UW Chemical Hazard Communication (HazCom) Responsibilities

Work Unit Responsibilities

Departments and/or Operational Units must either follow the compliance procedures on these web pages, or document their methods for meeting the requirements of the Chemical Hazard Communication (HazCom) Program and have them approved by EH&S 206-543-7388. Responsible individuals through first-level supervisors in department and operational units are responsible for implementing the following activities within their unit:

  • Identifying hazardous chemicals
  • Maintaining the chemical inventory in MyChem
  • Ensuring personnel have access to Material Safety Data Sheets (MSDSs)
  • Sending EH&S copies of any new MSDSs received
  • Ensuring containers are labeled
  • Informing employees of piping and tubing contents
  • Documenting safe procedures for handling chemicals
  • Assessing new and unusual tasks
  • Informing employees about the HazCom program
  • Providing work-specific training about safety requirements
  • Ensuring personnel complete annual asbestos awareness training and reminding personnel annually about program records
  • Maintaining training records
  • Including consumer chemicals in the HazCom program if their use is intensive
  • Generating MSDSs and labels on chemicals synthesized and provided to others
  • Informing contractors of potential chemical exposures they may receive from UW activities
  • Obtaining information from contractors when their use of hazardous chemicals can impact UW employees

The following paragraphs provide additional details about those responsibilities. In order to keep all the details straight, you should print out and refer to this checklist.

You must identify hazardous chemicals or processes which may result in exposure to your employees, students, or collaborators working at UW sites, i.e., those for whom you have a safety responsibility. Methods for doing this are described here.

You must arrange to enter chemical inventories into the University’s MyChem database. This could be done by either directly inputting information into the MyChem system or alternatively by maintaining inventories in a departmental spreadsheet or database that is formatted in such a way that it can be easily downloaded periodically into the MyChem database. MyChem requirements are described here.

You must ensure all employees have access to the MSDS for each hazardous chemical they may use. You can use electronic copies of MSDSs or paper copies of MSDSs. Methods are described here. It is important that employees can access the MSDSs at all times while working with chemicals – the computer terminal or MSDS file cannot be locked up in someone’s office unless everyone has a key.

You must send a paper or electronic copy to EH&S of any MSDS received by the unit that is not already in the MyChem MSDS system. Methods are described here.

You must ensure all containers are properly labeled. Labeling methods are described here.

You must ensure employees are informed of the contents of un-labeled pipes in the work area. Long runs of tubing where the source of the gas or fluid cannot be seen from the point of use should be labeled as to the contents. Methods for all types of labeling are described here .

You must assess and document procedures for the safe use of hazardous chemicals in the workplace. Assessment methods are described here. In general:

  • In chemical laboratories, ensure that Standard Operating Procedures (SOPs) are written, which include requirements for the safe use of hazardous chemicals, and are placed in the laboratory’s Chemical Hygiene Plan (CHP). (See the UW Laboratory Safety Manual.)
  • In other work areas, document the required procedures for safe use of hazardous chemicals and required personal protective equipment using a Job Hazard Analysis (JHA) or Job Safety Analysis (JSA).

You must ensure an assessment is made for chemical hazards when performing new or unusual, non-routine tasks. Assessment methods are described here.

You must inform personnel about the general provisions of the HazCom program and refer them to a copy of the UW Chemical Hazard Communication (HazCom) poster which must be posted on each departmental or unit safety bulletin board. Training methods are described here.

You must ensure employees receive work-unit-specific training about the hazardous chemicals in use prior to the first use of the chemicals, and when there is a change in how the chemicals are used or when a chemical or chemical process with new hazards is introduced. Training must cover the topics described here.

There are several other mandatory topics. You must ensure all employees are informed on an annual basis about asbestos in the building materials. Inform new employees about any other hazardous condition within the work area. You must inform workers on an annual basis that EH&S (and the work unit or department, if applicable) maintain exposure records, including air monitoring results (if the work area was monitored by EH&S or the work unit/department) and that EH&s maintains information about the chemicals in use in the workplace. See here for details.

You must maintain records that the training was provided for each employee who is likely to use or be exposed to the work area chemicals and procedures. Methods for maintaining training records are described here.

If your workers use consumer products such as furniture polish or art supplies extensively during a shift, you must ensure they are provided hazard communication training and the item is included in the MyChem inventory. Training methods are described here.

If you provide a chemical to an organization outside of the UW, you must ensure it is labeled and an MSDS is prepared using the methodology provided here, or using an alternate, written methodology maintained within the organizational unit and approved by EH&S.

If UW activities will be conducted that could expose contractor personnel to chemical hazards, the contractor must be informed of the hazards. You should take action to restrict your activities so as to not create an exposure, or else provide information as requested by the UW contract representative to the employers concerning chemical hazards present in the work area. See here for more information.

Conversely, if your unit purchases services from a contractor that involve the contractor potentially exposing UW personnel to chemical hazards or other hazards, you as the UW contract representative must inform the contractor that they must provide information about the hazard to the UW. Methods for accomplishing this are described here.

EH&S Responsibilities

EH&S is responsible for:

  • Developing the University-wide program and assisting units in achieving compliance
  • Providing regulatory and emergency agencies with chemical quantity information
  • Maintaining a Material Safety Data Sheet library
  • Maintaining certain other records pertaining to chemical use
  • Developing program support materials
  • Evaluating program effectiveness

EH&S has the responsibility to develop the University-wide chemical hazard communication program and assist operational units with achieving compliance with all the regulations addressing chemical hazard communication. Requirements for the UW HazCom program are set in UW Administrative Policy Statement (APS) 12.5 and suggested methods to accomplish the required activities are described in multiple web pages.

EH&S is also responsible for providing the UWPD, the US Environmental Protection Agency, and the US Department of Homeland Security - and other agencies upon request such as Washington Department of Labor and Industries - information as to chemical locations and amounts. EH&S uses the MyChem system as a tool to provide this required information. Therefore, all UW units are required to feed into the MyChem system.

EH&S is also responsible for collecting Material Safety Data Sheets (MSDSs) for items delivered to the University and making them available to all University units. EH&S uses the MyChem system to manage that collection. Whenever possible, MSDS collections from suppliers that provide frequent shipments to the University will be periodically uploaded into the MyChem system electronically. Individual MSDSs provided by operational units to EH&S or obtained by EH&S from manufacturers/suppliers will also be electronically added to MyChem by EH&S.

EH&S is also responsible for maintaining any exposure records associated with monitoring results and any assessments of exposure generated, and historical data of chemical use. These records are to be kept for the duration of any employees tenure plus 30 years.

EH&S also develops, updates, and provides training and instructional materials and informational materials concerning University-wide aspects of the Chemical Hazard Communication Program. As resources permit, EH&S can provide training concerning specific hazards as requested by operational units.

EH&S is also responsible for developing procedures to evaluate the effectiveness of the HazCom program. At this time, the procedures are to develop surveys annually to be sent to supervisors and employees concerning determining what they know and do not know about the HazCom program.

Chemical Hazards Advisory Committee Oversight

The UW Chemical Hazards Advisory Committee will review chemical use programs at the University of Washington and recommend changes to EH&S as required.