Hazardous Communication Guide / Right to Know
Summary of Requirements
- Employees working with or near hazardous materials must receive initial and annual refresher training.
- Containers with chemicals must be properly labeled at all times. This includes the name of the material and the required hazard warnings. Container labels must not be defaced unless empty.
- Appropriate labels must be placed on containers of hazardous materials unless used during a single shift.
- Safety Data Sheets (SDSs) must be obtained for all hazardous materials used at Stony Brook University. SDSs must be made available to employees working with hazardous materials.
- Hazardous materials must be inventoried and compiled into a Chemical Information List (CIL).
- A written Hazard Communication Program has been developed and implemented for Stony Brook University.
The Hazard Communication/Right to Know (RTK) program provides people with the hazards and identities of the chemicals they are exposed to in the workplace. When workers have this information, they can take steps to protect themselves. Stony Brook University has implemented a protective program for all workers potentially exposed to hazardous chemicals. The RTK program incorporates a "downstream flow of information," which means that producers of chemicals have the primary responsibility for generating and disseminating chemical safety information through labels and Safety Data Sheets (SDS), and Stony Brook University EH&S provides this information to the workers through training (EH&S Course EOS 018) and having the SDSs available.
EH&S maintains a written RTK plan and provides training in compliance with both the federal OSHA Hazard Communication Standard and the NYS PESH Right to Know laws. This RTK program covers hazardous chemicals used in most areas of Stony Brook University, including custodial, maintenance, and many classes. The Laboratory Safety program provides chemical safety information for chemicals used in the academic and research laboratories.
You Have a Right to Know!
Download the "You Have A Right To Know" poster
The regulations have been updated to provide clearer information to everyone who uses chemicals. These changes now make this the "Right-to-Understand" regulation. The safety information provided on product labels and safety data sheets (formerly material safety data sheets or MSDSs) is now standardized and all manufacturers are required to use the same hazard warnings and precautionary statements for the same chemical. This will allow for consistency in the information that the user has available to them.
There are 8 new "pictograms" or hazard warning symbols that are required to be used on the labels. Most products will have a combination of 2 or more symbols. These pictograms will provide immediate safety information to the user. (http://www.osha.gov/Publications/HazComm_QuickCard_Pictogram.html)
There is a new format for labels that will provide more information to the user. The information will be more consistent between manufacturers and provide quick visual notations to alert the user, providing immediate recognition of the hazards. (http://www.osha.gov/Publications/OSHA3636.pdf)
The new safety data sheets (SDS) are standardized into a 16-section format. The manufacturer is required to use the standardized hazard and precautionary statements on the SDS. The SDS will now provide additional safety information to the user that will be consistent between manufacturers. (http://www.osha.gov/dsg/hazcom/SDSitems.html) Safety data sheets can be found through the EH&S web site.
Some manufacturers have already begun using the new label and SDS formats. Manufacturers have until June 2015 to have all products with the new labels and SDS formats. EH&S is beginning to update all chemical safety training to include the new pictograms and SDS formats. This training will be available to the campus community soon.
If you have any questions on the labels, SDS or other chemical safety questions, contact the Department of Environmental Health & Safety at 632-6410.
Training
All employees working with or near hazardous materials receive RTK training during New Employee Orientation and annual refresher training scheduled by their department. Training includes:
- Information about the nature of the physical and health hazards of chemicals in the work area.
- Methods and observations to detect the presence or release of a hazardous chemical in the work area.
- Appropriate work practices, control programs and preventive measures to avoid chemical exposure.
- Emergency procedures.
- Details of the Hazard Communication Program.
- Explanation of container labeling systems.
- Introduction and explanation of the MSDS/SDS.
- Additional training is required when new hazards are introduced into the workplace, when procedure/equipment changes increase chemical exposures or when additional information becomes available.
Recordkeeping
- Employees must sign in during training classes and include their SBU ID number.
- Employees can check their safety training records on their SOLAR account, under "For Employees>Learning and Development>Training Summary".
- The sign in training sheets are saved by EH&S.
- Chemical inventories are maintained and kept current by the area supervisor. EH&S also saves the inventory records.
- Exposure monitoring records are saved by EH&S.
Written Program
Stony Brook's written Hazard Communication Program is available on the EH&S "Policies and Procedures" web page. It includes:
- The locations of the Chemical Information List and Material Safety Data Sheets, and the procedures employees follow to gain access.
- A description of the labeling system and other forms of warning.
- How employees are provided with information about hazardous, non-routine tasks.
EH&S Hazard Communication/Right to Know Policy
Applicable Regulation