Hazard Communication Policies and Programs
2. Retraining. You should consider requiring the retraining of employees on a periodic basis as well as after any accident
3. Access to medical records. You will need to coordinate your policy concerning access to records with this policy for compliance with hazard communication. Employees do have a right to access records concerning their exposure to chemicals in the workplace.
4. Emergency plan and notification. Facilities that manufacture, use, or store numerous hazardous chemicals may be required to include a requirement in their policy concerning hazard communication that they will inform state and local authorities of the presence of hazardous chemicals.
5. Who is to be trained? You need to evaluate your workforce to decide who needs to be trained in order for you to comply with the Hazard Communication Act. For example, do your office workers have the same exposure as do employees who are in your print shop?
6. Who will provide the training? Depending upon your size and resources, you may be able to do your training in-house or you may need the assistance of a consultant. In either event, you should make sure that you document your compliance with the training requirements of the law. If you decide to do it yourself, you can use films, videos, lectures, and training manuals that are commercially available.
7. Identifying hazards. As you perform your analysis of identifying hazards, you should consider whether any of the following factors are present: confined places, poor ventilation, the need for protective clothing, the need for eye and face protection, the need for respiratory protection, the need for emergency responses, the need for spill containment, the need for a liaison with local authorities, and the need for medical surveillance. You should then take action to correct the problem or meet the need.
8. OSHA inspections. You should consider coordinating your hazard communication compli-ance programs with your policy concerning cooperation with government inspections. For example, will you insist on a subpoena when a subpoena is required for the inspection? Who will accompany the inspectors on their audit? Who will respond to any questions by the OSHA inspector? Will you instruct managers to “never volunteer” information?
9. Documentation you will need. You should consider what information and forms you will require in order to document your full compliance with the law. For example, you will need to consider developing forms requesting an MSDS, reflecting surveys of the workplace, job safety analyses, audits of your compliance, attendance at training sessions, medical examinations, reports of emergencies such as spills, and the like.
10. Language. You will need to consider whether your employees understand English well enough to comprehend the written warnings as well as your training. While there is no clear-cut requirement that you provide translations from English to another language, you may want to do so in order to avoid employee injuries. You may also consider making it a condi-tion of hiring (depending on the laws of your state) that an employee read and speak English well enough to understand safety instructions.
The following sample Hazard Communication Program is provided as an example of how a program might be written. It is not guaranteed that it will comply with all the state or federal regulations to which an employer may be subject. Forms and Appendixes are for demonstration purposes only and are not included here.
Sample: Right-to-Know—Plan of Implementation for an end-user of chemicals Rowan Metal Stamping Hazard Communication Program
Rowan Metal Stamping Corp.
Approved by: Abel R. Rowan, President Date ____________________________
Introduction
Our plant is a 75-employee facility providing metal stampings to the lighting, automotive, and elec-tronic assembly markets. The plant operates a day shift and a small second shift. The facility has 100,000 square feet of manufacturing and warehouse space and a small office at the front of the building, which also houses three salespersons. We have little turnover and no temporary workers are employed. This is a nonunion facility.
In our operations we use a small number of chemicals and use these chemicals in small quantities for machine lubrication and machinery and parts cleaning purposes. Chemicals are also used in the repair and rework area to clean sheets of metal or to wipe and clean reworked products.
All chemicals are shipped to us in 45-gallon drums from major chemical manufacturers. Material safety data sheets (MSDSs) are on hand for all chemicals, and the drums are clearly identified with prominent labels. We do not prepare our own MSDSs but rely on the data sheets provided by these dependable suppliers.
It is our practice to actively communicate to employees the chemical hazards associated with their work and the necessary job safety precautions, safety equipment, or personal protective devices to be utilized. On the job, this information is communicated through supervisors and job trainers.
Our personnel clerk, Jean Gusto, and plant supervisor, Mario Lemaire, review the chemicals we use with any new hires and the safety precautions required in handling the chemicals. Material safety data sheets are also reviewed and employees shown where these MSDSs are available to them in the plant supervisor’s office. Personal protective equipment is provided for use in working with the small quanti-ties of these chemicals.
We use four transfer containers to carry chemicals from the chemical storage area (an outside caged area at the rear of the building), and employees draw on the amount of chemicals they need for the particular cleaning or clean-up purpose. These containers are labeled for the type of chemical in use.
It is an employee responsibility to follow safe working practices as outlined in our plant safety rules and local operating procedures or to follow the safe working practices outlined in the MSDS.
Mario Lemaire, plant supervisor, is designated as the plant’s hazard communication coordinator.
This Hazard Communication Program (HCP) summarizes and reinforces our regular safety
committee activities. The effectiveness of this program depends on the active support and involvement of all personnel.
This written HCP includes:
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A copy of the most recent materials and chemicals inventory for the facility•
Attendance lists of employees (and contractors’ employees) who have been trained in the Hazard Communication Standard•
A copy of the federal Hazard Communication Standard (There are no state or local regulations affecting hazard communication to our employees.)Responsibilities
The writer, president of the company, has the overall responsibility for this program with assistance from Mario Lemaire, the two other supervisors, the safety committee, and our personnel clerk. We will draw on other resources if necessary to implement and maintain the program.
Responsibilities of the program coordinator include:
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Coordinating the plant’s overall compliance with the standard.•
Directing the taking of the basic chemical inventory, adding or deleting from the inventory as new chemicals are added or no longer used in the facility.•
Assisting departments in developing safe handling procedures with any nonroutine chemical handling.•
Arranging to provide contractors with information on materials and chemicals used in this location should their work bring them near any of these chemicals.•
Coordinating emergency and hazardous spill procedures, fire drills, and fire department activi-ties related to hazardous chemicals.•
Coordinating new employee training and any transferred employees who have not had the training, as required under the Standard.•
Providing for employee training when involved in nonroutine activities, such as boiler cleaning and repair.•
Perform an annual audit or review of the effectiveness of the program.Labels of chemicals we receive are already affixed to drums by the chemical manufacturer. We advise these outside suppliers of any irregularities we see.
Chemical Inventory
A list of chemicals and other materials referenced under the standard is attached to this program.
This inventory is updated as new chemicals are added or individual chemicals are deleted from our inventory.
Material Safety Data Sheets
MSDSs are provided by our suppliers to outline the special precautions and controls necessary for handling hazardous materials.
A binder of MSDSs is maintained by plant supervisor Mario Lemaire in the operations office, which is immediately inside the door from the factory area. The office is open to other supervisors and employees whenever operations are scheduled. This binder is readily available to supervisors and employees and to the safety committee. Mr. Lemaire will follow up, if necessary, to obtain MSDSs on new materials or revised MSDSs for changed materials.
MSDSs are available to employees who work with these materials for review on request. If an employee who works with these materials or his or her physician wishes to obtain a copy, one will be provided in response to a written request. Since these are generic chemicals, we do not have concerns about trade secrecy with the chemicals.
When new or revised substances come into our plant, an MSDS, if not provided with the initial ship-ment, will be obtained, and employees will be trained in its use, as outlined in the training and
emergency notification requirements on the MSDS.
Labeling
Labels provide information to employees concerning the potential hazards of chemicals in use at the facility. All manufacturers’ labels, including names and addresses, will remain on drums and containers coming to the plant.
At a minimum, each label contains the following information:
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Identification of material in the container•
Appropriate hazard warnings, such as fire hazard, health potential, etc.•
Name and address of manufacturer or supplierPipes and piping systems are not used for the transfer of chemicals at this facility. Portable containers into which hazardous materials are transferred from labeled containers and that are intended only for immediate use of the employee who performs the transfer are not labeled, as outlined in the standard.
To meet the definition of “immediate use,” the container must be under the control of the employee performing the transfer and to be used within the workshift when the transfer was made. In our rework area, small containers of chemicals for cleaning purposes are drawn at the start of each shift, and any remaining chemicals are returned to the outside chemical storage cage at the end of the shift.
Training
Initial training of plant employees was conducted at the start-up of the plant. Any new hires are trained in the safe aspects of their work, including the Hazard Communication Standard, by the plant supervisor with assistance from the personnel clerk.
This Hazard Communication Program was also reviewed with the safety committee, and they are aware of its details and the location of MSDSs and of the written program in the plant supervisor’s office.
Contractors
We use two outside contracting firms on a regular basis—Aberdeen Electric Co. for electrical repairs and installations and Monmouth Millwrights, Inc., for new equipment installations. We have
conducted training sessions in hazard communication for our employees and for eight employees of these two firms who are in our facility on a regular basis. Their attendance is included on the atten-dance list of our employees who received the training.
Nonroutine Operations
Since establishment of this plant, machinery has been set in place, and the operation is now well stan-dardized. We have not had any “nonroutine operations” that would require special coverage under HCS, other than the annual boiler cleaning that is conducted in line with the provisions of the HCS and OSHA’s Confined Spaces Entry Standard.
Annual Review
Although not specifically required under HCS, we conduct an annual review of the requirements of the Hazard Communications Standard at our annual Safety Day each October. This activity also provides an opportunity for employees to ask questions about the Standard and our program of compli-ance with the Standard.
Abel R. Rowan President Date: