Transcript Document

Alfred University
A Globally Harmonized System (GHS)
The revised OSHA Hazard Communication Standard
Global Harmonization System 2013
Right To Understand
Compliance Phase-In:
The table below summarizes the phase-in dates required under the revised Hazard Communication
Standard (HCS):
Effective Completion Date
Requirement(s)
Who
December 1, 2013
Train employees on the new label elements and
safety data sheet (SDS) format.
Employers
June 1, 2015*
December 1, 2015
Compliance with all modified provisions of this
final rule, except:
The Distributor shall not ship containers labeled
by the chemical manufacturer or importer
unless it is a GHS label
Chemical manufacturers, importers,
distributors and employers
June 1, 2016
Update alternative workplace labeling and
hazard communication program as necessary,
and provide additional employee training for
newly identified physical or health hazards.
Employers
Transition Period to the effective completion
dates noted above
May comply with either 29 CFR 1910.1200 (the
final standard), or the current standard, or both
Chemical manufacturers, importers,
distributors, and employers
Major changes to the Hazard Communication Standard:
Hazard classification:
Chemical manufacturers and importers are required to determine the hazards
of the chemicals they produce or import. Hazard classification under the new,
updated standard provides specific criteria to address health and physical
hazards as well as classification of chemical mixtures.
Labels:
Chemical manufacturers and importers must provide a label that includes a
signal word, pictogram, hazard statement, and precautionary statement for
each hazard class and category.
Safety Data Sheets:
The new format requires 16 specific sections, ensuring consistency in
presentation of important protection information.
Information and training:
To facilitate understanding of the new system, the new standard requires that
workers be trained by December 1, 2013 on the new label elements and safety
data sheet format, in addition to the current training requirements.
Keys Words (Terminology)
Class the hazard or hazards assigned to a product, or inherent properties,
which are identified as physical, health, and environmental.
Category the degree of danger represented by the hazard of a particular
product, these range from category 1, great danger to
category 5, low danger.
Product Identifier chemical name or trade name or proper shipping name.
Safety Data Sheet (SDS) analogous to MSDS in the U.S. These are
sheets or a booklet that describe the hazards of the product,
and give details about safe handling and responding to
emergencies.
Pictogram the symbol or sign used to identify the class (hazard(s))
assigned to a product on the warning label. There are 9
pictograms.
Signal Word is the word Danger or Warning that will appear as part of the
warning label. Indicates the degree of hazard the product
possesses.
Hazard Statements are standardized statements that will appear
as part of the hazard communication system identifying
just what hazards the user should be aware of.
Precautionary Statements are standardized statements (and/or
pictogram) which describe recommended measures that
should be taken to minimize adverse effects resulting
from exposures to a hazardous product, or improper
storage or handling of a hazardous product.
GHS Classification:
Three basic classes of hazards:
Physical – e.g. flammability or reactivity
Health – immediate and long-term toxicity
Environmental – toxicity to aquatic
organisms, potential to bio accumulate or
persist in the environment, and things
hazardous to the ozone layer.
Physical Hazards:
• Explosives
• Flammable Gases
• Flammable Aerosols
• Oxidizing Gases
• Gases under pressure
• Flammable liquids
• Flammable solids
• Self-reactive substances – thermally unstable and may breakdown when heated
• Pyrophoric liquids and solids – ignite spontaneously at room
temperature or below
• Self-heating substances – react with oxygen and start to burn
• Water-reactive substances
• Oxidizing liquids and solids – cause ignition of other materials
by chemical reaction or increase the heat and speed of a fire
• Organic peroxides – oxidizers with a special chemical structure
that tends to make them unstable
• Corrosives – corrosive to metal (acids or bases)
Health Hazards:
Acute Toxicity (immediate hazard)
• Immediate toxicity –immediate and serious health effects possibly
including death on exposure
• Corrode or burn skin and eyes
• Irritation (significant) to skin and eyes
Chronic Toxicity (long-term hazard)
• Carcinogenicity – cancer causing
• Germ cell mutagenicity- cause mutations or genetic change to
germ cells in the body
• Reproductive toxicity – reproductive effects, e.g. birth defects or
sterility
• Skin/Respiratory sensitization – things which can cause allergic
reactions to the skin or respiratory system on exposure
• Target organ effects – certain chemicals can attack certain parts
of the body either on a single exposure or repeated exposure
(e.g. prolonged exposure to asbestos (lungs), many dry-cleaning
chemicals attack the liver and kidneys even after a single
exposure)
• Aspiration hazards – materials entering the lungs which cause a
serious inflammation called pneumonitis which can be fatal; many
petroleum based products and solvents may be aspiration
hazards.
Environmental Hazards:
• Existing IMDG (International Maritime Dangerous Goods
Code) Marine Pollutant criteria
• European Union criteria used in ADR/RID transportation
regulations - ADR= Agreement on Dangerous Goods by Road / RID
= Regulations concerning the Intl Transport of Dangerous Goods by
Rail
• U.S. EPA hazardous substance criteria
• Materials which are hazardous to the ozone layer
• Aquatic hazards:
 Acute toxicity
 Chronic toxicity
• Bioaccumulation – toxins accumulate faster than they can be
eliminated
Categories:
Categories 1 through 5 – similar to transportation packing group
• Category 1 – most hazardous
• Category 5 – least hazardous (only hazardous to vulnerable segments of
population, e.g. small children or people with compromised immune systems)
Categories may be further sub-divided, e.g. Category 1A, 1B, 1C, etc. Explosive hazards
are designated by “divisions”. The less dangerous categories may not be regulated in all
modes in all countries.
Example: Assigning categories using the GHS system
Note: A very small amount, 0-5 mg/kg of bodyweight (oral), of an acutely toxic substance yields an LD50
(the lethal dose kills 50 % of the tested population). This results in assigning a Category 1 – most
hazardous designation. ( Example: Cyanide - http://en.wikipedia.org/wiki/Cyanide )
GHS Label Elements:
 Product Identifier (chemical name or trade name or proper shipping
name – no chemical formulas, list hazardous ingredients where
appropriate)
 Chemical Identity (C[hemical] A[bstracts] S[ervice] # if applicable) –
optional on secondary labels
 Hazard pictogram(s) – one or more
 Signal words – either DANGER or WARNING
 Hazard statements
 Precautionary information – optional on secondary labels
 Supplier Identifier (supplier information, e.g.name, address, phone,
etc.)
Classification (class and category) drives labeling. Information should be
conveyed in more than one way, both symbols and text.
GHS Standardized Elements:
 Symbol (Hazard Pictogram)
 Signal Word
 Hazard Statements
 Precautionary Statements
Hazard Pictograms:
Signal Words:
Only two words are used, “Danger” or “Warning”, to emphasize the hazard and
differentiate between the degrees of hazard. Danger is used for higher hazard
materials, and Warning for lower level hazards. The use of one word excludes the use
of the other.
Hazard Statement:
GHS assigns a single harmonized statement for each level of hazard within each
hazard class. See Annex 3 – Section 1, of the Globally Harmonized System of
Classification and Labeling of Chemicals (2011) Fourth Revised Edition. Example
below:
Note: Another useful reference is Annex 1 “Allocation of Label Elements”. This
resource includes the label pictogram, signal word, hazard statement, and the
UN Model Regulation pictogram and information.
Precautionary Statements:
This element is not yet mandatory in the U.S. as of Jan 2013. Mandatory or
recommended inclusion of precautionary statements on the label will be left
up to the individual country. Annex 3- Section 2 discusses the codification
and use of precautionary statements.
Note: Only those label elements identified with a red arrow are currently
required under the GHS labeling system. The chemical or product/trade name
serves as the product identifier and one should identify the hazardous
ingredients where appropriate.
More on Hazard Statements
Hazard Statements: phrase assigned to a hazard class and category which
describes the nature of the hazard. Each statement will uniquely express the
hazardous product, including, where appropriate, the degree of hazard.
FAQ:
What does a Hazard Code look like?
• Each statement has a specific code associated in order to properly
reference.
• Codes will begin with a H followed by a 3 digit code “H###”
Where can I find further information on the different types of Hazard statements?
• Section 1 of Annex 3 of the GHS.
Do I need to apply both hazard statement and code when creating a Label?
• No. When creating a label, it is only required that the hazard statement is
located on the packaging, hazard codes are optional.
What are the requirements for hazard statements when preparing a SDS?
• When preparing a SDS both Hazard statements and codes are required.
Examples:
“H224: Extremely flammable liquid and vapor”
“H290: May be corrosive to metals”
More on Precautionary Statements
Precautionary Statements: phrases (and/or pictograms) that describe
recommended measures that should be taken in order to minimize or prevent
adverse effects that could result from improper storage and handling of or exposure
to a hazardous product.
FAQ:
What does a Precautionary Code look like?
• Codes will begin with a P followed by a 3 digit code “P###”
Where can I find further information on the different types of Precautionary
statements?
• Section 2 of Annex 3 of the GHS – see also Annex 3 for precautionary
pictograms
Do I need to apply a precautionary statement and code when creating a label?
• No. When creating a label, it is only required that the precautionary
statement is located on the packaging, precautionary codes are optional.
What are the requirements for precautionary statements when preparing a SDS?
• When preparing a SDS both precautionary statements and codes are
required.
Examples:
“ P313: Get medical advice/attention”
“ P330: Rinse mouth”
GHS Label Placement:
Confidential Business Information (CBI):
• CBI exemptions will not be harmonized under GHS (control left to
individual countries)
• Provisions for CBI should not compromise the health and safety of
users
• Non-disclosure names should be limited to the names of chemicals
and their concentrations in mixtures
• Mechanisms should be established for disclosure in emergency and
non-emergency situations (Manufacturer emergency # or CHEMTEC)
Safety Data Sheets - SDS Annex 4:
The SDS will provide comprehensive information about a chemical
substance or mixture, including:
 Composition
 Major Hazards
 Safe Handling
 Emergency Response
GHS referenced standards, include but not limited to, to assist in SDS
preparation:
ANSI Standard Z400.1
ISO Standard 11014
ILO Standard under Recommendation 177
SDS Standardized Format – 16 Headings:
1. Identification – product and supplier
2. Hazard(s) identification: GHS classification and GHS labeling statements
3. Product composition and basic information on ingredients including CAS #
4. First aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Safe handling and storage requirements
8. Exposure controls and personal protective equipment
9. Physical and chemical properties summary
10. Stability and reactivity summary
11. Toxicological information – carcinogenicity, mutagenicity, and reproductive
effects
12. Ecological information – toxicity to aquatic organisms and biodegradability
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information – relevant information not given elsewhere on the SDS
Note: All Safety Data Sheets, regardless of country, will contain these 16
informational headings.
Section 1: Identification
 Identification of the substance or mixture:
• GHS product identifier
• Other unique identifiers
 Supplier’s details:
• Name, full address and phone
number(s)
 Recommended use of the chemical and
restrictions on use; and
 Emergency phone number
Section 2: Hazard Identification
 Classification of the substance or mixture
 GHS labels, including hazard and
precautionary statements
 Other hazards which do not result in
classification
Section 3: Composition/information on
Ingredients
 Substances:
• Chemical identity
• Common name, synonym of the
substance
• CAS number and other unique
identifiers
Section 3: Continued
• Impurities and stabilizing additives
 Mixtures (for all hazardous ingredients):
• Chemical identity
• Identification number
• Concentration range
Section 4: First-aid Measures
 Description
 Most important symptoms/effects, acute
and delayed
 If needed, indication of:
• Immediate medical attention
• Special treatment
Section 5: Fire-fighting Measures
• Suitable extinguishing media
• Specific hazards arising from the
chemical
• Special protective equipment and
precautions for fire-fighters
Section 6: Accidental Release Measures
 Personal precautions, protective
equipment and emergency procedures
 Environmental precautions
 Methods and materials for containment
and cleaning up
Section 7: Handling and Storage
 Precautions for safe handling
 Conditions for safe storage (including
incompatibilities)
Section 8: Exposure Controls/Personal
Protection
 Control parameters
 Appropriate engineering controls
 Individual protection measures, including
personal protective equipment (PPE)
Section 9: Physical and Chemical
Properties
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Appearance
Odor
Odor threshold
pH
Melting point/freezing point, Initial
boiling point and boiling range
Flash point
Evaporation rate
Flammability (solid, gas, upper/lower
flammability or explosive limits)
Vapor pressure
Vapor density
Relative density
Solubility(ies)
Partition coefficient n-octanol/water
Auto-ignition temperature
Decomposition temperature
Viscosity
Section 10: Stability and Reactivity
 Reactivity
 Chemical stability
 Possibility of hazardous reactions
 Conditions to avoid
 Incompatible materials
 Hazard decomposition products
Section 11: Toxicological Information
 Provide data for all the health hazards
covered by the GHS.
• If data for any of those hazards is not
available, they should be listed on the
SDS with a statement that data is not
available.
 Information on the likely routes of exposure;
 Symptoms related to the physical, chemical
and
 toxicological characteristics;
 Delayed and immediate effects and chronic
effects from short or long term exposure;
 Numerical measures of toxicity (such as
ATE)
 Interactive effects
Section 11: Continued
 Where specific chemical data are not
available
 Mixtures
 Mixture versus ingredient information
 Other relevant information
Section 12: Ecological Information
 Toxicity
 Persistence and degradability
 Bioaccumulative potential
 Mobility in soil
 Other adverse effects
Section 13: Disposal Considerations
 Disposal methods
Section 14: Transport Information
 UN Number
 UN Proper Shipping Name
 Transport hazard classes
 Packing group, if applicable
 Environmental hazards
 Special precautions for user
 Transport in bulk according to Annex II
of MARPOL 73/78 and the IBC Code
Section 15: Regulatory Information
 Regulatory information not provided
elsewhere in the SDS
 Safety, health and environmental
regulations specific for the chemical in
question
Section 16: Other Information
 Date of preparation of the latest version
of the SDS
• Clear indication of the changes
made to the previous revision
 Key/legend to abbreviations and
acronyms used in the SDS
 Key literature references and sources for
data used to compile the SDS
SDS Example
OSHA / GHS Differences:
OSHA will not regulate:
 Non-health related hazards such as environmental hazards
 Acute toxic hazards in Category 5
 Skin corrosion/irritation hazards in Category 3 or higher (5)
 Aspiration hazards in Category 2 or higher (5)
Differences in cut-offs – OSHA new category “Unclassified Hazard” to cover
hazards originally included in the OSHA standard but not included in the
GHS.
U.S. Department of Transportation:
US DOT harmonization with GHS has already been completed.
Labeling Options – Secondary Labels focus at AU:
• Standard Avery label on EHS Website, pictograms contact EHS
• MSDS Online (Site Administrators only)
• From original container (on color copier)
• Black border pictogram is okay for domestic purposes, red border required
for overseas transport
Alfred University
GHS compliant
secondary label
Obstacles:
• Secondary Labeling – Interpretation of SDS’s until all are compliant
• Manufacturer’s delay in generating GHS compliant SDS – some are
going to wait until the last minute!
Question and Answer Session
GHS portion completed, break for 10 minutes
then return after break for Right To Understand
Right To Understand - Review
Encountering Hazardous Substances in the
Workplace
•Washing or filling a vehicle with gasoline or oil
•Cleaning and disinfecting
•Applying herbicides, pesticides or insecticides
•Using solvents, acids, bases, flammables, and re-actives
•Using personal hygiene and cosmetic products
•Painting, wood working, and metal working
•Making or using ceramics and clays
•Using various office products (e.g. toners, inks, etc.)
•Barbequing on a grill
•Plumbing, electrical, carpentry and grounds work
Requirements of the Standard
• Inform you about the hazards in your work area;
• Make Safety Data Sheets accessible to everyone and
ensure they know how to use them and where they are
located;
• Ensure containers are labeled and that everyone knows
how to read those labels;
• Provide a written program, (located in 117 Myers Hall
EH&S Office).
The Law
• OSHA/PESH – Employees, employers, students, Hazard
Communication - 29 CFR 1910.1200, respiratory
protection, personal protective equipment (PPE), etc.
• EPA – “cradle to the grave”, containment, storage and
disposal
• DEC – water, soil and air contamination
• Other Government Agencies – DOH (health), FDA (food
and drugs), NFPA (fire)
What is a Hazardous Substance?
• A hazardous substance includes, (but is not limited to),
products that are toxic, corrosive, flammable, reactive,
irritants, oxidizers, sensitizers, explosives, or radioactive.
• The key question to ask is, “Do these materials create an
unusual health or safety risk through their use or
storage?”
• If the answer is yes, the material is likely hazardous.
NOTE: The definitions and criteria of the hazards of a substance can
be found in the Globally Harmonized System Revision 4 2011 edition.
Physical hazards are found in Part 2, health hazards are found in part
3, and environmental hazards are found in part 4.
Informing of Hazards
• Signs – signage will inform you of hazards in your work
area, especially signs containing words like danger,
warning, notice, etc.
• Labels – label information should include the product or
chemical name/identifier (never use a chemical formula),
signal word, pictogram(s), hazard statement(s), and
manufacturer name, address and phone number.
• Safety Data Sheet (SDS) – required by law for all
manufacturers to prepare.
OSHA Recommendations
OSHA recommends that employers offer the following
prevention strategies (listed in order of OSHA priority):
Engineering controls eliminate or reduce exposure to a
chemical or physical hazard through the use or substitution
of engineered machinery or equipment. Examples include
self-capping syringe needles, ventilation systems such as a
fume hood, sound-dampening materials to reduce noise
levels, safety interlocks, and radiation shielding.
Administrative controls (or work practice controls) are
changes in work procedures such as written safety policies,
rules, supervision, medical surveillance and training with
the goal of reducing the duration, frequency, and severity of
exposure to hazardous chemicals or situations.
OSHA Recommendations Continued
Personal Protective Equipment (PPE) such as safety
glasses with side shields, splash goggles, face shields,
chemical resistant gloves, hard hats, rubber aprons, safety
shoes, respirators, & hearing protectors must be worn
when required, and maintained in good condition. The
employer is responsible for providing proper PPE to the
employee (this does not apply to students in classes or
labs).
Prior to Purchasing Chemicals
• Check your chemical inventory (NOTE: chemical
inventories are due to EH&S by June 15th annually).
• Contact EH&S to see if a surplus exists for what you
need.
• Obtain and read the SDS for the chemical.
• Know the hazards of the chemical.
• Make sure you have a safe way to use and store the
chemical.
• Know how to dispose of the chemical.
Routes of Entry
In order of most common to least common:
Inhalation, Absorption, Ingestion, Injection
Bodily Effects
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Acute
Chronic
Cumulative
Non-cumulative
Multiple exposures
Toxins
Sensitizers
Allergens
Factors that affect the degree of
hazard from toxic materials
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Amount of material
Conditions of exposure
Length and frequency
Toxicity
Total body burden
Multiple exposures
High risk groups
Chemical Safety – Alfred University Policy
Attire:
• Long sleeves and long pants
• Lab coat
• Close-toed shoes
• Eye protection is REQUIRED
• Do not wear contact lenses
• Secure long hair and loose clothing
• Wear appropriate gloves
Common Sense Safety
• Practice sensible, safe work habits.
• Understand the Hazard Communication Standard and how it
affects you and your co-workers.
• Identify the hazardous materials you work with and protect
yourself against them.
• Understand what an SDS is, how to use it and where to find it.
• Understand and utilize our labeling system..
• Post emergency numbers by phone.
• Know where safety equipment is located.
• Make sure safety equipment is available, not covered or
surrounded by clutter.
• Keep aisles clear to the eye wash, shower, and emergency exits.
• Check safety equipment and materials weekly to ensure they
work.
Physical Characteristics of Airborne
Substances
Gases, Vapors, Fumes, Dusts, Mists, Smoke
Compressed Gases
COMPRESSED GAS - Any gas, mixture of gases or liquids in a container
having a pressure or vapor pressure exceeding ANSI Standards.
The following precautions must be used when handling:
• Valve protector caps must always be in place on cylinders when they are in
storage or during transportation.
• Use a cylinder cart when transporting, even for a short distance.
• Compressed gas cylinders shall be properly stored, segregated, transported, and
utilized in an upright position and anchored with a chain or other device.
• Cylinders shall be stored in a well ventilated area away from flames, sparks or
any source of heat or ignition.
• Stored “Oxygen” cylinders, (empty or full), shall be separated from fuel gas
cylinders and combustible materials.
• When gases of different types are stored at the same location, cylinders must be
grouped by types of gas, e.g., flammable gases must not be stored near oxygen.
• When compressed cylinders are empty, they must be labeled, “Empty”.
Council on Green Efforts @ AU
• Purchase / use only enough for an experiment, a
semester or academic year
• Purchase the least hazardous product for the job
• See what others have on campus before buying
using MSDS Online
• Recycle / reuse wherever possible
• Educate yourself on the green efforts programs at
AU and the many ways we can reduce our carbon
footprint.
Containers and Labeling
• All containers must be properly labeled, always regard an
unlabeled container as dangerous.
• If the original label is illegible or you are transferring
contents to an empty container, use the GHS secondary
label available from EH&S.
• Do not deface manufacturer’s original label unless
container is completely empty.
• Do not use food containers to store hazardous products
or chemicals.
• Use only compatible and approved containers to store
hazardous products and chemicals.
• Do not eat, drink or apply cosmetics wherever chemicals
are used or stored.
Safety Data Sheet (SDS)
Exposure Situation
• First aid measures- what to do if you are exposed to the chemical.
• Fire fighting measures- important information about dealing with fire,
smoke and explosion.
• Accidental release measures- procedures to be followed in an
emergency spill or leak.
Hazard Protection / Prevention
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Handling and storage information
Engineering controls
PPE
Physical and chemical properties
Stability or instability
Conditions or materials that cause reactions
Hazardous substance released if material decomposes
Other Specific Information
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Toxicological
Ecological
Disposal
Transportation
Regulatory Information
EHS Exposure Monitoring
• In-house lab testing – used only for general identification of unknowns
• Certified lab testing – required by law, i.e. sumps, Foster Lake, areas of
suspected exposures, etc.
• QRAE II Portable 4 gas detector – confined space and air monitoring
• MSA personal air sampling pumps – we have 2 portable pumps which
may be used either as stationary samplers or worn for personal sampling
• Sound level meter – for noise monitoring
• VelociCalc – Meter for measuring exhaust hood velocity
MSDS Online at Alfred University
SDS’s for Alfred University can be found on the internet
by going to http://our.alfred.edu click on Faculty/Staff, and
then Environmental Health and Safety. At the top of the EH&S
page is the MSDS Online Click here link. The ensuing Access
MSDS Online page will give you the final link and instructions
for accessing MSDS’s at Alfred University.
If your work area or laboratory does not have access to a computer, a
hard copy of all SDS’s in a 3-ring binder must be maintained in addition
to the electronic copy. Supervisors are responsible for assigning an
MSDS Online site administrator, and notifying EH&S when a new site
administrator has been assigned. EH&S will train MSDS Online site
administrators utilizing both online and individual training.
It is the employee’s responsibility to read, understand and follow the
information provided by an SDS for any hazardous material they may
use or come in contact with.
Housekeeping – Alfred University Policy
• Manage chemicals properly
• Clean up after yourself after every use
• Keep all lab benches free from clutter, and put things
back where you found them
• Do not store ANYTHING in fume hoods
• Keep equipment away from shelf and bench edges
• Keep shelving orderly (do not store within 18 inches of
ceiling)
• Keep an access path of at least 3 feet at all times
Preparedness - Alfred University Policy
Ensure your work area/lab has the following safety
devices/systems:
• Telephone – with emergency numbers posted
• First aid kit
• Fire extinguisher
• Fire alarm pull station
• Eye wash (if required)
• Shower (if required)
• Chemical spill kit (if required)
• SDS’s readily available-MSDSOnline
Emergency Response Information
An Emergency Response information folder has been
published by Alfred University providing detailed
information relating to emergencies and non-emergencies.
A copy of this folder may be obtained by contacting the
office of Public Safety at ext. 2108.
Alfred University Accident Report
The Alfred University Accident/Incident/Near-Miss
Investigation Report can be found at the following link:
http://our.alfred.edu/index.cfm/fuseaction/ehs.first.cfm
The report must be submitted to EH&S within 24 hours.
Environmental Health and Safety Web Site
http://our.alfred.edu/index.cfm/fuseaction/EHS.first.cfm
Contact Information
The EH&S Office is located in Myers Hall Rm. 117
Emergency (from campus phone)
9-911
Cherise Haase (EH&S Manager)
Office: 607.871.2190
Cell:
315.408.7421
Dean Perry
(EH&S Tech.)
Office: 607.871.2196
Shanti Jonchhe (EH&S Tech.)
Office: 607.871.2497
Cell:
607.661.3303
Public Safety
Office: 607.871.2108
QUIZ