HEALTH AND SAFETY PROGRAM HAZARD COMMUNICATION

Transcription

1 Document Number: HSP Reviewed By: B.Ayres Manager s Approval: Paul Barton Reviewed: 06/16/2014 Revision No. 9 Page 1 of PURPOSE HEALTH AND SAFETY PROGRAM HAZARD COMMUNICATION The purpose of this document is to meet the written program requirements of the OSHA Hazard Communication Regulation (29 CFR ). 2.0 SCOPE Axiall is dedicated to the safe production and use of chemicals. Employees are expected to perform their duties in a safe and conscientious manner and be knowledgeable of the chemical hazards in their work areas. Employee awareness and training on the subject of hazardous chemicals are accomplished through initial employee orientation, employee training, Safety Data Sheets and container labeling. 3.0 DEFINITIONS Article--A manufactured item: Which is formed to a specific shape or design during manufacture; Which has end use function(s) dependent in whole or in part upon its shape or design during end use; and Which does not release, or otherwise result in a hazardous chemical under normal conditions of use. Chemical--Any element, chemical compound, or mixture of elements and/or compounds. Chemical Name--The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation. Common Name--Any designation or identification such as code name, code number, trade name, brand name, or generic name used to identify a chemical other than by its chemical name. Container--Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, or the like that could contain a hazardous chemical. For purposes of this policy, pipes or piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers.

2 Designated Representative--Any individual or organization to which an employee gives written authorization to exercise such employee's rights under this policy. Distributor--A business, other than a chemical manufacturer or importer, which supplies hazardous chemicals to other distributors or to employers. Employee--A worker who may come in contact with hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers, such as office personnel, who encounter hazardous chemicals only in non-routine, isolated instances are not covered. Foreseeable Emergency--Any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace. Hazardous Chemical--A chemical for which there is statistically significant evidence, based on at least one study conducted in accordance with scientific principles, which establishes the potential for acute or chronic health effects. Hazard Statement - a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Health Hazard--Hazardous chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic systems, or agents which damage the lungs, skin, eyes, or mucous membranes. Hazard Warning--Any words, pictures, symbols, or combination thereof is appearing on a label or other appropriate form of warning which conveys the hazard(s) and target organ effects of the chemical(s) in the container(s). Identity--Any chemical or common name which is indicated on the safety data sheet (SDS) for the chemical. The identity used will permit cross-references to be made among the required list of hazardous chemicals, the label, and the SDS. Immediate Use--The hazardous chemical will be under the control of and used only by the employee who transfers it from a labeled container and only within the work shift during which the chemical is transferred. Label--Any written, printed, or graphic material displayed on or affixed to containers of hazardous chemicals. Label Elements the specified pictogram, hazard statement, signal word and precautionary statement for each hazard class and category. Physical Hazard--A chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water-reactive.

3 Pictogram A composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category. Precautionary Statement - A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling. Produce--To manufacture, process, formulate, or repackage. Product Identifier - the name or number used for a hazardous chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of hazardous chemicals required in the written hazard communication program, the label and the SDS. Safety Data Sheet (SDS)--Written or printed material concerning a hazardous chemical which is prepared in accordance with the SDS section of Axiall's, Plaquemine Complex, Hazard Communication Program. Signal Word - a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in this section are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for the less severe. Specific Chemical Identity--The chemical name, Chemical Abstracts Service (CAS) Registry Number, or any other information that reveals the precise chemical designation of the substance. Trade Secret--Any confidential formula, pattern, process, device, information, or compilation of information that is used in an employer's business, and that gives Axiall an opportunity to obtain an advantage over competitors who do not know or use it. Use--To package, handle, react, or transfer. Work Area--A room or defined space in a workplace where hazardous chemicals are produced, stored or used, and where employees are present. Workplace--An establishment, job site, or project, at one geographical location containing one or more work areas. 4.0 RESPONSIBILITIES 4.1 Health and Safety (H&S): Implement a Hazard Communication Program Provide Axiall employees, all contractor personnel and service personnel with information on hazardous chemicals in the work place.

4 4.1.2 Provide Axiall employees with training on the Hazard Communication Program and its elements at the time of assignment and periodically thereafter Maintain an up-to-date inventory and master copy of all SDSs for hazardous chemicals. Currently, a master copy is located in the EHS Department.. The master copy is updated quarterly. SDS s are maintained electronically through an online service, SiteHawk. The electronic SDSs are accessible via any computer console with Intranet access. The path is connect.axiall.com, Departments (dropdown), Environmental Health and Safety, and Safety Data Sheets (SDS) button. Selection of Plaquemine will provide the SDS s for this site Ensure that the Hazard Communication Program and SDSs are readily available, upon request, to employees, on-site contractors, their designated representatives, Assistant Secretary and Director, in accordance with Axiall's, Plaquemine Complex, Employee Workplace Monitoring and Medical Records Program Conduct a review of Axiall's, Plaquemine Complex, Hazard Communication Program at least annually Inventory and list all hazardous chemicals in the workplace using the identity referenced on the SDS. 4.2 Department Supervision: Learn, understand, and follow Axiall's Plaquemine Complex, Hazard Communication Program Provide employees with information and training on specific chemical hazards in their work area upon initial assignment and annually thereafter Provide training to employees as new hazardous chemicals or procedures are introduced into their work area Inform employees of the hazards of non-routine tasks and hazards associated with chemicals contained in unlabeled pipes in their work area Ensure that all containers of hazardous chemicals in their work area are properly labeled. (See definition of containers to determine which plant containers need labels) Confer with Product Stewardship or Industrial Hygiene on questions concerning specific container labeling data Each hazardous chemical container in the workplace will be labeled in accordance with Section 5.5 Container Labeling.

5 4.3 Employees: Learn, understand, and follow Axiall's, Plaquemine Complex, Hazard Communication Program Understand how to access SDSs in the Axiall s, Plaquemine Complex Be familiar with hazardous chemicals in the work area by reading the product's SDS Ensure that proper chemical identity and hazard warning are placed on containers when chemicals are transferred into them Report unlabeled chemical containers to Department Supervision Are required to label all portable containers into which hazardous chemicals are transferred from labeled containers Will ensure that existing labels on hazardous chemical containers are maintained and not removed or defaced Will ensure containers routinely used for transporting hazardous chemicals are labeled. 4.4 Contractors: Implement a Hazard Communication Program that meets all requirements of Axiall's, Plaquemine Complex, Hazard Communication Program Submit an Axiall Material Approval form and receive approval for any hazardous chemicals prior to being brought on site Report unlabeled chemical containers to Department Supervision. 4.5 Shipping / Purchasing / Stores: Ensure that each container of hazardous chemicals leaving the workplace is appropriately labeled as described in section 5.5 Container Labeling Provide chemical industry placards to truck drivers prior to the transportation of chemicals from the Axiall, Plaquemine Complex facility Container labeling will comply with the requirements of the Hazardous Materials Transportation Act (49 USC 1801) and regulations issued under that act by the Department of Transportation Labels will meet the requirements of any hazardous chemical regulated by OSHA in a substance-specific health standard (e.g., vinyl chloride).

6 4.5.5 Inadequately labeled incoming containers will be moved to a quarantine area in Stores until the proper label information can be obtained from the manufacturer or H&S Department. 5.0 PROCEDURE 5.1 Hazard Determination The hazard determination requirement of OSHA s Hazard Communication regulation is performance-oriented. Axiall is not required to follow any specific methods for determining hazards, but must be able to demonstrate that they have adequately ascertained the hazards of the chemicals produced or imported in accordance with the criteria set forth in this section. Axiall has two hazard determination procedures: (1.) Material Approval Process (2.) Product Hazard Determination. 5.2 Material Approval Process Material Approval requires the completion of the Axiall Material Approval Process located within SiteHawk. This must be completed and approved for each new material before it can be purchased or received by the Plaquemine facility or brought into the plant by contractors To determine if this form needs to be completed and approved, an Axiall employee needs to examine the list of materials located in SiteHawk. A hard copy of the material inventory can also be found with the master copy SDS Binders located in the H&S Dept. If the chemical is not listed within SiteHawk, this process must be completed Anyone who wants a new material brought into the plant must initiate the process by: a. Obtaining a recent (<3 years old) manufacturer s SDS for the material(s). b. Completion of the Material Approval information located within SiteHawk. 1. Accessing this Material Approval If you search for a material within SiteHawk and are not able to locate the material, click on Material Approval located on the left side of the screen beneath SDS Search. Complete the resulting form, especially those items with red asterisks. 2. SiteHawk will deliver this Material Approval to the Gatekeeper, and to the following departments for review and approval: Industrial Hygiene, Environmental, Product Stewardship, Utilities

7 and Purchasing. Purchasing should be the last department to receive the form before going back to the Gatekeeper. A chemical cannot be placed in the purchasing system until all required approvals have been attained Upon notification from SiteHawk through , the appropriate Material Approval Team members will: a. Assess the hazards and effects of the chemical on their given area, using the SDS along with any other appropriate reference materials. b. Record the assessment results by completing their portion of the form (if applicable). c. Approve or disapprove the chemical for plant use. d. After approval by the Material Approval Team, the gatekeeper and the originator are sent s confirming the approval of the material. The gatekeeper then submits a Service Request within SiteHawk to have the material added to the Plaquemine Inventory which allows availability of the new material to all requesters. e. Members of the Material Approval Team can deny the material access to the facility. The team member would contact the originator explaining the reason for the denial. 5.3 Hazard Determination for Axiall Products In order to meet the requirements of the OSHA Hazard Communication Regulation, the following criteria will be used in making hazard determinations for Axiall Products. (a) Carcinogenicity As described in Appendix A of this section, a determination by the National Toxicology Program, the International Agency for Research on Cancer, or OSHA that a chemical is a carcinogen or potential carcinogen will be considered conclusive evidence for purposes of this section. (b) Human Data Where available, epidemiological studies and case reports of adverse health effects will be considered in the evaluation. (c) Animal Data Human evidence of health effects in exposed populations is generally

8 not available for the majority of chemicals produced or used in the workplace. Therefore, the available results of toxicological testing in animal populations will be used to predict the health effects that may be experienced by exposed workers. In particular, the definitions of certain acute hazards refer to specific animal testing results (see Appendix A). (d) Adequacy and Reporting of Data The results of any studies, which are designed and conducted according to established scientific principles, and which report statistically significant conclusions regarding the health effects of a chemical, will be a sufficient basis for a hazard determination and reported on any SDS. Axiall may also report the results of other scientifically valid studies, which tend to refute the findings of hazard. (e) The hazard determination procedure involves at least examining these sources of reference for health and safety data relevant to Axiall s products and putting that information on the appropriate SDS. (1) Dangerous Properties of Industrial Materials, N. Irving Sax, most current. (2) Registry of Toxic Effects for Chemical Substances, NIOSH, most current CD-ROM. (3) Documentation of the TLVs and BEIs, ACGIH, most current. (4) 29 CFR 1910, Department of Labor, most current, web site. (5) Threshold Limit Values for Chemical Substances and Physical Agents, ACGIH, most current. (6) Annual Report on Carcinogens, U.S. Department of Health and Human Services, most current. (7) Federal Register, daily publication. (8) Casarett and Doull s Toxicology, McGraw Hill, most current. (9) Toxicology Desk Reference, Taylor and Francis, most current. (10) National Fire Code, NFPA, most current. (11) Guide to Occupational Exposure Values, ACGIH, most current. (12) IARC, World Health Organization, web site. (13) National Institute of Health s TOXNET website 5.4 Trade Secret Axiall may withhold the specific chemical identity, including the chemical name and other specific identification of hazardous chemicals, from the SDS provided that:

9 (1) The claim that information withheld is a trade secret can be supported; (2) Information concerning the properties and health effects of the hazardous chemicals are disclosed; (3) The SDS sheet indicates that the specific chemical identity is being withheld as a trade secret; and (4) The specific chemical identity is made available to health professionals, employees, and designated representatives in accordance with applicable provisions in the following section Axiall will immediately disclose the specific chemical identity of a hazardous chemical to a physician or nurse, where it has been determined that a medical emergency exists, regardless of the existence of a written statement or confidentiality agreement For non-emergency situations, Axiall will, upon request, disclose a specific chemical identity to a health professional providing medical or other occupational health services to an employee, or designated representative, if the request is in writing and: (1) The request describes with reasonable detail one or more of the following occupational health needs for the information: (a) (b) (c) (d) (e) (f) (g) To assess the hazards of chemicals with which employees are in contact; To conduct or assess sampling of the workplace; To conduct pre-assignment or periodic employee medical surveillance; To provide medical treatment to employees; To select or assess appropriate personal protective equipment; To design or assess engineering controls or other protective measures; and To conduct studies to determine the chemical's health effects; (2) The request explains in reasonable detail why the disclosure of specific chemical identity is essential and that the disclosure of the following information to the health professional, employee, or designated representative would not satisfy the purposes described: (a) Chemical class;

10 (b) (c) (d) (e) Properties and health effects of the chemical; Measures for controlling worker's exposure to the chemical; Method of monitoring and analyzing the workplace for the chemical; and Methods of diagnosing and treating harmful exposures to the chemical; (3) The request includes a description of the procedures to be used to maintain the confidentiality of the disclosed information; and (4) The health professional, employee, or designated representative agrees that the trade secret information will not be used for any purpose other than the health need(s) asserted and agree not to release the information under any circumstances If the health professional, employee, or designated representative receiving the trade secret information decides that there is a need to disclose the information to OSHA, Axiall will be informed prior to or at the same time as such a disclosure If Axiall denies a written request for non-emergency disclosure of a specific chemical identity, the denial must: (1) Be provided to the health professional, employee, or designated representative within 30 days of the request; (2) Be in writing; (3) Include evidence to support the claim that the specific chemical identity is a trade secret; (4) State the specific reasons why the request is being denied; and (5) Explain in detail how alternative information may satisfy the specific or occupational health need without revealing the specific chemical identity The health professional, employee, or designated representative whose request for information is denied may refer that request and the written denial of the request to OSHA for consideration. 5.5 Container Labeling Each hazardous chemical container leaving the workplace will be labeled, tagged, or marked with the following information:

11 a. Identity of hazardous chemical(s); b. Specific physical (see Appendix A) and/or health hazard warning; and c. Name and address of the Axiall Plaquemine Complex facility Each hazardous chemical container in the workplace will be labeled in English, tagged, or marked with the following information: a. Identity of hazardous chemical(s) contained therein; and b. Specific physical and/or health hazard warning Employees shall not remove or deface existing labels on incoming containers of hazardous chemicals, unless the container is immediately marked with the required information Employees are not required to label portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for the immediate use of the employee who performs the transfer. If the container is left unattended by the employee or not in his personal possession, it must have a proper label affixed In-plant container labeling is achieved through use of the National Fire Protection Association (NFPA) or Hazardous Material Identification Guide (HMIG) hazard material sign marking system. These two labeling systems are complementary and are presented in Appendix B In-plant labeling is the responsibility of the Department Manager Chemical identity labels are given to truck drivers, ship captains and barge captains prior to their transportation of chemicals from the facility Questions about the Plaquemine Complex s Hazard Communication Program s labeling requirements should be referred to the Axiall Product Stewardship Group OSHA s new labeling requirements, which are compliant with the Globally Harmonized System (GHS) must be implemented by June 1, The labeling requirements for shipped containers will be as follows: a. Product identifier; b. Signal word; c. Hazard statement(s); d. Pictogram(s); e. Precautionary statement(s); and, Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party. 5.6 Safety Data Sheets Safety Data Sheets (SDSs) for Axiall products are prepared by the Product Stewardship Group and are available to Axiall employees on the Company

12 Connect Site and on Customers, vendors and others my obtain a copy of the SDS at The SDSs shall be in English and currently shall contain at least the following information: (1) The identity used on the label. (2) If the hazardous chemical is a single substance, its chemical and common names. (3) If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common names of the ingredients which contribute to these known hazards and the common names of the mixture itself. If the chemical is a mixture which has not been tested as a whole, the chemical and common names of all the ingredients which have been determined to be health hazards and which comprise 1% or greater of the composition (except for chemicals identified as carcinogens which shall be listed if the concentrations are 0.1% or greater) and the chemical and common names of all the ingredients which have been determined to present a physical hazard when present in the mixture. (4) The physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point, etc.). (5) The physical hazards of the hazardous chemical, including the potential for fire, explosion and reactivity. (6) The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical. (7) The primary routes of entry. (8) The OSHA Permissible Exposure Limits, ACGIH Threshold Limit Values and any other exposure limit used or recommended by Axiall where available. (9) Whether the hazardous chemical is listed in the National Toxicology Program (NTP), Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest edition) or by OSHA. (10) Any generally applicable precautions for safe handling or use which are known to Axiall, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, procedures for clean-up of spills and leaks.

13 (11) Any generally applicable control measures which are known to Axiall such as appropriate engineering controls, work practices or personal protective equipment. (12) The date of preparation of the SDS or last change to it. (13) Axiall's name, address and telephone number OSHA s new Safety Data Sheet requirements, which are compliant with the Globally Harmonized System (GHS) must be implemented by June 1, The requirements for Safety Data Sheets per (g)(2) are that they be in English, and include at least the following section numbers and headings, and associated information under each heading, in the order listed: Section 1, Identification; Section 2, Hazard(s) identification; Section 3, Composition/information on ingredients; Section 4, First-aid measures; Section 5, Fire-fighting measures; Section 6, Accidental release measures; Section 7, Handling and storage; Section 8, Exposure controls/personal protection; Section 9, Physical and chemical properties; Section 10, Stability and reactivity; Section 11, Toxicological information; Section 12, Ecological information; Section 13, Disposal considerations; Section 14, Transport information; Section 15, Regulatory information; and Section 16, Other information, including date of preparation or last revision. Note: OSHA will not be enforcing information requirements in sections 12 through 15, as these areas are not under its jurisdiction.

14 5.7 Availability of Safety Data Sheets SDSs for all chemicals manufactured, stored or used at the Plaquemine Facility are made available to Axiall employees and contractors All Safety Data Sheets may be found within SiteHawk on the intranet. SiteHawk is located on the Environmental Health and Safety page within the Axiall Connect! site. Safety Data Sheets are available on the company web site at A master set of SDS books containing copies of all SDSs chemicals manufactured, stored or used at the Plaquemine Facility are maintained in the Health & Safety Department

15 6.0 TRAINING 6.1 The training objectives are conveyed to Axiall employees by the Unit/Area personnel and H&S Department periodically. Supervisor or designees are provided training materials and information by the Health & Safety Department. Training objectives shall include: Information concerning hazardous chemicals. Supervisors should review the Hazard Communication Program and become familiar with the training, container labeling and SDS requirements described therein. Employees are to be trained on the existence and location of operations in their work area where hazardous chemicals are present The location and availability of the Plaquemine Division written Hazard Communication Program including the required list of hazardous chemicals and SDSs The methods and observations that may be used to detect the presence or release of hazardous chemicals in the work area. Techniques described should include, but not necessarily be limited to the following: a. Monitoring by stationary vapor monitors or personnel dosimeters. b. Visual appearance of chemical vapors. c. Odor of hazardous chemicals upon their release to the work area. d. Operation of pressure relief devices. e. Release of chemical liquid to the work area The physical and health hazards of chemicals in the work area. SDSs are an acceptable reference although the discussion does not have to be limited to the data sheet Measures employees can take to protect against an identified chemical hazard. Techniques described should include, but not necessarily be limited to the following: a. Appropriate work practices designed to prevent release of hazardous chemicals into the work area. b. Proper use of escape respirators, negative pressure air purifying respirators, supplied air respirators, and self-contained breathing air equipment as applicable. c. Emergency procedures. d. Evacuation procedures.

16 7.0 RECORDS e. Methods of isolating hazardous chemical releases. f. Hazards of non-routine tasks such as: HSP 307 Line Breaking Policy - Operations and contract employees responsible for disassembling process piping and equipment with the potential for chemical splash or spray, will be informed of the Line Breaking policy by personnel in the plant in which they work. Chemical sampling operations - Operations personnel will be trained in the proper methods and precautions necessary for safe sampling operations by area supervision. Other such non-routine operations will be presented by area supervision (or designee) to employees that could be exposed. g. The Axiall Permit system will be used to inform employees of hazards associated with chemicals contained in unmarked pipes The details of the Hazard Communication Program including an explanation of the container labeling system, SDS and how employees can obtain and use the appropriate hazard information Aspects of the Plaquemine Facility s Material Approval Process Production Units will maintain employee Hazard Communication training records. 7.2 Contractors will maintain their own records and keep them on site for H&S review. 8.0 PROGRAM REVIEW 8.1 H&S will ensure that Axiall's, Plaquemine Complex, Hazard Communication Program is reviewed at least annually. The purpose is to assess compliance, ensure that all employees who should be included are, and to evaluate program effectiveness The review will evaluate: (1) The current Hazard Communication Program; (2) Employee training records; and (3) Employee awareness. 8.2 Following the review, the Hazard Communication Program will be revised to

17 include any necessary changes. 8.3 All employees will be informed of any changes made in the plan. 9.0 REFERENCES American National Standards Institute (2006). "Hazardous Industrial Chemicals Precautionary Labeling," ANSI Z New York, NY. American National Standards Institute (2004). "Hazardous Industrial Chemicals Safety Data Sheets - Preparation," ANSI Z New York, NY. Occupational Safety and Health Administration (2012). "Hazard Communication," 29 CFR APPENDICES Appendix A OSHA Health Hazard Definitions. Appendix B NFPA and HMIG Labeling Information

18 HSP 400 APPENDIX A OSHA Health Hazard Definitions There have been many attempts to categorize effects and to define them in various ways. Generally, the terms "acute" and "chronic" are used to delineate between effects on the basis of severity or duration. "Acute" effects usually occur rapidly as a result of short-term exposures, and are of short duration. "Chronic" effects generally occur as a result of long-term exposure, and are of long duration. The acute effects referred to most frequently are those defined by the American National Standards Institute (ANSI) standard for Precautionary Labeling of Hazardous Industrial Chemicals (Z ) - irritation, corrosive, sensitization, and lethal dose. Although these are important health effects, they do not adequately cover the considerable range of acute effects, which may occur as a result of occupational exposure, such as, for example, narcosis. Similarly, the term chronic effect is often used to describe only carcinogenicity, teratogenic, and mutagenic. These effects are obviously a concern in the workplace, but again, do not adequately describe the area of chronic effects, excluding, for example, blood dyscrasia (such as anemia), chronic bronchitis, and liver atrophy. The goal of defining precisely, in measurable terms, every possible health effect that may occur in the workplace as a result of chemical exposures cannot realistically be accomplished. This does not negate the need for employees to be informed of such effects and protected from them. Appendix B, which is also mandatory, outlines the principles and procedures of hazardous assessment. For purposes of this section, any chemicals which meet any of the following definitions, as determined by the criteria set forth in Appendix B are health hazards. 1. Carcinogen A chemical is considered to be a carcinogen if: (a) (b) (c) It has been evaluated by the International Agency for Research on Cancer (IARC), and found to be a carcinogen or potential carcinogen; It is listed as a carcinogen or potential carcinogen in the Annual Report on Carcinogens published by the National Toxicology Program (NTP) (latest edition); or It is regulated by OSHA as a carcinogen. 2. Corrosive

19 A chemical that causes visible destruction of, or irreversible alterations in, living tissue by chemical action at the site of contact. For example, a chemical is considered to be corrosive if, when tested on the intact skin of albino rabbits by the method described by the U.S. Department of Transportation in Appendix A to 49 CFR Part 173, it destroys or changes irreversibly the structure of the tissue at the site of contact following an exposure period of four hours. This term will not refer to action on inanimate surfaces. 3. Highly toxic A chemical falling within any of the following categories: (a) (b) (c) A chemical that has an LD50 of 50 milligrams or less per kilogram of body weight when administered orally to albino rats weighing between 200 and 300 grams each; A chemical that has an LD50 of 200 milligrams or less per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between 2 and 3 kilograms each; or A chemical that has a median lethal concentration (LC50) in air of 200 parts per million by volume or less of gas or vapor, or 2 milligrams per liter or less of mist, fume, or dust, when administered by continuous inhalation for 1 hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each. 4. Irritant A chemical, which is not corrosive, but which causes a reversible inflammatory effect on living tissue by chemical action at the site of contact. A chemical is a skin irritant if, when tested on the intact skin of albino rabbits by the methods of the Consumer Products Safety Commissions' (CPSC's) 16 CFR for four hours exposure or by other appropriate techniques, it results in an empirical score of five or more. A chemical is an eye irritant if so determined under the procedure listed in CSPC's 16 CFR or other appropriate techniques. 5. Sensitizer 6. Toxic A chemical that causes an allergic reaction in normal tissue after repeated contact with the chemical. A chemical falling within any of the following categories: (a) A chemical that has an LD50 of more than 50 milligrams per kilogram but not more than 500 milligrams per kilogram of body weight when administered

20 orally to albino rats weighing between 200 and 300 grams each; (b) (c) A chemical that has an LD50 of more than 200 milligrams per kilogram but not more than 1,000 milligrams per kilogram of body weight when administered by continuous contact for 24 hours (or less if death occurs within 24 hours) with the bare skin of albino rabbits weighing between 2 and 3 kilograms each; or A chemical that has an LC50 in air of more than 200 parts per million but not more than 2,000 parts per million by volume of gas or vapor, or more than 2 milligrams per liter but not more than 20 milligrams per liter of mist, fume, or dust, when administered by continuous inhalation for 1 hour (or less if death occurs within one hour) to albino rats weighing between 200 and 300 grams each. 7. Target organ effects The following is a target organ categorization of effects which may occur, including examples of signs and symptoms and chemicals which have been found to cause such effects. These examples are presented to illustrate the range and diversity of effects and hazards found in the workplace, and the broad scope employers must consider in this area, but are not intended to be all-inclusive: (a) (b) (c) (d) (e) (f) Hepatotoxins: Chemicals which produce liver damage Signs & Symptoms: Jaundice; liver enlargement Chemicals: Carbon tetrachloride; nitrosamine Nephrotoxins: Chemicals which produce kidney damage Signs & Symptoms: Edema; proteinuria Chemicals: Halogenated hydrocarbons; uranium Neurotoxins: Chemicals which produce their primary toxic effects on the nervous system Signs & Symptoms: Narcosis; behavioral changes; decrease in motor functions Chemicals: Mercury; carbon disulfide Agents which act on the blood or hematopoietic system: Decreased hemoglobin function; deprives the body tissues of oxygen Signs & Symptoms: Cyanosis; loss of consciousness Chemicals: Carbon monoxide; cyanides Agents which damage the lung: Chemicals which irritate or damage the pulmonary tissue Signs & Symptoms: Cough; tightness in chest; shortness of breath Chemicals: Silica; asbestos Reproductive toxins: Chemicals which affect the reproductive capabilities including chromosomal damage (mutations) and effects on fetuses

21 (teratogenesis) Signs & Symptoms: Birth defects; sterility Chemicals: Lead; DBCP (g) (h) Cutaneous hazards: Chemicals which affect the dermal layer of the body Signs & Symptoms: Defatting of the skin; rashes; irritation Chemicals: Ketones; chlorinated compounds Eye hazards: Chemicals which affect the eye or visual capacity Signs & Symptoms: Conjunctivitis; corneal damage Chemicals: Organic solvents; acids

22 Appendix B NFPA, HMIG and GHS Labeling Information Fire Hazards (Flash Points) 4- Below 73 F 3-73 F to 100 F or Below 73 F and Boils at 100 F 2- Above 100 F, Not Exceeding 200 F 1- Above 200 F 0- Will Not Burn Health Hazards Reactivity 4- Deadly 3- Extreme Danger 2- Hazardous 1- Slightly Hazardous 0- Normal Material Health Fire Reactivity 4- May Detonate 3- Shock and Heat May Detonate 2- Violent Chemical Change 1- Unstable if Heated 0- Stable Special NFPA Hazard Rating Specific Hazard Oxidizer- Acid- Alkali- Corrosive- Water Reactive- Ox Acid ALK COR W

23 HMIG Hazard Warning Label Health Hazard 4- Extreme: Highly Toxic, May be fatal on short term exposure. Special Protective Equipment required 3- Serious: Toxic, Avoid Inhalation or skin contact. 2- Moderate: Moderately Toxic, May be harmful if inhaled or absorbed. 1- Slight: Slightly Toxic, May cause slight irritation. 0- Minimal: All chemicals have some degree of toxicity. Flammability Hazard 4- Extreme: Extremely flammable gas or liquid, Flash point below 73 F 3- Serious: Flammable, Flash point 73 F to 100 F 2- Moderate: Combustible, Requires moderate heating to ignite, Flash point 100 F to 200 F 1- Slight: Slightly Combustible, Requires strong heating to ignite 0- Minimal: Will not burn under normal conditions HEALTH FLAMMABILITY REACTIVITY PERSONAL PROTECTION PROTECTION Reactivity 4- Extreme: Explosive at room temperature 3- Serious: May explode if shocked, heated under confinement or mixed with water 2- Moderate: Unstable, may react with water 1- Slight: May react if heated or mixed with water 0- Minimal: Normally stable, does not react with water Personal Protective Equipment A: Safety eyewear B: Safety eyewear, Gloves C: Safety eyewear, Gloves, Apron D: Eye and face protection, Gloves, Apron E: Safety eyewear, Gloves, Dust/mist respirator F: Safety eyewear, Gloves, Apron, Dust/mist respirator G: Safety eyewear, Gloves, Vapor Respirator H: Safety eyewear, Gloves, Apron, Vapor respirator I: Safety eyewear, gloves, Dust and vapor respirator J: Safety eyewear, Gloves, Apron, Dust and vapor respirator K: Supplied air respirator, Gloves, Full suit, Boots X: Ask your supervisor for special handling instructions

24 GHS Compliant Label