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TRAINING AND HAZARD INFORMATION

Training

Line managers are responsible for ensuring that employees complete a Job Hazards Analysis (JHA) and complete the required training.

Training for employees working in areas where hazardous materials are present is completed at three levels:

  • LBNL Introduction to EH&S at LBNL (Course EHS0010). This course provides general hazard communication training.
  • Chemical Hygiene and Safety Training (Course EHS0348) (Available On-Line). This course reviews the provisions of the CHSP and information on, chemical hazards and controls, and
  • Operation/procedure-specific training. This is to be provided individually or in small groups by the line manager. The purpose of this training is to review the hazards of an employee's assigned work, the uses and limitations of controls, the warning signs of exposure to hazardous materials used in the operations (e.g., odors, irritation, etc.), and the emergency procedures for off-normal events.  Line managers are responsible for ensuring employees are trained in the hazards and controls associated with new materials introduced into the work area.

EH&S Subject Matter Experts are available to assist line management in providing job specific training.

Collectively, this training addresses the following topics:

  • The requirements of the Hazard Communication and Laboratory Standards
  • Health and physical hazards
  • Operations involving hazardous materials
  • Applicable health standards (e.g., OSHA PELs and ACGIH TLVs)
  • Use and location of Material Safety Data Sheets
  • Labeling requirements
  • Purpose and use of control measures (work practices, substitution, engineering, administrative and PPE)
  • The warning properties of chemical releases (e.g., odors, eye irritation, etc.)
  • The signs and symptoms of exposure
  • Exposure monitoring and medical surveillance
  • Spill response and emergency procedures
  • Possible non-routine tasks
  • Hazards of unlabeled pipes, wastes, etc.

Hazard Information

Information regarding the hazards of chemicals is conveyed in two primary ways: Material Safety Data Sheets and labels/placards.

Material Safety Data Sheets (MSDSs)

An MSDS provides safety and health related information such as known hazards of the material, its physical and chemical properties, exposure limits, precautionary measures, and emergency and first aid procedures. Additional information on How to Read an MSDS is provided in the appendices.

MSDSs are required for all hazardous materials and must be readily accessible to LBNL employees.  Note: MSDSs are not required for consumer products (e.g., Formula 409 all- purpose cleaner) provided it is used in the manner intended by the manufacturer. 

flag image MSDSs may be accessed from the EH&S Chemical Safety Web Page.  When necessary, line managers will contact the manufacturer of the product or access their web site to secure an MSDS. An EH&S Industrial Hygienist can also be contacted for assistance.

MSDS Requirements for Chemicals Produced in Laboratories or That Are Shipped Off Site:

LBNL is considered to be a chemical manufacturer or distributor by federal OSHA if chemicals produced in laboratories are shipped off site. LBNL is required to communicate chemical hazards through MSDSs and labels. There is no exemption based on quantity.  These hazard communication requirements are delineated in the section entitled, Control Procedures for Chemicals Produced in Laboratories and Shipped Off Site.

Line managers shall ensure that MSDSs are prepared. The Chemical Hygiene and Safety Program Manager may be contacted for assistance. OSHA requires that MSDSs be written in English and contain the following information. The enclosed MSDS template may be used.

  • Product identity. This must be the same name on the container label;
  • Chemical and common name of the material
  • Physical and chemical characteristics
  • Physical and health hazards, including signs and symptoms of exposure and prior and/or existing medical conditions that may be aggravated by exposure to the chemical. Consult the section entitled: Definition of Hazardous Chemicals to determine health and physical hazards;
  • Primary routes of entry;
  • Known exposure limits (OSHA PELs or ACGIH TLVs);
  • Whether the hazardous chemical is listed in the NTP Annual Report on Carcinogens or is a potential carcinogen according to IARC or OSHA;
  • Precautions for safe handling and use, and procedures for spill/leak cleanup;
  • Control measures;
  • Emergency first aid procedures;
  • Date of preparation, and
  • Name, address and telephone number of a person who can provide additional information on the chemical. This is normally the individual who produced the chemical.

If no relevant information is available for any given category on the MSDS, then mark it to indicate so.

Trade Secrets

The specific chemical identity, including the chemical name and other specific identification of a hazardous chemical, may be withheld from the MSDS, provided that:

  • The identity is a trade secret. A "trade secret" is any confidential formula, pattern, process, device, information or compilation of information that is used in an employer's business, and that gives the employer an opportunity to obtain an advantage over competitors who do not know or use it.
  • The claim that the information withheld is a trade secret can be supported;
  • Information contained in the material safety data sheet concerning the properties and effects of the hazardous chemical is disclosed;
  • The material safety data sheet indicates that the specific chemical identity is being withheld as a trade secret; and,
  • The specific chemical identity is made available to health professionals, employees, and designated representatives upon request.

Labeling and Posting

    Labels

    This section provides labeling requirements for containers of hazardous materials. Refer to the section entitled Definition of Hazardous Chemicals to determine if a chemical, material, product or mixture is hazardous. Exceptions to these requirements may be granted by the EH&S Division Director provided that justification is given and that the requestor can demonstrate that safety will not be compromised.

    Labels are required for all primary and secondary containers of hazardous materials except where noted below. Labels are also required on containers that are shipped off site. Labels shall be clearly legible and written in English. Primary containers are the original containers received from the manufacturer, distributor or vendor.  Secondary containers are jars, cans, squeeze bottles and other containers to which hazardous materials are transferred by an individual.

    Though labeling is not required for containers of non-hazardous materials (e.g., deionized water), listing the material identity on the container is recommended to avoid confusion among research and other personnel.

    These labeling provisions are not required for hazardous wastes, or immediate use containers. Waste containers must be labeled in accordance with Pub 3092 - Guidelines for Generators to Meet HWHF Acceptance Requirements for Hazardous, Radioactive, and Mixed Wastes at Berkeley Lab. Immediate use containers are those that are under the control of the user and will be used in the same work shift.

    Primary Container Labeling

    Labels on primary containers must:

      • Show the chemical identity or product name of the material (must be the same as listed on the MSDS);
      • Provide hazard warning information appropriate for employee protection;
      • List the name and address of the manufacturer; and
      • Be legible and prominently displayed.

    Users must not remove or deface labels on primary containers, i.e., those containing the original contents. Labels may be removed/defaced for containers designated for a different purpose such as accumulating waste. Containers used for this purpose must be labeled to indicate so.

    Labeling Containers of Hazardous Materials Produced in Laboratories

    LBNL is considered to be a chemical manufacturer or distributor by federal OSHA if chemicals produced in laboratories are shipped off site. Containers shall be labeled as described above in the section entitled Primary Container Labeling. If the chemical is regulated by an OSHA Substance Specific Standard then the label must comply with the provisions of that standard. Consult with the Chemical Hygiene and Safety Program Manager to help make this determination.

    • If the chemical is produced for use at LBNL, then storage containers shall be labeled with the chemical name as described in the section entitled, Secondary Container Labeling in Laboratory Areas and Uses. If the composition is unknown then the container will be labeled with some other means of identification such as the parent material(s) from which it was derived, or a reference such as a citation to a lab book.

    Labeling Process Containers

    Process containers such as plating baths and degreasing tanks shall be legibly labeled with the chemical identity of the material/mixture and hazard warning.

    Secondary Container Labeling

    LBNL requires secondary containers of hazardous materials to be labeled.

    Two labeling systems are used at LBNL, depending on the work environment and the type of material usage. See Table 1 for a summary of the secondary labeling requirements.

    Table 1 Summary of Secondary Container Labeling Requirements

     

    Laboratory Areas & Use

    Non Laboratory Areas & Use - Machine Shop, Paint Shop, Custodial Services

    Information 1

    Secondary Container 2

    Pre-labeled Secondary Container 3

    Secondary
    Container 2

    Pre-labeled Secondary
    Container 3

    Chemical Identity

    Required

    Required 4

    Required

    Required 4

    Hazard Warning

    Not Required

    Not Required

    Required

    Required 4

    Owner Name

    Not Required

    Not Required

    Not Required

    Not Required

    Date Transferred

    Not Required

    Not Required

    Not Required

    Not Required




    1. This information may be added to the secondary container by writing on it with a pen, or by using a commercially available label, the EH&S- provided label (see below) or other equivalent means.
    2. Examples include: Squeeze bottles, glass bottles, and cans.
    3. Generally, these are squeeze bottles which have the chemical identity (e.g., acetone) and a hazard warning (such as a fire symbol to indicate flammability) printed on them. These are normally sold for pure substances as opposed to mixtures.
    4. Chemical identity and hazard warning should already be printed on the container.

    Secondary Container Labeling in Non-laboratory Areas and Uses

    LBNL applies the labeling requirements of the OSHA Hazard Communication Standard to non-laboratory areas such as machine shops, paint shops and for uses such as custodial services. Secondary containers shall be labeled with the chemical identity or product name of the material and hazard warning. The chemical identity or product name must be the same as listed on the MSDS. In practical terms, this means that the name on the secondary container shall be the same as the name on the original container label. Product names such as "X-14" are permissible provided that they match the name on the label of the primary container. Listing individual chemical components of mixtures is not required. A hazard warning can be words, pictures, symbols, or a combination thereof, which provide at least general information regarding the hazards of the chemicals. Generally, the hazard warning can be the same as the one listed on the primary container label. Listing the name of the person who transfers the material and the date of transfer is recommended but not required.

    An optional stick on label has been developed for this purpose (below) and is available from EH&S (ext. 2916). This is recommended for secondary containers of hazardous materials used in non-lab areas.

    Non-Laboratory Material

    Material Name:

    Hazard:

    Owner (Optional):

    Alternatively, this information may be written directly on the secondary container or by using commercially available labels. Pre-labeled secondary containers displaying the chemical identity and hazard warning are also acceptable for pure substances such as ethyl alcohol and acetone.

     

    Secondary Container Labeling in Laboratory Areas and Uses

    Secondary containers in laboratory areas are used for pure substances such as acetone and ethanol which are transferred from primary containers, substances created in the laboratory and for mixtures such as buffers that are either commercially procured or that are prepared in the laboratory. LBNL applies the OSHA Laboratory Standard to laboratory areas. This is a performance oriented standard which has no prescriptive labeling requirements. However, for employee safety purposes, LBNL requires secondary containers of materials used in laboratory areas to be labeled with the chemical identity or product/mixture name of the material. Abbreviations and chemical formulae are permitted provided that research personnel in the laboratory understand the nomenclature. Listing the name of the person who transfers the material and the date of transfer is recommended but not required.

    An optional stick on label has been developed for this purpose (below) and is available from EH&S (ext. 2916). This is recommended for secondary containers of hazardous materials used in lab areas.

    Laboratory Material

    Material Name:

    Hazard (Optional):

    Owner (Optional):

    Date (Optional):

    Alternatively, this information may be written directly on the secondary container or by using commercially available labels. Pre-labeled secondary containers displaying the chemical identity and hazard warning are also acceptable for pure substances such as ethyl alcohol and acetone.

    Labeling Small Containers (Vials and Tubes) in Laboratories

    There may be practical limitations to carrying out the above labeling requirements to small containers such as sample vials and tubes.  Alternatives such as labeling a tray or rack that holds the containers or applying a numbering or coding system are permissible provided that the material's identity and hazards are readily accessible (e.g., by means of a lab notebook, a spreadsheet or some other equivalent means) to research personnel in the laboratory and that they understand the system.

    Pre-packaged Kits Containing Individual Containers

    Kits containing individual containers of hazardous materials are often used in both laboratory and non-laboratory work environments. These are considered as primary containers, and require no additional labeling if they get separated from the kit.

Hazard Communication Requirements for Chemicals Produced in Laboratories and Shipped Off Site

Chemicals Produced in Laboratories and Shipped Off Site

LBNL is considered to be a chemical manufacturer or distributor by federal OSHA if chemicals produced in laboratories are shipped off site. LBNL is required to evaluate chemical hazards and communicate this information through MSDSs and labels. There is no exemption based on quantity. 

Supervisors shall ensure that:

  • The chemicals are evaluated to identify their health and physical hazards. This may be done by consulting sources such as chemical hazard information and references. Refer to the section entitled: Definition of Hazardous Chemicals. It defines health and physical hazards and has links to hazard databases and references. An EH&S Industrial Hygienist may also be consulted to assist in evaluating chemical hazards.
  • A Material Safety Data Sheet is developed. Refer to the section entitled: Material Safety Data Sheets (MSDSs) for requirements. Note: If there is no relevant information on a material's hazards, then mark the MSDS to indicate so.
  • The container is labeled with the chemical identity, its hazards and the name, address, and phone number of a contact person. If the composition is unknown then label the container with some other means of identification such as the parent material(s) from which it was derived, or a reference such as a citation to a lab book.
  • Labels and MSDSs are updated with any new significant information regarding the hazards of a chemical.
  • The recipient is contacted (e.g., via email) prior to shipping.
  • Shipping is coordinated with Facilities Material Services (ext. 5084). Note: Only qualified individuals in Facilities Material Services may pack and ship these materials off site. 

Hazard Communication Requirements for Transporting Research Samples

Employees who transport research samples either by hand or in a passenger vehicle for use by another person shall follow the hazard communication requirements described above and the packaging requirements in the section entitled, Transporting Research Samples, Hazardous Materials and Field Sampling Materials by LBNL Staff. Moreover, they shall inform vehicle passengers about the research samples/hazardous materials being transported.

Chemicals Produced in Laboratories and Used On Site

MSDSs are not required for chemicals produced in an LBNL laboratory if they will be used on site. However, LBNL is required to evaluate and communicate chemical hazards. Moreover, if these chemicals are hazardous then users must complete EHS 0348 (Chemical Hygiene and Safety Training) and EHS 0344 (Safe Handling of Engineered Nanomaterials - if the chemical is an engineered nanomaterial).

Supervisors shall ensure that:

  • The chemicals are evaluated to identify their health and physical hazards. This may be done by consulting toxicological and chemical hazard information and references. Refer to the section entitled: Definition of Hazardous Chemicals. It defines health and physical hazards and has links to hazard databases and references. An EH&S Industrial Hygienist may also be consulted to assist in evaluating chemical hazards. If the composition of the material is unknown then assume it is hazardous.
  • Containers are labeled with the chemical identity. If the composition is unknown then label the container with some other means of identification such as the parent material(s) from which it was derived, or a reference such as a citation to a lab book.

Posting Area Entrances

Entrance placard example

Area Safety Leaders shall ensure that entrances to technical areas are posted with a Caution Placard which indicates the hazard types in the work area (such as corrosives and carcinogens) as depicted by hazard icons, minimum PPE requirements and emergency contact information.   

The enclosed MS Word placards shall be used for this purpose. There are two sizes available: Letter (8 1/2" x11") and Legal (8 1/2" x 14"). Follow the enclosed instructions and use the hazard icons to create the placards. Note:  Use the icons provided in the Powerpoint file.  If there is a hazard in your work area for which there is no available icon, or if you have an icon you wish to add to the list, then consult with the Chemical Hygiene and Safety Plan Program Manager.  Do not create and use your own icons.

flagIf interim conditions or activities in a technical area pose temporary hazards that require additional controls, then supplemental signs may be posted. Use the Posting Template. The description of hazards, controls, and points of contact must be agreed upon by an EH&S subject matter contact and the Division representative (such as the area safety leader, work lead, or principal investigator). Post the sign in a prominent location.flag

An emergency response flipchart shall be posted in laboratories and work areas where chemicals are used. These flipcharts instruct personnel on the actions to take during off-normal events (chemical, radiological and biological spills, fires, and earthquakes). Please contact EH&S at extension 7032 to obtain a flipchart for your area.

Designated Areas

Designated areas are specific locations within a lab for work involving particularly hazardous substances and engineered nanomaterials.  Their purpose is to ensure that proper controls are in place and that all activities involving these higher hazard materials are confined within the designated area.

Designated areas can be a piece of equipment, such as a fume hood or a centrifuge, or they can be entire labs.  However, it is best to limit the number and size of designated areas to the minimum needed because there are additional control procedures required. 

The Work Lead shall establish and post designated areas.  The enclosed template shall be used for this purpose.

Employees working in designated areas must be informed of the hazards and controls of the materials used. 

Designated areas established for engineered nanomaterials shall be cleaned (e.g., wet wiped) at least once per day when work is performed in them.

Labeling Refrigerators

Refrigerators must be labeled as to their purpose with regard to food or chemical storage. Refer to Chemical Storage Guidelines for information on the proper labeling of refrigerators.

Line managers are responsible for ensuring that work areas and entrances are appropriately posted.

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Last updated: 06/26/2012
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