Hazard Communications

Purpose:

To ensure that information about the dangers of all hazardous materials used by the Company are known to all affected employees and contractors.  A secondary purpose is to comply with the requirements of the OSHA Hazard Communication Standard and corresponding state laws.

 Responsibility:

All employees of the company will participate in the hazard communication program and comply with all provisions of this policy.  The Safety Coordinator is responsible for maintaining this program and ensuring compliance with all local, state, and federal laws.

 Scope:

This policy covers container labeling, material safety data sheets, employee training and information, hazardous non-routine tasks, contractors, list of hazardous chemicals, chemicals in unlabeled pipes and safety procedures.

 Policy:

Container Labeling

1.      The Safety Coordinator will verify that all containers received for use will be clearly labeled with the following: 1) contents, 2) the appropriate hazard warning (i.e. flammable), and 3) the name and address of the manufacturer.  Existing labels will not be removed or defaced on incoming containers unless containers are to be immediately marked with required information.

2.      All materials on site are to be stored in their original container with the label attached.

3.      Any material with a label missing or illegible should be reported to the supervisor immediately for proper labeling.

4.      Stationary, secondary, or portable containers should be clearly labeled with either an extra copy of the original manufacturer’s label or with tile “central stores” generic labels which have a block for identification and blocks for the hazard warning.

5.      Signs, placards, or other written materials that convey specific hazard information may be used in place of individual container labels if there are a number of stationary process containers within a work area which store similar contents.

6.      Portable containers do not need to be labeled if the chemicals are transferred to labeled containers and used by the employee making the transfer during that shift.  No unmarked containers of any size shall be left unattended in the work area.

Material Safety Data Sheets (MSDS)

1.      Any product having a hazardous warning on its label requires a MSDS.

2.      The manufacturer, distributor, or vendor shall provide the MSDS for the hazardous product.

3.      All MSDS’s shall be forwarded to the Safety Coordinator and reviewed by the Safety Coordinator and employee using the product to determine safe work practices and personal protection, as needed.  The MSDS’s will be maintained and kept at the following location:      .

4.      The MSDS provides 1) chemical information, 2)hazardous ingredients, 3) physical data such as the potential for fire, explosion, and reactivity, 4) health hazards, 5) spill or leak procedures, 6) special protection and precautions, 7) personal protective equipment needed, and 8) name, address, and phone number of MSDS author or distributor.

Employee Training and Information

1.      The Safety Coordinator will provide training to employees when hired and routinely thereafter on the hazardous nature of chemical products.  Training will include:

	The Hazard Communication Policy
	Chemicals present in their workplace operations
	Physical and health effects of the hazardous chemicals
	Appropriate work practices and controls when using chemicals
	Emergency and first-aid procedures
	How to read labels and review an MSDS to obtain appropriate hazard information
	Location of the MSDS file and written hazard communications program

2.      After attending the training class, each employee will sign a form to verify that they attended the training, received the written materials, and understand the company’s policies on Hazard Communication.

Hazardous Non-Routine Tasks

1.      Periodically, employees are required to perform hazardous non-routine tasks.  Examples of non-routine tasks performed by employees of this company are as follows: Confined space entry, tank cleaning, and painting reactor vessels.

2.      Prior to starting work on such projects, each affected employee will be given information by the safety coordinator about the hazards he/she may encounter during such an activity.  This information will include specific chemical hazards, protective safety measures the employee can use, and measures the company has taken to lessen the hazards including ventilation, respirators, presence of other employees, and emergency procedures.

Informing Contractors and Others

1.      The Safety Coordinator shall advise contractors and other clients of our Hazard Communication Program.

2.      Copies of the MSDS’s for all materials brought onto the site will be made available upon request to each contractor from the Safety Coordinator.

3.      The Safety Coordinator will also obtain chemical information from contractors that may expose our employees to hazardous chemicals which they bring into our workplace.

List of Hazardous Chemicals

Attached is a list of all known hazardous substances presently being used.  Listed chemicals are denoted as EX for explosive, HT of highly toxic, C-R for corrosive or irritant, and CAR for proven or suspected carcinogen-mutagen in humans or animals.  Further information on each chemical can be found by reviewing the MSDS’s.

Chemicals in Unlabeled Pipes

1.      Work activities are often performed by employees in areas where chemicals are transferred through unlabeled pipes.

2.      Prior to starting work in these areas, the employee shall contact the Safety Coordinator for information regarding:

	The chemical in the pipes
	Potential hazards
	Safety precautions which should be taken

Safety Wear

	ANSI approved eye or face protection should be worn continuously.
	Gloves should be worn which will resist penetration by the chemical being handled and have been checked for pin holes, tears, or rips.
	Wear a lab jacket or apron
	Footwear should cover feet completely:  no open-toe shoes or sandals

Facilities and Equipment

	Have separate container for trash and broken glass
	Never block any escape routes, and plan alternate escape routes
	Never block a fire door
	Never store materials in storage aisles
	All moving belts and pulleys should have safety guards
	Instruct all personnel in the proper use of the eye-wash fountain, emphasizing rolling of the eyeballs and turning the eyelids “inside-out”
	Ensure that eye-wash fountains will supply at least 15 minutes of water flow
	Sample breathing air space for measurement of possible contaminants, and keep good records
	Regularly inspect fire blankets for rips and holes and keep good records of the inspections
	Regularly inspect safety showers and eye-wash fountains and keep records on inspections
	Keep up-to-date emergency phone numbers posted next to the phone
	Place fire extinguishers near an escape route, not in a “dead end”
	Regularly maintain fire extinguishers, maintain records, and train personnel in the proper use of extinguishers through actual fire situations
	Acquaint personnel with the meaning of “Class A fire”, “Class B fire”, etc., and how they relate to fire extinguisher use
	Regularly check hood for proper draft also verify that exhaust air from an external hood vent is not re-drawn into room air
	Secure all compressed gas cylinders when in use and transport them secured on a hand truck
	Install chemical storage shelves with lips, and never use stacked boxes in lieu of shelves
	Only use an explosion-proof refrigerator for storage
	Have appropriate equipment and materials available for spill control replaced when it becomes dated

Chemical Storage

	Do not store materials on the floor
	Separately store Organic and Inorganic chemicals
	No top or above eye level chemical shelve storage
	Shelf assemblies are firmly secured to walls, preferred material is wood
	Store acids, poisons, and flammable liquids in separate dedicated cabinets

Purchasing, Use, and Disposal

	If possible, purchase chemicals in class-size quantities only.  Label all chemicals accurately with date of receipt, or preparation, initialed by the person responsible, and pertinent precautionary information on handling
	Follow all directions for disposing of residues and unused portions of reagents
	Properly store flammable liquids in small quantities in containers with a provision for bonding to receiving vessels when the liquid is transferred
	Never open a reagent package until the label has been read and completely understood.   Have a Material Safety Data Sheet on hand before using a chemical
	Prepare a complete list of chemicals of which you wish to dispose
	Classify each of the chemicals on the disposal list into a hazardous or non-hazardous waste chemical (Check with the local environmental agency office for details)
	Unlabeled bottles (a special problem) must be identified to the extent that they can then be classified as hazardous or non-hazardous wastes.  Some landfills will analyze a mystery bottle for a fee if it is shipped to the landfill in a separate package, labeled as a sample, and accompanied by a letter also identifying it as a sample, with instructions to analyze the contents sufficiently to allow proper disposal

Substitutions

	Reduce risk by diluting substances instead of using concentrates
	Use films, videotapes, and other methods rather than experiments involving hazardous substances
	Undertake all substitutions with extreme caution

 Training Documentation for Hazard Communication Program

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