HAZARDOUS CHEMICAL PROTECTION COMMUNICATION
(RIGHT TO KNOW PLAN)

Middle Georgia College

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Right to Know

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Policy

All employees at all workplaces of Middle Georgia College shall comply with Middle Georgia College's Right to Know Plan. Copies of the plan are located on the MGC website, in the RTK coordinator's office (The Environmental Health and Safety Office) and in each work area at Middle Georgia College. Supervisors are the most knowledgeable of conditions and situations in their work areas, therefore they shall be responsible for assuring their units' compliance with this Right to Know program.

Definitions

"Right to Know (RTK) Coordinator" - the individual who is assigned the responsibilities associated with that title in this written Hazardous Chemical Protection Communication (RTK) plan, and who is assigned the responsibilities of the Hazardous Chemical Protection Communication Coordinator in the Chapter 300-3-19 Rules.

“Work area” means a room inside a building or structure, an outside area, or other defined space in a workplace where hazardous chemicals are produced, stored, or used and where employees are present in the course of their employment.

“Workplace” means an establishment or business of an employer at one geographic location at which work is performed by a state employee and which contains one or more work areas. In the case of an independent contractor or subcontractor, the workplace shall be defined as all work areas wholly owned or controlled by such independent contractor or subcontractor.

"Hazardous Chemical" is a chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in an exposed employee. This includes chemicals which are carcinogens, toxic or highly toxic, nephrotoxins, neurotoxins, agents which act on the hematopoietic (blood-forming) systems, and agents which can damage the lungs, skin, eyes or mucous membranes.

"Supervisor" or "Area Supervisor" means the individual who is responsible for the supervision of the given work area. Supervisor may be used to denote division chair, department heads, directors, administrators, shift directors or leaders, etc.

Responsibilities of the RTK Coordinator

  1. Act as liaison between The University System Right To Know Coordinator and Middle Georgia College on hazardous chemicals issues.
  2. Resolve questions regarding applicability of the Chapter 300-3-19 rules to individual workplaces and work areas of Middle Georgia College.
  3. Make arrangements for and/or provide appropriate and adequate Right To Know training (basic training) to all employees of Middle Georgia College.
  4. Make arrangements for and/or provide for area supervisors, written specific hazard communication programs (specific training) for each workplace in Middle Georgia College. The workplace specific program should include information concerning the hazardous chemicals used, stored, or manufactured in that particular workplace. The area supervisor is responsible for the specific training for all employees in his area.
  5. Acquires the hazardous chemical inventory information from the area supervisor in each department.
  6. Disseminate updated MSDS information provided by area supervisors so that all employees of that particular workplace will have access to current MSDS’s for those hazardous chemicals used in their work.
  7. Coordinates information to the appropriate departments to assure that employees are made aware of and are properly trained in the uses and hazards associated with chemicals to which they are exposed in their work area.
  8. Arranges information to appropriate departments for confirming that employee training on and notification of the use of hazardous chemicals in the work area are adequately documented.
  9. Consults with departments about workplace hazards to insure that supervisors provide employees with personal protective equipment appropriate to each work environment, and receive adequate training in the use and maintenance of this equipment.
  10. Review the hazardous chemical labeling practices of work areas which use secondary storage containers (at least annually).

Responsibilities of Area Supervisors

  1. Be knowledgeable of the HazCom plan and its requirements
  2. Make sure that every employee in their area reads either the printed version or online version of the RTK plan and takes the appropriate training tests. These tests will be assigned by the area supervisor and are available on the web at http://www.mgc.edu/envsrv/RTK/ .
  3. Assure that the training records from each session are forwarded to the EHS office for filing.
  4. Set up a HazCom Station in their work area that contains a written copy of the MGC HazCom Program and the MSDS files for every hazardous chemical in their area.
  5. Maintain a list of hazardous chemicals that are used in the work area and report an updated list each May and November to the EHS office. Each chemical must have a MSDS on file in the appropriate station in their work areas.
  6. To assure that all employees have unrestricted access to this station during their work shift.
  7. To follow the correct hazardous material procurement procedure.

Procurement of Hazardous Chemicals

To order chemicals, one must consult with their department head who will use a purchasing card to order the material. Once the chemical arrives you will be notified by the division head and you will be able to pick it up. The department head should request an updated MSDS for all chemicals ordered.

Material Safety Data Sheets

Supervisors, in keeping with their obligation to ensure a safe work environment, are responsible for maintaining the MSDS file in his/her department. The supervisor is also responsible for employee training in MSDS interpretation. (Refer to the MSDS training module for more information.)

A central file of MSDSs for chemicals used in various work areas for Middle Georgia College will be maintained by the RTK coordinator in the EHS office in the form of MGC's chemical manager. Supervisors can contact the EHS office for access to the chemical manager.

Supervisors will be responsible for sending the RTK coordinator a copy of the MSDS for any new chemical received in his/her work areas. They will also be responsible for advising the affected employees of such changes.

Hazardous Chemical Inventory

It is the responsibility of the area supervisors of work areas using or storing chemicals to maintain the updated inventory of all chemicals in their work areas. (The list should be kept with the MSDS files, and he MSDS files must include the chemicals on this list.)

Hazardous Chemical Inventory Reporting

Each year on May 1st and November 1st, each supervisor shall provide the RTK coordinator an updated list, by name, of all hazardous chemicals present at the department's workplaces. This list shall include, but not be limited to, all chemicals labeled as:

This list shall include chemicals used in all science labs, allied health labs, all areas of plant operations (custodial, grounds, warehouse, water treatment, maintenance, etc.), art departments, drama departments and dark room areas. NOTE: Some office supplies are hazardous materials (Liquid Paper, toner cartridges, etc.) and need to be reported if they are stored in large quantities in one room (such as in the case of toner cartridges in a closet) but do not have to be reported if just one or two items exist for general office use.

The College’s RTK Coordinator will provide to the University System RTK Coordinator, as mandated by state law in section 45-22-9 of Georgia's Public Employees Hazardous Chemical Protection and Right to Know Act of 1988, in June and December of each year the list of all hazardous chemicals present at the College’s workplaces.

Chemical Labeling

All hazardous chemicals introduced into the workplace shall be labeled in containers that meet the requirements of OSHA's HazCom Standard (29 CFR 1910.1200).

Primary labels are prepared by the manufacturer. They are required to meet all of the requirements established by OSHA. Once an employee transfers a chemical from a primary container into another container, that container is now known as a secondary container. The work shift supervisor must ensure that secondary labels include the identity of the chemical (same as on MSDS), appropriate hazard warnings, and the name and address of the manufacturer, distributor, or responsible party.

Portable containers will be classified as secondary containers and must be labeled unless only ONE person uses the material AND the material is used ENTIRELY in one shift. If the secondary container is intended only for short term storage (one week or less), the label shall include the date of filling. Vials and test tubes may have chemical labels affixed to the rack or container in which they are held rather than on each vial or test tube, so long as every vial or test tube in the rack or container presents the same hazard(s). This type “temporary secondary containers” shall be labeled with the name of the chemical, the fill date, and initial of the preparer at a minimum.

If an employee finds an unlabeled or defaced labeled container in the workplace, it is considered to contain a hazardous chemical. The employee should immediately notify the supervisor. It is the responsibility of the supervisor to identify the contents. The supervisor should either request a label from the manufacturer, label the container using the MSDS to transfer accurate information, or use a copy of a properly labeled container. If after exhausting all efforts to identify the contents, the supervisor shall call the RTK Coordinator for assistance in investigating and attempting to determine the contents. If such efforts fail to identify the contents, the supervisor will isolate the container from other chemicals, treat it as a container of hazardous chemicals having all possible hazardous characteristics. The supervisor should then contact the EHS office for proper storage considerations until the container can be removed as hazardous waste.

Labeling systems approved for use on the Middle Georgia College Campus are: the National Fire Protection Association (NFPA), and the Hazardous Material Identification Guide or System (HMIG or HMIS, respectively). Employees will be trained on these systems during their initial RTK training. Refer to the Labeling and Labeling Systems Training Module for more information.

Removal of Hazardous Chemicals

Supervisors are responsible for preparing an inventory of any chemicals they wish to be disposed. The list should include the name of the chemical, quantity to be disposed, and type, size and condition of container. Supervisors must report this to the RTK coordinator who will contact vendors and start the process for removal of the hazardous chemicals.

Closeout Policy

The Area Supervisor, in conjunction with the Director of EHS, is responsible for ensuring that all hazardous chemicals remaining on College property as a result of the departure of a faculty or staff member, or the vacating or reassignment of an assigned space, shall be managed in accordance with the following guidelines:

Informing Contractors

Contractors doing work at Middle Georgia College may expose employees of the College to hazardous chemicals used by the contractor’s employees, expose employees and sub-contractors of the contractor to hazardous chemicals used by the contractor’s employees, and expose employees and sub-contractors to hazardous chemicals used by the College.

Any and all contracts with Middle Georgia College which may involve exposure to hazardous chemicals must require the contractor to:

  1. Notify the workplace supervisor at the work site at least thirty days prior to the commencement of work, of any hazardous chemicals which will be used or stored at the work sites by the contractor or sub-contractor. (In emergency situations, the thirty day policy may be waived.) The workplace supervisor will then:
    • Relay this information to employees whose workplace is at the work site.
    • Upon request be provided with the chemical list and the MSDSs for those hazardous chemicals.
    • Supply the RTK Coordinator with the information about the contract work.
    • Request assistance with MSDSs etc. if needed.
  2. Provide documentation to the workplace supervisor and RTK coordinator, that employees of the contractor have been provided with information and training on the hazardous chemicals being used by the contractor or sub-contractor, at the work site.
  3. Director of Plant operations will be responsible for contacting each contractor before work is started in the college to obtain and disseminate any information concerning chemical hazards that the contractor is bringing to the college’s workplace.
  4. Prior to the commencement of work, the contractor must contact the EHS office and provide written verification of satisfactory environmental data.

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