2.1  Hazardous Chemical Definition

2.2  Texas Hazard Communication Act

2.3  Chemical Inventory Systems

2.4  Chemical Labeling Policy

2.4.1  Scope

2.4.2  Purpose

2.4.3  Policy

2.4.4  Procedure

2.5  Material Safety Data Sheets (MSDSs)

2.6  Hazard Communication Training Policy

2.6.1  Scope

2.6.2  Training Content

2.6.3  Training Documentation

2.6.4  Employee Responsibilities

2.1       Hazardous Chemical Definition

A hazardous chemical is any chemical that poses a physical and/or health hazard. 

A chemical that is a physical hazard has scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water-reactive. 

A chemical that is a health hazard has statistically significant evidence (based on at least one study conducted in accordance with established scientific principles) that acute or chronic health effects may occur in exposed persons.  This includes chemicals that are:

· carcinogens or known to cause neoplastic effects

· highly toxic agents

· moderately toxic agents

· reproductive system toxins

· teratogens

· mutagens

· sensitizers or allergens (immunologic system effects)

· substances causing target organ effects (hepatotoxins, nephrotoxins, neurotoxins, hematopoietic system toxins, and agents which damage the lungs, skin, eyes, or mucous membranes)

· corrosives

· irritants


2.2       Texas Hazard Communication Act

The Texas Hazard Communication Act (HCA) of the Texas Health and Safety Code (Chapter 502) is a law that requires public employers to provide employees with specific information on the hazards of the chemicals to which employees may be exposed in the workplace.  The specific information required includes:

· A list of hazardous chemicals used or stored in the workplace; the list must be revised as necessary, but at least annually.

· Readily accessible and current Material Safety Data Sheets (MSDSs) for these chemicals (hard-copy or online)

· Labeling information for the chemicals; Employees shall not be required to work with unlabeled chemicals except for portable containers for immediate use, the contents of which are known to the user.

· Training on the hazards of the chemicals and measures employees can take to protect themselves from those hazards; The training shall be repeated as needed, but at least whenever new chemicals are introduced into the workplace or new information is received on the chemicals already present. 

Per the HCA, hazardous chemicals are defined as in section 2.1 above and include any of the substances listed in 29 CFR 1910.1200, parts (c) or (d), or any chemicals listed in the most current American Conference of Governmental Industrial Hygienists booklet “Threshold Limit Values and Biological Exposure Indices.”


2.3       Chemical Inventory Systems

UTMB Policy and the Texas HCA require that all areas using or storing hazardous chemicals maintain a chemical inventory.  This inventory must be updated each year via a physical inventory of chemical containers.  This inventory must be provided to EHS on request, typically during the annual Lab Audit process. 

Keep the following guidelines in mind while performing the physical inventory:

· Replace deteriorating labels before the information is illegible or lost.

· Dispose of material not anticipated to be used within a reasonable time period.

· Have experienced personnel inspect and dispose of deteriorating containers or containers in which it is apparent that a chemical change has occurred.

· Dispose of or recycle chemicals before the expiration date. 

It is recommended that chemical inventories be maintained electronically with a minimum of the following information:

Smith Lab Chemical Inventory

May 1, 2008




Catalog #


Room #



4 L


A18 sk-4

Flammables Cabinet



1 mg.



-80 CFreezer



25 g.



Shelf above bench



2.4       Chemical Labeling

2.4.1       Scope

This policy applies to all who purchase, use and store chemicals or commercial products containing chemicals including, but not limited to, paints, aerosol lubricants, cleaning agents, and other such non-laboratory products.  This policy does not affect pharmaceuticals dispensed by the UTMB Pharmacy Department.

2.4.2       Purpose

The purpose of this policy is to communicate to employees the chemical identity and other pertinent hazard information for the chemicals in their work area. 

2.4.3       Policy

The Texas HCA and UTMB Policy require that all containers of hazardous chemicals be labeled with certain information.  The Texas HCA Chapter 502.007 further states that a label on an existing container of a hazardous chemical may not be removed or defaced unless it is illegible, inaccurate, or does not conform to the OSHA standard (29 CFR 1910.1200) or other applicable labeling requirements. 

This policy is to be part of new employee HCA training before working with any chemicals or chemical products. 

Labels can be printed or handwritten.  Information can also be written directly on the container (e.g., permanent marker, wax or grease pencil).  Some commercial labeling systems are allowed as well.  The HMIS (Hazardous Materials Identification System) is acceptable.  The NFPA (National Fire Protection Association) 704 labeling system is not acceptable.  HMIS labels can be purchased through Scientific Alley or through lab supply catalogs.

2.4.4       Procedure

New Containers

Check each new chemical container upon delivery to make sure it is labeled.  Original manufacturer container labels or new labels on original containers must contain: 

· Chemical identity (use chemical names not abbreviations)

· Concentration

· Appropriate hazard warnings (e.g. HMIS numerical ratings)

· Manufacturer’s name and address

If the information is present, place the date received on the container along with the name of the owner.  If the owner’s initials are used, they must be unique to that laboratory so that the owner may be located if necessary.  Place the container in an appropriate storage place according to its hazards.  When the chemical container is opened, place the date opened on the label as well.

Existing Containers

Containers used to prepare a solution or mixture must be labeled with:

 · Chemical identity (use chemical names not abbreviations)

· Concentration

· Appropriate hazard warnings (e.g. HMIS numerical ratings)

· Date prepared

· Initials of the person who prepared the solution or mixture 

For mixtures, assign the value of the most hazardous component in each category.  Refer to a chemical catalog or the MSDS for the HMIS numerical ratings.  If these sources do not have the information, see HMIS III HAZARD RATINGS below or contact EHS for assistance. 

Pipeline Labeling Exemption

Labeling of pipelines carrying chemicals is not required, provided that employees have ready access (within their normal work shift) to documents to determine the contents of pipes at any time. 


* Chronic Hazard Chronic (long-term) health effects may result from repeated overexposure

0 Minimal Hazard No significant risk to health

1 Slight Hazard Irritation or minor reversible injury possible

2 Moderate Hazard Temporary or minor injury may occur

3 Serious Hazard Major injury likely unless prompt action is taken and medical treatment is given

4 Severe Hazard Life-threatening, major or permanent damage may result from single or repeated overexposures


0 Minimal Hazard Materials that will not burn

1 Slight Hazard Materials that must be preheated before ignition will occur. Includes liquids, solids and semi solids having a flash point above 200 F. (Class IIIB)

2 Moderate Hazard Materials which must be moderately heated or exposed to high ambient temperatures before ignition will occur. Includes liquids having a flash point at or above 100 F but below 200 F. (Classes II & IIIA)

3 Serious Hazard Materials capable of ignition under almost all normal temperature conditions. Includes flammable liquids with flash points below 73 F and boiling points above 100 F. as well as liquids with flash points between 73 F and 100 F (Classes IB & IC)

4 Severe Hazard Flammable gases, or very volatile flammable liquids with flash points below 73 F, and boiling points below 100 F. Materials may ignite spontaneously with air.

(Class IA)


0 Minimal Hazard Materials that are normally stable, even under fire conditions, and will NOT react with water, polymerize, decompose, condense, or self-react. Non-Explosives.

1 Slight Hazard Materials that are normally stable but can become unstable (self-react) at high temperatures and pressures. Materials may react non-violently with water or

undergo hazardous polymerization in the absence of inhibitors.

2 Moderate Hazard Materials that are unstable and may undergo violent chemical changes at normal temperature and pressure with low risk for explosion. Materials may react violently with water or form peroxides upon exposure to air.

3 Serious Hazard Materials that may form explosive mixtures with water and are capable of detonation or explosive reaction in the presence of a strong initiating source.

Materials may polymerize, decompose, self-react, or undergo other chemical change at normal temperature and pressure with moderate risk of explosion

4 Severe Hazard Materials that are readily capable of explosive water reaction, detonation or explosive decomposition, polymerization, or self-reaction at normal temperature and pressure. 


The HMIS coding for Personal Protective Equipment (PPE) is listed below.  For any hazardous chemical, a minimum of safety glasses is required.


Safety glasses only


Safety glasses + gloves


Safety glasses + gloves + chemically resistant apron


face shield + gloves + chemically resistant apron


Safety glasses + gloves + dust mask


Safety glasses + gloves + dust mask


Safety glasses + vapor respirator


Safety goggles + gloves + vapor respirator


Safety glasses + gloves + dust and vapor respirator


Safety goggles + gloves + apron + dust and vapor respirator


full face, supplied air respirator + gloves + protective suite + boots


Ask your supervisor for special handling instructions

NOTE: Any respiratory protection use must be authorized by EHS.
Personnel will have to comply with the UTMB Respiratory Protection Plan.

References:  TDH Chapter 502 Hazard Communication Act Revised 1993, 29 CFR 1910 Subpart Z OSHA regulated chemicals


2.5       Material Safety Data Sheets (MSDSs)

The Texas HCA requires manufacturers or distributors of hazardous chemicals to assess the physical and health hazards of the chemicals or products. This information must be included in the Material Safety Data Sheet (MSDS), which must be provided to the purchaser of the product with at least the initial shipment of the chemical. MSDSs must be obtained and maintained for every chemical used in the workplace. The MSDSs must be accessible to all personnel during their work hours.

The ANSI (American National Standards Institute) 16 section format for MSDSs is recommended:

1.                   Substance identity and company contact information

2.                   Chemical composition and data on components

3.                   Hazards identification

4.                   First aid measures

5.                   Fire-fighting measures

6.                   Accidental release measures

7.                   Handling and storage

8.                   Exposure controls and personal protection

9.                   Physical and chemical properties

10.                   Stability and reactivity

11.                   Toxicological information

12.                   Ecological information

13.                   Disposal considerations

14.               Transport information

15.               Regulations

16.               Other information

MSDSs are available electronically at Employees must be instructed in how to interpret the information in each section of the MSDS.


2.6       Hazard Communication Training

2.6.1       Scope

The Texas HCA requires specialized chemical training for all employees who may be exposed to hazardous chemicals.  This training must be provided to all new or newly assigned employees before working with hazardous chemicals or within 10 days after beginning employment, whichever is shorter.  Hazardous chemicals are defined in section 2.1 of this chapter.  Employees designated as HCA Trainers must receive training from EHS B&C prior to performing this function.

2.6.2       Training Content

This training must include general information on how to interpret hazardous chemical labels and MSDSs as well as information on safe handling, spill cleanup and disposal of hazardous chemicals.  The training must also include specific information on the chemicals used by the employees including chemical storage location, health and physical hazards, safe handling, spill cleanup, PPE and first aid treatment.   

The general information is covered by on-line training assigned to all new employees that may be exposed to hazardous chemicals.  The specific information is covered by training provided by departmental HCA Trainers.  Principal Investigators and Department Managers are responsible for identifying HCA Trainers and notifying HCA Trainers of personnel requiring specific HCA training.  HCA Trainers also provide retraining when new hazardous chemicals are introduced into the workplace or when new information is received on existing chemicals in the workplace.

2.6.3       Training Documentation

On-line general HCA training is documented electronically.  Specific HCA training must be documented with the type of training provided, the training date, signature of the trained employee and signature of the trainer. This training documentation must be forwarded to EHS B&C.  Principal Investigators and Department Managers are responsible for ensuring the completed documentation is sent to EHS B&C.

2.6.4       Employee Responsibilities

· Complete general and specific HCA training

· Become familiar with chemical labels & MSDSs for chemicals in their work area

· Use and dispose of hazardous chemicals per specific HCA training, MSDSs and UTMB policies and procedures

· Report any work-related changes or suspected changes in their health status to the Manager and/or Employee Health

· Report all spills, accidents and exposures to their Manager