Hazardous Materials Management and Hazardous Waste Policy

Applicable Regulations: 

Community Right to Know - DILHR 101.58
Employee Right to Know - RCRA NR 181

In order to promote a safe environment for employees and students, facilitate compliance with the law, and mitigate liability, The University of Wisconsin-Platteville has established the following policies and procedures. These are believed to be in compliance with the stated and inherent responsibilities contained in the Federal Superfund and Reauthorization Act of 1986 (SARA), Title III; the Department of Industry, Labor, and Human Relations, Section 101.58; The Resource Conservation and Recovery Act of 1980 & Amendments (RCRA, codified in NR1 81); and UW System Policy.

I. Material Safety Data Sheet Management

  1. A Material Safety Data Sheet (MSDS) should be provided to the campus by the vendor for each product that requires an MSDS per OSHA regulation.
    1. The vendor shall supply a copy of the MSDS attached to the invoice and sent directly to Accounts Payable. Accounts Payable will record the purchase order number on the MSDS and forward it to the Hazardous Materials Coordinator.
    2. The Vendor shall also include a copy of the MSDS with the product being shipped. This copy will remain with the shipment until it reaches the designated person in the ordering department.
  2. The central Material Safety Data Sheet (MSDS) file is established in the office of the Hazardous Materials Coordinator.
    1. The Hazardous Materials Coordinator shall maintain a file of all MSDS copies forwarded to him/her by the various departments on the University campus and farm.
    2. The Hazardous Materials Coordinator shall work with the departments to assure the completeness and accuracy of the file.
    3. Each new Material Safety Data Sheet received by the Hazardous Materials Coordinator shall be assigned a master number, copied, and sent to the ordering department.
    4. The Hazardous Materials Coordinator is designated the responsibility of submitting reports and MSDS's to the State Emergency Response Board, the Local Emergency Planning Committee, and the local Fire Department as specified by SARA Title III.
    5. The Hazardous Materials Coordinator is the person designated to be the contact person at the University for these agencies. S/He will also work with the Local Emergency Planning Committee in developing any necessary plans.
    6. The Hazardous Materials Coordinator shall, in cooperation with the Safety Director, develop and exercise Emergency Response Plans for the facility in accordance with RCRA and SARA Title III.
    7. The Hazardous Materials Coordinator is designated by the campus to maintain the MSDS's for substances for thirty (30) years following the last use of the product, following notification by the department using the material.
  3. Each Department shall maintain a complete MSDS file for the materials they purchase, store, and use.
    1. The Department is responsible for obtaining the MSDS for each product or chemical currently in inventory so far as is possible.
    2. The Department should request on the purchase order the MSDS for each new product ordered for which OSHA requires an MSDS.
    3. The Department is responsible for storing the MSDS during the period of use and for notifying the Hazardous Materials Office when the product/chemical is discontinued in use and inventory.
    4. The Department is responsible for cross referencing the MSDS with the product, including subsequent dilutions or conbinations of the product. This may be done using a numbered index system or other concise, simple system.
    5. When the Department receives an MSDS directly, the Department is responsible for providing a dated copy of the MSDS to the Hazardous Materials Coordinator.
  4. Each department should designate a faculty or staff member who will be responsible for the administration of the Material Safety Data Sheet program, the training of employees and students (Paragraph II), the employee/student right-to-know program (Paragraph III), the annual inventory of stocks (Paragraph IV), and meeting the hazardous waste management responsibilities of the Resource Conservation and Recovery Act (Paragraph V).

II. Training of Employees and Students

  1. Each Department shall provide training for its employees and students who use or come in contact with the various hazardous products/chemicals.
    1. This training shall be documented and in accordance with DILHR 101.58 which states in part:
      ". . . prior to an employe's initial assignment to a workplace where the employe may routinely be exposed to any toxic substance, infectious agent, or pesticide, an employer shall provide the employe with an education or training program. . . . Additional instruction (shall be provided) whenever the employe may be routinely exposed to any additional toxic substance or infectious agent."
      Where a large number of chemicals in very small order quantities (1 kg per order, 10 x per year) are involved, a general education/training program may be acceptable.
    2. The training shall include advisement of the risks and proper handling techniques for the product/chemical using the MSDS as one source of information.
    3. Training shall also include location of the toxic substance or infectious agent, personal protective equipment to be used, emergency measures, symptoms of acute or chronic over exposure, and proper cleanup and waste management procedures.
    4. Oversight of training and assurance of adequacy of training shall be monitored by the Hazardous Materials Coordinator in cooperation with the Departments.

III. Employee Right to Know/Student Right to Know

  1. Each Department shall provide MSDS information for a specific product/chemical if requested in writing by an employee or student.
    1. Employee Right to Know
      1. The employee should make the request for the MSDS to his/her immediate supervisor or department chairperson. The request should be in writing to maintain rights for the employee and liability protection for the university.
      2. The employee must be provided with a copy of the MSDS in accordance with DILHR 101.58 which specifies the following time frames:
        1. Toxic Substances (present at facility at time of request): 15 working days
        2. Infectious Agents (present at facility within last 30 days): 72 hours
        3. Pesticides (label information): 72 hours Time frames exclude weekends and legal holidays. If the employer does not have the information on hand, the information must be provided within 30 working days of the request. If the employer requests and cannot obtain the informtion from the supplier, and does not otherwise have it, the employer is not required to provide it but shall notify the employee of that fact.
      3. If the supervisor is not responsive, the request can be made of the following offices in succession: Department Chairperson, Hazardous Materials Coordinator, Chancellor's Office.
      4. An employee includes faculty, academic staff, classified staff, LTE's, student employees, and subcontractors.
  1. Student Right to Know
    1. A student may request MSDS information for a particular product/chemical s/he is exposed to by expressing that request in writing to the faculty/staff person in charge of the class, lab, or research project.
    2. The faculty/staff person receiving the request must make a reference copy available to the student within the time frames listed above in 1.b.
    3. If the faculty/staff person is not responsive to the request, then a request may be made to the following offices in succession: Department Chairperson, Hazardous Materials Coordinator, Chancellor's Office.
  2. Record of the MSDS requests and replies/provision of the MSDS should be kept on file to verify compliance with DILHR requirements.

IV. Annual Inventory of Stocks

  1. Each Department shall maintain an Annual Inventory which is adequate to provide for the following purposes (including but not limited to):
    1. Departmental Management of Stocks and MSDS's
    2. Inter-departmental transfer of surplus
    3. University-wide cataloging of stock on hand including location information for the purpose of SARA compliance, conservation, waste management, and MSDS management.
  2. The inventory format (including electronic format) shall be compatible with the format required for the university-wide cataloging system.
  3. The departments are responsible for conducting the inventory and updating the inventory annually and upon receipt of shipments.
  4. The Annual Inventory for the calendar year must be provided to the Hazardous Materials Coordinator by February 1 of the following year.
  5. The Hazardous Materials Coordinator is responsible for coordinating the chemical/ product inventory at the University, and maintaining the university-wide inventory.
  6. All stocks will be labeled with the Material Safety Data Sheet reference key and the NFPA Hazard Diamond in addition to other labeling on the container. If the NFPA diamond is not on the manufacturer's label, the Department will be responsible for placing the NFPA Diamond on the container.

V. Hazardous Waste Management and Responsibilities

  1. The Resource Conservation and Recovery Act of 1980 (RCRA), NR 181, and the US EPA have established a criteria for and a list of chemicals, products, and by-products that pose a serious threat to the environment and/or its inhabitants. These materials, when they become waste, must be managed and disposed of properly in accordance with the regulatory requirements. Wastes with any one or more of the following characteristics must be managed by the Hazardous Waste Program at the University of Wisconsin-Platteville.
    1. Ignitability: Liquid with a closed cup flash point of less than 140 F and other.*
    2. Corrosive: pH of greater than 12.5 or less than 2.0 and other.*
    3. Reactivity: Unstable and readily undergoes violent change without detonation, reacts violently with water, and other.*
    4. Tclp Toxic Waste: Waste containing certain levels of specified materials.*
    5. Listed Wastes: Wastes or waste products containing specifically listed chemicals/compounds. Lists are found in NR 181.16.

      * Criteria and characteristics are fully described in NR 181.14 and 181.15. These should be consulted to obtain the full information regarding waste determination. Questions may be directed to the Hazardous Materials Coordinator.
  2. Generator Responsibility
    1. The person in charge of the activity which results in production of hazardous waste is responsible to see that the properly contained material is picked up by the Hazardous Materials Coordinator or Representative for proper disposal.
    2. Prior to removal of the waste by the Coordinator or Representative, the generator shall complete a written form indicating the contents and characteristics of the waste. The generator shall also indicate the MSDS sheet number(s) which correspond to the waste or are components of the waste. The generator shall also identify any special or unusual hazards regarding the waste prior to the removal of the waste from his/her possession.
    3. The Hazardous Materials Coordinator or Representative is responsible for receiving and transporting the waste from the generator's possession to the Hazardous Waste Storage Facility.
    4. Upon receipt, the Hazardous Materials Coordinator is responsible for coordinating the proper storage and disposal of the waste.
    5. When an instructor conducts a laboratory experiment, the waste by-products should be assessed for their hazardous waste characteristics. The hazardous waste should be collected and managed under the University's Hazardous Waste Program. Instructors are permitted to include, as a part of their laboratory instruction, elementary neutrali-zation procedures and applications in order to provide students with a better under- standing of methods to protect the environment and reduce hazardous waste. If this instructional activity is employed, the amount of waste from the primary experiment, the neutralization procedure used in the secondary experiment, the date, and the outcome should be recorded and forwarded to the Hazardous Materials Coordinator.

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