Hazard Communication Plan

Scope

This procedure applies to all college workplaces, departments, facilities, and operations where workers, students, student workers, or contractors may be exposed to hazardous chemicals under normal conditions of use or in a foreseeable emergency.

In accordance with 29 CFR 1910.1450(a)(3), this procedure does not apply to the "laboratory use of hazardous chemicals" as defined by OSHA. All academic and research laboratories (including Science division labs, stockrooms, and bench-scale testing facilities) that utilize multiple chemicals on a single-person scale under standard engineering controls are strictly excluded from this plan. Those spaces are governed independently by the Lane Community College Chemical Hygiene Plan (CHP). Conversely, any chemical use within a laboratory space that does not meet the operational definition of laboratory use remains under the jurisdiction of this Hazard Communication Plan.

This procedure does not apply to tobacco, wood products (except where processed or sanded, creating combustible dust), foods, drugs, cosmetics, or other items intended for personal consumption or workplace use by employees that match typical consumer usage. It explicitly excludes biological hazards and ionizing/non-ionizing radiation.

Identifying Hazardous Chemicals

A list of all hazardous chemicals with a potential for employee exposure is maintained and available online via the campus safety data sheet (SDS) system at lanecc.kha.com. Detailed information about the health, physical, and newly classified hazards of each chemical is housed within a SDS.

How to use the campus SDS system

Go to lanecc.kha.com.

After the page loads, you can enter a search term in the text box. Your keywords will be matched against all data that has been indexed from the SDSs in your system. Entering a chemical or product name, manufacturer, ingredient, or synonym to begin. You may also search using the CAS Registry Number (commonly called a CAS number or CAS RN), which is a unique, universal numerical identifier assigned to every chemical substance described in scientific literature.

The “Binders to look in” drop down menu references the organizational structure of our SDS system. By default all SDSs are included in the “Master” binder. At Lane Community College we have entered chemicals in binders associated with departments and locations. You can limit the scope of your search to an organizational subsection within our system by selecting a subsection of your choosing from the “Binders to look in” drop down.

The green “Search for SDS” button executes your search when clicked. If no text is entered and no subsection has been selected from the “Binders to look in” dropdown menu, clicking the button will return search results listing all SDS in our system.

Search results are displayed in sortable columns. From the displayed search results you can choose to open the complete manufacturer-authored SDS or view an SDS Detail page.

The SDS Detail Page allows users to view the full Safety Data Sheet and confirm key details such as product name, manufacturer, revision date, country, and language. Clicking on any of the product names in the center “Product Name” column will launch the SDS Detail window summarizing the associated SDS.

The detail page for each chemical allows all users to do the following:

1. The “Download SDS” button allows you to download the SDS, in PDF format, directly to your device. The SDS can then be shared as needed or saved for future reference.
2. The “Print Label” button allows you to create secondary container labels for items that may have been moved to a secondary container and need a GHS label.
3. Clicking the “Send SDS” button allows you to share the SDS via Email. The Share SDS feature can be used to provide read-only SDS access to individuals who may not have access to your Online-SDS account, such as Emergency Responders or contractors.

How to display a list of hazardous chemicals present in your specific work area using the campus online SDS system 

1. Access the online SDS system for Lane Community College by doing either of the following:
   1. Navigate to the following website: https://lanecc.kha.com/

   2. Scan the QR code displayed below with the camera on your smart device: 

      
2. In the field under “Binders to look in” click on the downward arrow on the right to display a list of binders. The number shown in parentheses is the number of chemicals in any given binder or area. 
3. Use the bar to scroll to the desired binder, then click on the binder name.
4. Click on “Search for SDS”
5. Click on “Product Name” to order alphabetically.
6. Scroll to the bottom of the page and click on “Print” at the bottom left to generate a printable table of the hazardous chemicals. 
7. In order to access the SDS for any particular chemical, click on the SDS ID in the left column.

Identifying Containers of Hazardous Chemicals

All hazardous chemical containers used at this college must bear either the manufacturer’s original shipped label or a workplace label. No container will be released for campus use by Departmental Safety Data Sheet Coordinators until label verification is complete.

Workplace labels must be legible, written in English, and prominently displayed. To ensure compliance with GHS Revision 7 updates, any workplace or secondary chemical container label must feature:  

1. Product Name: Cross-referenced directly to the SDS.  
2. Globally Harmonized System (GHS) Label Elements: A signal word (i.e. Danger or Warning), standardized pictogram(s), specific hazard statement(s), and all required precautionary statements.
3. Alternative Workplace Labeling: If alternative words, pictures, or symbols are used, they must be paired with the college's overall hazard communication program to give employees immediate access to specific hazards and protective measures.

Secondary Container Labeling

A secondary container (such as a spray bottle, safety can, flask, beaker, or smaller jar) is any container utilized to hold a hazardous chemical transferred from its original, manufacturer-labeled primary container. To prevent accidental exposure, chemical cross-contamination, or improper disposal, all secondary containers must be labeled immediately upon transfer unless they meet a strict regulatory exemption.

To enable compliant secondary labeling, it is highly recommended for secondary labels to be printed from the SDS detail page on lanecc.kha.com.

Minimum Labeling Requirements

Every secondary container that requires labeling must be clearly marked, tagged, or stenciled in English with:

• The Product Identifier: The exact chemical name, common name, or alphanumeric code that matches the primary container's label and Section 1 of its corresponding Safety Data Sheet (SDS).
• Hazard Warning Information: Words, pictures, symbols, or a combination thereof which provide at least general information regarding the specific physical and health hazards of the chemical.

Use of Alternative Workplace Labeling Systems

The college permits the use of alternative hazard warning systems on secondary containers (such as National Fire Protection Association (NFPA) 704 diamonds or Hazardous Materials Identification System (HMIS) bars). However, to maintain alignment with Oregon OSHA's updated standards, these alternative systems are only acceptable if:

1. They do not contradict or obscure the primary GHS hazard classifications.
2. Employees are comprehensively trained on how to interpret them.
3. Employees have immediate access to the complete physical and health hazard details via the campus SDS system at lanecc.kha.com throughout their entire work shift.

The "Immediate Use" Exemption

A secondary container is exempt from labeling requirements only if it meets all of the following "immediate use" criteria:

• The hazardous chemical is transferred into the portable container by the same employee who will be using it.
• The chemical remains under the continuous, sole control of the transferring employee at all times.
• The chemical is completely used up, neutralized, or transferred back into a legally labeled container by the end of that employee's specific work shift.

Important Note: If a secondary container is left unattended for any period of time, is handed off to another worker or student, or contains material that persists past the end of the work shift, it loses its exemption status and must be labeled immediately. Unlabeled, unattended secondary containers discovered on campus are subject to immediate confiscation and hazardous waste disposal by FMP.

Keeping Safety Data Sheets

Safety Data Sheets are fully accessible electronically to all employees during their work shifts via departmental digital binders at lanecc.kha.com. Departmental Safety Data Sheet Coordinators are responsible for ensuring that the electronic database is kept current. All modern SDSs uploaded or received must follow the standardized 16-section format. If an updated SDS reveals new or altered chemical hazards, affected employees must be retrained on that information before the chemical is used again on campus.

Training Employees About Chemical Hazards

Department managers must ensure employees receive comprehensive hazard training before they begin work or are exposed to new chemical hazards. Training covers college-wide fundamentals via Vector Solutions, alongside department-specific guidance.

To satisfy revised Oregon OSHA guidelines, training programs must explicitly teach employees how to recognize, understand, and interpret the updated GHS Revision 7 label elements (including new pictograms and precautionary statements) and the standardized 16-section SDS format.

Student Training and Information 

Instructors bear the direct responsibility of advising students on the specific nature and risks of hazardous chemicals utilized in classroom or laboratory settings. Students must be briefed on this policy, basic hazard recognition, and how to access the Safety Data Sheets within their respective classrooms or studios.

Informing Employees Who Do Special Tasks & Pipe Labels

Supervisors must evaluate non-routine tasks, inform employees of chemical hazards, and provide necessary Personal Protective Equipment (PPE). Before employees perform special (non-routine) tasks that may expose them to hazardous chemicals, their supervisors will inform them about the chemical hazards. Their supervisors also will inform them about how to control exposure and what to do in an emergency. The employer will evaluate the hazards of these tasks and provide appropriate controls including Personal Protective Equipment and additional training as required.

Pipe Labels

For piping systems, the college complies with OAR 437-002-0378. Before working near unlabeled pipes or pipes insulated with asbestos, employees must contact Facilities Management at (541) 463-5000. Pipes containing hazardous substances must be clearly labeled using lettered stenciling, markers, or adhesive tape near valves, flanges, direction changes, and wall crossings. Lettering must match the full or abbreviated chemical name and include sufficient hazard detail.

Informing Employees About Hazardous Chemicals in Pipes

This workplace follows the labeling requirements in OAR 437-002-0378 concerning the labeling of pipes. Before working in areas where hazardous chemicals are transferred through unlabeled pipes or where pipes are insulated with asbestos-containing material, employees will contact the Facilities Office at (541) 463-5000 for the following information:

• The chemicals in the pipes.
• The physical or health hazards of the chemicals present.
• The safe work practices necessary to prevent exposure.

Informing Contractors

College personnel coordinating contractor activities must provide external workers with information regarding on-site chemical exposures, our pipe/container labeling conventions, and SDS access. Campus coordinators must also secure an SDS for any hazardous chemical a contractor intends to bring onto college property.

Phase-In & Transitional Compliance Dates

During the rolling transition period established under OAR 437-002-0376, the college will update its chemical inventories, alternative workplace labels, and training in accordance with Oregon OSHA's revised state compliance deadlines:

• July 1, 2026: Revised Hazard Communication rules officially take effect in Oregon.
• June 1, 2027: Deadline for the college to update all alternative workplace labeling, update the hazard communication program, and deliver additional employee training for any newly identified chemical substance hazards.
• June 1, 2028: Deadline for the college to fully update workplace labeling, program documentation, and employee training for newly identified chemical mixture hazards.