The Office of Environmental Health and Safety’s Industrial Hygienist is Nicole Moskal. To contact Nicole, please email moskaln@tcnj.edu or call extension x2881. Below, you will find information on the programs managed by the Industrial Hygienist including Indoor Air Quality, Asbestos Management, & Right to Know.
Right to Know – Hazard Communication – GHS
Important Dates:
**GHS Compliance** since June 1, 2016
**RTK Survey Reporting is Due to EHS by the following FEBRUARY 15th of each year**
The Right to Know program is managed by the College’s Industrial Hygienist, Nicole Moskal. If you have any questions, please email moskaln@tcnj.edu or call (609)-771-2881.
EHS has developed a GHS Compliance Log for those areas who wish to keep products that are no longer Globally Harmonized System (GHS) compliant and meet all the specific criteria.
The Mandatory Right to Know (RTK) Survey is submitted annually to the NJ Department of Health through our office for the entire campus. The Mandatory RTK Survey is the required means of communicating which chemical containing products with hazards are being stored and/or used on campus for the purposes of reporting to emergency responders, tracking of chemicals and occupational safety. Here at the College, the RTK and Hazard Communication Programs have been combined. As such, we report all chemical containing products within the RTK Survey. The RTK Survey will need to be a FULL list of items stored and used on campus each year.
Each year, an email will be sent from EHS regarding the specific information due each year for the RTK Surveys. Each year the email will provide reminder instructions on how to complete that year’s Survey and refresher classes associated with the Survey that is due in June of each year.
Areas completing the Survey should take this inventory as an opportunity to confirm additional RTK, Hazard Communication, Chemical Hygiene, and Globally Harmonized System requirements are being met.
Additional items that should be confirmed include:
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- Every shipped container has the manufacturer label. Whenever possible, additional containers created by the user are labeled with the manufacturer provided label, otherwise the product identity, manufacturer’s name and address, hazard warning, target organs, chemical name and the top five ingredients are required to be on the container.
- Every container and/or secondary container is labeled in English.
- Some containers that do not have to be labeled are ones in which the chemical transferred is intended for the immediate use (by the end of the shift) of the employee who performed the transfer or containers such as test tubes, beakers, flasks, and similar which are used and reused in process for different substances.
- Containers which are two ounces or smaller may be labeled by chemical identity or using a code or number system. A code or number system can only be used if the code or number system will allow the employee or emergency responders ready access to the identity, names and CAS numbers or the trade secret registry numbers of the ingredients.
- There are special labeling considerations for office products, petroleum products, process containers, and some other materials. If you are unsure of labeling requirements, please contact EHS.
- Every chemical product has an available Safety Data Sheet near the location it is used as well as a copy sent to EHS. Hard copies are to be used unless a computer with access to the information is immediately available in the area in which the chemical work is being performed. For example, if the department office has a computer that has access to the required chemical information, but closes at 4:30pm and on weekends, this would not be appropriate for access to RTK information for labs using chemicals during off hours.
- Areas should confirm that the Safety Data Sheet is the most recent available from the manufacturer.
- Chemicals are being stored properly (compatibles stored together, secondary trays, etc.).
- Waste chemicals should be labeled and prepared for the next hazardous waste disposal.
- Requirements for GHS that has gone into effect in June 1, 2016 and as discussed in training it is recommended that you take the opportunity now to start looking for any changes in the hazard classification information coming from the manufacturers. While manufacturers aren’t required to complete this evaluation and update their product information yet, some have already begun or completed this process.
GHS Upcoming Compliance
As a reminder from training chemicals/products with hazardous by manufacturers that no longer exist or chemicals/products that are no longer are being manufactured, the following are required to be tracked through the department:
- A list identifying these chemicals/products as no longer manufactured, with the chemical/product location, identification name, and manufacturer name is available and accurate.
- The chemical’s/product’s most updated MSDS is available.
- Keep the original manufacturer label legible.
- EHS has developed a spreadsheet for those areas who wish to keep products that are no longer GHS compliant. GHS Compliance Log
While the GHS compliance schedule is in June, EHS will be requesting to review and/or be made aware which areas are creating the list mentioned above for products they intend to keep that are not in compliance with GHS. Given the administrative burden of tracking these chemicals for each area and when possible it is best that these products are removed with the hazardous waste collection.
As a reminder, EHS is available to assist with the following:
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- RTK Survey specific questions
- Provide a refresher session on the RTK Survey
- Assist and/or advise on Safety Data Sheets
- Review any new Safety Data Sheets from manufacturers that have reclassified a chemical product
- Any other RTK/Hazard Communication Program or GHS assistance as needed
Asbestos
- Asbestos is naturally occurring in the environment and was added into certain building products to make them last longer.
- Most building on campus constructed prior to 1980’s contain asbestos building materials. Asbestos containing building materials in good condition do not pose any health hazard. When these materials are disturbed is when the potential exists for releasing asbestos fibers to affect human health.
- In order to prevent exposure to asbestos materials, do not disturb building materials. If you are unsure if a building material is asbestos containing or not, please contact EHS prior to disturbing it or assuming that it is asbestos containing.
- Projects that disturb asbestos containing materials are highly regulated and all projects are coordinated through an asbestos team of a consultant and/or a contractor. Please contact the project’s Project Manager or the Industrial Hygienist with any questions or concerns related to an asbestos project on campus.
Lead Based Paint
- Lead based paint is a consideration for renovation, repair and painting for buildings constructed prior to the 1980’s.
- Lead based paint in good condition does not pose any human health hazard.
- Please report all water leaks to Facilities at extension 2353. Reporting water leaks will alleviate the potential situation of lead based paint surfaces from deteriorating. For after-hours reporting of active leaks, please contact Campus Police at (609) 771-2345.
- Do not disturb painted surfaces within College buildings. Please contact Facilities Operations at extension 2353 for any requested work disturbing painted surfaces in College buildings.
- Please contact the Industrial Hygienist with any questions or concerns related to lead based paint.
Drinking Water Quality
- Drinking water for the campus is supplied through the Trenton Water Works. The College does not treat the water that is supplied to the campus. Should you have a specific question or concern about the drinking water on campus, please contact Facilities Operations at extension x2353.