Hazard Communication Program
WAC 296-800-170
Hazardous Chemical Communication Program
ESD 101 is committed to the prevention of exposures that result in injury and/or illness, and to comply with all applicable state health and safety rules. To make sure that all affected employees know about information concerning the dangers of all hazardous chemicals used by ESD 101 the following hazardous information program has been established.
All work units will participate in the hazard communication program. This written program will be available in our written Accident Prevention Program for review by any interested employee.
Container Labeling
The Safety Program Manager is responsible for container labeling procedures, reviewing, and updating. The procedures for proper labeling of all containers and reviewing and updating label warnings are as follows:
· Ensure that all chemicals received are properly labeled and contain an MSDS.
· Ensure that all chemicals transferred from one container to another are properly labeled.
It is the policy of ESD 101 that no container will be released for use until the above procedures are followed.
Material Safety Data Sheets (MSDS)
The Safety Program Manager is responsible for establishing and monitoring the employer's MSDS program. This person will make sure procedures are developed to obtain the necessary MSDSs and will review incoming MSDSs for new or significant health and safety information. This person will see that any new information is passed on to affected employees.
The procedures to obtain MSDSs and review incoming MSDSs for new or significant health and safety information are as follows:
Copies of MSDSs for all hazardous chemicals in use will be kept in the Safety Program Manager’s office.
MSDSs will be available to all employees during each work shift. If an MSDS is not available or a new chemical in use does not have an MSDS, immediately contact the Safety Program Manager.
Employee Information and Training
The Safety Program Manager is responsible for the employer/employee training program.
The procedures for how employees will be informed and trained will be established by the Safety Program Manager.
The Safety Program Manager will make sure that before starting work, each new employee of ESD 101 will attend a health and safety orientation that includes information and training on the following:
· An overview of the requirements contained in the Hazard Communication Standard.
· Hazardous chemicals present at his or her work places.
· Physical and health risks of the hazardous chemical.
· The symptoms of overexposure.
· How to determine the presence or release of hazardous chemicals in his or her work area.
· How to reduce or prevent exposure to hazardous chemicals through use of control procedures, work practices, and personal protective equipment.
· Steps the employer has taken to reduce or prevent exposure to hazardous chemicals.
· Procedures to follow if employees are overexposed to hazardous chemicals.
· How to read labels and review MSDSs to obtain hazard information.
· Location of the MSDS file and written hazard communication program.
Before introducing a new chemical hazard into any section of ESD 101, each employee in that section will be given information and training as outlined above for the new chemical.
Hazardous non-routine tasks
Examples of non-routine tasks include:
· confined space entry,
· tank cleaning, and
· painting reactor vessels.
No non-routine tasks will be performed by employees of ESD 101 without specific permission, training and personal protective equipment. Normally non-routine tasks will be assigned to a contractor.
Multi-employer work places
It is the responsibility of ESD 101 to provide employers of any other employees at the work site with the following information:
· Copies of MSDSs (or make them available at a central location) for any hazardous chemicals that the other employers’ employee may be exposed to while working.
· Inform other employers of any precautionary measures that need to be taken to protect employees during normal operating conditions or in foreseeable emergencies.
· Provide other employers with an explanation of the labeling system that is used at the work site.
It is also the responsibility of ESD 101 to identify and obtain MSDSs for the chemicals the contractor is bringing into the work place.
List of hazardous chemicals
Information on each chemical may be obtained by reviewing the chemical inventory and MSDSs located at the Safety Program Manager’s office.
OSHA clarifies “consumer product” exemption of Hazard Communication Standard.
In July of 2004, OSHA issued a Letter of Interpretation to address a situation regarding the Hazard Communication’s consumer product exemption. OSHA notes that their Letters of Interpretation apply only to the specific circumstances described, but the information provided can make employers think about similar situations in their facilities. The Letter includes the following:
“The consumer products exemption applies when a product is defined a “consumer product” by the Consumer Safety Act (15 U.S.C. 2051 et seq.), and “the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer or importer of the product and its use results in a duration and frequency of exposure which is not greater than the range of exposures that could reasonably be experienced by consumers when used for the purpose intended” (29 CFR 1910.1200(b)(6)(ix)). The term “consumer product” mean any article, or component part thereof, produced or distributed (i) for sale to a consumer for use in or around a permanent or temporary household or residence, a school, in recreation, or otherwise, or (ii) for the personal use, consumption, or enjoyment of a consumer in or around a permanent or temporary household or residence, a school, in recreation, or otherwise… (15 U.S.C. 2052).”
Question: ESD 101 only uses and stores small quantities of office chemicals such as white-out, adhesive, copier chemicals and cleaning agents. Are these covered by the Hazard Communication Standard (HCS)?
Response: OSHA considers office chemicals such as white out, cleaning chemicals, and copier chemicals to be exempt under the provisions of the rule, as consumer products. Consumer products, which are hazardous chemicals as defined by the HCS, fall under the provisions of the standard only when they are used with greater frequency or duration than a normal consumer, or for uses not intended by the manufacturer. For instance, OSHA has previously stated that intermittent or occasional use of a copying machine does not result in coverage under the rule. However, if an employee were hired to service the machine (such as for a copier repair position), then the HCS would be applicable.
ESD 101
Hazard Communication Checklist
1. Have we prepared a list of all the hazardous chemicals in ESD 101?
2. Are we prepared to update our hazardous chemical list?
3. Have we obtained or developed a material safety data sheet (MSDS) for each hazardous chemical we use?
4. Have we developed a system to ensure that all incoming hazardous chemicals are checked for proper labels and material safety data sheets?
5. Do we have procedures to ensure proper labeling or warning signs for containers that hold hazardous chemicals?
6. Are our employees aware of the specific information and training requirements of the WISHA Hazard Communication Standard?
7. Are our employees familiar with the different types of chemicals and the hazards associated with them?
8. Have our employees been informed of the hazards associated with performing non-routine tasks?
9. Do our employees understand how to detect the presence or release of hazardous chemicals in ESD 101 buildings?
10. Are employees trained about proper work practices and personal protective equipment in relation to the hazardous chemicals in their work areas?
11. Does our training program provide information on appropriate first aid, emergency procedures and the likely symptoms of overexposure?
12. Does our training program include an explanation of labels and warnings that are used in each work area?
13. Does the training describe where to obtain material safety data sheets (MSDS) and how employees may use them?
14. Have we worked out a system to ensure that new employees are trained before beginning work?
15. Have we developed a system to identify new hazardous chemicals before they are introduced into a work area?
16. Do we have a system for informing employees when we learn of new hazards associated with a chemical we use?
NIOSH Hazard Communication Checklist
1. Has a written hazard communication program been developed, implemented, and maintained at your worksite?
2. Has a list of known hazardous chemicals at your facility been prepared?
3. Have methods been developed to inform employees of the hazards of non-routine tasks?
Note: Such tasks may include emergency response or equipment repair.
4. Are methods developed for communicating hazards to outside contractors or vendors who may be exposed to hazardous chemicals at your worksite?
Labels
5. Are all containers of hazardous chemicals in the workplace labeled, tagged, or marked with the following information?
· The identity of the hazardous chemical(s)
· The appropriate warnings
· The name and address of the chemical manufacturer, importer, or other responsible party.
Note: Labels must be affixed to all containers of hazardous chemicals when they are shipped by a manufacturer or supplier. If the container is received without a hazard warning label, you must make a good faith effort to obtain the missing information from the manufacturer or supplier. The following hazardous chemicals are exempt from this labeling requirement, although subject to other labeling requirements: pesticides, foods, food additives, color additives, drugs, cosmetics, medical devices, alcoholic beverages, consumer products, hazardous waste, tobacco products, and wood products.
6. Is removal or defacing of labels on incoming containers of hazardous chemicals prohibited?
7. Are labels or other forms of warnings legible, in English, and prominently displayed?
Material Safety Data Sheets
8. Are material safety data sheets on hand for each hazardous chemical used and identified on the hazardous chemical?
9. If a hazardous chemical has no material safety data sheet, are attempts made to obtain one from the chemical manufacturer or importer as soon as possible?
10. Are material safety data sheets for the hazardous chemicals kept in the facility and made readily accessible to employees?
Information and Training
11. Is information and training on hazardous chemicals in the worksite provided on initial assignment and whenever new physical hazards or health hazards are introduced into the work area?
12. Does the information provided include the requirements of this standard, as well as the following?
· The operations at the worksite where hazardous chemicals are present
· The location and availability of the written hazard communication program, including the list of hazardous chemicals and material safety data sheets
13. Does the training provided include information about the following?
· Methods and observations that may be used to detect the presence or release of a hazardous chemicals in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc)
· The physical hazards and health hazards of the chemicals in the work area.
· The measures employees can take to protect themselves from these hazards, including procedures the employer has implemented to protect employees from exposures to hazardous chemicals (appropriate work practices, emergency procedures, and personal protective equipment).
· The details of the hazard communication program developed by the employer, including explanations of the labeling system, material safety data sheets, and how employees can obtain and use the appropriate hazard information.
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