Chemical Safety and Hazardous Materials

Chemical Inventory Management is required by the Workplace Right to Know “Public Employee Hazardous Chemical Protection and Right to Know Act of 1988” (O.C.G.A. 45-22-2). KSU uses Chematix Chemical Management System for chemical tracking as well as procurement and waste management. Chemicals are tracked from purchase to disposal through the system. All chemicals and chemical products are included. All chemicals and chemical products purchased at KSU must be reviewed and approved by EHS prior to purchase. The Chemical Approval Request Form should be completed and emailed to chemicalapprovals@kennesaw.edu. A Chemical Approval Report will be returned to the requestor which can be uploaded to the electronic P-card prior approval request, OwlPay or ePro requests. The Chemical Approval Report is valid for one year from the date on the report and may be reused as often as necessary. Note that the approval is for the chemical or chemical product from the listed manufacturer. The same chemical or chemical product from a different manufacturer will require a separate approval. In the absence of the Chemical Approval Report, the request will still be reviewed (approved or denied); however, the approval process may be delayed as pertinent information is gathered by EHS.

All chemicals and chemical products purchased at KSU must be reviewed and approved by Environmental Health and Safety (EHS) prior to purchase. Chemical Inventory Management is required by the Workplace Right to Know “Public Employee Hazardous Chemical Protection and Right to Know Act of 1988” (O.C.G.A.45-22-2). Part of this law requires KSU to have on hand and make available all safety data sheets (SDS) for all hazardous chemicals and products we hold in our possession. An online solution, MSDSOnline, is employed by KSU for storing the SDSs for the chemicals that have been approved for use at KSU. Additional SDSs are added as needed. KSU employs a chemical management system, Chematix, for chemical tracking and waste management. Chemicals are tracked from delivery to disposal through the system. All chemicals and chemical products are included.

As an employee of the State of Georgia, you have the right to know about hazardous chemicals in the workplace. This right is guaranteed under Georgia's “Public Employee Hazardous Chemical Protection and Right to Know Act of 1988” (O.C.G.A. 45-22-2). Along with your right to know, recent federal regulations now provide you the “right to understand” with an updated Hazard Communication Standard (HCS) found in 29 CFR 1910.1200. This new standard makes it easier for you to understand labels on hazardous chemicals and information in safety data sheets.

Right to Know training is required for all new employees and all employees are required to take annual refresher training. The training is available through OwlTrain as well as offered in a classroom setting.

Various University activities, particularly Science labs, Visual Art studios, maintenance shops, and grounds-keeping operations, generate various types of hazardous wastes. Typical hazardous wastes generated include spent solvents, acids and bases, heavy metals, paints, oils, and unused chemicals, among others.

The handling and disposal of hazardous waste is regulated by the Environmental Protection Agency (EPA) under the Resource Conservation and Recovery Act (RCRA) found in 40 CFR part 261. State and local jurisdictions may also have additional regulations governing management of hazardous waste. To ensure a safe workplace and to adequately protect the environment and comply with Federal and State regulations, all University personnel who generate hazardous waste must ensure that the wastes they generate are properly managed in accordance with the University's Hazardous Waste Management Procedures.

Proper management of hazardous waste includes:

• Correctly identifying wastes as hazardous
• Storing wastes in a properly labeled and closed container
• Adequately segregating waste containers and ensuring secondary containment to reduce spills
• Performing weekly visual inspections of 180-day waste areas
• Ensuring the timely removal from operating areas through EHS services

The Environmental Protection Agency (EPA) oversees The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).  FIFRA is a law that is written to protect consumers, applicators and the environment.  The EPA seeks to meet the goals of the act by controlling the production, sale, distribution and use of pesticides (40 CFR 152-180).

Under FIFRA, all pesticide-manufacturing plants, and all pesticides sold or distributed in commerce, must be registered with the EPA.  Labels on pesticide containers include important safety information, instructions for applying the pesticide, and the intervals at which applicators can re-enter application areas.  FIFRA regulations require that workers follow all label instructions.  Workers must follow safety standards (the Worker Protection Standard) when they mix and apply pesticides, and state agencies must certify the workers who apply certain pesticides.  FIFRA also mandates practices for managing waste pesticides and for handling container residues.

Certain aspects of FIFRA will apply to Kennesaw State University (KSU) if KSU personnel  apply pesticides.  If a contractor applies pesticides, that contractor must adhere to the applicable portions of FIFRA.  All workers using pesticides must receive training, and applicators must be state-certified if they work with restricted use pesticides.

The Worker Protection Standard does not apply to the research uses of unrestricted pesticides.  It also does not apply to workers who do no more than handle empty containers.

Respiratory protection is needed when personnel are required to work in an area that is oxygen deficient or where harmful dusts, mists, fog, smoke, fumes, gases, vapors or sprays are present.  If exposed to harmful conditions, a person may develop cancer, lung impairment, other diseases or death.

At KSU, we desire to provide engineering controls, such as laboratory fume hoods, that will eliminate the hazards and thus reduce the need for personnel to wear respirators.  However, in those jobs where a respirator is required, a respirator protection program will be employed.

The solution is not as simple as choosing a respirator and wearing it.  A person must be trained on the correct use of a respirator, care of a respirator and undergo a fit test for a particular respirator.  A medical evaluation is also required for persons who are required to wear a respirator on the job.

If your work environment requires the use of a respirator or if you need to have your work environment evaluated, please contact us.

Congress enacted the Toxic Substances Control Act (TSCA) in 1976.  TSCA gives the Environmental Protection Agency (EPA) the ability to track the 75,000 industrial chemicals produced in the United States or imported into the United States.  EPA collects data on these chemicals and can require the manufacturer or importer to determine the risks that these chemicals pose to human health or the environment.  Under TSCA, the EPA can control the production, distribution, and importation of new and existing chemicals; establish specific disposal rules; and ban the use of high-risk chemicals, such as Polychlorinated biphenyls (PCBs).

TSCA also controls specific substances, such as asbestos, PCBs, lead, and biotechnology.  TSCA excludes tobacco, foods, food additives, drugs and cosmetics.  The TSCA program also excludes nuclear materials, munitions, and chemicals used solely as pesticides.  Other exemptions include naturally occurring materials, products of incidental reactions and end-use reactions, mixtures, byproducts, and substances made solely for export.

TSCA defines “research” as commercial research if a commercial entity directly provides partial or complete funding for the work.  It is not important who actually conducts the research.  If KSU personnel import or export chemicals for any purpose, the chemicals must be accompanied by import/export rule certifications.  In most cases, research activities are either exempt from TSCA rules pertaining to the significant new use rule and the pre-manufacture notice, or those activities are subject to fewer demands than those made on manufacturing.  As long as KSU meets the safety and recordkeeping requirements in 40 CFR 720.36 and 720.78, the chemicals created in small amounts for research are exempt from TSCA reporting.  However, if KSU were to produce chemicals commercially, more extensive TSCA requirements will apply.