BGSU HAZARDOUS MATERIAL POLICY
BGSU is committed to the concept of safe management of hazardous materials. As an educational institution, the University is aware of its obligation to its students, all levels of personnel, and the surrounding community to properly store, use, and dispose of hazardous chemicals, hazardous substances, and hazardous wastes.
The purpose of this policy is to assure that BGSU meets and/or exceeds standards for the handling of hazardous materials as set by State and Federal agencies, such as the Occupational Safety and Health Administration (OSHA), the State and Federal Environmental Protection Agencies (EPA), and professional organizations. In this way, the University will meet its responsibility to protect its students, personnel, and the environment.
- Hazardous Materials. Materials which are either pure or mixtures of substances (containing more than 1% by weight or volume of any hazardous component) which has the capability of causing injury to personnel, property, and/or the environment through improper use, storage, or disposal. Material Safety Data Sheets (MSDS) as supplied by the manufacturer will be used to determine a product's hazards.
- Hazardous Wastes. A waste, or combination of wastes, which because of its quality, concentration, or physical, chemical, or infectious characteristics may:
- Cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or
- Pose a substantial present or potential hazard to human health or the environment when improperly, treated, stored, transported, or disposed of or otherwise managed. The four properties of hazardous wastes as determined by USEPA in 40 C/content/bgsu/en/technology-architecture-and-applied-engineering/engineering-technologies/directory/mohammad-mayyas/robotics-club1.html (Code of Federal Regulations) are (1) ignitability, (2) toxicity, (3) corrosivity, and (4) reactivity.
- Hazardous Substances. The term "hazardous substance" means (A) any substance designated pursuant to section 1321(b)(2)(A) of Title 33, (B) any element, compound, mixture, solution, or substance designated pursuant to section 9602 of this title, (C) any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act [42 U.S.C. 6921] (but not including any waste the regulation of which under the Solid Waste Disposal Act [42 U.S.C. 6901 et seq.] has been suspended by Act of Congress) (D) any toxic pollutant listed under section 1317(a) under Title 33, (E) any hazardous air pollutant listed under section 112 of the Clean Air Act [42 U.S.C. 7412], and (F) any imminently hazardous chemical substance or mixture with respect to which the Administrator has taken action pursuant to section characteristics as outlined in sections A and B above.
- Hazardous Chemical. "Hazardous chemical" means any hazardous chemical as defined under 1910.1200(g) of Title 29 of the Code of Federal Regulations.
- Materials Safety Data Sheet (MSDS). The sheet required to be developed under 1910.1200(g) of Title 29 of the Code of Federal Regulations which is a means by which manufacturers and importers of hazardous materials convey the hazard information pertaining to their products in accordance with the hazard communication program as described in /content/bgsu/en/technology-architecture-and-applied-engineering/engineering-technologies/directory/mohammad-mayyas/robotics-club1.html 52 Fed. Reg. 31852-31856 (August 24, 1987).
- Resource Conservation and Recovery Act (RCRA). Federal statute which amended the Solid Waste Disposal Act in 1976, and which provides authority for the government to regulate hazardous waste management from the waste's generation to it's ultimate disposal ("cradle to grave" management). The cradle-to-grave concept affects hazardous waste generators, transporters, and treatment, storage, and disposal facilities. In 1984, amendments to RCRA established deadlines for regulatory actions, restricted land disposal of certain hazardous wastes, and brought new entities, such as universities, into the scope of RCRA's authority.
- Superfund Amendments and Reauthorization Act (SARA). Regulates the reporting of hazardous and extremely hazardous substances (as identified in 40 C.F.R. 355) which are produced and/or stored at or above established quantities. This legislation also requires the reporting of spills involving hazardous and extremely hazardous/toxic substances which may affect individuals outside of the established boundaries of the facility (BGSU).
- University Areas/Departments. All units identified on University organizational charts. These include academic colleges, departments, as well as administrative divisions or departments, regardless of their source of operating funds (E&G, general fee, auxiliary funds).
III. GENERAL POLICY
- Areas/Departments. In academic areas, department chairs and/or their appointed designees are responsible for overseeing the safe use of hazardous materials. For non-academic areas, the director and/or supervisor/manager of such areas has those responsibilities. A formal written safety program must be initiated and maintained within the department/area concerning the use of these materials. This written program shall incorporate any teaching and research necessary to educate individuals about any hazardous materials used in the operation of the department/area. The chair/supervisor should see that an on-going effort is made by the department to stay abreast of changing safety standards and to assure that these new safety standards are either met or exceeded; academic and non-academic department personnel are responsible for adhering to these standards.
- Individual Users. Once trained, the individual user is responsible for using the materials in a safe manner according to University safety guidelines. The user is also responsible for reporting unsafe conditions to his/her supervisor and to the person responsible for safety concerns in his/her department. The supervisor is responsible for seeing that safety guidelines are observed, that proper equipment is available, that users are properly trained in the safe use of hazardous materials in their respective areas, and for reporting unsafe conditions to the next administrative level and to the Department of Environmental Health and Safety.
- Department of Environmental Health and Safety. The Department of Environmental Health and Safety (EHS) must play a key role in maintaining a high level of safety awareness on this campus. EHS will keep a central file of all products' MSDSs supplied by University areas/departments. EHS will also assist areas/departments to develop training for new personnel as well as reviewing safety and training for current employees. EHS should also notify all appropriate persons on campus of changing safety standards and updating MSDS information as they occur. EHS should also be notified of those hazardous materials being used by departments/areas which require notification of off-campus authorities in the event of an emergency or spill or for the purpose of annual regulatory reporting (SARA Title III requirements). EHS should also act as an information resource to academic, administrative, and operation areas, and should notify these areas of changing regulations and standards regarding hazardous materials.
- University. The University is responsible for providing a safe workplace, which includes proper training, and for providing appropriate equipment to those using hazardous materials as well as proper facilities in which to use them.
- Training. Only properly trained personnel employing appropriate safety gear, when necessary, should use any of the above defined hazardous chemicals, substances, or wastes. Such materials should be used only under appropriate conditions and within proper facilities. Training or educational procedures must be provided utilizing direct supervision of experienced personnel and optimized conditions. The supervising personnel should be specifically trained as instructors, in addition to being well-versed in the use of the hazardous materials involved. Training will be one component of the written safety program identified in III.A.1.
IV. OPERATIONAL PROCEDURES
- Purchasing. The purchaser(s) should review the MSDS(s) of the materials to be purchased. An evaluation of the degree of hazard posed by the specific material during storage, use, and disposal should be a part of the evaluation of that material prior to procurement. If a more expensive, but less hazardous, substitute is available, the reduced training time, required safety equipment, and handling costs might well lower the overall cost of the item.
When a requisition is prepared for the off-campus purchase of a hazardous material(s), thePurchasing Department should be so notified. This procedure will provide Inventory Management and/or other receiving areas with the opportunity to take any necessary precautions in preparation for the arrival of the material. Transfers of hazardous materials between University areas should include some inquiry by both the sender and the recipient which insures that the recipient has received the pertinent safety information for that material prior to its arrival.
The responsibility for the safe handling of hazardous materials begins at the point of requisition, and is assigned to the individual signing that requisition. In addition, the requisitioner/purchaser is responsible for keeping the original MSDS on file and for forwarding a copy of the MSDS for any ordered material to EHS (FAX 2-2194 or campus mail) before the material is used. The MSDS form shall include the requisitioner's name, the department/area involved, the department/area phone number, and the intended use of the material (this may assist in identifying unknown materials involved in accidents). No person should request that a material with hazardous properties be ordered or delivered to his/her area of supervision unless that individual is willing to take these responsibilities.
- Use. If the use of personal safety equipment is recommended by the manufacturer's MSDS, only personnel trained in the use of and properly fitted for that safety equipment should handle that particular hazardous material. If a respirator or other breathing protection is required, specific fitting and medical review of the individuals involved should be required prior to their use of such materials. These arrangements should be in place before the hazardous material is ordered, as part of the preliminary review.
The dissemination of safety information should be an efficient process. Those responsible for bringing a hazardous material onto the campus should recognize that they are responsible for seeing that the appropriate information accompanies the material. That information should be available in usable form directly to the individuals involved in its use. The user should be able to request the information from the immediate supervisor. If the information supply is not sufficient or if questions remain, a request should be made of EHS to provide additional information and/or explanation. It should be pointed out to all personnel that they should not make decisions regarding safety if they lack the qualification and expertise to do so.
- Storage. The storage of hazardous materials on this campus should be kept to the minimum required for reasonable short-term operation. Furthermore, hazardous materials should be stored only in central facilities under proper conditions as described in their MSDS forms and/or pursuant to State regulation. An exception to this procedure would be the storage of those quantities required at point-of-use for day-to-day operations. Area supervisors should understand that they are responsible for the proper storage, disposal, and safe use of all hazardous materials in their respective areas.
- Disposal. All University departments have the responsibility for properly managing wastes and substances which they generate. According to Federal and State regulations, wastes and substances which are deemed to be hazardous must be handled differently than wastes and substances which are nonhazardous.
RCRA identifies specific wastes and types of wastes that cannot be placed in the normal trash or flushed into the sanitary sewer system. These wastes are either identified under one or more hazardous characteristics (EP toxic, ignitable, corrosive, or reactive) or are specifically listed. The listing and/or description of these wastes can be found in 40 C/content/bgsu/en/technology-architecture-and-applied-engineering/engineering-technologies/directory/mohammad-mayyas/robotics-club1.html Pare 261.
The disposal of hazardous wastes and substances must be done in accordance with all State and Federal EPA guidelines and in conjunction with EHS. Hazardous wastes are to be only temporarily accumulated on campus only in properly designated areas. Hazardous waste must be reported immediately after its identification as such to the Hazardous Waste Coordinator in the Department of Environmental Health and Safety (EHS). Individuals who are unfamiliar with the hazardous waste(s) generated should not attempt to handle them. The proper reporting procedure is as follows:
Proper management of hazardous wastes begins with determining whether the waste(s) generated are indeed hazardous. This determination can be done by either consulting the MSDS for the material from which the waste was generated or by contacting the Hazardous Waste Coordinator in the Department of Environmental Health and Safety (372-2171). If the waste material is indeed hazardous, procedures may be available to render the material nonhazardous. If these procedures cannot be applied, the waste will need to be properly stored until formal packaging and disposal activities can take place. However, inquiry should be made in a timely fashion since storage of hazardous wastes by a generator of the University's present volume for more than 180 days is illegal. It should also be emphasized that improper handling of hazardous waste may have serious legal ramifications for both the individual and the University. Any waste the status of which is either questionable or unknown must be reported to the Hazardous Waste Coordinator for evaluation.
- Emergencies. Emergency situations involving hazardous chemicals, hazardous waste, or hazardous substances such as spills, personal accidents, and environmental contamination must be reported immediately to the area supervisor, the campus Public Safety dispatcher (911), and to Environmental Health and Safety (372-2171). Notification in some instances must be within a few hours, and delay in those cases may subject the University and/or the individuals responsible for the delay to legal action by State and/or Federal authorities.
Approved by University Board of Trustees December, 1990