Hazard Communication Program

Hazard Communication Overview

Who does the Hazard Communication Program apply to?

Personnel whose chemical use is limited to consumer or commercial chemicals/chemical products are subject to the Hazard Communication Program at Virginia Tech.

(Personnel who use scientific-grade hazardous chemicals/gases and "laboratory-scale" quantities in laboratory research are regulated differently).

OSHA Compliance

Virginia Tech’s Hazard Communication Program has been prepared in accordance with the requirements of the OSHA Hazard Communication Standard, 29 CFR 1910.1200. OSHA requires manufacturers and importers to evaluate their hazardous chemicals for physical and health hazards and to communicate specific hazard information to downstream chemical users. OSHA also requires employers to both ensure hazard information is available to employees, and train their employees to understand and use hazard communication in order to work safely.

Virginia Tech departments will accomplish the safety goals of the OSHA Hazard Communication Standard for their employees, personnel, and students in the following ways:

Ensure that the following information is available to personnel on workplace-specific chemical hazards:

1. Labels and other forms of warning on chemical and chemical product containers;
2. Safety data sheets (SDS); and
3. Employee information and training.

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Hazard Communication Online Program

Definitions

Hazardous chemicals: Hazardous chemicals implies that exposure to a chemical could pose a physical and/or health hazard. Physical hazard indicates that the chemical is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water-reactive. Health hazard indicates that acute or chronic health effects may occur in exposed employees.

Exempt chemicals: Common exemption - If you are using a consumer product in the same size container you would use at home, in same way/in same quantity you would use the product at home, the Hazard Communication Standard does not apply. However, if you are using multiple containers or bulk-volume containers of the product for a task, or are using the product for any purpose or in any way other than as described on the label, the standard would apply. Certain chemicals are specifically exempt from this Hazard Communication Program, including pesticides, fungicides, rodenticides, food, food additives, drugs, cosmetics, and medical or veterinary products. A more complete list is provided in the OSHA standard 1910.1200 (b)(6).

Responsibilities

Environmental Health and Safety will:

• Maintain and update this written hazard communication plan and the plan templates for departmental use, as well as provide assistance when necessary and requested. Environmental Health & Safety will provide online Hazard Communication Training and Hazard Communication Coordinator Training for use by personnel at Virginia Tech.

Department management bears the responsibility for providing Hazard Communication Program resources to supervisors who oversee work areas and manage personnel and hazardous communication coordinators who facilitate safe chemical use in the workplace. In some instances, a supervisor may also serve as the hazardous communication coordinator. Department management also is responsible for ensuring that hazard communication training records for personnel are up-to-date and maintained in department files and/or the Environmental Health & Safety Safety Management System.

Hazard communication coordinators are responsible for executing the requirements of this program so that all persons safely work with hazardous chemical products in their work areas.
Responsibilities include:

• All individuals who will serve as hazard communication coordinators must successfully complete the Environmental Health & Safety online module for HazCom Coordinator Training. Training will include topics covered in basic Hazard Communication Training, as well as a review of coordinator responsibilities.
• Chemical inventory: Develop and maintain an inventory list of all hazardous chemicals stored or used in the workplace, ensure the inventory is available to employees (see Hazard Communication Chemical List Template), and ensure that chemical containers are properly labeled.
• Safety data sheets: Ensure safety data sheets are present for all hazardous chemicals and chemical products in the workplace and readily available to employees.
• Hazard communication plan checklist and annual review: Complete this template to capture department/area-specific details.
  • Non-routine task awareness: Identify non-routine tasks involving hazardous chemicals. Ensure written standard operating procedures are established and included in department-specific training for employees performing non-routine tasks involving hazardous chemicals.
  • Retain the completed form in the hazard communication plan binder, along with other required elements of your plan.
  • Review and update your hazard communication plan contents as necessary and at least annually.

Employees must:

• Comply with the guidelines set forth in this program and in the department-specific hazard communication plan.
• Complete required Hazard Communication Training.
• Following training, know how to recognize hazards associated with chemical products, and use chemical products safely.

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Hazard Communications Plan (HAZCOM Plan)

• A hazard communication plan is required for each workplace that is subject to the requirements of the Hazard Communication Program (i.e., for workplaces that are NOT research laboratories using scientific-grade hazardous chemicals/gases).
• The required elements of a hazard communication plan include:
  1. Hazardous chemical inventory/list;
  2. Safety data sheets; and
  3. Hazard communication plan checklist and annual review.
• Print out the Hazard Communication Program document and include it in your hazard communication binder for ready reference, especially if your computer access to the program document is limited/not available.

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Hazardous Chemical Inventory List

• Each Virginia Tech department, facility, or workplace for which the Environmental Health & Safety Hazard Communications Program applies must list or inventory all hazardous chemicals in the workplace. This list includes the name of the chemical and the specific work area in which the chemical is used, or the person responsible for the chemical. Refer to the Hazard Communication Chemical List Template.
• The hazardous chemical inventory or list is compiled and maintained by the hazard communication program coordinator or departmental designee.
• This list shall be retained with the designated hazard communication program documentation (binder) in the workspace.
• When new chemicals are received, this list must be updated (including date the chemical was put into use). To ensure any new chemical is added in a timely manner, the following procedures should be followed:
  1. If the chemical is ordered by any individual other than the hazard communication program coordinator, they must notify the coordinator of all chemicals ordered, including the following:
     1. The date the order was placed;
     2. The name of the chemical and manufacturer;
     3. The specific work area in which the chemical will be used;
     4. The quantity to be used; and
     5. The expected receipt date.
  2. When a shipment arrives, the receiving department must notify the hazard communication program coordinator immediately and deliver the new safety data sheets and any additional information on the chemical provided with shipment to the coordinator.
  3. The hazard communication program coordinator must then add new chemicals to the list with all required information. An updated copy of the list must then be attached to the workspace-specific hazard communication program documentation and the old list destroyed.

Safety Data Sheets

Employers must ensure that safety data sheets are readily accessible to employees.

Safety data sheets are documents (paper or electronic) supplied by manufacturers which provide product users with detailed information on hazardous chemicals.

Information found in safety data sheet documents includes, but is not limited to, the product name, chemical abstract service numbers, composition, handling precautions, type of personal protective equipment recommended, physical and health hazards, storage requirements, emergency, and first aid procedures, the date the safety data sheet was prepared, name, address and telephone number of the chemical manufacturer or the importer. 

For more in depth information regarding SDSs, please see: Hazard Communication Standard: Safety Data Sheets 

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Container Labeling and Other Forms of Warnings

The hazard communication coordinator or designee shall ensure primary and secondary hazardous chemical containers are properly labeled. All labels and warnings should be legible, written in English, and prominently displayed on the container.

Primary or original manufacturer’s labels

Chemical manufacturers, importers, or distributors are required by OSHA to label, tag, or mark each container of hazardous chemicals with the following label elements after they classify the hazards of the chemical:

• Name, Address, Telephone Number
• Product Name 
• Signal Words (Warning/ Danger)
• Hazard Statements and Pictograms
  • 
• Precautionary statements
  • Prevention, Response, Storage, Disposal        

Labels on incoming containers must not be defaced or removed until the container is empty. If the label becomes faded, illegible or destroyed they should be replaced and remain durable, legible, and firmly affixed to the container(s). 

Secondary or alternative labeling

The following guidelines summarize the secondary or alternate labeling options available:

1. Creating your own container labels:
   • The full chemical or product name(s) (as it appears on the safety data sheet) and the primary or general hazard can be written directly on the container or written/printed on a label to be affixed to the container. 
     • If a container is too small or the identity name is too large, a codified name may be used on the container when defined in a notebook or reference sheet that is accessible to all. When many chemical names are needed, readily accessible notebook references may be used and primary hazards must also be communicated in the notebook or in the general workspace using words, symbols, or pictograms.
     • The primary or general hazards can be placed on container labels using words, pictures, symbols, or a combination of these that provide general information about the hazards of the chemical. 
   • Secondary labeling requirements:
     • Every label must convey the required information clearly, legibly, and in English. Where other languages are spoken in the work area, information may be presented on labels in other languages in addition to the required English words. Virginia Tech does not mandate any single labeling system. 

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Hazardous Non-Routine Tasks

• A non-routine task is one which the employee does not normally perform and for which he/she has not previously been trained. 
• Standard operating procedures should be written and available to employees performing "non-routine" tasks involving hazardous chemicals. 
  • Prior to beginning non-routine tasks involving actual or potential exposures to hazardous chemicals, employees should be informed of the hazards present, and the steps the department/ work area is taking to reduce the hazards, including ventilation, respirators, the presence of another employee (buddy systems), and emergency procedures. 
  • The employee should be given appropriate work instructions, and provided with required personal protective equipment prior to starting the task.

Detection of and/ or Potential Release of Hazardous Chemicals

The presence of hazardous chemicals in the work environment can typically be detected by visual appearance or odor if the hazardous chemical is being used and/or released outside of established containment measures. If a release is identified, contact your supervisor immediately and evacuate the work area in accordance with your department’s Emergency Action Plan as appropriate.

Hazardous chemicals can also be detected through air monitoring or physical symptoms when there is no visible indication of a spill or odors cannot be used as indicators of a release. Virginia Tech Environmental Health & Safety may conduct air monitoring on an as needed basis to determine whether PPE or engineering controls are to be utilized when using a hazardous chemical. 

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Personnel Training Requirements

• Complete Environmental Health & Safety's online Hazard Communication (HAZCOM RTK) Training.
• Workplace-specific information on chemicals/products used and associated hazards, required personal protective equipment, and safe work practices must be provided to new personnel by the work area supervisor. Some of this information will also be conveyed by the hazard communication coordinator when he/she reviews the hazard communication plan with each new employee. 
• Additional workspace-specific training on hazards must be provided by the department and or work area supervisor whenever a new hazardous chemical/chemical product that is introduced into the workspace. Records of this additional training shall be maintained by the hazard communication program coordinator.
• Hazard Communication Training (online and workplace-specific) should include:
  • The requirements of the Hazard Communication Standard (29 CFR 1910.1200).
  • The contents, location and availability of my workplace hazard communication plan.
  • The physical and health hazards of hazardous chemicals in my work area and their locations.
  • The location of my work area’s hazardous chemicals inventory list.
  • The location of safety data sheet documents for all hazardous chemicals in my work area, and how to find/understand the hazard information from them that I could need.
  • How to properly label containers, and understand workplace labels/ labeling systems and other forms of warning.
  • The emergency procedures to follow related to chemical hazards.
  • The methods used to determine the presence or release of hazardous chemicals in the work area.
  • How to reduce or prevent exposure to hazardous chemicals by using good work practices, engineering controls and personal protective equipment

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Program Review

The HAZCOM Program will be reviewed by the Environmental Health & Safety Hazard Communication Program administrator annually and updated as necessary.

In addition, each department's hazard communication program coordinator is responsible for annual submission of and review/revision of their department's or workplace's completed hazard communication plan. The hazard communication plan is subject to Environmental Health & Safety review during safety evaluations.

Last review: December 15, 2025

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