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Chemical Risk Management

Policy Administrator: Vice President for Administration/CFO

Authority: Title 8, California Code of Regulations (CCR) Section 5191; Title 8, California Code of Regulations (CCR) Section 5194; Title 8, California Code of Regulations (CCR) Section 3203

Effective Date: July 16, 2019

Updated: January 2019

Index Cross-References: Chemical Hygiene Plan

Policy File Number: ADM-0114

CHEMICAL RISK MANAGEMENT

Policy Statement:

This policy provides regulation for the purchase, storage, use, and disposal of any chemical, or chemical waste classified as hazardous by the State of California or the Federal government on the campus of California State University, Sacramento (“Campus”) by any student, faculty, staff or member of the public.

The primary purpose of the California State University System is to provide education to the citizens of California. This policy is written to ensure that all the following interests are met by regulating all hazardous chemicals on the Campus at all times: the interest of providing safe and equal access to the Campus for the purpose of education; the interest of the safety and health of all persons on the Campus, the purpose of protecting both the campus environment and the surrounding Campus environment, the purpose of protecting public safety; the interest to protect all persons on Campus from harm; the interest to protect property, buildings and grounds from damage; the interest to protect the California State University, Sacramento (“University”) from liability. 

Therefore, it is the policy of the University that all hazardous chemicals as defined by the State of California or the Federal government are regulated by the University everywhere within the boundaries of the Campus as to time, place and manner, for safe and environmentally protective acquisition, storage, use, and disposal. 

Further, it is the policy of the University that all persons who use, have access to, or are potentially exposed through their work, academic activities, or research activities on Campus receive all the legally required training including the response to a hazardous chemical emergency or release, and have access to all the legally required personal protective equipment.

Further, it is the policy of the University that all persons who use, have access to, or are potentially exposed through their work, academic activities, or research activities on Campus are provided with the supervision, resources, equipment and programs necessary to implement this Chemical Risk Management Policy, government regulatory requirements and any applicable University procedure requirements, including the Chemical Hygiene Plan (“CHP”) referenced in this policy. 

Further, it is the policy of the University that the requirements of the following California regulations, and any other regulations not listed but applicable to the University, are fully and completely implemented:

Title 8: Section 5191, Laboratory Safety; Section 5194, Hazard Communication; Section 3203, Injury and Illness Prevention Program; Section 5192 Hazardous Waste operations and Emergency Response; Sections 5216 and 1532.1, Lead in General Industry and Lead in Construction; Sections 5208 and 1529, Asbestos in General Industry and Lead in Construction

CCR Title 22, Division 4.5, Environmental Health Standards for the Management of Hazardous Waste; CCR Title 3, Division 6, Chapter 3, Pest Control Operations;

Health and Safety Code DIVISION 103. PART 5. CHAPTER 4. Residential Lead-Based Paint Hazard Reduction

SMAQMD Rule 902, Asbestos

Further, it is the policy of the University that additional procedures and guidelines for implementing this Policy in University laboratories are found in the referenced Chemical Hygiene Plan.

Who the Policy applies to:

This Chemical Risk Management Policy (“Policy”) applies to all current and future students, faculty, and staff on the Campus of the University as well as all visitors to the Campus facilities and grounds, who acquire, transport, store, use or dispose of hazardous chemicals in the course of performing work, academic activities, research, artwork, or other activities on the Campus.

Why the Policy is necessary:

To manage the risk to people’s health and safety, and manage risk to the environment from hazardous chemicals, to prevent injuries, illnesses to people, safeguard the environment including air, land and water, to comply with the applicable government regulations and requirements, and to manage the liability risk from these hazards.

Responsibilities:

University Executive Management:

While the overall responsibility for the Campus-wide Policy belongs to the President, the immediate operational Campus-wide responsibility for ensuring compliance with this Policy belongs to the VP of Administration and Business Affairs (ABA) which is where the Risk Management Services (RMS) group is located.  The day to day compliance and leadership for ensuring Chemical Risk Management for the University belongs to the University Chief Risk Officer, who manages the University Environment Health and Safety (EHS) office and programs. 

Executive Safety Committee (ESC): 

The ESC serves as the “Campus Chemical Hygiene Committee”, and provides all University stakeholders including all bargaining units, students, faculty, and staff access to chemical safety issues and solutions, recommendations and findings, and an avenue to directly report any concerns, hazards, incidents, or risks to University Management in a timely, transparent, and consistent manner.

Office of Environment, Health and Safety: 

The EHS office functions as a part of Risk Management in ABA, and provides the center of technical excellence for chemical risk management on the Campus.  The EHS office conducts chemical assessments and monitoring to scientifically determine exposure potential, provides expert advice and recommendations regarding chemical safety, personal protective equipment, chemical safety training, chemical emergency and release incident response, hazardous waste safety recommendations and training. 

The EHS office is the chemical regulations expert on campus that determines compliance, and interacts with hazardous chemical regulators, auditors, and inspectors when they are on the Campus. 

The Campus Chemical Hygiene Officer is an employee in the EHS office.  The EHS office reviews the CHP annually for effectiveness and potential improvements, conducts chemical safety inspections and self-assessments on Campus, and provides the technical expertise to gather, review and analyze the facts related to the accuracy of incident narratives involving hazardous chemical spills or chemical exposures on behalf of the Departments where the incident occurred and on behalf of the University President.

Directors, Deans, and Department Chairs: 

Directors, Deans, and Department Chairs are responsible to ensure that employees, faculty, and students in the workplaces, classrooms, and research facilities within their Colleges or Departments they supervise are compliant with the Policy, referenced government regulations, referenced CHP, and any other applicable University or Department chemical safety policies, procedures and guidelines.

They are responsible for consulting with the EHS office as needed to determine compliance with the Policy and any referenced regulations, procedures or guidelines, to provide the resources for chemical safety training for their College or Department and to lead their organization’s coordination with the EHS office for determining the narrative of a significant spill or release incident. Colleges and Departments may, with the assistance of EHS, develop their own specific chemical safety procedure manuals for their academic and research activities.  These College and Department specific chemical safety procedures are to be incorporated by reference here under Procedures.

Managers, Leads, and Laboratory Supervisors:

Managers, Leads, and employee, faculty or student Laboratory Supervisors are responsible for knowing the inventory of hazardous chemicals in the workplaces they supervise and the classrooms and research facilities they supervise and operate.  In the workplaces, classrooms, and research facilities they supervise, they ensure compliance with the Policy, referenced government regulations, referenced CHP, and any other University or Department chemical safety policies, procedures and guidelines.

These compliance responsibilities include supervising the staff, faculty and students to ensure they know and understand the Policy, regulations, procedures and guidelines; have taken the training required for conducting work, education and research activities safely; are aware of the safe response procedures in the event of a hazardous chemical emergency or release; know how to use personal protective equipment for chemical safety for the chemicals in the location where their work occurs.

These responsibilities also include consulting with the EHS office for guidance related to all aspects of this Policy, consulting on determining compliance with Policy, regulations, and university procedures; and reporting to the EHS office in a timely manner chemical concerns, injury incidents, spills or releases. 

All employees and students: 

At the time and place where employees, faculty, and students are conducting their work, academic activities, or research activities, employees, faculty, and students are responsible to know the hazardous chemicals that they are working with in their workplace or classroom or laboratory, how to protect themselves from exposure to those hazardous chemicals, how to handle and dispose of those hazardous chemicals safely, and how to respond appropriately and safely in the event of a hazardous chemical emergency or release of those hazardous chemicals. 

Employees and faculty are responsible for knowing and understanding their rights, requirements and responsibilities under the Injury and Illness Prevention Program regulation (IIPP) as well as under the Hazard Communication regulation (HazCom). Employees, faculty, and students are also responsible for reporting spills or releases involving chemicals according to regulation, procedure and guidelines. 

All employees, faculty, and students are responsible for knowing they can, without fear of retaliation, ask questions about their chemical safety or report unsafe conditions, chemical concerns, spills, leaks or other chemical releases, or any other issues regarding their chemical safety situation to their supervisor, lead, manager, laboratory supervisor, faculty, Chair, Dean, Departmental safety committee, or directly through the EHS office’s Safety Hotline (8-2020), or directly to the Executive Safety Committee.

Visitors and the Public:

Visitors, including invited teachers and students from the community, and others who may from time to time visit or use the campus facilities for community, academic or camp events or programs, either through facilities rental or invitation and coordination with faculty, in locations where hazardous chemicals may be present, stored or used, are required to know that that Campus has a Chemical Risk Management Policy. 

Risk Management Services will assist visitors and the public for knowing and implementing the Policy, including any procedures necessary for the acquisition, storage, transportation, use and disposal of any hazardous chemical or substance whether they bring such substances to campus as part of the visit or program, or whether they are in a location where such substances are located.

Space Management:

Space Management is responsible for notifying customers that indicate they will bring hazardous chemicals to campus or that request campus facilities where hazardous chemicals are present that there is a Chemical Risk Management Policy and that Risk Management Services is available to assist them with policy compliance if necessary.

Procurement:

Procurement is responsible for consulting with the EHS office to ensure compliance with all regulations that involve shipping of hazardous chemicals that may be brought into campus through mail or other delivery service contracts.  Procurement is responsible for notifying bidding contractors or vendors who may use or bring hazardous chemicals to campus or are performing work where hazardous chemicals are present that there is a Chemical Risk Management Policy and that the EHS office is available to assist them with policy compliance if necessary.

Definitions:

Hazardous chemical means any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified according to regulation Title 8: Section 5191, Laboratory Safety; Section 5194, Hazard Communication; Section 3203, Injury and Illness Prevention Program; Section 5192 Hazardous Waste operations and Emergency Response. The EHS office provides consultation regarding the determination of any chemical as a hazardous chemical for purposes of this policy.

Procedures:

California State University, Sacramento Chemical Hygiene Plan

Injury and Illness Prevention Plan

Hazard Communication Program

(Reserved) College or Department Chemical Safety Manual, Procedure or Guidelines

Approved by: Robert S. Nelsen, President        Date: July 16, 2019