Hazard Communication/Right-To-Know

The OSHA/MIOSHA Hazard Communication Standard (Right-To-Know Law) is now aligned with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). This update to Hazard Communication (HazCom) will provide a consistent approach to classifying chemicals and communicating hazard information on labels and safety data sheets.

WSU's Hazard Communication Program

General Information

  1. Hazard Determination

  2. Labeling of Hazardous Substances

  3. Safety Data Sheets (SDSs)

  4. Employee Information and Training

  5. Contractor Information

  6. Hazardous Non-Routine Tasks

  7. Identification of Hazardous Chemicals

  8. Hazardous Chemical Inventories

Appendix 1: SDS Location Poster

Appendix 2: New or Revised SDS Poster

Appendix 3: Glossary

Appendix 4: MIOSHA Hazard Communication Standard

General information

The following hazard communication/right-to-know program has been developed for Wayne State University. The master program is available through the Wayne State University Office of Environmental Health and Safety (OEH&S). Copies of the plan are available to all employees or their designated representatives, students, compliance officers, the Assistant Secretary of Labor for Occupational Safety and Health (OSHA), the Director of NIOSH, and the Director or a designee of the U.S. Department of Health and Human Services. For more information, contact:

Office of Environmental Health & Safety (OEHS)
5425 Woodward Ave., Suite 300
Detroit, Michigan 48202
Phone: 313-577-1200 Fax: 993-4079
Throughout this document, recognized hazardous substances shall be referred to as chemicals and/or materials. This program is intended to supplement and compliment existing WSU, MiOSHA and OSHA health and safety standards, and is not intended to fulfill the University's responsibilities under the Michigan Occupational Safety and Health Act 154 of 1974, and the Hazardous Substances in the Workplace Statute, Public Act 79 of 1986.

I. Hazard determination

  1. Wayne State University will rely on safety data sheets (SDSs) from suppliers to meet hazard determination requirements.
  2. OEHS has surveyed University departments to identify and inventory areas where hazardous chemicals are used. Hazardous chemicals are substances that have been identified as such by the American Conference of Government Industrial Hygienists (ACGIH), NIOSH/OSHA Occupational Health Guidelines for Chemical Hazards, and OSHA General Industry Standards (1910 Subpart Z - Toxic and Hazardous Substances).
  3. All final contracts covering goods and services agreed to by the University's designee shall have a statement requiring the contractor and/or their agents to submit SDSs for any hazardous substance which will be used at a Wayne State University work site. Executors of the contract for the University, the contract manager or their designees shall be responsible for ensuring that copies of SDSs are provided with the contract, stored in the project file, and on file at OEHS.

II. Labeling of Hazardous Substances

  1. Department supervisors or designees are responsible for ensuring that all hazardous chemicals shipped from manufacturers are labeled with the following information:
  2. Labels shall be legible, in English, and prominently displayed on all containers of hazardous materials. Labels on containers of hazardous substances shall not be defaced. If a label becomes unreadable, loose, defaced or is missing, employees shall contact their supervisor immediately so that a new label is placed on the container.
  3. If a substance can't be identified, the container shall be removed from the work area until it can be properly disposed of. Unidentified hazardous chemicals are disposed of by OEHS.
  4. Department supervisors shall be responsible for ensuring that chemicals placed into secondary or portable containers are immediately labeled as to the identity of the chemical and the principle hazard. If the chemicals are intended for the immediate use of the employee who performs the transfer, the department supervisor is not required to label the containers.
  5. Piping systems which contain a hazardous substance will be painted and/or labeled at access points and every ten feet where the piping is eight feet or closer to regular employee contact. In tunnels, piping will be labeled at access points, connections and where appropriate.
  6. A placard depicting the same information required on a hazardous substance container will also be displayed for easy readability by those employees working in the area. Facilities Planning and Management will use consistent color-coding when painting piping in accordance with this section.
  7. Inspections
    1. identity of the hazardous substance(s);
    2. appropriate hazard warning; and
    3. name and address of manufacturer.
  8. Portable Containers
  9. Piping Systems

III. Safety Data Sheets (SDSs)

Each department that places an order with a vendor and receives a SDS will keep a copy of it on file. SDSs must be available to employees upon request.

  1. Requests to Vendors
    1. Departments requesting and ordering chemicals will use reasonable efforts to determine whether the products are hazardous. Departments needing assistance with this determination should contact OEHS.
    2. A SDS shall be acquired and maintained for each hazardous material used. The SDSs will be revised or replaced as new or updated SDSs are received.
    3. All chemical suppliers are required to provide a SDS or equivalent for hazardous products, either with the shipment of the material, or prior to its shipment.
    4. If a vendor does not supply the required SDS, OEHS will determine whether a SDS for the product has already been received with a previous order. If a SDS has not been received previously, OEHS will request the SDS from the vendor.
  2. Hazard Communication / Right-To-Know Postings
    1. Postings with the location and availability of SDSs are posted by OEHS in each building where hazardous chemicals are used. The posting contains the name and phone number of OEHS so that employees may contact the department for assistance in obtaining a SDS.
    2. Departmental supervisors are responsible for posting signs throughout the workplace advising workers of the following:
      1. The location of SDSs in the department, and the name of the contact person.
      2. That Wayne State University is prohibited from discriminating against or discharging a worker who exercises the right to information on chemicals in the workplace.
    3. Departmental supervisors are responsible for posting notices of new or revised SDSs within 5 days of receipt of the new or revised SDS.

IV. Employee Information and Training

  1. The Office of Environmental Health & Safety is responsible for coordinating and maintaining records of information and training on hazardous chemicals in the workplace.
  2. Training is mandatory for all employees covered by this Standard.
    1. For non-laboratory staff, to fulfill the training requirements, please complete the HazCom slide presentation. The last slide contains a link to a brief quiz and registration form. This must be completed to confirm and document your training.
    2. For laboratory workers, this training requirement is covered by the Hazard Communication course found in the Collaborative Institutional Training Initiative (CITI Program).
  3. Training will include the information on the following:
    1. Any hazardous chemical in the work area, including its health and physical hazards.
    2. Methods to prevent or minimize exposure to hazardous chemicals in the workplace.
    3. Steps the department has taken to minimize or prevent employee exposure to hazardous chemicals, and how employees can protect themselves.
    4. Ways of detecting the presence or release of a hazardous chemical into the work area.
    5. How to locate, read and interpret chemical labels and SDSs.
    6. Work practices and personal protective equipment to use to prevent overexposure.
    7. Emergency procedures to follow in the event of a spill, illness and/or injury.
    8. The requirements of the Hazard Communication Standard.
    9. The location of the written Hazard Communication/Right-To-Know Program.
    10. The location and availability of a hazardous chemical inventory list.
  4. Before any new hazard is introduced into the workplace, affected employees will be given information from the department supervisor or a designee on the health and physical hazards associated with the chemical, and appropriate methods to protect themselves from exposure.
  5. New employees, or employees transferred into new areas, who haven't received training on the known hazardous chemicals in their work area, will receive training from OEH&S, or from the departmental supervisor, before beginning the new job assignment.
  6. Information and training is provided by a combination of videotape, booklets and presentations by OEHS and department supervisors.
  7. Wayne State University will evaluate the effectiveness of information and training by monitoring the following information:
    1. Whether employees are aware of the "Right-To-Know" Standard.
    2. Whether employees have received information and training.
    3. Whether employees know the location and availability of SDSs.
    4. Whether employees have knowledge of the hazardous chemicals in their work area.

V. Contractor Information

  1. The contract administrator or project manager will inform contractors that a list of hazardous chemicals and precautionary measures for each work site can be obtained from the department supervisor. Access to the WSU written Hazard Communication Program and SDSs will be provided to the contractor upon request.
  2. Department supervisors may direct specific concerns regarding the potentially hazardous chemicals used by contractors to OEHS.

VI. Hazardous Non-Routine Tasks

  1. At various times, employees are required to do non-routine tasks which present hazards. Prior to starting such work, the department supervisor is responsible for providing the employee with information about the hazards associated with the task, including:
    1. Information on the health and physical hazards of the chemicals being used.
    2. Methods to prevent exposure, including appropriate personal protective equipment.
    3. Measures the department has taken to minimize the hazard, including, but not limited to, augmenting ventilation, training and emergency response procedures.
  2. Employees will not begin work on any hazardous non-routine task without first receiving an appropriate safety briefing from the departmental supervisor or a designee.

VII. Identification of Hazardous Chemicals

  1. The following references will be used to identify hazardous chemicals:
    1. OSHA's Regulated Substances; 29 CFR 1910, Subpart Z
    2. American Conference of Government Industrial Hygienists Threshold Limit Values (ACGIH-TLVs)
    3. National Toxicology Program Annual Report on Carcinogens (NTP)International Agency for Research on Cancer Monographs (IARC)
    4. SDSs and labels from chemical manufacturers
  2. Questions about the Hazard Communication Standard can be directed to OEHS at 313-577-1200.

VIII. Hazardous Chemical Inventories

Each department that uses hazardous chemicals must keep an up-to-date inventory of the chemicals being used.

Appendix 1 - Michigan Right-To-Know Safety Data Sheet Posting

Appendix 2 - New or Revised Safety Data Sheet Posting

Appendix 3 - Glossary

ACUTE EFFECT: An adverse effect with severe symptoms occurring very quickly, as a result of a single excessive overexposure to a substance.

ACUTE TOXICITY: The adverse effects resulting from a single excessive overexposure to a substance. Usually a figure denoting relative toxicity.

AEROSOL: Liquid droplets or solid particles dispersed in air that are of fine enough size (less than 100 micrometers) to remain dispersed for a period of time.

ASPHYXIANT: A vapor or gas that can cause unconsciousness or death by suffocation. Most are associated with a lack of sufficient oxygen to promote life.

BOILING POINT: A temperature at which a liquid turns to a vapor state. This term is usually associated with the temperature at sea level pressure when a flammable liquid gives off sufficient vapors to promote combustion.

"C" or CEILING: In terms of exposure concentrations, this is the exposure level that should never be exceeded even for a short period, for a substance.

CARCINOGEN: A substance or agent capable of producing cancer in animals or humans.

CFR: Code of Federal Regulations

CHRONIC EFFECT: An adverse effect with symptoms that develop or recur very slowly, or over long periods of time.

CHRONIC TOXICITY: The adverse effects resulting from prolonged or repeat exposures to a substance, usually used as an indicator of relative toxicity for exposures over great lengths of time.

COMBUSTIBLE: A term used to classify liquids, gases, or solids that will burn readily. This term is often associated with 'flash point', which is a temperature at which a given material will generate sufficient vapors to promote combustion.

CONCENTRATION: A figure used to define relative quantity of a particular material. Such as a mixture in air of 5 ppm acetone in air.

CORROSIVE: A substance that is capable of causing visible destruction and irreversible harm to human skin at the site of contact, or steel by contact. Many acids and bases are classified as corrosives.

DECOMPOSITION: The breakdown of materials or substances into other substances or parts of compounds. Usually associated with heat or chemical reactions.

DERMAL: Used on or applied to skin.

DERMAL TOXICITY: The adverse effects resulting from exposure of a material to the skin. Usually associated with lab animal tests.

DUSTS: Solid particles generated by handling, crushing, grinding or rapid impact of organic and inorganic materials such as rock, metal, coal, wood, and grain. Dust is a term to describe airborne solid particles that range in size from 0.1 to 25 micrometers.

EVAPORATION RATE: The rate at which a liquid material is known to evaporate, usually associated with flammable materials. The faster a material will evaporate, the sooner it will become concentrated in the air, creating either an explosive/combustible mixture or toxic concentration, or both.

EXPLOSIVE: A substance that causes a sudden, almost instantaneous release of pressure, gas and heat when subjected to a sudden shock, pressure, or high temperature.

FLAMMABLE GAS: A gas that can burn with the evolution of heat and a flame. Any compressed gas of which a mixture of 13% or less by volume with the air is flammable, or the flammable range with air is under 12%.

FLAMMABLE LIQUID: Any liquid that has a flash point of 100 degrees F. or below.

FLAMMABLE SOLID: A solid, other than a blasting agent or explosive, that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited, burns so vigorously and persistently as to create a serious hazard.

FLASH POINT: The temperature at which a liquid will generate sufficient vapors to promote combustion. Generally, the lower the flash point, the greater the danger of combustion.

FUME: Small solid particles that have condensed in the air resulting from the heating of a solid body. Gases and vapors are not fumes, although the terms are often mistakenly used interchangeably.

GAS: A form of matter that is neither solid nor liquid. In its normal state (at room temperature and atmospheric pressure) it can expand indefinitely to fill a container completely. A gas can be changed to the liquid or solid state under the right temperature and pressure conditions.

GENERAL EXHAUST: A term used to define a system for exhausting or ventilating air from a general work area. Not as site specific as localized exhaust.

HAZARDOUS CHEMICAL: Any chemical which is either a physical or health hazard or both.

IGNITIBLE: A term used to define any liquid, gas or solid which has the ability to be "ignited", which means having a flash point of 140 degrees F. or less.

INCOMPATIBLE: Materials which could cause dangerous reactions from direct contact with one another.

INGESTION: Taking a substance into the body through the mouth.

INHALATION: The breathing in of a substance in the form of a gas, liquid, vapor, dust, mist or fume.

INHIBITOR: A chemical added to another substance to prevent unwanted change from occurring.

IRRITANT: A chemical which causes reversible inflammatory effects on the site of contact, however, is not considered a corrosive. Normally, irritants affect the eyes, skin, nose, mouth and respiratory tract.

LC - LETHAL CONCENTRATION: In lab animal tests, this is the concentration of a substance which is sufficient to kill the tested animal.

LC 50 - LETHAL CONCENTRATION 50: In lab animal tests, this is the concentration of a substance required to kill 50% of the group of animals tested.

LD - LETHAL DOSE: The concentration of a substance required to kill the lab animal used for the test with a specific material.

LD50 - LETHAL DOSE 50: The single dose concentration of a substance required to kill 50% of the lab animals tested.

L.E.L. - LOWER EXPLOSIVE LIMIT: The lowest concentration, or percentage in air, of a vapor or gas, that will produce a flash fire when an ignition source is introduced.

LOCAL EXHAUST: The system for ventilating or exhausting air from a specific areas, such as in welding operations. More localized than general exhaust.

MELTING POINT: The temperature at which a solid changes to a liquid.

mg/m3 - MILLIGRAMS PER CUBIC METER: A unit of measurement usually associated with concentrations of dusts, gases, or mists in air.

mppcf -MILLION PARTICLES PER CUBIC FOOT: A unit of measure usually used to describe airborne particles of a substance suspended in air.

MUTAGEN: A substance or agent capable of altering the genetic material in a living cell. Normally associated with carcinogens.

NFPA (National Fire Protection Association): An organization which promotes fire protection and prevention, and establishes safeguards against loss of property and/or life by fire. The NFPA has established a series of codes identifying hazardous materials by symbol and number for fire fighting purposes. These codes also classify materials in their order of flammability, with 0 being not burnable up to 4, which means it will burn spontaneously at room temperature.

OLFACTORY: Relating to the sense of smell.

ORAL TOXICITY: A term used to denote the degree at which a substance will cause adverse health effects when taken through the mouth. Normally associated with lab animal tests.

ORGANIC PEROXIDE: Highly unstable compounds, sensitive to heat, friction, impact, and light, as well as to strong oxidizing and reducing agents. All organic peroxides are highly flammable. Two types of compounds known to form peroxides are aldehydes and ethers.

OXIDIZER: A substance which yields oxygen readily to stimulate the combustion of an organic material.

OXIDIZING AGENT: A chemical or substance which brings on oxidation reactions by providing the oxygen to promote oxidation.

PEL (Permissible Exposure Limit): An exposure, inhalation or dermal permissible exposure limit specified in 29 CFR Part 1910, subpart Z. PELs may be either a time-weighted average (TWA) exposure limit (8-hour), a 15 minute short-term exposure limit (STEL), or a ceiling (C). The PELs are found in OSHA regulations part 1910, subpart Z. (see also TLV)

PPM (parts per million): A unit of measurement for the concentration of a vapor or gas in air, usually expressed as number of parts of vapor or gas per million parts of air by volume.

PPB (parts per billion): Same as above, only expressed as number of parts per billion parts of air.

POISON GAS: Extremely dangerous poisons, highly toxic gases or liquids that are dangerous to life when present in the air as gas or vapor in small concentrations.

RADIOACTIVE: Any material, or combination of materials, that spontaneously gives off ionizing radiation.

REACTIVITY: A substances's susceptibility to undergoing a chemical reaction or change that may result in dangerous side effects, such as explosion, burning, and corrosive or toxic emissions. The conditions that cause the reaction, such as heat, other chemicals, and dropping, will usually be specified as "conditions to avoid" on the MSDS.

REDUCING AGENT: In an oxidation reaction, this is the material that combines with oxygen.

REPRODUCTIVE TOXINS: Chemicals which affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses (teratogenesis).

RESPIRATORY HAZARD: A particular concentration of an airborne contaminant that, when it enters the body by way of the respiratory system or by being breathed into the lungs, results in some body function impairment.

SENSITIZER: A substance which may cause no reaction in a person during initial exposures, but afterwards, further exposures will cause an allergic response to the substance.

SOLVENT: A substance, commonly water, but in industry often an organic compound, which dissolves another substance.

SPECIFIC GRAVITY: The weight of a material compared to the weight of an equal volume of water. Usually expresses a material's heaviness. A material with a specific gravity of greater than 1.0 will sink to the bottom of water, whereas a material with a specific gravity less than 1.0 will float on top of water.

STEL (Short Term Exposure Limit): The maximum concentration to which workers can be exposed for a short period of time (15 minutes) with no adverse health effects. This is limited to a maximum of four times throughout the day, with at least one hour between exposures.

TERATOGEN: An agent or substance that may cause physical defects in the developing fetus when a pregnant female is exposed to the substance.

TLV (Threshold Limit Value): Airborne concentrations of substances devised by the American Conference of Government Industrial Hygienists (ACGIH) that represent conditions under which it is believed that nearly all workers may be exposed day after day with no adverse health effects. TLVs are advisory exposure guidelines, not legal standards, that are based on evidence from industrial experience, animal studies, or human studies when they exist. (see also PEL)

TOXICITY: The sum of adverse effects of exposure to materials, generally by mouth, skin or respiratory tract.

TWA (Time Weighted Average): The average time, over a given work period (e.g., 8-hour work day), of a person's exposure to a chemical or agent. The average is determined by sampling for the contaminant throughout the time period. Represented as TLV-TWA.

U.E.L. - UPPER EXPLOSIVE LIMIT: The highest concentration of a gas or vapor in the air that will sustain or support combustion, when an ignition source is present.

VAPOR: The gaseous form of substances which are normally in the liquid or solid state (at normal room temperature and pressure). Vapors evaporate into the air from liquids such as solvents. Solvents with lower boiling points will evaporate quicker.

VAPOR DENSITY: A term used to define the weight of a vapor or gas as compared to the weight of an equal volume of air. Materials lighter than air have a vapor density of less than 1.0, whereas materials heavier than air have a vapor density greater than 1.0.

VAPOR PRESSURE: A number used to describe the pressure that a saturated vapor will exert on top of its own liquid in a closed container. Usually, the higher the vapor pressure, the lower the boiling point, and therefore, the more dangerous the material can be, if flammable.

Updated 12/2016