USU Research Farms & Extension Agricultural Locations
All USU research farms and extension agricultural locations that store or use hazardous chemicals (pesticides, shop chemicals, fuels, etc.) are required by law to maintain a Hazard Communication (HazCom) Program.
The OSHA Hazard Communication Standard 29 CFR 1910.1200 (e)(1) requires there be a written HazCom program describing how the employer will meet requirements for labeling and warnings, safety data sheets (SDS), employee information, and training.
To simplify compliance, EH&S provides a Written Hazard Communication Program Template. Available for download in our list of HazCom Programs & Guides.
Agricultural locations are not required to write a program from scratch. They must complete Appendix A of the template with site-specific information and attach their chemical inventory.
Below are the steps to establish the HazCom Program:
Step 1: Complete the Written HazCom Program Template
EH&S provides a standardized Written Hazard Communication Program.
What you need to do:
- Download the HazCom Program Template
- Complete Appendix A with your site-specific details
- Attach your current chemical inventory
- Send a copy of it to EH&S Farm Safety Officer (sierra.mcbride@usu.edu)
- Maintain a copy accessible to employees
How to Complete Appendix A
You are not rewriting policy language. You are documenting how your location operates.
Appendix A is the location-specific portion of the HazCom Program.
This is where each farm or agricultural unit documents:
- Program documentation
- Where SDS are stored (binder location or electronic access method)
- How employees receive HazCom training
- Spill and Accident Information
- Chemical Waste Disposal
- Personal Protective Equipment
Appendix A makes the program specific to your site and has questions embedded to guide your response.
Step 2: Maintain a Chemical Inventory
Each agricultural location must maintain a current list of hazardous chemicals present onsite. A chemical inventory guide is available in the List of HazCom Programs & Guides.
Include:
- Fuels (gasoline, diesel, 2-cycle mix, etc.)
- Agricultural chemicals (pesticides, herbicides, fertilizers, etc.)
- Shop and maintenance chemicals (including spray paint)
- Cleaning chemicals
- Compressed gases (if applicable)
Do not include:
- Office supplies
- Food items
- Non-hazardous materials
The inventory must be:
- Updated when new chemicals are introduced
- Reviewed periodically for accuracy
- Attached to your HazCom Program
- Available upon request
Step 3: Ensure Safety Data Sheets (SDS) Are Accessible
SDS must:
- Be available for every chemical on your inventory
- Be accessible to employees at all times during work hours
- Be located where employees know how to find them
Electronic systems are acceptable only if employees have reliable access at any time they are working.
A printed SDS binder is strongly recommended in locations with limited internet access.
Step 4: Verify Labeling
All chemical containers must:
- Have manufacturer labels intact
- Be labeled if transferred to secondary containers
- Clearly identify product name and hazards
Unlabeled containers are a frequent compliance issue.
Step 5: Provide HazCom Training
Employees who may be exposed to hazardous chemicals must receive HazCom training:
- Before working with chemicals
- When new hazards are introduced
- As refresher training when required
EH&S offers initial HazCom training to assist agricultural locations with compliance. This training is completed with Rachel Curry upon request; to schedule, email Rachel.curry@usu.edu to be added to the next available session. Initial HazCom training is documented and maintained in the EHSA (Environmental Health and Safety Assistant) database. Ongoing HazCom training must be completed by site management as needed whenever a new chemical or hazard is introduced into the workplace.
Roles & Responsibilities
Farm Managers / Site Supervisors
- Complete Appendix A of the HazCom Template
- Maintain a current chemical inventory
- Ensure SDS are accessible
- Ensure employees receive training
- Maintain training documentation and written HazCom program
Employees
- Follow safe chemical handling procedures
- Review labels and SDS before use
- Report missing labels or safety concerns
- Attend required training
EH&S
- Provide templates and guidance
- Support implementation
- Offer initial HazCom training
- Assist with compliance questions
- Set up EHSA profile for hazardous waste disposal