EHS

Hazardous Materials Procurement Program

This program helps ensure that faculty, staff and auxiliary organizations consider applicable safety and environmental compliance issues before obtaining hazardous materials.

I.  Purpose/Scope

    • Purpose:  The use of hazardous materials at CSU Northridge creates a variety of potential safety and environmental compliance issues.  The purpose of this Procedure is to ensure that applicable compliance issues are considered and addressed before a material is procured.
    • Scope:  This procedure applies to all faculty, staff and students who purchase hazardous materials that will be stored or used on campus.  Also included are purchases by CSUN auxiliary organizations, purchases for sponsored projects, and hazardous materials that are obtained as free samples or gifts. 

 II.  Definitions

    • Authorized Individual:  Person within a department, college or other administrative unit who has received the necessary training, and is authorized to review and approve hazardous materials procurement requests.
    • Carcinogen:  The term carcinogen refers to any substance that is an agent directly involved in the promotion of cancer or in the increase of its propagation.
    • Class Code:  A chartfield available through the PeopleSoft Financial System used to identify hazardous materials procurements. Class Code 10400 is identified as Hazardous Materials.  User defined class codes 10450 through 10455 can also be used.  User defined codes allow users to further break down the class value for department use.  
    • EH&S:  Environmental Health and Safety Department
    • EPCRA:  Emergency Planning and Community Right to Know Act
    • Hazardous Material:  For the purposes of this procedure are defined as chemical substances, which if released or misused can pose a threat to the environment or health. 
    • MSDS (Material Safety Data Sheet):  Product safety and handling information supplied by the product manufacturer.  It is a requirement of the OSHA Hazard Communication Standard that a copy of a chemical's MSDS be made available to any person working with or around a hazardous material.
    • NIOSH (National Institute of Occupational Safety & Health):  Federal Agency that conducts scientific research, develops guidance and authoritative recommendations, disseminates information, and responds to requests for workplace health hazard evaluations.
    • OSHA:  (Occupational Safety and Health Administration) Federal and State agencies responsible for establishing and enforcing occupational safety and health regulations.
    • RQ (Reportable Quantity): The amount of chemical that, if released to the environment, requires notification to emergency response agencies.
    • SCAQMD:  South Coast Air Quality Management District
    • TAC (Toxic Air Contaminants):  Chemicals published in the South Coast Air Quality Management District’s Rule 1401, New Source Review for Toxic Air Contaminants, Table 1.
    • TPQ (Threshold Planning Quantity): The amount of chemical that, if possessed by the University, requires the development and implementation of a chemical specific risk analysis and risk management plan. 
III.  Exemptions/Exclusions

Radioactive materials and consumer products (those that do not require a Material Safety Data Sheet) are excluded from this procedure. 

IV.  Responsibilities

    • Hazardous Materials Requestor:  Responsible for ensuring all provisions of these procedures are followed when requesting and procuring hazardous materials. 
    • Authorized Individuals:  Responsible for reviewing all hazardous material requisitions to ensure applicable compliance issues have been addressed prior to purchase.
    • EH&S:  Responsible for maintaining the list of Authorized Individuals and for providing periodic training for these individuals.  Will also maintain and monitor the effectiveness of the program.
    • Departments and Colleges:  Responsible for ensuring these procedures are followed in their department or college.  Also must ensure that there are an adequate number of Authorized Individuals to prevent excessive delays when hazardous materials are requested.
    • Purchasing (including The University Corporation):  Monitor all mechanisms for hazardous material procurement (PeopleSoft, Procurement Card, and manual requisitions) to ensure review by an Authorized Individual has occurred. 

V.  Training

Authorized Individuals will be provided training as required.  This training will cover the relevant safety and environmental issues that must be considered when reviewing a request for hazardous materials. 

 VI.  Forms Used

None.

VII.Procedures

    • These procedures apply to any mechanism that is used to obtain a hazardous material.  The most common methods currently used are:
      • Online requisition (PeopleSoft)
      • Credit Card purchases (Procurement Card)
      • Purchase order via the University Corporation
      • Donation
      • All hazardous materials requests will be routed to an Authorized Individual within the department or college.  A current list of Authorized Individuals is available from EH&S (Ext 2401).
      • The Authorized Individual will review the request to ensure all applicable safety and environmental compliance impacts have been considered using the guidelines found in Section 8. 
      • If the Authorized Individual has concerns about a request, the concern must be resolved with the requestor as soon as possible. 
      • Once the request has been reviewed, and any concerns addressed, the Authorized individual will submit the request for purchase.  Note:  for donations, the Authorized Individual will notify the requestor that the donation request has been approved.
      • Purchase orders that are sent to the University Corporation shall be marked in a manner that indicates they have been reviewed and approved by an Authorized Individual. 
      • When entering a requisition into the on line requisition system; the class code for "Hazardous Materials" (104XX) will be used.
      • The Authorized Individual will indicate (in a text field on the requisition) if an MSDS is required from the material supplier. 
      • On a periodic basis, EH&S will audit the records of purchases to ensure all hazardous materials requisitions are being reviewed by Authorized Individuals. 

VIII.  Guidelines/Rules

    • Hazardous materials purchase requests (including donations) will be evaluated to ensure applicable safety and environmental compliance issues have been addressed. 
    • Three lists of chemicals should be consulted to determine if a chemical purchase or use would involve particularly severe hazards.  Substitution or reductions of quantity are desirable:
      • The NIOSH “List of Carcinogens” should be consulted to determine if a chemical is carcinogenic and therefore requires special handling.
      • The EPA “Extremely Hazardous Substances” list should be consulted both to determine if a chemical is extremely hazardous and to check the Threshold Planning Quantity (TPQ) and the Reportable Quantity (RQ).  See Appendices A & B of Title 40, CFR Part 355.
      • An effort should be made to purchase less than the RQ if possible. 
      • In no case should an amount exceeding the TPQ of a listed chemical be purchased without first contacting EH&S.
      • The SCAQMD “List Toxic Air Contaminants” should be consulted to determine if the chemical could produce air emissions that may be a health hazard and regulated by the SCAQMD.
    • Preventing the generation of hazardous waste: 
      • Hazardous waste reduction begins at the source of generation.  Purchases should be reviewed to determine if it is possible to alter the process or materials used in order to reduce the quantity or hazard of the waste produced.  Consider the following options:
      • Purchase only the quantity of material necessary for the job at hand.  Excess material and materials that age past its shelf life becomes hazardous waste.
      • Determine if a less hazardous material can be substituted for the same job.  Suppliers often have suggestions for safer or more environmentally friendly products.
      • Determine if a reusable or recyclable material can be used for the same job.
    • Resources for more information:
      • The Material Safety Data Sheet (MSDS) is a document that outlines safety and health information for a particular chemical.  MSDSs are available in Campus departments and are a resource for familiarization with chemical hazards.
The Environmental Health and Safety Department (extension 2401) has a number of resources including personnel with hazardous materials expertise.

IX.  References

List of Carcinogens:

The Consolidated List of Chemicals Subject to the Emergency Planning and Community Right-to-Know Act (EPCRA) and Section 112(r) of the Clean Air Act (also known as the List of Lists) was prepared to help firms handling chemicals determine whether they need to submit reports under sections 302, 304, or 313 of EPCRA and, for a specific chemical, what reports may need to be submitted. It will also help firms determine whether they will be subject to accident prevention regulations under CAA section 112(r). These lists should be used as a reference tool, not as a definitive source of compliance information. Compliance information for EPCRA is published in the Code of Federal Regulations (CFR), 40 CFR Parts 302, 355, and 372. Compliance information for CAA section 112(r) is published in 40 CFR Part 68. The List of Lists is available several formats.

Toxic Air Contaminants:

    • SCAQMD Rule 1401, New Source Review of Toxic Air Contaminants, Table 1 (page 13 of Rule 1401)

X. Revision Record

RevisionChangesDate
1.0Establishes ProcedureDecember 6, 2006
2.0Update FormatOctober 15, 2008
2.1Update references and definitionsOctober 15, 2009
2.2Migrated to Web-One; links updatedJanuary 31, 2014