Written Program for Hazard Communication
1910.1200 Hazard Communication The following hazard communication program is provided as a guide to assist employers and employees in complying with the requirements of 29 CFR 1910.1200, as well as to provide other helpful information. It is not intended to supersede the requirements of the standard. An employer should review the standard for particular requirements which are applicable to their individual situation and make adjustments to this program that are specific to their company. An employer will need to add information relevant to their particular property or facility in order to develop an effective, comprehensive program.
Property Name: Address: City, State, Zip: Phone: Property Manager: Maintenance Supervisor: Person Responsible for HAZCOM Compliance: Date:
Action Plan/ Guideline for OSHA Compliance The Hazard Communication Standard (legal reference: 29 CRF Part 1910.1200) requires employer action in five major areas: 1) Hazard determination 2) Written Hazard Communication Program 3) Labels and other forms of warnings 4) Material Safety Data Sheets (MSDS) 5) Employee information and training Chemical manufacturers, importers and distributors were required to be in compliance by November 25, 1985. Employers in SIC Codes 20 through 39 were required to comply by May 25, 1986. (See copy of 29 CRF Part 1910.1200) Your State Right-to-Know laws may include additional requirements particularly with respect to the timing and frequency of employee training, posting of information, and reporting hazardous chemical information to local and State authorities. Refer to the section on State Right-to-Know laws for information on whom to contact for the specific requirements of your state regulations and compliance assistance. (See copy of State Law) In Order To Be In Compliance with OSHA s Hazard Communication Standard, The Following 8 Steps Are to Be Followed: Step 1: ASSIGN RESPONSIBILITY for complying with the Standard to an individual or department. Step 2: REVIEW THE LAW to be familiar with its overall scope and requirements. A summary, as well as the complete text of the law, is enclosed as appendices for your information. Step 3: DEVELOP A WORKPLACE CHEMICAL INVENTORY. The form, Workplace Chemical Inventory which is included at the end of this section, will help you organize your material for use in collecting Material Safety Data Sheets, writing your Hazard Communication Program, and tailoring your program to meet your employee s specific needs. Be sure to check storage closets, receiving areas and maintenance store rooms when conducting your inventory. Step 4: IDENTIFY HAZARDOUS CHEMICALS in your work area. An employer can rely on the information provided by the chemical manufacturer or importer in their MSDS or can conduct independent testing of purchased chemicals to determine the hazards. Be sure that the chemical names used on your Hazard Chemical List are the same as the names used in the MSDS s. OSHA defines a hazardous chemical to be any chemical which is a physical or a health hazard. Health Hazards include irritants, sensitizers, corrosives, toxic agents, highly toxic agents, carcinogens, and damage to specific organs such as the liver or kidneys. Physical hazards include
combustible liquids, compressed gasses, explosives, flammables, organic peroxides, oxidizers, pyrophorics (spontaneously combustible), unstable (reactive) or water reactive. Step 5: COLLECT CURRENT MATERIAL SAFTEY DATA SHEETS for all hazardous products used in your facility or work area. An MSDS should be provided to you at the time you receive your first shipment of a product. Contact the distributor or manufacturer for copies of MSDS s if you do not automatically receive them. MSDS s must be available for reference by employees in their work areas during regular working hours. Consider placing them on file in the maintenance supervisor s office or in the storage closet. Step 6: REVIEW THE LABELING of all containers of hazardous chemicals. The originals, secondary or portable storage, and permanent storage containers must have labels that include: the identity of the hazardous chemicals, the appropriate warning statements, the name and address of the chemical manufacturer. Some manufacturers such as The Butcher Polish Company; supply pre-painted secondary labels to their customers. Note that procedures that are labeled according to other Federal laws and agencies are exempt from the OSHA labeling requirements. This includes pesticides, EPA registered disinfectants, food, food additives, drugs, cosmetics, distilled spirits, wine, and malt beverages intended for non-industrial purposes, consumer products and hazardous wastes. These items are not exempt from the other requirements of this law. STEP 7: DEVELOPE A TRAINING PROGRAM to provide employees with information about the Hazard Communication Standard and the hazardous chemicals in their work areas. Training must be provided when the employee is first assigned to the job and any time a new hazard is introduced to the work area. 1) Identify who is exposed to hazardous substances and who needs to be trained. Group employees according to the severity of the hazards he or she must work with. 2) The videotape The Employee Right to Know will inform employees of the existence and requirements of the Hazard Communications Standard; how to obtain and how to use available hazard information; what to look in product labels and MSDS s, including information on personal protective equipment, emergency procedures, how to detect the presence of hazardous chemicals in the work area and specific hazardous chemical handling information. 3) Determine the categories of hazardous products to which your employees are exposed. Group the chemicals used in your work areas into categories based on the type of hazards they present (irritants, flammable, corrosive, reactive, etc.). You will needs to train employees in how to identify and safely work with the specific categories of hazardous chemicals in their work areas. The MSDS s and product labels will provide you with the information you need to do this. You do not have to provide training for each specific product used in the workplace, but you do not need to cover the general classes of chemicals. 4) Inform employees of the specific operations which involve hazardous chemicals in their work areas, the hazards associated with chemicals in unlabeled pipes, hazards of non-routine tasks, if
any, and where the written materials for this program (the written program, chemical list, MSDS s) are kept. Step 8: WRITE YOUR HAZARD COMMUNICATION PROGRAM to document the findings and methods used to complete the previous seven steps. The written program must describe how the employer will handle: Labeling Material safety data sheets Listing hazardous chemicals in each work area Employee training Informing employees of hazards from chemicals in unlabeled pipes Informing employees of hazards of non-routine tasks Informing contractors of the hazards a contractor s employees may be exposed in the work area. Making hazardous chemicals list, the MSDS s and the written program accessible to employees. The enclosed Example Written Hazards Communication Program included with this guide provides a suggested format and outline for your written program. Example Written Hazard Communication Program 1. General Information In order to comply with the Hazard Communication Standards, the following written Hazards Communication Program has been established for: (Name of Company). All work units of the company are included with this program. The written program will be available in the Location For review by any interested employee. A. Container Labeling The (Name/Position) will verify that all containers received for use will: -Be clearly labeled as to the contents, -Note the appropriate hazard warning, -List the name and address of the manufacturer. The (Name/ Position) in each section will ensure that all the secondary containers are labeled with either an extra copy of the original manufacturers label it with the generic labels which have a block for identity and blocks for the hazard warning. For help with labeling, please see our safety/ health officer. (If written alternatives to labeling of in-plant containers are used add a description of the system used). The (Position/Name) will review the company labeling system every (time period) and update as required.
B. Material Safety Data Sheet (MSDS) (Position/Name) will be responsible for obtaining and maintaining the data sheet for the company. (Position/Name) will review incoming data sheets for new and significant health/safety information. He/She will see that any new information passed on to the affected employees. (If alternatives to actual data sheets are used, provide a description of the system). Copies of MSDS s for all hazardous chemicals to which employees of this company may be exposed will be kept in (Location) and (Location). MSDS s will be available to all employees in their work area for review during each work shift. If MSDS s are not available or new chemicals in use do not have MSDS s immediately contact (Name/Position). C. Employee Training and Information (Name/Position) is responsible for the employee training program. He/She ensures that all elements specified below are carried out. Prior to starting work each new employee of (Name of Company) will attend a health and safety orientation and will receive information and training on the following: An overview of the requirements contained in the Hazard Communication Standards Chemicals present in their workplace operations, Location and availability of our written hazard program, Physical and health effects of the hazardous chemicals, Methods and observation techniques used to determine the prescience or release of hazardous chemicals in the work area. How to lessen or prevent exposure to these hazardous chemicals through usage of control/work practices and person protective equipment. Steps the company has taken to lessen or prevent exposure to these chemicals, How to read labels and review MSDS s to obtain appropriate hazard information, Location of MSDS file and location of hazardous chemical list. After attending the training class, each employee will sign a form to verify that they attended the training, received our written materials, and understood this company s policy on Hazardous Communication. 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. (Name/Position) is responsible for ensuring that MSDS on the new chemical(s) are available. 2. List of Hazardous Chemicals The following is a list of Hazardous Chemicals used by employees of (Name of Company). Further information on each noted chemical can be obtained by reviewing Material Safety Data Sheets located in (Location) and (Location).
See Attachment B
ATTACHMENT B SAMPLE MSDS INDEX/INVENTORY CATEGORY: 1 CLEANING SUPPLIES INDEX NUMBER PRODUCT DESCRIPTION INTRODUCED DISCONTINUED 1-1 Bleach - Clorox 06-21-2012 Use: Disinfection Janitorial Staff 1-2 1-3 1-4 1-5 1-6 1-7 1-8 1-9 1-10 1-11 1-12
ATTACHMENT B SAMPLE MSDS INDEX/INVENTORY CATEGORY: 2 HVAC INDEX NUMBER PRODUCT DESCRIPTION INTRODUCED DISCONTINUED 2-1 2-2 2-3 2-4 2-5 2-6 2-7 2-8 2-9 2-10 2-11 2-12
ATTACHMENT B SAMPLE MSDS INDEX/INVENTORY CATEGORY: 3 PLUMBING INDEX NUMBER PRODUCT DESCRIPTION INTRODUCED DISCONTINUED 3-1 3-2 3-3 3-4 3-5 3-6 3-7 3-8 3-9 3-10 3-11 3-12
ATTACHMENT B SAMPLE MSDS INDEX/INVENTORY CATEGORY: 4 PEST CONTROL INDEX NUMBER PRODUCT DESCRIPTION INTRODUCED DISCONTINUED 4-1 4-2 4-3 4-4 4-5 4-6 4-7 4-8 4-9 4-10 4-11 4-12
ATTACHMENT B SAMPLE MSDS INDEX/INVENTORY CATEGORY: 5 POOLS INDEX NUMBER PRODUCT DESCRIPTION INTRODUCED DISCONTINUED 5-1 5-2 5-3 5-4 5-5 5-6 5-7 5-8 5-9 5-10 5-11 5-12
ATTACHMENT B SAMPLE MSDS INDEX/INVENTORY CATEGORY: 6 MISCILANEOUS/OTHER INDEX NUMBER PRODUCT DESCRIPTION INTRODUCED DISCONTINUED 6-1 6-2 6-3 6-4 6-5 6-6 6-7 6-8 6-9 6-10 6-11 6-12
3. Hazardous Non-Routine Tasks Periodically, employees are required to perform hazardous non-routine tasks. Prior to starting work on such projects, each effected employee will be given information by their supervisor about hazardous chemicals to which they may be exposed during such activity. This information will include: -Specific chemical hazards -Protective chemical hazards -Measures the company has taken to lesson the liability including ventilation, respirators, presence of another employee, and emergency procedures. Example of non-routine tasks performed by the employees of this company TASK HAZARDOUS CHEMICALS 4. INFORMING CONTRACTOR It is the responsibility of (Name/Position/Department/etc.) to provide contractors (with employees) the following information: -Hazardous chemicals to which they may be exposed to on the job site; -Precautions the employees may take to lessen the possibility of exposure by usage of appropriate protective measures. ( (Position/Name) will be responsible for contracting 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). It is the responsibility of the contractor to train his or her employees. End of Written Program