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ESH Manual Page: 8000: Environmental Management
1.0 POLICY

It is the policy of the Sanford Underground Laboratory at Homestake (here after referred to as Sanford Laboratory) that all Sanford Laboratory personnel be informed of the dangers of all on-site hazardous substances. This is accomplished by establishing procedures for purchasing, labeling, handling, storing and disposal of a hazardous substance. Training is required to familiarize personnel with these procedures. In particular, personnel will be trained on the OSHA Hazard Communications standard, the use of material safety data sheets (MSDSs), and proper and safe management of hazardous substances which include hazard identification and avoidance, safe handling procedures, personal protection measures, and waste disposal.

2.0 SCOPE

This policy applies to all employees, contractors, scientists, vendors and visitors in accordance with OSHA’s standards for hazard communication.

3.0 RESPONSIBILITIES

All Personnel have a “right to know” what hazardous substances they are being asked to work with, and they have a right to be trained to safely manage the risks associated with hazardous substances. The following positional responsibilities outline how this will be accomplished:

3.1. Industrial Hygiene Specialist

The Industrial Hygiene Specialist has overall responsibility for the Hazard Communication Policy/Procedure and ensures that all policy elements are carried out. Specific responsibilities include the following:

  • Annually review and update this policy as necessary.
  • Annually review and update hazardous substance labeling and create new labels as required.
  • Assist with the development and presentation of hazard communication training material
  • Review the MSDSs and meet with the purchaser (typically a supervisor/ foreman or the SPC) about his/her responsibilities prior to approving the purchase/receipt of new hazardous substances.
  • Maintain the HazCom Database (HCD) as outlined in Section 3.0 above.
  • Review the monthly Science Hazardous Substance Tracking Data Base (SHSTD) outlined in Section 3.0.
  • Upon approving a previously non-approved hazardous chemical, notifying the Procurement Specialist so the “Approved List” can be updated to the list of Approved Hazardous Substances for the Sanford Laboratory.

3.2. Environmental Specialist

The Environmental Specialist, in conjunction with the Industrial Hygiene Specialist, is to review all new purchases and determine if the substance is a hazardous waste based on waste codes or characteristics. Responsibilities include the following:

  • Review science collaborations proposed receipt of hazardous substances.
  • Review the monthly science collaboration
  • Determine if a substance is subject to EPCRA reporting (Tier II)
  • Determine the response to any non-incidental spill.
  • Notify Personnel (primarily Foreman and Science Program Coordinators) of any special waste management procedures for a substance such as rag contamination, special disposal, and mixing issues. This will be performed in the annual Hazcom training along with Hazard training of new chemicals.
  • Enter data (waste) into the hazardous waste tracking database to determine site generator status.

3.3. Procurement Specialist

  • All Sanford Laboratory Personnel (non-science) hazardous substance purchase orders shall go through the Procurement Specialist. His/her responsibilities include the following:
  • Ensure that the Industrial Hygiene Specialist and Environmental Specialist have approved the hazardous substance prior to purchasing.
  • Assist the purchaser in obtaining MSDSs when they are not provided.
  • Maintain a binder with a master list of MSDSs for reference.
  • Maintain a list of Approved Hazardous Substances for the Sanford Laboratory.

3.4. Warehouse Specialist

Responsibilities of the Warehouse Specialist include the following:

  • Verify that all containers received for use clearly display the contents, the appropriate hazard warning(s), and the manufacturer's name prior to accepting the hazardous substance on-site.
  • Maintain appropriate safe storage and containment of the hazardous substances with input from Industrial Hygiene Specialist and/or the Environmental Specialist.
  • Maintain a binder with a master list of MSDSs for reference.

3.5. Foremen/Supervisors

  • Foremen/supervisors are responsible for all hazardous substances used within their area of responsibility. This includes hazardous substance handling, labeling, storage, transportation and disposal. Specific responsibilities include the following:
  • Follow established protocol when ordering a new hazardous substance (see section 5.1).
  • Ensure that employees under their responsibility who work with or could be exposed to hazardous substances have received documented hazard communication training.
  • Maintain hazardous substance and MSDS inventories for the specific work areas.
  • Ensure that MSDSs are available and readily accessible to all employees, contractors, science users, etc.
  • Ensure that personal protective equipment and engineering controls are available and used.
  • Communicating to all employees when a new chemical hazard is introduced in the work area
  • Ensure that all secondary containers are labeled with either an extra copy of the original manufacturer’s label or with NFPA labels. For help with labeling, contact the Environment, Health and Safety (EHS) Department.
  • Ensure that all accidents, incidents or exposures involving hazardous substances are reported to the Emergency Response Coordinator, Industrial Hygiene Specialist and respective chains of command as required.

3.6. Program Science Coordinators

Program Science Coordinators shall adhere to the following procedures:

  • Obtain prior approval from the Industrial Hygienist and Environmental Specialist concerning hazardous substance brought onto the Sanford Laboratory Site
  • Maintain SHSTD and MSDS inventories for the specific work areas.
  • Ensure that MSDSs are available and readily accessible to all employees.
  • Ensure that personal protective equipment and engineering controls are available and used.
  • Assist in the coordination of document hazard level training.
  • Ensure that fellow science collaboration members who work with hazardous substances and/or whose work area contains hazardous substances receive the general hazard communication training and receive work area specific training prior to their initial assignment of working with and/or being exposed to hazardous substances in the work area. This includes any new chemical hazards introduced in the work area subsequent to initial training, those associated with non-routine tasks, and those introduced by non-Sanford Laboratory personnel (subcontractors, experimenters, etc.). This may be performed in conjunction with the Laboratory Supervisor.
  • Ensure that all secondary containers are labeled with either an extra copy of the original manufacturer’s label or with NFPA labels. For help with labeling, contact the Environment, Health and Safety (EHS) Department.
  • Ensure that all accidents, incidents or exposures involving hazardous substances are reported to the Emergency Response Coordinator, Industrial Hygiene Specialist and appropriate line management as required.
  • The disposal of hazardous waste will be coordinated with the Industrial Hygiene Specialist and/or the Environmental Specialist.
  • It is imperative that Program Science Coordinators inform the Industrial Hygiene Specialist about any hazardous substances they bring to the Lab. This shall be done prior to the arrival of the substances.

3.7. Project Managers

  • Enclose a summary of this Hazard Communication Policy/Procedure to contractors and subcontractors participating in work on-site.
  • Ensure that contractor employees have received some form of general hazard communication training.
  • Identify the use of any hazardous substances by contractors, and provide IH Specialist with MSDSs for review and approval
  • Distribute the appropriate information to all potentially affected employees when a contractor brings a hazardous substance or substances to the Laboratory.

3.8. Contractors

Sanford Laboratory uses and stores hazardous substances on-site in a way that may expose employees of other employers (for example, employees of a construction contractor working on-site), the Industrial Hygiene Specialist shall enclose a summary of this Hazard Communication Policy/Procedure in contracts involving work on-site. Alternatively, this summary may be provided to subcontractors in pre-construction meetings.

Contractors performing work on-site have the following responsibilities:

  • Include a copy of their hazard communication program in their site safety and health plan if they intend to bring any hazardous substances to the premises.
  • Maintain the MSDSs for these hazardous substances and give them to the Industrial Hygiene Specialist for distribution.
  • Dispose of all hazardous material waste generated at the Lab.

Contractors employed by science shall submit a list of proposed hazardous substances brought on-site to the SPCs who will in turn submit this list to the Industrial Hygiene and Environmental Specialists for review as outlined in Section 3.2.1

4.0 DEFINITIONS

Hazardous Substance – A substance listed in EPCRA section 302 or 313, CERCLA, Clean Air Act Section 112(r), or OSHA’s list of hazardous substances.

Hazard Communications Database (HCD) - This is the database maintained by the Industrial Hygiene Specialist where Sanford Laboratory MSDS are traced and indexed (this does not include Hazardous substances maintained by Science Collaborations or contractors).

MSDS - a form containing data and the properties of a particular substance. An important component of product stewardship and workplace safety, it is intended to provide workers and emergency personnel with procedures for handling or working with that substance in a safe manner, and includes information such as physical data, health effects, first aid, reactivity, storage, disposal, protective equipment, and spill-handling procedures.

Personnel – Refers to all employees, visitors, scientists and contractors at the Sanford Laboratory.

Project Manager – An individual who manages projects and associated contractors.

Sanford Laboratory Employees – Refers to individuals who maintain the Sanford Laboratory Infrastructure. These individuals are employed by either DUSEL or SDSTA.

Science Collaboration - A group of scientists dedicated to a specific science project or projects. The Science Collaboration designates a Project Science Coordinator (PSC) to act as an on-site point of contact. Within the Collaboration, a designated representative is responsible for the safety of the respective employees.

Science Hazardous Substance Tracking Data Base (SHSTD) – These are the individual hazardous substance databases maintained by each science collaboration.

Science User – Refers to all science experimenters physically working on SDSTA property.

5.0 PROCUREMENT OF HAZARDOUS MATERIALS

Hazardous substances may be brought onto the Sanford Laboratory site via three means:

i) Purchasing of a hazardous substance by a Sanford Laboratory employee.

ii) Through a science collaboration.

iii) Through a contractor.

In any case, the person responsible for ordering or bringing the hazardous substance on site is responsible for ensuring proper storage for these materials and for ordering associated mitigation measures in the event this material is spilled or released (such as spill kits). Hazardous materials found on SDSTA property without an approved MSDS will be quarantined until the proper approvals are obtained.

5.1. Sanford Laboratory employees shall adhere to the following hazardous substance purchasing procedure (HSPP). Refer to Appendix A, Purchasing Flowchart for Sanford Laboratory Employees:

  • Determine if the substance is hazardous. This information may be obtained from the Industrial Hygiene Specialist or the Environmental Specialist. If you are ordering a hazardous substance go section 5.1.2, or section 5.1.3. Otherwise, use non-hazardous substance purchasing procedures.
  • If the hazardous substance has been previously purchased, order the hazardous substance via the Procurement Specialist and pick up the substance from the Warehouse Specialist. Ensure that the MSDS is current (within 3 years) and the container(s) housing the hazardous substance are properly labeled (see section 5.0 “Container Labeling” below). The foremen/supervisors shall give the appropriate information to the Industrial Hygiene Specialist who shall enter purchase information into the Hazard Communications Database (HCD). See Appendix B for the Sanford Laboratory MSDS database template. Foremen/supervisors and subcontractors are then responsible for ensuring their employees have adequate training for dealing with the hazardous substance. See Section 7.0 “Employee Training and Information”. Also refer to Appendix C, Purchaser Checklist for Hazardous Substances.
  • If the hazardous substance has not been purchased in the past, the proposed purchase shall be forwarded to the Industrial Hygiene and Environmental Specialists who will review the new hazardous substances MSDS before the purchase is made. The Industrial Hygiene Specialist must approve the purchase and notify the Procurement Specialist to proceed with the purchase. The Industrial Hygienist is responsible for uploading the new MSDS into the MSDS directory and updating the HCD located on the network server. Finally, the stipulations outlined in section 3.1.2 above shall be followed.

5.2. Science Collaborations and their contractors shall adhere to the following Hazardous Substance Procurement Procedure (see Appendix D, Hazardous Substance Purchasing Flowchart):

  • Purchases and/or site-receipt of a hazardous substance shall be performed in coordination with the Science Program Coordinator (PSC) or his/her designee. Prior to purchase or receipt of a hazardous material, the PSC shall submit to the Industrial Hygiene and Environmental Specialists a copy of the substance’s MSDS and amount to be purchased. The hazardous substance must be approved for use onsite before the material is shipped to or brought onsite. Once approved, the PSC shall log the substance into the Science Hazardous Substance Tracking Database (SHSTD) (see Appendix E). This database is specific to each science collaborations (i.e. there will be separate database for each science collaboration) because their purchases are not processed through the Sanford Laboratory purchasing department. Further, many hazardous substances may be brought on site by non-conventional means (such as personal vehicle.) SPCs shall provide monthly copies of their respective HSTD and highlight changes that occurred during the month to the Industrial Hygienist and Environmental Specialist. Collaboration institutional representatives are responsible for ensuring their employees are properly trained on any hazardous substances associated with work they are directed to perform.

5.3. Contractors and any associated sub-contractors will adhere to the following Hazardous Substance Procurement Procedure:

  • • It is the responsibility of contractors to provide Project Managers with information about hazardous substances they may bring to the Laboratory prior to arrival.
  • • The Project Managers shall provide the Industrial Hygiene and Environmental Specialist a list of all hazardous substances, and copies of MSDSs for review.
  • • If approved, the Industrial Hygiene Specialist distributes the appropriate information to all potentially affected Personnel.
  • • This list, including MSDSs, is to be included in the Project Manager’s “Job” file, and will not be recorded in the Laboratories inventory, unless deemed necessary by the Industrial Hygiene and Environmental Specialist (this will be based upon quantities, and duration for which the hazardous chemical will be on site).
  • The Project Manager shall ensure the contractor will remove all hazardous materials brought on site at the end of the project.
6.0 CONTAINER LABELING

All hazardous substances shall have appropriate labels to best inform Personnel of hazards present. The Hazardous Substance Labeling Procedure is found in Appendix F.

Labels on shipped/incoming containers of hazardous substances shall have the substance identity and hazard warnings appropriate for Personnel protection. The name of the manufacturer, importer or other responsible party of the hazardous chemical must be present on the label.

The Warehouse Specialist verifies that all containers received for use clearly display the contents, the appropriate hazard warning(s), and the manufacturer's name prior to accepting the hazardous substance on-site. The Laboratory uses NFPA Chemical Hazard Labels in compliance with NFPA 704 when a standard label is missing or when a hazardous substance is transferred to another container for use. A copy of the NFPA label can be found in Appendix G.

Labels are required on all containers of hazardous substances to identify their contents. Warning labels shall be affixed to all containers of small quantity hazardous substances, (e.g., small test tubes, reaction vessels). Substances that are synthesized shall be evaluated to determine their hazards and appropriate warning labels shall also be placed on their containers. Uncharacterized substances shall be labeled as toxic and handled accordingly. All routes of entry should be assumed. Other hazardous properties, such as flammability, corrosivity and stability, shall also be considered and appropriate precautions taken.

Labels shall not be removed or defaced unless immediately replaced with a label having equivalent or superior information. Labels shall be written in the English language, although additional languages are permitted as long as the English version is present. Pipes containing hazardous substances shall also be labeled with only the name of the substance being conveyed in the pipe.

The PSC (or his/her designee) and supervisor/foreman ensure that all secondary containers are labeled with either an extra copy of the original manufacturer's label or with NFPA labels. For help with labeling, contact the Environment, Health and Safety (EHS) Department.

The Industrial Hygiene Specialist will review the company labeling procedures yearly and will update labels as required.

7.0 MATERIAL SAFETY DATA SHEETS (MSDS)

MSDSs contain the physical and chemical properties of a substance, as well as the physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures and control measures. See Appendix H, Guidelines for Reading and Understanding an MSDS.

Copies of MSDSs for all hazardous substances to which employees are exposed or are potentially exposed will be kept in the Warehouse, the Procurement Specialist’s office, the Industrial Hygiene Specialist’s office and on the network drive. Any areas where hazardous substances are stored or used also have MSDSs available for reference. If an MSDS is not available, contact the Industrial Hygiene Specialist or PSC (see Appendix I, Site Specific Hazardous Substance Safety Checklist)

The substance name and hazard information on the MSDS shall match the substance name and hazard information on the container label of the incoming shipment of a hazardous substance. The substance name and hazard information on the MSDS shall also match the label information of a portable container into which a hazardous substance has been transferred.

MSDSs are required for new substances synthesized at the Lab, especially if such substances are to be shipped offsite.

 

8.0 EMPLOYEE TRAINING AND INFORMATION

New employees and science user will receive initial training on this plan, the hazard communication standard, how to read and understand a MSDS, the hazardous substances they will encounter at the site and finally how to manage these hazards. A health and safety orientation will also be provided to each new employees/science user that includes the following Hazard Communication information and training:

  • Symptoms of overexposure
  • How to determine the presence or release of hazardous substances in the work area
  • How to reduce or prevent exposure to hazardous substances through use of control procedures, work practices and personal protective equipment
  • Steps the company has taken to reduce or prevent exposure to hazardous substances
  • Procedures to follow if employees are overexposed to hazardous substances
  • Location of the MSDS file and written Hazard Communication Policy/Procedure

Prior to introducing a new hazard into any section of this company, each employee in that section is given information and training as outlined above for the new hazard.

9.0 LIST OF HAZARDOUS SUBSTANCES

The HCD used at the Sanford Laboratory is attached to this plan (Appendix J). This list includes the name of the chemical, the manufacturer, the work area in which the chemical is used, and the inventory date. Further information on each chemical may be obtained from the MSDS.

Each science collaboration’s hazardous substances database (SHSTD) will be linked to the Sanford Laboratory’s HCD to help consolidate hazardous substance information and possible future merging of these two databases.

10.0 REFERENCE AND RELATED DOCUMENTS

10.1. Standards

  • 29 CFR 1910.1200 Hazard Communications Standard (general industry)
  • 29 CFR 1926.59 Hazard Communications Standard (construction industry)

10.2. Related Documents

  • Hazardous Waste Tracking Database (HCD)
  • Science Collaboration Data (SHSTD)
  • Emergency Response Plan

10.3. Appendices

  • Appendix A: Purchasing Flowchart for Sanford Laboratory Employees
  • Appendix B: MSDS Database Template
  • Appendix C: Hazardous Substances Checklist for Purchasers
  • Appendix D: Hazardous Substance Purchasing Flowchart
  • Appendix E: Science Hazardous Substance Tracking Database template (SHSTD)
  • Appendix F: Hazardous Substance Labeling Procedure
  • Appendix G: NFPA 704 Label
  • Appendix H: Guidelines for Reading and Understanding an MSDS
  • Appendix I: Site Specific Hazardous Substance Safety Checklist
  • Appendix J: Hazard Communications Database