Hazard Communication & Chemical Safety Program

Purpose

This document serves as the Company's Hazard Communication Program. It provides detailed safety guidelines and instructions for receipt, use and storage of chemicals at our facility by employees and contractors. Reference: OSHA Standard 1910.1200. 

Responsibilities

Management

• Ensure compliance with this program
• Conduct immediate corrective action for deficiencies found in the program
• Maintain an effective Hazard Communication training program
• Make this plan available to employees or their designated representative

Shipping & Receiving Manager

• Ensure all received containers are properly labeled and that labels are not removed or defaced
• Ensure all shipped containers are properly labeled
• Ensure shipping department employees are properly trained in spill response
• Ensure received Material Safety Data Sheets (MSDS) are properly distributed

Obtain, from the manufacturer, MSDS for chemicals purchased from retail sources

• Maintain a list of hazardous chemicals using the identity that is referenced on the MSDS
• Monitor the effectiveness of the program
• Conduct annual audit of the program
• Monitor employee training to ensure effectiveness
• Keep management informed of necessary changes
• Ensure MSDSs are available as required
• Monitor facility for proper use, storage and labeling of chemicals

Company Nurse

• Ensure MSDS are available for emergency medical personnel when treating exposed employees
• Provide information, as requested, concerning health effects and exposure symptoms listed on MSDSs

Supervisors

• Comply with all specific requirements of the program
• Provide specific chemical safety training for assigned employees
• Ensure chemicals are properly used stored & labeled
• Ensure only the minimum amount necessary is kept at work stations
• Ensure up to date MSDS are readily accessible to all employees on all shifts

Employees

• Comply with chemical safety requirements of this program
• Report any problems with storage or use of chemicals
• Immediately report spills of suspected spills of chemicals
• Use only those chemicals for which they have been trained
• Use chemicals only for specific assigned tasks in the proper manner

Contractors

• Comply will all aspects of this program
• Coordinate information with the Safety Manager
• Ensure Contractor employees are properly trained
• Notify the Safety Manager before bringing any chemicals into company property of facilities
• Monitor and ensure proper storage and use of chemicals by Contractor employees

General Program Information

This written Hazard Communication Plan (HAZCOM) has been developed based on OSHA Hazard Communication Standard and consists of the following elements:

Identification of Hazardous Materials

Product Warning Labels

Material Safety Data Sheets (MSDS)

Written Hazard Communication Program

Effective Employee Training

Some chemicals are explosive, corrosive, flammable, or toxic. Other chemicals are relatively safe to use and store but may become dangerous when they interact with other substances. To avoid injury and/or property damage, persons who handle chemicals in any area of the Company must understand the hazardous properties of the chemicals. Before using a specific chemical, safe handling methods and health hazards must always be reviewed. Supervisors are responsible for ensuring that the equipment needed to work safely with chemicals is accessible and maintained for all employees on all shifts.

Employee Training

Initial Orientation Training

All new employees shall receive safety orientation training covering the elements of the HAZCOM and Right to Know Program. This training will consist of general training covering:

Location and availability of the written Hazard Communication Program

Location and availability of the List of Chemicals used in the workplace

Methods and observation used to detect the presence or release of a hazardous chemical in the workplace.

The specific physical and health hazard of all chemicals in the workplace

Specific control measures for protection from physical or health hazards

Explanation of the chemical labeling system

Location and use of MSDS

Job Specific Training

Employees will receive on the job training from their supervisor. This training will cover the proper use, inspection and storage of necessary personal protective equipment and chemical safety training for the specific chemicals they will be using or will be working around.

Annual Refresher Training

Annual Hazard Communication refresher training will be conducted as part of the company's continuing safety training program.

Immediate On-the-Spot Training

This training will be conducted by supervisors for any employee that requests additional information or exhibits a lack of understanding of the safety requirements.

Non-Routine Tasks

Non-routine tasks are defined as working on, near, or with unlabeled piping, unlabeled containers of an unknown substance, confined space entry where a hazardous substance may be present and/or a one-time task using a hazardous substance differently than intended (example: using a solvent to remove stains from tile floors).

Steps for Non-Routine Tasks

Step 1: Hazard Determination

Step 2: Determine Precautions

Step 3: Specific Training & Documentation

Step 4: Perform Task

All non-routine tasks will be evaluated by the Department Supervisor and Safety Department before the task commences, to determine all hazards present. This determination will be conducted with quantitative/qualitative analysis (air sampling, substance identification/analysis, etc., as applicable).

Once the hazard determination is made, the Department Supervisor and Safety Department will determine the necessary precautions needed to either remove the hazard, change to a non-hazard, or protect from the hazard (use of personal protective equipment) to safeguard the Employees present. In addition, the Department Supervisor or Safety Department will provide specific safety training for Employees present or affected and will document the training using the Chemical Safety Training Checklist form which shall be marked "Non-Routine Task Training".

Off-site use or transportation of chemicals

An MSDS will be provided to employees for each chemical and each occurrence of use or transport away from the company facilities. All State and Federal DOT Regulations will be followed including use of certified containers, labeling & marking, securing of containers and employee training.

General Chemical Safety

Assume all chemicals are hazardous. The number of hazardous chemicals and the number of reactions between them is so large that prior knowledge of all potential hazards cannot be assumed. Use chemicals in as small quantities as possible to minimize exposure and reduce possible harmful effects.

The following general safety rules shall be observed when working with chemicals:

• Read and understand the Material Safety Data Sheets.
• Keep the work area clean and orderly.
• Use the necessary safety equipment.
• Carefully label every container with the identity of its contents and appropriate hazard warnings.
• Store incompatible chemicals in separate areas.
• Substitute less toxic materials whenever possible.
• Limit the volume of volatile or flammable material to the minimum needed for short operation periods.
• Provide means of containing the material if equipment or containers should break or spill their contents.

Task Evaluation

Each task that requires the use of chemicals should be evaluated to determine the potential hazards associated with the work. This hazard evaluation must include the chemical or combination of chemicals that will be used in the work, as well as other materials that will be used near the work. If a malfunction during the operation has the potential to cause serious injury or property damage, a Safe Operational Procedure (SOP) should be prepared and followed. Operations must be planned to minimize the generation of hazardous wastes.

Chemical Storage

The separation of chemicals (solids or liquids) during storage is necessary to reduce the possibility of unwanted chemical reactions caused by accidental mixing. Explosives should be stored separately outdoors. Use either distance or barriers (e.g., trays) to isolate chemicals into the following groups:

• Flammable Liquids: store in approved flammable storage lockers.
• Acids: treat as flammable liquids
• Bases: do not store bases with acids or any other material
• Other liquids: ensure other liquids are not incompatible with any other chemical in the same storage location.
• Lips, strips, or bars are to be installed across the width of storage shelves to restrain the chemicals in case of earthquake.

Chemicals will not be stored in the same refrigerator used for food storage. Refrigerators used for storing chemicals must be appropriately identified by a label on the door.

Container Labels

It is extremely important that all containers of chemicals are properly labeled. This includes every type of container from a 5000 gallon storage tank to a spray bottle of degreaser. The following requirements apply:

• All containers will have the appropriate label, tag or marking prominently displayed that indicates the identity, safety and health hazards .
• Portable containers which contain a small amount of chemical need not be labeled if they are used immediately that shift, but must be under the strict control of the employee using the product.
• All warning labels, tags, etc., must be maintained in a legible condition and not be defaced. Facility weekly supervisor inspections will check for compliance of this rule.
• Incoming chemicals are to be checked for proper labeling.

Emergencies and Spills

In case of an emergency, implement the proper Emergency Action Plan

1. Evacuate people from the area.
2. Isolate the area.
3. If the material is flammable, turn off ignition and heat sources.
4. Only personnel specifically trained in emergency response are permitted to participate in chemical emergency procedures beyond those required to evacuate the area.
5. Call for Emergency Response Team assistance if required.

Housekeeping

1. Maintain the smallest possible inventory of chemicals to meet immediate needs.
2. Periodically review stock of chemicals on hand.
3. Ensure that storage areas, or equipment containing large quantities of chemicals, are secure from accidental spills.
4. Rinse emptied bottles that contain acids or inflammable solvents before disposal.
5. Recycle unused laboratory chemicals wherever possible.
6. DO NOT Place hazardous chemicals in salvage or garbage receptacles.
7. DO NOT Pour chemicals onto the ground.
8. DO NOT Dispose of chemicals through the storm drain system.
9. DO NOT Dispose of highly toxic, malodorous chemicals down sinks or sewer drains.

Contractors

All outside contractors working inside Company Facilities are required to follow the requirements of this program. The Company will provide Contractors information concerning:

Location of MSDS

Precautions to be taken to protect contractor employees

Potential exposure to hazardous substances

Chemicals used in or stored in areas where they will be working

Location and availability of Material Safety Data Sheets

Recommended Personal Protective Equipment

Labeling system for chemicals

Definitions

Chemical: any element, chemical compound or mixture of elements and/or compounds.

Combustible liquid: means any liquid having a flash point at or above 100 deg. F (37.8 deg. C), but below 200 deg. F (93.3 deg. C), except any mixture having components with flash points of 200 deg. F (93.3 deg. C), or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.

Compressed gas: any compound that exhibits:

(i) A gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70 deg. F.

(ii) A gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130 deg. F. regardless of the pressure at 70 deg. F.

(iii) A liquid having a vapor pressure exceeding 40 psi at 100 deg. F.

Container: any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or piping systems, and engines, fuel tanks, or other

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