8431 Operations_Written Hazard Communication Program

Introduction
 
As part of the District’s overall safety and health program, the District has established this written chemical Hazard
Communication Program. The Hazard Communication Program is designed to comply with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard. To the extent that the Program
conflicts with the Standard, the Standard will govern.
 
The objective of the Hazard Communication Program is to prevent occupational injuries and illnesses related to
chemical exposure by educating employees about workplace chemical hazards.
 
This Hazard Communication Program applies to all work areas where hazardous chemicals are known to be
present both under normal conditions and in a foreseeable emergency. The safety officer has the responsibility for
overall coordination of the hazard Communication Program. The safety officer has the responsibility to administer
and implement the program at Good Steel, Inc.
 
This Program outlines and describes how the following information will be organized and transmitted:
 
    A. List of hazardous chemicals known to be present in the workplace.
 
    B. Information on precautionary labels and other forms of warning for known hazardous chemicals in the
        workplace.
 
    C. Material Safety Data Sheets (MSDS’s) for known hazardous chemicals in the workplace.
 
    D. Methods used to provide employee information and training.
 
    E. Methods used to inform employees of hazards of non-routine work.
 
    F. Methods used to inform contractor employees of any hazardous chemicals to which contractor employees
        may be exposed.
 
    G. The Hazardous Communication Program is available for review by all employees upon request to their
        supervisor.
 
Definitions
 
The term "hazardous chemicals" means any chemical which is a physical hazard or health hazard. Chemical
physical hazard characteristics include substances which are:
 
    • Combustible
 
    • Compressed gases
 
    • Explosive
 
    • Flammable
 
    • Organic peroxides
 
    • Oxidizers
 
    • Pyrophoric
 
    • Unstable (reactive) or water reactive
 
Chemical health hazards includes substances which are:
 
    • Toxic or highly toxic
 
    • Irritants
 
    • Sensitizers
 
    • Carcinogens and those with
 
    • Target organ effect
 
Chemical Inventory List
 
The safety officer has the responsibility to maintain an inventory list of known chemicals in the workplace. Any
changes to the inventory list should be approved by the safety officer. The chemical inventory list is available to
employees. Employees who have questions about the chemical inventory list should contact their immediate
supervisor.
 
Precautionary Labeling
 
    A. Containers in the Workplace
 
        The safety officer and building principal have the responsibility to ensure all known hazardous chemicals
        present in their building display a precautionary label stating:
 
            • Identity of the hazardous chemical(s)
 
            • Appropriate hazard warning(s)
 
        In the event of an improperly labeled hazardous chemical container, a proper label will be requested, by
        telephone, and letter from the chemical supplier. Failure of a supplier to correct labeling deficiencies within
        sixty (60) days will result in suspension of use of the affected product.
 
        All labels on incoming chemicals must not be defaced in anyway. Observation or other detection of defaced
        labels must be immediately reported to the building principal so appropriate  labels can be applied.
 
    B. Process Vessels
 
        All plant process vessels which routinely store bulk chemical products shall be labeled in the following
        manner:
 
            • Name of contents (chemical and/or common name)
 
            • Identity of process lines served by vessel (if not obvious by machine arrangement)
 
            • Appropriate hazard warning
 
            • National Fire Protection Association (NFPA) 704 M diamond, Hazard Identification
 
        Where necessary, commercially available warning labels will be purchased. If no standard commercial labels
        are available for a specific hazardous chemical, a proper label is prepare internally. Material Safety Data
        Sheets will provide the necessary information for hazardous warnings. The building principal is responsible for
        assuring that process vessels are appropriately labeled.
 
    C. Temporary Storage Tanks
 
        Temporary storage tanks including, but not limited to, blend tanks and holding tanks used for variable
        process chemical formulations normally do not have permanently fixed warning labels. To ensure employees
        know of the vessel contest, formulation batch tickets are maintained which list the name of chemicals stored
        in specific vessels. The hazard warning is part of the label for temporary storage tanks and is located on the
        batch cards, or fixed on the storage tanks as part of the label. Employee having questions about labeling
        should contact their immediate supervisor.
 
    D.  Portable Containers
 
        All portable containers of hazardous chemicals require labeling. The exception to this policy is that portable
        containers of hazardous chemicals do not have to be labeled if they contain chemicals transferred from a
        labeled container, and are intended only for the immediate use by and remain the constant control of the
        employee who performs the transfer. All other portable containers and usage will require labeling. Employees
        who have questions about portable container labeling should contact their immediate supervisor. The
        employee who uses the portable container is responsible for placing the label on the container, and the
        safety officer and building principal are responsible to see that labeling is done.
 
    E.  Piping Systems
 
        Labeling of chemical pipes is not specifically required by the Hazard Communication standard, but
        employees must be aware and informed of the contents in chemical pipes. This can best be accomplished
        by labeling all piping used to transfer the same hazardous chemicals. The latest American National Standard
        Institute (ANSI) Standard (ANSI 13.1-1981), Scheme for Identification of Piping Systems, is used as a guide
        for location and design of pipe labels.
 
        Employees who have questions about piping systems labels and/or content hazards, should contact their
        immediate supervisor.
 
    F.  Product Containers Leaving the Workplace
 
        All hazardous chemical containers that are shipped shall be labeled and shall include the following
        information:
 
            • Identity of the hazardous chemicals
 
            • Appropriate hazard warning(s)
 
            • Name and address of the chemical manufacturer or other responsible party
 
        Special information on labels, tags or other markings will be consistent with the information contained on the
        Material Safety Data Sheet and similar information suggested in the American National Standard Institute
        (ANSI) Precautionary Labeling Standard (Z129.1-1982). The safety officer is responsible for coordinating the
        labeling program for containers leaving the workplace.
 
    G. Update and Review
 
        The safety officer responsible for reviewing the labeling system annually and updating it if necessary,
        changes in the labeling system will be transmitted to affected supervisors and employees. Employees who
        have questions about the precautionary labeling system should contact the safety officer or building principal.
 
Material Safety Data Sheets (MSDS)
 
    A. MSDS Format
 
        MSDS’s are written or printed material concerning product hazard determination, which are prepared and
        distributed with chemicals by chemical manufacturers and distributors. (See Form 8431 F1). MSDS’s contain
        the following information:
 
            • Identify of the chemical as provided on the container label
 
            • Physical hazards of the material
 
            • Health hazards of the material
 
            • Primary route(s) of entry
 
            • Exposure limits, Threshold Limit Value (TLV), OSHA Permissible Exposure Limit (PEL), or Supplier
              recommended limits
 
            • Whether or not the material or components have been found to be a potential carcinogen by the
              International Agency for Research on Cancer (IARC), National Toxicology Program (NTP), or by OSHA
             
            • Applicable precautions for safe handling and use

            
• Applicable control measures

            
• Emergency and first-aid procedures
 
            • Date of preparation or date of last change
 
            • Name, address and telephone number of the chemical manufacturer, importer, employer or other
              responsible party, who can provide addition information
 
    B. Obtaining MSDS
 
        The buyer of any chemical is responsible for obtaining a MSDS for chemical. The buyer shall also notify the
        safety officer and building principal before purchasing any new chemical. A MSDS should be available for
        every hazardous chemical listed on the inventory list. If a MSDS is not available, the Buyer will use the
        following procedures to obtain MSDS’s:
 
            1. The supplier will be contacted by telephone and letter (See Form 8431 F3), and all correspondence and
                communication documented as proof of effort to comply.
 
            2. If a supplier should not satisfy the first written request within thirty (30) days, a second written request
                for a MSDS should be sent to the supplier and the Department of Labor will be contacted if MSDS is
                not received within fifteen (15) days.
 
            3. All requests to suppliers and the Department of Labor including letters and telephones calls must be
                documented and maintained on file.
 
    C.  Review of MSDS
 
        The safety officer is responsible for reviewing all incoming data sheets for new and significant health/safety
        information. Any new information will be transmitted to building principals so appropriate measures can be
        taken to inform affected employees.
 
        If deficiencies exist or additional information is need concerning MSDS’s, the chemical manufacturer or
        supplier will be contacted to obtain necessary information.
 
    D. MSDS Maintenance
 
        The safety officer is responsible for maintaining the MSDS’s.
 
        The MSDS’s for chemicals and the chemical inventory list are maintained by the building principal in a
        notebook titled "Hazard Communication Program". These are accessible to employees during work.
 
        If MSDS’s are not available or new chemicals in use do not have MSDS’s employees should contact their
        immediate supervisor.
 
        A master copy of the MSDS’s and inventory list will be maintained by the safety officer.
 
    E. New Chemicals
 
        The buyer shall notify the safety officer and building principal before purchasing any new chemical. The safety
        officer must approve all new chemicals before use by employees. A MSDS must be reviewed before the
        chemical is used.
 
    F. Hazard Determination
 
        The District relies upon the hazard determination and Material Safety Data Sheet supplied by the chemical
        manufacturer or distributor to determine the hazards of all chemicals bought, used or stored in the facility.
        Employees who have questions about Material Safety Data Sheets should contact their immediate
        supervisor.
 
Employee Training and Education
 
Effective employee training and education is the most critical component of the hazard communication program. A
properly conducted training program will ensure that employees are aware of hazards in the workplace and
appropriate control measures to protect themselves. The safety officer coordinates the employee training and
education program for the District.
 
    A. Program Outline
 
        All employees who work in areas where hazardous chemicals are used and/or maintained and those who
        may be exposed in an emergency are involved in the employee training and educational program. The
        program is presented in two (2) phases:
 
            1. General Information Training
 
                    • Explanation of the Hazard Communication Standard
 
                    • Location and availability of written hazard communication program
 
                    • Operations in the work area where hazardous chemicals are present
 
                    • General introduction of chemical hazards, labeling and Material Safety Data Sheet (MSDS)
 
            General information training is administered by the safety officer during the initial orientation.
 
        2. Specific Hazard Training
 
                • Location of hazardous chemicals in the work area
 
                • Discussion of methods and means of determining/detecting the presence/release of hazardous
                  chemicals in the work area
 
                • The chemical physical and health hazards in the work area
 
                • Explanation of internal labeling system
 
                • Hazard’s associated with piping system
 
                • Review of appropriate work practices, personal protective equipment and emergency procedures
 
                • Access to safety and health information
 
                • Work area list of hazardous chemicals and Material Safety Data Sheets
 
                • How to obtain additional information
 
                • Specific hazard training is administered by the immediate supervisor
 
        All employees who receive general information and specific hazard training sign a training sheet as
        documentation. (See Form 8431 F4).
 
    B. Re-Assigned/Transferred Employees
 
        Employees re-assigned or transferred to other work areas will undergo a review of specific hazard training in
        their new work area. The building principal is responsible for scheduling and ensuring that this retraining
        session is conducted by the immediate supervisor, and initiated on the first day of employment in a new work
        area. Employees will be required to sign a transfer safety-training sheet.
 
    C. New Hires
 
        Whenever a person is hired for employment, hazard communication training and education will be provided at
        the time of their initial assignment. New employee training will be provided by the safety officer as part of new
        employee orientation at the time of initial employment and prior to handling hazardous chemicals. New hires
        will be required to sign a safety training sheet.
 
    D. New Hazard
 
        There are three (3) ways in which a new hazard may be introduced:
 
            1. A new hazardous chemical may be brought into the workplace; or
 
            2. A current hazardous chemical in use may expose additional employees in the same work area; or
 
            3. A former non-hazardous chemical may begin to be used in a manner that is hazardous.
 
        Whenever a new hazard is introduced, the immediate supervisor is responsible for providing specific hazard
        training to all affected employees prior to the introduction of the hazard.
 
        The safety officer can provide assistance and guidance with new hazard training. Employees will be required
        to sign a new chemical training sheet.
 
Non-Routine Work
 
Occasionally employees will be asked to perform non-routine work, which can be defined as work not normally
performed by an employee during the normal course of job duties. Example of non-routine work could be, but not
limited to:
 
        • Floor stripping/coating
 
        • Building and structural repair
 
        • Maintenance activities during school shutdowns
 
        • Breaking and opening piping systems
 
         • Using internal combustion engines in enclosed areas
 
The following procedures will be used when employee performs non-routine work:
 
    A. The building principal will determine the need for non-routine work and the hazards associated with the work.
        The safety officer can provide assistance to determine the hazards involved.
 
    B. The immediate supervisor will train the employees performing the non-routine work of the hazards associated
        with the work and of procedures/permits to follow. The training should be given each time prior to employees
        performing non-routine work.
 
Contractors
When contractors are working on District property they must comply with all OSHA standards and requirements,
where applicable. The Hazard Communication Standard requires all contractors working on District property to be
informed by the safety officer concerning applicable workplace hazardous chemicals which the contractor’s
employees may be exposed to while performing their work and of appropriate protective measures. This information
is provided so contractor employers can properly train their employees. In addition, the contractor will inform the
safety officer about hazardous chemicals that the contractor brings onto District property so that precautions can
be taken.
 
Audit
 
The Hazard Communication Program will be audited at least annually. A report will be generated from the review
audit and sent to the building principal, the safety officer and the Superintendent. The building principal and safety
officer are responsible for following up to see that supervisors take corrective action concerning recommendations
resulting from the audit.
 
Hazardous Chemical Use in Science, Art and Technical Education Classrooms and Laboratories
 
A. The safety officer shall coordinate and maintain a list of chemicals approved for classroom and laboratory use
    within the District (the "Authorized Use List").
 
B. Before any new chemicals is used, it must be approved for instructional use and appear on this Authorized Use
    List.
 
C. Chemicals not on the Authorized Use List are prohibited from use. Students and staff members found using
    unauthorized chemicals shall be subject to disciplinary action.
 
Approved/Adopted:  July 13, 2009
ĉ
Shari Weinstock,
Aug 3, 2011, 12:03 PM