GENERAL MOTORS
MILFORD PROVING GROUND
HAZARDOUS MATERIAL CONTROL PROGRAM
This program was written in accordance with
OSHA 29 CFR 1910.1200 Hazard Communications
MIOSHA Parts 42, 92, 430 Hazard Communications
EPA 40 CFR 350-372 Emergency Planning and Community Right-to-Know Act
EPA 40 CFR Parts 700-799 Toxic Substances Control Act
EPA 40 CFR 150-189 Federal Insecticide, Fungicide, and Rodenticide Act
GM Hazardous Materials Control Program
UAW-GM Hazard Communication Program
16th Revision: August 2011
GENERAL MOTORS MILFORD
HAZARD MATERIAL CONTROL PROGRAM
TABLE OF CONTENTS
Section
PAGE
0.0 Foreword
1.0 Summary of Hazard Communication Standards
2.0 Program Requirements
3.0 Procedure For New Chemical Materials
4.0 Labels and Hazard Warning Requirements
5.0 Material Safety Data Sheets (MSDS)
6.0 Employee Training and Information Requirements
7.0 Chemical Material List
8.0 Safe Use Instructions (SUI)
9.0 Sign Posting Requirements
10.0 Special Requirements for Piping, Piping
Systems and Stationary Process Containers
11.0 Contractor/Construction/Events
12.0 Non-GM Tenant's
13.0 Long Term Service Contractors
14.0 Mobile Workshop Support Vehicles
ATTACHMENTS
Attachment A "Request for Approval to Purchase or Receive Chemical Material" form
Attachment B "Blank Label"
Attachment C "Completed Label"
Attachment D “HMCS Access Instructions”
Attachment E “New Chemical/Material Training Record”
Attachment F "MSDS(s) For This Workplace" sign.
Attachment G “New or Revised MSDS” sign.
Attachment H “Pipe Color Code Schedule”
Attachment I “Contractor/Construction/Events Chemical Material List" form
Attachment J “Non GM Tenants Chemical Material List” form
Attachment K “A-Card Deviation Procedure” and form
This procedure can be found online at Milford Proving Ground, Health & Safety Department., Local Safety Procedures, Hazard Communication Program. http://gmna1.gm.com/pgtl/safeoccu/procedur.htm
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0.0 FORWARD
It is recognized that every situation or circumstance that arises in the course of business, may not be included in the administration of this written program. Therefore, the Hazardous Materials Control Committee (HMCC) reserves the right to execute this policy, portions of the policy, or take independent actions that address the operating needs of the business, with due diligence given to the intention and spirit of the Chemical Risk Management program guidelines. Any disputes with the HMCC decisions should first be submitted, in writing, to the HMCC. The HMCC will attempt a resolution of the dispute. In the event the HMCC fails to resolve the dispute, the HMCC will direct the dispute to the appropriate leadership for further review.
1.0 SUMMARY of HAZARD COMMUNICATION STANDARDS
The purpose of the MIOSHA Hazard Communication Standard is to ensure that the hazards of all chemical materials produced or imported are evaluated and every employee who has the potential to be exposed to a hazardous chemical is informed about possible physical and health hazards of that chemical, and that all employees know how to safely handle hazardous chemicals. This plan has been prepared to meet those objectives and has been reviewed and approved by the Milford Proving Grounds (MPG) Director of Operations.
2.0 PROGRAM REQUIREMENTS
A key requirement of the Standard is that the Milford Proving Ground (MPG) will develop, implement, and maintain a Written Hazard Communication Program. The written Program describes how the requirements for labels and other forms of warning, Material Safety Data Sheets (MSDSs), and information and training for employees are going to be met at MPG operations. This Program includes a list of hazardous chemicals present, and information and training concerning their hazards and appropriate protective measures. In addition to the use of chemical materials in their normally assigned tasks, employees are to be informed of the hazards of non-routine tasks and the hazards associated with chemicals in containers and piping systems. Provisions are included in this Program for the roles and responsibilities of a multi-employer workplace.
3.0 PROCEDURE FOR NEW CHEMICAL MATERIALS
Before a chemical material can be introduced in a department, the HMCC must approve it. To obtain authorization, a "Request for Approval to Purchase or Receive a Chemical Material", (Attachment A), must be completed. In addition, trial, experimental, and developmental chemical material(s) must also be approved utilizing the same process. Even if a product is already in the Hazardous Material Control System (HMCS), or already approved for another department at MPG, the building/department has to request approval.
1. The form requires the signature of the supervisor and the building’s Safety Representative. To obtain the name of the Safety Representative, please contact the supervisor or MPG Health & Safety at 248.685.6269.
2. The requesting department must include the HMCS number or a GM compliant MSDS from the manufacturer. It is required that the MSDS must be less than three years old and identify 100% of the ingredients.
3. Submit the completed form(s) to MPG Environmental Services for inclusion in the HMCC meeting for chemical material request approvals. Request can be emailed to . A courtesy copy to the Building Safety Representative will be accepted as a signature.
The HMCC members will review the product usage request, MSDS, and other technical information.
Upon approval, the chemical material will be given a HMCS number and assigned a Safe Use Category. The Requester will receive the MSDS and authorization to obtain the chemical material. Future deviations (i.e., increases) to volumes, application, and frequency of use must be brought to the attention of the HMCC for approval.
In the event a material approval request is denied, the Requester will receive a written notice stating the reason(s) and the name of the person that rejected the request.
Chemical material means any element, chemical compound, or mixture of elements and/or compound that during use could be inhaled, ingested, absorbed, or altered. Any product intended to be altered or processed (e.g., cut, molded, grinded, heated) must be approved.
Chemical materials intended for use at the Milford Proving Ground cannot generally be purchased with an “A-Card because chemical materials purchased with an “A” card cannot be controlled, monitored, or tracked. The HMCC has to review all chemical materials to understand possible hazards for fire, health, and other physical dangers. The MPG Environmental Services has to know what chemicals are on site for Federal Regulation reporting. Deviations from this policy require a written request to the HMCC explaining the necessity or the justification of the purchase of materials with an A-card. Deviations may be granted on a case by case basis. (Attachment K)
Members of the HMCC include MPG Health & Safety, UAW Health & Safety, MPG Environmental Services, Security, MPG Health Services, WFG Utilities, and a Chemical Advisor.
The Requester and other technical advisors (i.e., for the Requester and/or the HMCC) are welcome to attend HMCC meetings. The Requester is not required to attend unless the HMCC Administrator requests his or her presence.
The HMCC has the right to remove previously approved chemical materials from service. Examples of when this might be necessary are when chemical materials are misused or used in an unauthorized manner, when chemicals become banned due to regulatory requirements, or when the chemical material is deemed to pose an unacceptable risk to human health or the environment.
Periodically, the HMCC will perform audits or inspections in work areas to verify compliance with this Program.
The HMCC reviews all chemical approval requests for the Toxic Substance Control Act (TSCA) compliance statements on the MSDS. If the MSDS does not contain a statement saying that all components are TSCA compliant, the MSDS is sent to the Tetra Tech MSDS Processing Center for review. The Tetra Tech MSDS Processing Center advises the HMCC if the product is TSCA compliant. If the product is compliant, the request is processed using the normal processing procedure. If it is not TSCA compliant, the HMCC cannot approve the product for use at the MPG.
When a MSDS states that a product is (Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) regulated, a copy of the product label must be provided to the HMCC chairperson. If a label is not available before the product arrives on site, as soon as it does come on site a label must be provided to HMCC. Examples of this would be biocides and insecticides. The HMCC must track these chemical materials for regulatory and audit purposes and follow up.
It is the responsibility of the department supervisors to ensure this procedure is followed. When special instructions are written on the signed (i.e., approved) material approval form, those instructions must be provided to the end-user(s). If a product requires a rush approval, contact the Building Safety Representative for assistance. If the Building Safety Representative is not available, call Brenda Korth (Hazardous Material Administrator / HMCC Co-chair) at 517.204.9002 or Gary Field (HMCC Co-chair) at 248.685.4073.
4.0 LABELS AND HAZARD WARNING REQUIRMENTS
All containers of chemical materials used in the workplace must be properly labeled. Existing manufacturer’s labels on containers meet these requirements and must not be removed or defaced. If manufacturer’s labels are removed or become defaced, re-label the container utilizing the procedure outlined below. Transferring chemical materials to secondary containers requires proper labeling of the containers. The following procedure outlines the correct method for proper labeling of secondary containers:
1. Prior to transferring the chemical material, determine the name of the product and the Safe Use
Category (SUC). This information is available on the HMCS system or the MPG Health & Safety web page.
2. Using the Safe Use Category (SUC) number, select the correct label by finding the corresponding SUC number located in the lower left corner of the label. Labels are available through the POU pull stations. Example: The SUC number “3” corresponds to a category titled “Solvents – Flashpoint: > 100F”. (See attachment “B”).
3. Once the correct label is obtained, write the product name and HMCS number on the label. Example: (see attachment “C”).
4. Apply the label to the container.
NOTE:
* Four different size labels are available.
* Labels are available through your POU pull station.
Supervisors shall ensure that containers of chemical materials used in the workplace are labeled, or tagged and marked legibly. Containers include, but are not limited to any bag, barrel, box, can, cylinder, drum, pipe and piping system, reaction vessel, storage tank and stationary process tank.
The identity of the chemical material written on the label shall match that of the Material Name in HMCS and the product name on the MSDS.
Portable containers used to transfer chemical materials from labeled containers need not be labeled if intended only for the immediate use by the employees performing the transfer and the chemical material is used in its entirety. However, MPG strongly recommends that labeling or other forms of identification be provided to these containers, keeping safety and “Best Management Practices” a priority. Any containers not in immediate use of the employee must be labeled.
5.0 MATERIAL SAFETY DATA SHEETS (MSDS)
The Hazardous Material Control System (HMCS) is the General Motors global system for accessing, evaluating, and communicating information about chemicals and their potential hazards. GM personnel can use HMCS to obtain available product data in order to safely manage chemicals for: material use, safe handling, regulatory reporting, and disposal. Milford has a common, non-expiring ID and password. There are several ways to access this data.
1) The Supervisor or Building Safety Representative may help.
2) Direct access to HMCS is available. See HMCS- Plant Floor Access Instructions. The site common ID, password, and link are included. (see attachment “D”)
3) The Master Chemical Material list and all the MSDSs can be accessed from the MPG Health & Safety web page. http://gmna1.gm.com/pgtl/safeoccu/index.htm
4) The building/ department/ can have a CD available for employees use.
5) Security is also available for assistance. They have access to both the HMCS system and a back- up copy of the CD in case the system is ever down.
Each building/department should decide which option is preferred and advise employees.
Any questions, problems, or suggestions for improvement should be directed to Brenda Korth, Phone 517.204.9002, Nextel 130*1*51158, or .
6.0 EMPLOYEE TRAINING AND INFORMATION REQUIREMENTS
Supervisors must ensure that effective information and training is provided to all employees who may be exposed to chemical materials in their work area at the time of the employees’ initial assignment, transfer, or whenever a new physical or health hazard the employees have not been previously trained on is introduced into the work area. Examples of these situations are as follows:
A newly hired employee must receive training on the MPG Hazardous Communication Program. This training is provided by the UAW-GM MPG Safety Training Department. Department supervisors can receive applications for this training by calling 248.676.1639 or by accessing the MPG Health & Safety Web page at http://gmna1.gm.com/pgtl/safeoccu/train.htm. As part of the above training, the employee will view Module 1 of the UAW-GM Hazard Communication Program. If the employee will need additional training on Modules 2 through 10, the department supervisor may arrange a review of these Modules by calling 248.676.1639 or 1620. Documentation of this training will be retained by the Safety Training Department. In addition, the supervisor must ensure that the employee is instructed as to the location of the Safe Use Instructions (SUI) and how to get a MSDS for the chemical materials he or she will use.
An employee transferred to the Milford Proving Ground from another GM facility must receive the same training as a new hire. (Exception: If the supervisor has documentation indicating the employee was previously trained on Hazard Communication Modules 1, then these requirements can be met by reviewing the MPG Hazard Communication Program with the employee.) . If the employee will need additional training on Modules 2 through 10, the department supervisor may arrange a review of these Modules by calling 248.676.1639 or 1620. Documentation of this training will be retained by the Safety Training Department. In addition, the supervisor must ensure that the employee is instructed as to the location of the Safe Use Instructions (SUI) and how to get a MSDS for the chemical materials he or she will use.
An employee is transferred from one department to another; the supervisor must ensure that the employee is trained on the safe use of the chemical materials used in that department. In addition, the employee must be instructed as to the location of the Safe Use Instructions (SUI) and how to get a MSDS for the chemical materials he or she will use.