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 purpose of this procedure is to ensure that applicable environmental health and safety issues are considered and addressed before a hazardous material is procured.  
 
Scope: 
This procedure applies to all purchases of hazardous materials that will be stored or used on campus. 

 II.  DEFINITIONS

Authorized Requester:  person within a department, college or other administrative unit who has working knowledge of hazardous materials, the necessary training, and is authorized to review, approve, and purchase hazardous materials including those using a procurement card (P-Card) with an approved waiver. 
 
Chemical Abstracts service (CAS):  a division of the American Chemical Society.
 
CAS Registry Number® (CAS#):  a universally recognized unique and unmistakable identifier for chemical substances.  
 
Consumer Product:  products that are used in the workplace in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience.
 
Hazardous Materials:  chemical substances, which if improperly stored, handled, used, or disposed may pose a threat to human health or the environment or health.
 
Safety Data Sheet (SDS) formerly known as Material Safety Data Sheet (MSDS):  product safety and handling information supplied by the product manufacturer.  It is a requirement of the OSHA Hazard Communication Standard that a copy of each chemical's SDS be made available to any person working with or around a hazardous material.
 
Occupational Safety and Health Administration (OSHA):  federal and state agencies responsible for establishing and enforcing occupational safety and health regulations.
 
Procurement Card (P-Card): a university liability card that is used for certain business-related purchases and serves as an alternate procurement method without direct involvement of CSUN'S Purchasing & Contract Administration Department
 
Procurement Card (P-Card) Waiver:  a written documented approval for a transaction that requires review by CSUN's Purchasing and Contracts Administration Department prior to purchase.
 
III.  EXEMPTIONS / EXCLUSIONS

Materials or consumer products that do not require Safety Data Sheet (e.g. non-hazardous chemicals) are excluded from this procedure. 

IV.  RESPONSIBILITIES

Authorized Requestor:  responsible for ensuring that their department and end users of hazardous materials have the necessary skills and training to safely handle, store, use, and dispose of hazardous materials before the hazardous materials are purchased. 
 
Environmental Health and Safety (EH&S):  responsible for the development, implementation and monitoring of hazardous materials procurement.
 
Colleges and Departments:  responsibility of deans, directors and department heads to ensure their respective Colleges and/or Departments comply with the Hazardous Materials Procurement Policy and Procedure, including providing the necessary resources and personnel.  

V.  TRAINING

Authorized Requesters 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.  PROCEDURES

These procedures apply to mechanism(s) used to obtain a hazardous material:

      • Online requisitions
      • P-Card
      • Gifts and donations
All hazardous materials requests will be routed to a College or Department Authorized Requester.
 
The Authorized Requester shall consult Attachment 2, Materials Requiring EH&S Approval, for each purchase to determine if the chemical requires EH&S approval.  If the hazardous material requires EH&S approval, the Authorized Requester will complete Attachment 3, Hazardous Materials Requiring Approval Form and submit the completed form to for reviewal by EH&S.
 
EH&S will work with Authorized Requester to ensure environmental health and safety requirements are in place for that hazardous material.  Once the hazardous material has been approved for purchase, EH&S will sign Attachment 3 and the Authorized Requestor and/or their department will retain the approved Attachment 3 form for future purchases of the same material.  
If the hazardous material is not on Attachment 2, the Authorized Requester will review the request to ensure all applicable safety and environmental compliance requirements have been considered and are in place for safe handling, storage, and disposal before purchasing.  If the Authorized Requester has concerns about a request, the concern must be resolved with EH&S before the purchase request can be processed. 

VII.  P-CARD PURCHASES

P-Cards may be used for the purchase of hazardous materials under the following conditions:

  • the hazardous materials are infrequently needed
  • the hazardous materials are available only from specialty vendors
  • there are no established Blanket Purchase Orders in place with vendors who can supply the majority of a College’s or Department’s hazardous materials needs
  • an approved Attachment 3 for the hazardous materials being requested for purchase is in place
  • a current P-Card waiver approved by P-Card Help is in place

Colleges or Departments using P-Cards for the purchase of hazardous materials shall have their Authorized Requester complete Attachment 3 – Hazardous Materials Requiring Approval Form and submit the completed form to ehs@csun.edu. EH&S will review Attachment 3 to verify that the Authorized Requester is listed on Attachment 1 - Authorized Requestors and that the Authorized Requestor has certified that the personnel who will handle the hazardous material have received the required training noted in Attachment 3. Once the Authorized Requestor and required training have been validated, EH&S will indicate approval by signing the Attachment 3 – Hazardous Materials Requiring Approval Form and shall email the approved form back to the Authorized Requestor.

Upon receipt of the approved Attachment 3, the Authorized Requestor shall submit a P-Card waiver request that shall include the approved Attachment 3 to pcardhelp-l@csun.edu for approval to purchase the hazardous materials in Attachment 3.

Upon receipt of the waiver request, P-Card Help will review the request for an approved Attachment 3.  If the waiver request contains an approved Attachment 3, Purchasing will process the waiver request and the Authorized Requestor will be notified of the approval of their waiver. If the waiver request does not include an approved Attachment 3, the waiver request will be denied by Purchasing and the Authorized Requestor will be notified.

An Authorized Requester may purchase hazardous materials by submitting an approved Attachment 3 – Hazardous Materials Requiring Approval Form for EACH and EVERY P-Card purchase request whether or not the hazardous material is listed on Attachment 2-Materials Requiring EH&S Approval.

EH&S may review records of P-Card purchases to ensure all hazardous materials are being procured in accordance with this procedure.

VIII. REFERENCES

Procurement Card Handbook

IX.  FORM / ATTACHMENTS

ATTACHMENT 1 - AUTHORIZED REQUESTORS

ATTACHMENT 2 - MATERIALS REQUIRING EH&S APPROVAL

ATTACHMENT 3 - HAZARDOUS MATERIALS REQUIRING APPROVAL FORM

X. REVISION RECORD

REVISIONCHANGESDATE
1.0Hazardous Materials Procurement Program EstablishedDecember 6, 2016
2.0Major RevisionsJanuary 24, 2020
2.1Consumer Product definition & minor revision to Attachment 1 – Authorized RequestorsFebruary 17, 2020