Hazard Communication Guide for Printing Operations

Version 2.0

SAMPLE GENERAL HAZARD COMMUNICATION CHECKLIST

Disclaimer

This is a sample checklist provided only as a tool to assist in complying with 29 CFR 1910.1200, OSHA's Hazard Communications Standard. It is not intended to supersede the requirements detailed in the standards. You need to review the standard for particular requirements which are applicable to your specific situation. Employers may need to delete or add information relevant to your particular facility and operation in order to develop an effective, comprehensive hazard communication plan.

Although every effort has been made to provide accurate information within this program, the authors, organizations, and individuals that assisted in its development make no representation or warranty, express or implied, as to the completeness, correctness, or utility of the information and related materials.

The printer should not rely exclusively on this program to address specific questions that apply to a particular set of facts or circumstances. Business practices and operations can vary significantly. Suggested practices in this program and related materials should only be considered to be potential options for achieving improved performance and should not be considered to be the only means to reduce or eliminate exposures to hazardous chemicals. Your particular facility may have unique or additional concerns based upon processes, practices, and materials.

It is assumed and intended that users of this material will exercise appropriate personal judgment and responsibility when utilizing or applying potential hazard abatement procedures and practices. The authors will not be held responsible for any misuse or incorrect use of the suggested procedures or practices depicted.

SAMPLE GENERAL HAZARD COMMUNICATION CHECKLIST

Note: This checklist providesonly a general guidance tool for common application of the Hazard Communication standard, but does not cover all types of operations or non-routine tasks that can be found in printing facilities. This checklist can be adopted, modified, or expanded as needed. Printers should conduct a site-specific hazard analysis to identify additional hazardous chemicals or non-routine tasks in order to help ensure OSHA compliance. Use of this or other checklists does notconstitute compliance with OSHA regulations.

Company Name: ______Date Performed: ______

Performed By: ______

Written Program

Has a written program been developed to meet the Hazard Communication Standard Requirements?

Does the written program include the following elements?

Description of how the requirements for labeling, other forms of warning, safety data sheets, and employee information and training will be met.

An inventory of hazardous substances used in your workplace.

Procedures for informing employees of non-routine tasks and hazards associated with chemicals contained in unlabeled pipes.

Procedures to be used for informing outside contractors of hazards.

Chemical Inventory

Is there a procedure for updating the chemical inventory when new products are received?

Is there a procedure for ensuring that each product on the inventory has a corresponding SDS?

Container Labeling

Are there procedures in place to ensure all containers of hazardous substances are properly labeled?

Is there a responsible person identified for labeling containers?

Is each incoming container for a hazardous substance (i.e., drums, bottles, storage tanks, etc.) properly labeled?

Is each in-plant container for a hazardous substance properly labeled or identified with an alternative labeling approach that conforms to the regulation?

Has a warning system or labels been established for pipes and piping containing hazardous chemicals?

Safety Data Sheets (SDS)

Is there a collection of Safety Data Sheets (SDS) readily available for each hazardous substance used?

Has a person(s) been identified to be responsible for obtaining/maintaining SDSs?

Is there a system in place for reviewing incoming SDSs?

Has a system been established for maintaining active and obsolete SDS’s (obsolete SDSs must be kept for 30 years)?

Has a system been established for employee to access/obtain SDSs?

Has a procedure been established when an SDS is not received in an initial shipment?

Has a procedure been established for providing notice of existence of updated SDSs?

Employee Training

Has a Hazard Communication training program been established for the company?

 Has a competent person(s) been identified who is responsible for conducting training?

Does the training program cover the required elements of the Standard, including:

Scope and purpose of the Hazard Communication Standard

Details of the written program

Hazardous properties of all chemicals present and worked with

Safe handling procedures and measures to take for personal protection

How to read and identify labels on hazardous substance containers

How to locate and read Safety Data Sheets (SDS)

Physical and health hazards of chemicals used

Means to detect the presence or release of hazardous substances

Appropriate personal protective equipment, its location, and how to use it

Is training documented each time it is conducted, showing which employees attended?

Is training conducted for new employees prior to starting job responsibilities?

Is training conducted for employees exposed to a newly identified hazard within 6 months of discovery?

Is training conducted for employees changing job assignments that are exposed to new hazards, prior to beginning their new job responsibilities?

Recommended Tasks for Maintaining a compliant and effective HCS Program

Is the written program reviewed annually?

Are the chemical inventory and SDS collection reviewed annually?

Are period inspections of labels and program procedures conducted by a competent employee?

Is the inspection designed to correct deviations or inadequacies related to program procedures?

Are program reviews and procedure inspections documented?