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. This individual will also have working knowledge and understanding of all necessary documented training, and is authorized to review, approve, and/or purchase hazardous materials including those using University 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:  biological, chemical, or radiological substances, which if improperly stored, handled, used, or disposed may pose a threat to human health or the environment.

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 verifying with P.I., faculty or department end users of hazardous materials that the individual users have the necessary skills and documented training to safely handle, store, use, and dispose of hazardous materials before the hazardous materials are purchased. These individuals will be recognized and listed on Attachment 1. It is strongly suggested that the chemical end user(s) assist with the documentation of Attachment 3.

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 by EH&S[FMA1] .  This training will cover the relevant safety and environmental issues that must be considered when reviewing a request for hazardous materials. To include the following:

      • Hazard Communication
      • Hazardous Material Handling
      • Hazardous Material Storage Requirements
      • CSUN Hazardous Waste Management Program, and
      • RSS Chemical Inventory updating

VI.  QUALIFYING PURCHASES

The following items shall not be purchased on a P-Card without prior EH&S consultation.

      • Radioactive Materials (radionuclides or isotopes)
      • Radiation Emitting Equipment (X-Ray generating devices)
      • Laser rated Class III of IV (excludes laser pointers and projection devices)
      • Controlled Substances (Requires approval from Research and Sponsored Programs)

VII.  PROCEDURES

P-Card Purchasing Process

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

      • the hazardous materials are infrequently needed and,
      • the hazardous materials are available only from specialty vendors and,
      • 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
All hazardous materials requests from departmental end users will be routed to a College or Department Authorized Requester.
Both faculty end users and 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 item(s) in question is/are identified as a hazardous material,  the Authorized Requester will complete Attachment 3, Hazardous Materials Requiring Approval Form and submit the completed form along with a copy of the Safety Data Sheet (SDS) to for reviewal by EH&S.

EH&S will work with Authorized Requester to ensure environmental health and safety requirements are considered and in place for that hazardous material prior to their purchase.  Once the hazardous material has been acknowledged, EH&S will sign Attachment 3 and shall email the approved form back to the Authorized Requestor. 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 identified 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. 

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 CSUN TopDesk for final approval of purchase.

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.

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

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
2.2Additional names to Attachment 1 – Authorized RequestorsApril 29, 2021
2.3ReviewedOctober 2022