A. Hazard Determination
The manufacturer of any substance used by Hillcrest is responsible to determine if the substance is hazardous under OSHA Standards and any other applicable standards or regulations. Hillcrest will not test any purchased materials to determine their hazard properties. Hillcrest staff who deal with hazardous substances are aware of the following hazard determination procedures:
1. DOT hazard class labels and product container labels must be consistent with the hazards described on the Safety Data Sheet (SDS).
2. If initial experience indicates that the material has characteristics or properties different from those stated on the SDS, the supplier will be contacted for explanation or clarification before the substance is used.
3. If the SDS states the ingredients are a trade secret but gives no hazard warning, the supplier must provide a new and more complete SDS before the substance is used.
Hillcrest is in compliance with the Massachusetts ‘Children’s Protection Act of 2000’. This law applies to all Massachusetts public and private schools. It regulates the use of pesticides and pest management procedures, and requires notifications to students and staff when pesticides are to be used. The law also requires the development of an Integrated Pest Management Plan that is submitted to the state Dept. of Food and Agriculture, and that is periodically reviewed, evaluated and updated.
B. Labeling
1. All Hillcrest campuses preserve and use the labels already on the containers provided by manufacturers or suppliers. At a minimum it is expected that these labels will:
• Be written in clear, basic language.
• Be prominently displayed.
• Include the Hazardous Substance Identity, appropriate Hazard Warning information and the name and address of the manufacturer of the substance.
2. Whenever substances are transferred to other containers for later use, the new containers will be labeled immediately with the substance or product name as it appears on the manufacturer label. The new container will also include any hazard warning information.
3. Storage containers for bulk material (e.g., surface finishes) are labeled as indicated above. These labels will be weather proof and placed conspicuously on the container.
C. Safety Data Sheets (SDS)
1. Hillcrest requires that manufacturers, distributors and suppliers of products used by Hillcrest provide SDS information. Hillcrest will not use any substance with an SDS that does not, for any reason, include health and/or safety information.
2. The department that orders and/or uses the substance is responsible for obtaining SDS for all substances used by that department. No hazardous substance may be purchased, received or used without the appropriate SDS. The associated Department Head must determine the ability of the agency and/or campus to safely manage any new substance.
3. Each department that orders and/or uses the substance will ensure that every substance in inventory has a corresponding SDS and reviews the SDS file at least twice each year.
4. A master file of SDS is maintained in the specific department on each campus. This file is arranged so that particular SDS may be found quickly, and all department staff are oriented to that filing system.
5. Current departmental inventories of hazardous substances are maintained in specific, designated locations at each Hillcrest campus. These inventories coincide with the departmental SDS files for that campus.
6. SDS books are located in the lobby of the main building at each Hillcrest site in a “Right To Know” rack.
7. At Hillcrest sites that have swimming pools, a separate “pool only” SDS book is located at the pools where the chemicals are stored.