The University of Wisconsin–Madison is committed to protecting employees from physical and health hazards associated with chemicals in all work environments. Every effort is made to ensure that risks associated with the use of hazardous chemicals are mitigated to an acceptable level through appropriate engineering controls, specific procedures, and policies instituted by the campus. While the university provides significant resources to ensure that work performed is done in full compliance with applicable federal, state, and local regulations, the responsibility for ensuring a safe workplace must truly be a shared responsibility between managers, supervisors, employees and health and safety professionals.
All University of Wisconsin-Madison departments, facilities and affiliates that work with or use hazardous chemicals in a non-laboratory environment (such as art studios, printing operations, custodial operations, animal care staff, Agricultural Stations, etc.) are subject to the requirements outlined in this policy. Employees who work in laboratories are covered under OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450) – also referred to as the OSHA Laboratory Standard. See the UW–Madison Campus Chemical Hygiene Plan and Compliance Guide for more information.
The University of Wisconsin–Madison is committed to protecting employees from physical and health hazards associated with chemicals in all work environments. Every effort is made to ensure that risks associated with the use of hazardous chemicals are mitigated to an acceptable level through appropriate engineering controls, specific procedures, and policies instituted by the campus. While the university provides significant resources to ensure that work performed is done in full compliance with applicable federal, state, and local regulations, the responsibility for ensuring a safe workplace must truly be a shared responsibility between managers, supervisors, employees and health and safety professionals.
Ensuring that chemical hazard information is available in non-laboratory workplaces through an effective Hazard Communication program is vital to employee health and safety. A successful Hazard Communication Program provides employees with the identities and associated hazards of the chemicals and the information they need to protect themselves. The University of Wisconsin–Madison Hazard Communication Standard Policy for Non-Laboratory Workers was developed to establish and maintain compliance with the Occupational Health and Safety Administration (OSHA) Hazard Communication Standard and GHS by outlining requirements for non-laboratory work environments and defining responsibilities of all parties involved. For laboratory workers, see the OSHA Laboratory Standard at 29 CFR 1910.1420 and the UW–Madison Campus Chemical Hygiene Plan and Policy for more information.
The UW–Madison Chemical Safety Committee has reviewed and approved this policy. Together the actions of employers and employees reduce the potential for adverse effects to occur. The information transmitted under the Hazard Communication Standard requirements provides the foundation upon which a chemical safety and health program can be built in the workplace.
OSHA has estimated there are over 650,000 hazardous chemicals produced today and hundreds of new chemicals introduced annually. Additionally, it is estimated that 190,000 illness and 50,000 deaths are related to chemical exposures. In 1983, OSHA set out to help control employee chemical exposure by issuing the Hazard Communication Standard. It can be found in the Code of Federal Regulations (CFR), specifically 29 CFR Part 1910.1200. The Wisconsin Department of Safety and Professional Services which adopts and enforces safety and health standards for public sector in the State of Wisconsin (Wis. Stat. § 101.055) adopted the Hazard Communication Standard for Wisconsin workplaces. It is located in Wis. Admin. Code SPS § 332.
On March 26, 2012, the Hazard Communication Standard was revised to align with the United Globally Harmonized System of Classification and Labeling of Chemicals also known as GHS. This provides a standard for classifying, formatting and content of chemicals and their hazards in the global economy in which we participate. Communication of health and safety information include Safety Data Sheet (SDS), formerly Material Safety Data Sheet (MSDS) as well as standard labeling criteria which include Signal words, pictograms and other pertinent information for ease of identifying specific, important information.
The OSHA Hazard Communication Standard imposes numerous requirements on both the manufacturers of hazardous chemicals and employers who require their employees to use the chemicals. Specifically, the standard requires that:
The Hazard Communication Standard covers all forms of chemicals such as liquids, solids, gases, vapors, fumes and mists whether they are contained or not.
All University of Wisconsin–Madison departments, facilities and affiliates that work with or use hazardous chemicals in a non-laboratory environment (such as art studios, printing operations, custodial operations, animal care staff, Agricultural Stations, etc.) are subject to the requirements outlined in this policy. Employees who work in laboratories are covered under OSHA’s Occupational Exposure to Hazardous Chemicals in Laboratories (29 CFR 1910.1450) – also referred to as the OSHA Laboratory Standard. See the UW–Madison Campus Chemical Hygiene Plan and Compliance Guide for more information.
Employees have both the need and right to know the identity of the chemicals they are exposed to in the workplace, the specific hazards of those chemicals and methods and measures they can take to protect themselves. All non-laboratory departments, facilities and affiliates where hazardous chemicals are used must develop and implement a written Hazard Communication Program. The required elements of a Hazard Communication Program are outlined below.
The supervisor of each non-laboratory department, facility or affiliate working with or using hazardous chemicals must maintain an inventory of the hazardous chemicals. At a minimum, the inventory should include the name of the chemical which matches the name on the label and SDS, manufacturer’s name and address and the location of the chemical (building and room). The supervisor must update the inventory at least annually or when changes occur. The inventory should be kept with the Written Hazard Communication Program. A Chemical Inventory Form can be found on the Hazard Communication Webpage.
All containers of hazardous chemicals must be labeled according to the Hazard Communication Standard, described below:
If assistance is needed in determining proper labeling please contact the Office of Chemical Safety, contact information is provided at the end of this document.
A Safety Data Sheet (SDS) is a document created by the chemical manufacturer for a specific chemical. The SDS must be in English and contain the following: Chemical or common name as it appears on the label, physical and chemical characteristics, physical and health hazards, primary routes of entry, precautions for safe handling and use, control measures such as personal protective equipment (PPE), work practices or engineering controls, emergency and first aid procedures, the date of preparation, name and address of manufacturer.
The manufacturer of the chemical is responsible for providing a SDS with each initial shipment and with the first shipment after a SDS is updated. If the chemical manufacturer becomes aware of any significant information regarding the hazards of the chemical they produce, this new information shall be added to the SDS within three months. SDS guidance documents are located at the Hazard Communication Webpage.
The supervisor shall provide each employee with information and training on the hazardous chemicals they work with at the time of their initial assignment and whenever a new chemical hazard is introduced. Employees must be informed of:
Prior to starting work with hazardous chemicals and when a new chemical is introduced, each employee must attend training which covers the following:
When employees are required to perform hazardous non routine tasks (infrequent tasks) such as equipment maintenance then training must be provided to inform the employees of the hazardous chemicals they may be exposed to, physical and health hazards of the chemicals, precautions needed, Personal Protective Equipment required, first aid and spill procedures, etc.
The documentation should include the employee’s name, signature, topics covered, date of training, the method of training, and who performed the training.
All UW–Madison departments, facilities and affiliates using hazardous chemicals (excluding laboratory operations) must develop a written Hazard Communication Program. This is a summary document that describes how program elements will be met. The written information required includes the identification of designated persons with responsibility for administration, SDS, labeling as well as chemical inventory, container labeling, employee access to SDS, employee information and training, non-routine tasks, contractor employees and multi-employer worksites.
The written program must be made available to employees. UW–Madison has a written Hazard Communication Program template available for use by non-laboratory departments, facilities and affiliates which meet the requirements of the regulations. Information is available on the Hazard Communication Webpage. Other written programs are acceptable as long as the regulatory requirements are met.
All department or work area written Hazard Communication Programs shall be reviewed annually by the Supervisor to ensure that the contents are appropriate and adequate for current operations. If changes are necessary before the review date, the Supervisor will review and amend the written program.
When outside contractors are working for UW–Madison, they must be informed of any hazardous chemicals they may come in contact within the project area. Likewise, the contractor must inform the University of any hazardous chemicals they intend to bring in or use while on university property. Both parties must have SDS accessible for the duration of the project.
In order to create and maintain an effective Hazard Communication program it is important for all parties to clearly understand the responsibilities inherent in their roles. Below are the minimum requirements necessary to remain compliant with regulations.
The Assistant Vice Chancellor of Environment, Health & Safety (EH&S) will provide the necessary staffing and resources to maintain an effective Hazard Communication Program for each non laboratory work environment.
The campus Hazard Communication Coordinator will:
The Environment, Health and Safety Department have staff with expertise covering all areas of safety and compliance. EH&S personnel will:
The Supervisor/Manager has the primary responsibility for providing a safe work environment and for ensuring compliance with all elements of the Hazard Communication Standard within their own assigned work area. While these responsibilities can be delegated to other individuals within the work area, the Supervisor/Manager must ultimately assure that the duties are performed safely. The Supervisor must:
Each employee is responsible for the safe use, storage and handling of hazardous chemicals in the workplace. The employees working under the supervision of the area Supervisor must:
The UW–Madison Chemical Safety Committee is comprised of university faculty and staff drawn from many organizations and departments. The Chemical Safety Committee will:
In an effort to assist with compliance activities and meet the needs of the campus departments, the following resources and references listed below can be found at the UW–Madison Chemical Safety website. If you have questions, please contact Timothy Lanzhammer, UW–Madison Hazard Communication Coordinator at 608-220-4273 or 608-265-5700 or email timothy.lanzhammer@wisc.edu.
Hazard Communication Compliance Checklist
Hazard Communication Standard, OSHA 29 CFR 1910.1200
Hazard Communication with Globally Harmonized System (GHS) Fact Sheet
Hazard Communication Written Program
Occupational Exposure to Hazardous Chemicals in Laboratories, OSHA 29 CFR 1910.1450
Secondary Container Labels
Training Log
01-24-2013, 10-08-2018, 11-2020
