1.0    Statement

The use of hazardous materials at the University creates a variety of environmental and safety issues.  It is the intent of the University to evaluate these issues prior to the procurement of hazardous materials and thereby avoid, to the extent feasible, adverse consequences.

2.0    Purpose/Scope

2.1    Purpose

         To establish a hazardous materials procurement procedure that will ensure all purchases are given appropriate safety and environmental considerations.

2.2    Scope

         These procedures apply to all purchases of chemicals or other hazardous materials that will be used in University business.  All persons who make these purchases should observe these procedures.  Also included are hazardous materials which are obtained as free samples or gifts.

3.0    Definitions

Chemical of Interest – A chemical defined by the Department of Homeland Security in 6 CFR part 27 Appendix A, that may present a potential security issue.

Hazardous Material - Any material which contains a substance that is defined as hazardous by the OSHA Hazard Communication Standard.

Select agent, overlap agent, high consequence livestock pathogen or toxin - as defined under Public Laws 107-56 and 107-188.

SDS; Safety Data Sheet (or Material Safety Data Sheet, MSDS) - Product safety and handling information supplied by the product manufacturer.  It is a requirement of the OSHA Hazard Communication Standard that a copy of a chemical's SDS be made available to any person working with or around a hazardous material.

4.0    References

4.1    41 FR 35050; Aug. 18,1976 (Waste Management Hierarchy)
4.2    CFR Title 29 Part 1910.1200 (Hazard Communication Standard)
4.3    Patriot Act:  Public Law 107-56
4.4    Public Health & Bioterrorism Preparedness and Response Act of 2002:  Public Law 107-188

5.0    Procedures

5.1    General Procedures

         Hazardous materials purchases will be reviewed, before purchase, by “authorized individuals” knowledgeable about relevant environmental and safety issues.  These individuals will prevent unnecessary purchases and suggest alternatives to reduce risks, wastes or regulatory burdens.

         The office of Environment, Health and Safety will authorize individuals by providing appropriate training.

5.2    Responsibilities of Authorized Individuals

The Authorized Individual will review the purchase to ensure that all safety and environmental considerations have been addressed according to the campus Chemical Procurement Guidelines.

If for some reason the purchase is not approved, the concerns of the Authorized Individual will be resolved before purchase.

The Authorized Individual will keep a record of all hazardous materials purchases.

The Authorized Individual will ensure that a SDS is available for every hazardous material purchased.

The Authorized Individual will contact the office of Environment, Health and Safety prior to purchase whenever a purchase is inconsistent with the Chemical Procurement Guidelines, or the material or organism may create a new hazard or regulatory burden.

6.0    Gifts and Donations

6.1    Gift and Donation Requirements

         All gifts and donations of hazardous materials must be approved in advance by an authorized individual.  A SDS or equivalent safety information must accompany the donated hazardous material.

7.0  Authorized Individual Procurement Guidelines

Hazardous material and microorganism purchases should be evaluated for safety and environmental considerations.  Some guidelines are presented below for that purpose.

Prevent Generation of Hazardous Waste

Hazardous waste reduction begins at the source of generation.  Purchases should be reviewed with the goal of somehow altering the process or materials used in order to reduce the quantity or hazard of the waste produced.

1)  Purchase only the quantity of material necessary for the job at hand.  Excess material and material that ages past it’s shelf life becomes hazardous waste.

2)  Determine if a less hazardous material can be substituted for the same job.  Suppliers often have suggestions for safer or more environmentally friendly products.

3)  Determine if a reusable or recyclable material can be used for the same job.

Chemicals or Agents that are Particularly Dangerous

Several issues must be considered to determine if a chemical or microorganism purchase/use will involve particularly severe hazards.  Once again, substitution, reduction of quantity, or possibly elimination of the purchase are options.

1)  Manufacturer/supplier information, Safety Data Sheet (SDS) or Material Safety Data Sheet (MSDS), should be consulted to determine if a chemical is carcinogenic and therefore requires special handling.  Carcinogenicity must be recorded in your department’s chemical inventory.

2)  The “Extremely Hazardous Substances” list should be consulted both to determine if a chemical is extremely hazardous and also to check the Reportable Quantity (RQ) and the Threshold Planning Quantity (TPQ).

The RQ is an amount of chemical that, if released to the environment, requires notification of emergency response agencies.

The TPQ is an amount of chemical that, if possessed by the University, requires the development and implementation of a chemical specific risk analysis and risk management plan.

An effort should be made to purchase less than the RQ if possible.  In no case should an amount exceeding the TPQ of a listed chemical be purchased without first contacting Environment, Health and Safety.

3) Lists of Select Agents and Toxins and Chemicals of Interest are defined in antiterrorism regulations; these lists (attached) must be consulted to determine if a purchase involves any of these agents, toxins or chemicals.  There are potentially significant institutional burdens associated with possession of these hazardous materials – contact the Office of Environment, Health and Safety before purchase if a contemplated purchase is on one of these lists.

Other Regulated Materials – Institutional Limitations

Be vigilant for other types of materials, machinery etc. that may create hazards or University regulatory obligations.  Examples include radioactive materials, machines that produce high energy radiation such as X-ray producing machines and lasers, human blood or human blood products, ordinarily benign materials ordered in large quantity, pesticides, organisms that create biosafety concerns, materials for recombinant DNA work, etc.

Resources for More Information

1) A Safety Data Sheet (or Material Safety Data Sheet) is a document that outlines safety and health information for a particular chemical.  SDSs are available in Campus departments and are a resource for familiarization with chemical hazards.

2)  The office of Environment, Health and Safety, (x-8847) has primary responsibility for hazardous materials management at the University.  The office has resources and references and can be helpful with hazardous materials management issues; please contact that office with any questions or concerns.