the SDS, recognize pressure-related physical hazards (such as rapid decomposition, violent rupture, or projection hazards), and follow safe handling and storage
   4. How to read and interpret labels and SDS.Each affected employee will sign a statement that they have received this training and  information.
   5. Before any new, hazardous chemical is introduced into an area, each affected employee will be trained as outlined above. The department supervisor or designee is responsible for ensuring the SDS for the new chemical is available.
   6. Before any new, hazardous chemical is introduced into an area, each affected employee will be trained as outlined above. The department supervisor or designee is responsible for ensuring the SDS for the new chemical is available.
5. Hazardous Non-routine Tasks and Confined Spaces
   No employee will begin a non-routine hazardous task or enter a confined space without first completing training assigned by Human Resources and/or specific instructions from their supervisor. Before completing non-routine, chemical-related tasks, employees will be trained in the following four elements:
   1. Specific Chemical Hazards: Exactly what hazardous chemicals will be encountered/used during this task.
   2. Required Protective Measures: The specific Personal Protective Equipment (PPE) required (i.e. chemical-resistant gloves, respirator, ventilation requirements) two person rules, etc.
   3. Existing Safety Measures: What the college has done to mitigate the risk.
   4. Emergency and Spill Procedures: Steps to take if something goes wrong. (i.e. location of nearest eyewash station, safety showers, and spill kits.)
6. Pipe Labeling
   Facilities, along with external contractors, will ensure all pipes and piping containing hazardous chemicals, compressed gases, or high-pressure utilities on campus  are properly labeled to prevent accidental exposure. This includes water treatment, boiler system operations, natural gas, propane, oxygen, and any other chemical-based pipelines on any of NMC’s campuses.
   1. Identification Methods: Facilities will ensure that piping systems are identified with standardized color-coded physical labels, tags, or prominent placards that clearly state the name of the substance and its direction of flow.
   2. Alternative Tracking: In areas where direct labeling is structurally impractical, current mechanical schematics, process flow charts, or piping maps detailing the contents will be maintained and made available to employees by the facilities staff.
   3. Employee Training: Before beginning any work involving or adjacent to piping systems, affected employees must be trained by their supervisor or designee on how to read and interpret the specific pipe labeling system or schematics used in the work area.
7. Reciprocal Contract Information Sharing 
   Departmental supervisors will coordinate a reciprocal safety data exchange with contractors before onsite work begins.  NMC will provide localized hazard and emergency protocols, and contractors must provide SDSs for any chemicals they bring to campus. Supervisors will ensure contractors are informed that the master campus SDSs are on file on the Google Shared Drive.
8. List of Hazardous Chemicals
   An active, accurate Workplace Chemical Inventory List must be compiled and maintained by each department, and cross-referenced exactly to the names found on the SDSs as required by MIOSHA guidelines. Master copies of all departmental chemical lists are consolidated and maintained by the Campus Safety and Security Coordinator. 
9. First Responder/Fire Department Notification
   A copy of the campus written hazard communication program, the master chemical inventory list, and explicit maps showing where hazardous chemicals are used or stored on campus will be provided to the Traverse City Fire Department or first responders within 10 working days of a request, or during annual compliance updates.
   

The Associate Vice President of Human Resources and the Vice President of Finance and Administration, in conjunction with the appropriate faculty and staff, are responsible for the development and publication of any procedures or guidelines that may be necessary to administer this policy effectively.

If any provision(s) of this policy or set of bylaws conflicts with laws applicable to Northwestern Michigan College, including the Community College Act of 1966, the Freedom of Information Act, or the Open Meetings Act, as each may be amended from time to time, such laws shall control and supersede such provision(s).