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Introduction: The Hazard Communication Standard requires you to develop a written hazard communication program. The following is a sample hazard communication program that you may use as a guide in developing your program.
Our Hazard Communication Program
General Company Policy
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The purpose of this notice is to inform you that our company is complying with the OSHA Hazard Communication Standard, Title 29 Code of Federal Regulations 1910.1200, by compiling a hazardous chemicals list, by using MSDSs, by ensuring that containers are labeled, and by providing you with training.
This program applies to all work operations in our company where you may be exposed to hazardous chemicals under normal working conditions or during an emergency situation.
The safety and health (S&H) manager, Robert Jones, is the program coordinator, acting as the representative of the plant manager, who has overall responsibility for the program. Mr. Jones will review and update the program, as necessary. Copies of the written program may be obtained from Mr. Jones in Room SD-10.
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 yourselves from these chemicals. You will also be informed of the hazards associated with non-routine tasks, such as the cleaning of reactor vessels, and the hazards associated with chemicals in unlabeled pipes.
List of hazardous chemicals
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Each list also identifies the corresponding MSDS for each chemical.
Material Safety Data Sheets (MSDSs)
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MSDSs provide you with specific information on the chemicals you use. The safety and health manager, Mr. Jones, will maintain a binder in his office with an MSDS on every substance on the list of hazardous chemicals. The plant manager, Jeff O'Brien, will ensure that each work site maintains MSDSs for the hazardous chemicals in each work area. MSDSs will be made readily available to you at your work stations during your shifts.
The safety and health manager, Mr. Jones, is responsible for acquiring and updating MSDSs. He will contact the chemical manufacturer or vendor if additional research is necessary or if an MSDS has not been supplied with an initial shipment. All new procurements for the company must be cleared by the safety and health manager. A master list of MSDSs is available from Mr. Jones in Room SD-10.
Labels and Other Forms of Warning
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The safety and health manager will ensure that all hazardous chemicals in the plant are properly labeled and updated, as necessary. Labels should list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer or other responsible party. Mr. Jones will refer to the corresponding MSDS to assist you 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 property labeled.
If there are a number of stationary containers within a work area that have similar contents and hazards, signs will be posted on them to convey hazard information. On stationary process equipment, regular process sheets, batch tickets, blend tickets, and similar written materials will be substituted for container labels when these documents contain the same information as labels. These written materials will be made readily available to you during your work shift.
If you transfer chemicals from a labeled container to a portable container that is intended only for your immediate use, no labels are required on the portable container. Pipes or piping systems will not be labeled but their contents will be described in training sessions.
Non-Routine Tasks
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When you are required to perform hazardous non-routine tasks (e.g., cleaning tanks, entering confined spaces, etc.), a special training session will be conducted to inform you of the hazardous chemicals to which you might be exposed and the precautions you must take to reduce or avoid exposure.
Training
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Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training on the Hazard Communication Standard and the safe use of those hazardous chemicals. The safety and health manager will conduct these training sessions. A program that uses both audiovisual materials and classroom-type training has been prepared for this purpose. Whenever a new hazard is introduced, additional training will be provided. Regular safety meetings will also be used to review the information presented in the initial training. Foremen and other supervisors will be extensively trained regarding hazards and appropriate protective measures so they will be available to answer questions from employees and provide daily monitoring of safe work practices.
- A summary of the standard and this company's written program.
- The chemical and physical properties of hazardous materials (e.g., flash point, , reactivity) and methods that can be used to detect the presence or release of chemicals (including chemicals in unlabeled pipes).
- The physical hazards of the chemicals in your work area (e.g., potential for fire, explosion, etc.).
- The health hazards, including signs and symptoms of exposure, of the chemicals in work area and any medical condition known to be aggravated by exposure to these chemicals.
- Procedures to protect against chemical hazards (e.g., required personal protective equipment, and its proper use and maintenance; work practices or methods to ensure appropriate use and handling of chemicals; and procedures for emergency response).
- Work procedures to follow to assure protection when cleaning hazardous chemical spills and leaks.
- The location of the MSDSs, how to read and interpret the information on labels and MSDSs, and how employees may obtain additional hazard information.
The training program will emphasize these items:
The safety and health manager or his/her designee will review the employee training program and advise the plant manager on training or retraining needs. Retraining is required when the hazard changes or when a new hazard is introduced into the workplace. It will be company policy to provide training regularly in safety meetings to ensure the effectiveness of the program. As part of the assessment of the training program, the safety and health manager will obtain input from employees regarding the training they have received, and their suggestions for improvement.
Contractor Employers
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The safety and health manager, Robert Jones, upon notification by the responsible supervisor, will advise outside contractors, in person, of any chemical hazards that may be encountered in the normal course of their work on the premises, the labeling system in use, the protective measures to be taken, and the safe handling procedures to be used. In addition, Mr. Jones will notify these individuals of the location and availability of MSDSs. Each contractor bringing chemicals on-site must provide Mr. Jones with the appropriate hazard information for these substances, including MSDSs, labels, and precautionary measures to be taken when working with or around these chemicals.
Additional Information
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All employees, or their designated representatives, can obtain further information on this written program, the hazard communication standard, applicable MSDSs, and chemical information lists at the safety and health office, Room SD-10.
