HazCom Involving Contractors

You Need to Inform Contractors You Hire of UW Hazardous Materials

Contractors must be informed of hazardous chemicals present from UW activities which may result in exposures to the contractor's employees. The University is responsible for any hazardous chemical exposures to contractors caused by UW activities, but not those brought to the job by the contractor.

If you hire an outside contractor, you need to advise the contractor of any HazCom concerns. Normally, this advice is that the University’s program is available on the EH&S websiteand that the work area supervisor occupying the work area the contractor may need to enter is the contact point for information about any local procedures for labeling containers and about any chemical hazards due to on-going work area activities. Whenever possible, on-going UW activities that could cause an exposure to contractor personnel should be stopped before they arrive.

  • With the assistance of EH&S, the Capital Projects Office will provide the necessary hazard communication information to the contractor through contract and purchase specifications. The affected department or organizational unit may need to answer questions and provide more specific hazard communication information as it relates to any on-site activities.
  • For service contracts where vendor personnel are required to work in areas with possible hazardous chemical exposures, the requesting University department or organizational unit must indicate on the Purchase Requisition that these potential exposures exist, and must provide the name of a contact person for further information. The University Purchasing Department will notify the vendor that hazard communication information is available when placing service contracts.

Some areas are "restricted" with controlled access due to the presence of unusual hazards such as high radiation areas and magnetic field areas in the Medical Centers, and asbestos and polychlorinated biphenol (PCB) contaminated areas in different buildings. The University's contracting representative should coordinate access with the operational unit if the restriction of entry into the area is due to operations or due to a local condition such as a chemical spill by the occupants which had not been adequately cleaned. If the problem is a locked access into an asbestos-contaminated or PCB-contaminated area, coordinate with EH&S.

If the non-UW employer wants an MSDS for a presumed work area exposure caused by UW personnel, but the work area supervisor cannot provide it, the UW construction manager or project manager should contact EH&S.

Informing Contractors that They Must Inform UW of Their Hazardous Chemicals

Conversely, contractors must inform the University of processes or hazardous chemicals they bring onto the University sites which may result in exposures to our employees or that may cause the University to exceed Department of Homeland Security notification limits. The University representative should understand how the chemicals are to be used, and if there is any question as to whether the chemical may present especial hazards or that university faculty, staff, students or visitors may be exposed to a potentially significant risk, the University representative should consult with EH&S (206-543-7388).

  • Specifications addressing contractor and outside vendor work must include language that they are responsible for notifying the University of any hazardous products brought to the job site.
  • Contractors must review the chemicals to be brought on site in light of the list of tracked chemicals developed by the Department of Homeland Security (full list at DHS website (pdf)). If any of the listed chemicals are to be brought onto University property, the contractor shall advise the University of the total amount and the size of container(s) of the specified chemical using the Chemicals of Interest (COI) worksheet provided by the contracting office.

If the contractor intends to perform procedures that may result in injuries, fires, explosions, or even such things as odor complaints from adjacent occupants, the contractor should inform the University's contracting representative well in advance so the work can be well planned and any necessary precautions taken by the University to inform employees and to prevent or minimize exposures. This is also necessary if there is a potential for starting a fire while performing "hot work" such as welding or cutting metal with a torch.