HAZARD
COMMUNICATION PROGRAM
I. PURPOSE
In
order to protect our employees and comply with 29 CFR 1910.1200 the Hazard
Communication Standard, the following written Hazard Communication Program has
been established for our company. Under
this program, you will be informed of the contents of the Hazard Communication
Standard, the hazardous properties of chemicals with which you work, safe
handling procedures, and measures to take to protect yourself from these
chemicals. You will also be informed of
the hazards associated with non‑routine tasks, such as the cleaning in
confined spaces, and the hazards associated with chemicals in unlabeled pipes.
II. GENERAL PROGRAM MANAGEMENT
A. Responsibility
The
Safety Officer, ____________________, has responsibility for this program. The Safety Officer will review and update
the program, as necessary. Copies of
the written program may be obtained from office.
B. Program Review and Update
In
order to have an effective Hazard Communication Program the program will be
reevaluated on a quarterly basis. The
MSDS's will be renewed every three years in order to assure that all chemicals
used at this company current. Training
and reviewing of the program will also be done under these circumstances:
1)
for employees before they are sent to their work station
2)
when new chemicals or hazardous materials are introduced into work areas.
III. METHODS OF COMPLIANCE
A. List of Hazardous Chemicals
The
Safety Officer will make a list of all hazardous chemicals and related work
practices used in the facility, and will update the list as necessary. (When
new chemicals or MSDS sheets are received).
Our list of chemicals identifies all of the chemicals used in the work
areas. A separate list is available for
each work area and is posted there.
Each list also identifies the corresponding MSDS for each chemical. A master list of these chemicals will be
maintained by, and is available from the Safety Officer. (Appendix A)
B. Container Labeling
The
supervisor in each section will verify that all containers received for use
will:
1) Be clearly labeled as to the contents,
2) Note the appropriate hazard warning,
3) List the name and address of the manufacturer.
The
Safety Officer will refer to the corresponding MSDS to assist in verifying
label information. Containers that are
shipped from the plant will be checked by the supervisor of shipping and
receiving to make sure all containers are properly labeled.
The
Safety Officer will ensure that all secondary containers are labeled with
either an extra copy of the original manufacturer's label or with the
"central stores" generic labels.
For help with labeling, please see our Safety Officer. The Safety Officer will review and update
the company labeling system quarterly.
C. Material Safety Data Sheets
The
Safety Officer will be responsible for obtaining and maintaining the data sheet
system for the company. The Safety Officer will review incoming Material Safety
Data Sheets for new health or safety information. He will see that any new information is included in the program
and that the new information is passed on to the affected employees.
Copies
of MSDS's for all hazardous chemicals which employees of this company may be
exposed will be kept in office.
MSDS's
will be available to all employees in their work areas for review during each
work shift. If MSDS's are not available
or new chemicals in use do not have MSDS's, immediately contact the Safety
Officer.
To
ensure Material Safety Data Sheet information is current replacement data
sheets will be requested upon notification of a change in the product, or
reason to believe a change has been made. Communication from our Purchasing
Department is required each time a new or substitute chemical product is
brought into the facility. In such
cases a Material Safety Data Sheet will be immediately requested from the
supplier/manufacturer. To request a
copy of material safety data sheet, which is not currently on file, two (2)
letters will be sent to the supplier at a two (2) week interval. (See Appendix B)
D. Employee Training and Information
The
Safety Officer is responsible for the employee training program. They will ensure that all elements specified
below are carried out.
Prior
to starting work each new employee of this company will attend a health and
safety orientation and will receive information and training on the following:
1) An overview of the requirements contained in the Hazard
Communication Standard,
2) Chemicals
present in their workplace operations,
3) Location
and availability of our written hazard program,
4) Physical
and health effects of the hazardous chemicals,
5) Methods and observation techniques used to determine the
presence or release of hazardous chemicals in the work area,
6) How to lessen or prevent exposure to these chemicals through
usage of control/work practices and personal protective equipment,
7) Steps
the company has taken to lessen or prevent exposure to these chemicals,
8) How
to read labels and review MSDS's to obtain appropriate hazard information,
9) And
the location of MSDS file and hazardous chemical list.
After
attending the training class each employee will sign a form to verify that they
attended the training, received the written material, and understood this
company's policies on Hazard Communication.
(Appendix C) Prior to a new
chemical hazard being introduced into any section of this company, each
employee of that section will be given information as outlined above. The
Safety Officer is responsible for ensuring that MSDS on the new chemical(s) are
available.
E. Hazardous Non‑Routine Tasks
Any
maintenance, or other infrequent work shall be reviewed by the Safety Officer
for potential exposure to hazardous chemicals or other safety problems. (e.g., cleaning tanks, entering confined
spaces, etc.) A written procedure shall
be agreed on, detailing appropriate actions and safeguards for the control of
exposure to any hazardous chemicals.
This procedure shall be used whenever the work is to be performed. Permits shall be required for working on
energized systems, and valve closures.
Appropriate lock‑out and tag‑out procedures shall be
followed. (See Facility's Lock‑out
Tag‑out Policy)
The
written procedure will include:
1) Specific
chemical hazards,
2) personal
protective equipment or safety measures the employee should use,
3) measures the company has taken to lessen the hazards
including ventilation, respirators,
presence of other employees, emergency procedures and etc..
F. Informing Contractors
It
is the responsibility of the Safety Officer to provide contractors and
employees the following information:
1) hazardous
chemicals to which they may be exposed to while on the job site,
2) precautions the employees may take to lessen the possibility
of exposure by usage of protective measures.
The
Safety Officer will be responsible for contacting each contractor, before work
is started in the company, to gather and disseminate any information concerning
chemical hazards that the contractor is bringing to our workplace.
Appendix A
CHEMICAL
INVENTORY
TRADE NAME HAZARDOUS
CHEMICAL MSDS NUMBER
Appendix B
Letter
Requesting an MSDS
Dear_____________:
The
Occupational Safety and Health Administration (OSHA) Hazard Communication
Standard (29 CFR 1910.1200) requires employers to be provided Material Safety
Data Sheets (MSDS's) for all hazardous substances used in their facility, and
to make these MSDS's available to employees potentially exposed to these
hazardous substances.
We,
therefore, request a copy of the MSDS for your product listed as Stock Number
(Number) . We
did not receive an MSDS with the initial shipment of the (name) we received from you on (Date) . We also request
any additional information, supplemental MSDS's, or any other relevant data
that your company or supplier has concerning the safety and health aspects of
this product.
Please
consider this letter as a standing request to your company for any information
concerning the safety and health aspects of using this product that may become
known in the future.
The
MSDS and any other relevant information should be sent to us with in _____
days. Delays in receiving the MSDS information may prevent use of your
product. Please send the requested
information to ________________________.
Please
be advised that if we do not receive the MSDS on the above chemical by (date) , we may have to notify OSHA of our
inability to obtain this information.
It is our intent to comply with all provisions of the Hazard
Communication Standard (1910.1200) and the MSDS's are integral to this
effort.
Your
cooperation is greatly appreciated.
Thank you for your timely response to this request. If you have any
questions concerning this matter, please contact our Safety Officer, at
( )
‑ .
Sincerely,
Company President
Appendix C
HAZARD
COMMUNICATION TRAINING CERTIFICATION
I
have received Hazard communication Training as described on the Hazard
Communication Program. The training was
conducted on __________________.
(Date)
______________________________
Employee Signature
______________________________
Social Security Number
_______________________________
Work Area
I
hereby certify that the above named employee has been provided with Hazard
Communication Training on __________________________.
(Date)
________________________________
Instructor's Signature