HAZARD COMMUNICATION PROGRAM

HAZARD COMMUNICATION PROGRAM March 2018

Hazard Communication Program TABLE OF CONTENTS Introduction...3 I. Responsibilities College-wide...4 Department...6 II. Compliance Requirements Chemical Product Purchase...9 Receiving Chemical Products...10 Chemical Product Container Labels...11 Transferring Chemical Products from Manufacturer s Containers...11 Transporting Chemical Products on Campus...11 Damaged or Leaking Containers or Containers of Unknown Chemical Products...12 Annual College Chemical Product Inventory... 12 Employee Information and Training...12 III. Notices College Employees...13 Contractors...13 IV. Definitions...16 Appendix 1: Material Safety Data Sheet (MSDS) / Safety Data Sheet (SDS) Forms and Requirements.........18 Appendix 2: Exhibit 1: OSHA BRIEF- Hazard Communication Standard: Labels and Pictograms.........20 Appendix 2: Exhibit 2: Examples of In-House Labels...29 2

Introduction The Hazard Communication Program describes the College s requirements for the purchasing of chemical products and the communicating of information about the potential dangers of hazardous chemicals to employees and students who may work with or near these chemicals. This program also establishes requirements to assure that College personnel recognize and appropriately address chemical hazards. This program applies to any chemical products present in employee workplaces that are used in such a manner that employees or students may be exposed to them under normal conditions of use or, to the extent it may be foreseeable, in an emergency. FIT s program may exceed the requirements of the Public Employees Safety and Health Bureau (PESH)* as well as the Occupational Safety and Health Administration (OSHA) standards in areas in which the College has determined that additional protective measures are in the best interest of the employees and students. The College s policy is to comply with the OSHA and PESH regulations that pertain to the Hazard Communication Standard. The purpose of this program is to protect students, faculty, staff and visitors (including contractors) from the potential adverse effects of toxic or hazardous chemicals used or present on College campus. This program applies to the purchase, use, or storage on campus of all chemical products regulated as toxic or hazardous chemicals by the federal OSHA or the New York City Department of Environmental Protection (NYCDEP). This program also applies to the purchase, use, or storage of all other chemical products on campus, even if not regulated by OSHA or NYCDEP. This program applies to all faculty, staff, students, and visitors (including contractors) at the College as well as all College premises including college buildings, facilities and residence halls. Questions about this critically important program should be directed to the Director of Environmental, Health & Safety Compliance at (212) 217-3752. * The Definitions section at the end of this Program provides definitions for acronyms and capitalized terms as they are used in the Program. 3

I. RESPONSIBILITIES COLLEGE-WIDE Vice-Presidents Designate employees who are responsible for ensuring compliance with federal, state, and local regulations, and this FIT Hazard Communication Program. Facilities Management Facilitate the exchange of MSDS/SDS information about chemicals between FIT departments and contractors working in the department area prior to the start of work on the FIT campus. Designate a Trained Haz Com Employee to supervise any contractor working on the FIT campus. Verify information supplied by contractors prior to the start of work on the FIT campus. Retain the contractor s list of hazardous chemicals and MSDS/SDS sheets during the construction period and after construction is complete. Human Resources Maintain records of employee training for 30 years from the date of training. Maintain records about incidents that involve uncontrolled spills or releases, including exposure to hazardous chemicals and retain reports of employee exposure to a hazardous chemical for 30 years. Purchasing Confirm that MSDS/SDS sheets, as approved by EHS, are obtained and are on file with EHS for all chemical product orders and contracts prior to purchase. Inform contractors about FIT s Hazard Communication Program. Require contractors who intend to work with chemical products on campus to submit a completed copy of contractor s Hazard Communication Plan prior to any work at FIT. Public Safety FIT Public Safety Department receives reports from students, faculty, staff, and visitors about uncontrolled spills, releases, or chemical exposures to chemical products on campus, including 4

reports about unlabeled or unidentified containers or packages that may contain chemical products. The Public Safety Department will: Record and respond as appropriate to reports of uncontrolled spills or releases to chemical products, or chemical exposures, and prepare written incident reports. Report in writing to EHS, the Vice President for Finance and Administration and other appropriate administrators any uncontrolled spills or releases of chemical products, or chemical exposures, on campus. Attend supervisory training in Hazardous Waste Operations and Emergency Response/(HAZWOPER), including annual updates. Attend FIT Fire Extinguisher training as needed. Office of Environmental, Health and Safety Compliance (EHS) Ensure that programs and procedures meet all regulatory requirements as part of a formal annual program review. Develop, review and assist with training of FIT employees as required by OSHA/PESH. Provide advice and counsel to FIT employees about OSHA/PESH Hazard Communication Standard and FIT s Hazard Communication Program. Identify toxic and hazardous chemicals regulated by OSHA and NYCDEP which are used, or proposed for use, on the FIT campus. Approve the use prior to purchase by FIT of chemical products containing hazardous chemicals regulated by OSHA and NYCDEP. Serve as FIT s primary point of contact with regulatory agencies such as OSHA/PESH in matters that concern compliance with Hazard Communication requirements. Respond to reports of spills of hazardous chemicals, including suspected student and employee exposures to hazardous chemicals, and prepare written reports as needed. Respond to reports of suspected environmental, health and safety issues that may not meet OSHA/PESH Communication Standard, and prepare written reports as needed. Maintain a college-wide online MSDS/SDS database of chemical products approved for use on campus. Collect annual inventory information from departments and compile for submission of reports to regulatory agencies. 5

Students, faculty, staff and visitors (including contractors) Follow the College s Hazard Communication Program. This includes use of appropriate chemical handling procedures and personal protective equipment and follow manufacturer instructions for chemical use. DEPARTMENT Deans and Directors Deans and Directors either maintain responsibility or designate Department Chairs and Department Heads, to ensure that Designated Trained Haz Com Employees supervise the purchase, use, or storage of chemical products on campus in compliance with FIT s Hazard Communication Program. Deans and Directors also receive reports from the EHS department about compliance with this Program and are responsible to take appropriate administrative and disciplinary action in cases of non- compliance. Department Chairs and Department Heads Administer the department s compliance with this Program. Designate one or more Trained Haz Com Employees for the departments who will act as program coordinators for each department s Functional Facility that purchases, uses, or stores hazardous chemicals. Ensure that department designated employees are scheduled for required annual training by or through EHS. Ensure the maintenance of lists of hazardous chemicals to which employees or students may be exposed at the department s workplaces or Functional Facilities. Ensure that MSDS/SDS sheets are obtained from suppliers and manufacturers before purchase of chemical products for use on campus. Ensure the submission to EHS for approval of lists of chemicals and their intended use prior to purchase. Prohibit use of chemical products containing hazardous chemicals in the Department s Functional Facilities unless EHS has approved usage and the MSDS/SDS sheets for each chemical submitted to EHS. Provide employees on all shifts with access to MSDS/SDS sheets for hazardous chemicals to which they are or may be exposed at their workplace. Ensure that students have access to MSDS/SDS sheets for chemicals used in the department s Functional Facility. 6

Report misuse of chemical products or suspected employee or student exposure to hazardous chemicals to FIT Security and EHS. Ensure that containers of hazardous chemicals used by the department are properly labeled. Provide contractors working for the College with MSDS/SDS information about hazardous chemicals to which the contractor's employees may be exposed. Inform EHS and administrators as appropriate about proposed work that may result in either detectable levels of chemical odors, fumes, dust, or smoke in areas occupied by students or employees. Provide information as requested by EHS about hazardous chemicals used in department Functional Facility, as required for compliance with state and local government emergency response procedures. Designated Trained Haz Com Employee: Maintain a copy of this Program in each FIT Functional Facility that uses hazardous chemicals. Work with students, faculty, staff, and visitors, and EHS to implement this program. Attend Hazard Communication Program training, including annual updates and department-specific training. Evaluate hazards associated with any chemical product that EHS has not previously approved. Submit MSDS/SDS sheets to EHS for review and approval before purchasing new chemical products for use on campus. Ensure that MSDS/SDS sheets are on file with EHS and that EHS has approved use of the chemical product for chemical products that are routinely used on campus, before submitting a Purchase Requisition to obtain additional quantities of the product. Ensure that manufacturer and College guidelines are followed when chemical products are used in an area for which the Designated Trained Haz Com Employee has responsibility. Maintain one or more binders, as appropriate, of MSDS/SDS sheets for all chemical products a department may use in each Functional Facility. 7

Report misuse of chemical products or other violation of this Program to Department Chair or Department Head. Report uncontrolled spills or releases of chemicals or any suspected employee or student exposure to hazardous chemicals to FIT Security and Department Chair or Department Head. 8

II. COMPLIANCE REQUIREMENTS CHEMICAL PRODUCT PURCHASE Department Chair or Department Head The Department Chair or Department Head will assure that any purchase agreement for chemical products complies with this Program to ensure MSDS/SDS are on file for all chemical products to be used or present in classrooms, laboratories, studios, store rooms and workplaces on campus. The Department Chair or Department Head will request that department Trained Haz Com Employees comprehensively review ongoing and anticipated work and classroom practices that require chemical product use prior to the beginning of each semester in preparation for purchase of chemical products. The Department Chair or Department Head will ensure that legible MSDS/SDS sheets are obtained from manufacturers or suppliers of chemical products (whether OSHA regulated or not) and that these MSDS/SDS sheets along with a description of the chemical s intended use are to be submitted to EHS for review and approval prior to submitting a purchase requisition to the Purchasing Department. The Department Chair or Department Head will ensure that either a Designated Trained Haz Com Employee or a Trained Haz Com Employee maintain binders of MSDS/SDS sheets as follows: EHS approved MSDS/SDS sheets must be contained in one or more binders marked Material Safety Data Sheets or Safety Data Sheets and must be located in each department s Functional Facility that uses regulated hazardous chemicals and chemical products deemed necessary by FIT. Tabular dividers in each binder shall show all chemical products actively in use or stored at a department s Functional Facility listed according to use category (see Table 1) including all chemical products that the department s Trained Haz Com Employee determine may be found at the Functional Facility of during anticipated work. Each Department Chair or Department Head shall ensure that the use of chemical products by department faculty and staff on campus is compatible with manufacturer instructions. The College does not allow, and department administrators, faculty and staff shall not give permission for students to purchase or use chemical products on campus at any time unless EHS approved MSDS/SDS sheets and approved department use are available in EHS central file and Trained Haz Com Employees have provided students with instruction to identify the hazards associated with the use of the chemical product that contains hazardous chemicals. 9

All department administrators, faculty, and staff will take appropriate and immediate action to stop the purchase or continued use of any chemical products on campus for which there is no EHS approved MSDS/SDS sheet and approved use in EHS central file. EHS EHS will review lists of chemical products used or those proposed for use on FIT campus to identify OSHA and NYCDEP regulated toxic and hazardous chemicals. EHS will review and approve the use of all chemical products with OSHA and NYCDEP regulated hazardous chemicals. EHS will also review and approve those chemical products deemed necessary by FIT and their department specific use prior to the submission of a purchase requisition by the department. RECEIVING CHEMICAL PRODUCTS The Department Chair or Department Head will assign a Designated Trained Haz Com Employee to be responsible for receiving shipments of chemical products. The Department Chair or Department Head will require that the Designated Trained Haz Com Employee follows the procedures to ensure that all containers of hazardous chemicals are labeled as required by OSHA. The department Designated Trained Haz Com Employee must receive and inspect shipments of chemical products before the Receiving Department delivers any chemical product to a FIT classroom, laboratory, studio, or workplace on campus. The department s Designated Trained Haz Com Employee shall: Inspect each container of hazardous chemicals in the shipment to make sure that there is no damage or leakage and that the container is labeled, tagged, or marked with all of the following information: The identity of the hazardous chemical; Appropriate hazard warnings; and The name and address of the manufacturer. Compare the packing slip to the purchase requisition to verify that the correct chemical products were shipped. Compare the EHS approved MSDS/SDS sheet with the product label and confirm that the chemical contents of the shipped product are the same as indicated on the approved MSDS/SDS sheet. The Designated Trained Haz Com Employee responsible for receiving shipments of chemicals will take one of the alternative actions outlined in Appendix 2, Exhibit 2 when containers in a 10

shipment of hazardous chemicals are delivered without labels containing the information required by OSHA CHEMICAL PRODUCT CONTAINER LABELS The labeling requirements of the OSHA HAZARD COMMUNICATION STANDARD ensure that the identity of hazardous chemicals and hazard warnings are available to employees in the workplace. Labels provide an immediate source of information to employees and shall be maintained as required by OSHA on both manufacturers and in-house containers of hazardous chemicals. OSHA requires manufacturers or suppliers of hazardous chemicals to label, tag, or mark (in English) each container. If a manufacturer's label is removed from a container or if the information on the label cannot be read, the department s Designated Trained Haz Com Employee shall affix an in-house label to the container. The Designated Trained Haz Com Employee shall report to the Department Chair or Department Heads any instances of unlabeled chemical products or instances where the chemical product s ingredients listed on the product label are not comparable to EHS approved MSDS/SDS. TRANSFERRING CHEMICAL PRODUCTS FROM MANUFACTURER S CONTAINERS Whenever a hazardous chemical is transferred from a manufacturer's container to an in-house container, or when a manufacturer's label on a container has been removed or defaced, the Designated Trained Haz Com Employee or the Trained Haz Com Employee supervising chemical use must apply an in-house label to the new container. The only exception to the OSHA container-labeling requirement is when the material transfer is for the immediate use (that is, used on that shift) of the employee who performs the transfer. TRANSPORTING CHEMICAL PRODUCTS ON CAMPUS A Designated Trained Haz Com Employee from the Receiving Department will transport the chemical products received from the supplier from the Receiving Department to the department who ordered the chemicals. The department s Designated Trained Haz Com Employee can only receive the chemical products. The department s Designated Trained Haz Com Employee will transport or supervise the transport of chemical products to an FIT classroom, laboratory, studio and workplace on campus only after confirming that a chemical product is properly labeled and not leaking. The Designated Trained Haz Com Employee will insure that the chemical product is properly secured and stored in a properly labeled and approved storage area in the department s Functional Facility. 11

DAMAGED OR LEAKING CONTAINERS OR CONTAINERS OF UNKNOWN CHEMICAL PRODUCTS Students, faculty, staff, and visitors (including contractors) who discover damaged, leaking, uncontrolled spills or containers of unknown chemical products (that is, unlabeled containers) shall take appropriate actions as outlined on FIT Crisis Management and Disaster Preparedness Plan. At a minimum, this requires that the student, employee, or visitors (including contractors) that discover this condition must immediately report the condition to FIT Public Safety and stand-by at a safe distance to warn others about the condition until FIT Public Safety arrive. ANNUAL COLLEGE CHEMICAL PRODUCT INVENTORY On an annual basis, EHS will initiate an annual college wide chemical product inventory in March or April which will include any chemical with ingredients that OSHA or NYCDEP lists as a toxic or hazardous substance or any chemical product that FIT will use or store on the FIT campus. EMPLOYEE INFORMATION AND TRAINING Any FIT employee who either works directly with hazardous (or potentially hazardous) chemicals, orders such chemicals, or manages/supervises someone who works with, or orders, these chemicals is required to take the training described below. This includes faculty who teach classes involving the use of hazardous chemicals. As such, it is mandatory both training protocols listed below are completed. 1. Online Hazardous communication training (must only be completed once) 2. In-person Safety Training provided by the FIT Director of Environmental Health & Safety (must be completed annually- you will be contacted in the fall semester) In addition to being a critical safety measure, protecting both employees and students, this training is required for FIT s compliance with both federal and state law. 12

III. NOTICES COLLEGE EMPLOYEES You Have a Right to Know Posting - EHS will ensure that each Department Chair or Department Head receives the New York State Department of Health You Have a Right to Know Poster (Form 2706, 4-00). The Department Chair or Department Head will ensure that the poster is posted conspicuously on campus. Departments may post additional copies of the poster as needed to inform employees. EHS will make a copy of the required posting available on-line. Job Safety and Health Protection Posting - EHS will ensure that the New York State Department of Health Job Safety and Health Protection Poster (Form SH 908 (1-04)) is posted conspicuously on campus. Table 3 identifies the locations on- campus where the postings will occur. A Department Chair or Department head may request additional copies of the poster as needed to inform employees from EHS. EHS will make a copy of the required posting available on-line. CONTRACTORS When a contractor is working on campus, the contractor must exchange information about the types of chemical products the contractor is using on campus. This includes an exchange of information between FIT and the contractor who is working on campus, or between other contractors who are working on campus. The Purchasing Department will require that a contractor provide information, including: A copy of the contractor s written Hazard Communication Program that OSHA requires. The contractor s Hazard Communication Program shall be equal in scope to the FIT program and shall include at least: The methods that FIT and contractors will use to provide each other with copies of or access to MSDS/SDS sheets for hazardous chemicals to which (the other) employees may be exposed; List of names of chemical products that a contractor intends to use on campus, including the anticipated amount of each chemical product a contractor proposes to have on campus, proposed storage locations, and copies of MSDS/SDS sheets for all products that contain hazardous chemicals that the contractor will have on campus; Written request for the name of the contractor s OSHA Competent Person for Hazard Communication Program Compliance who will supervise and be present on campus during work that involves chemical use; 13

Methods that the contractor s OSHA Competent Person and the Facilities Management Department Designated Trained Haz Com Employee will use to inform each other of any precautionary measures that need to be taken to protect the other employees during normal operations at the common workplace or in a foreseeable emergency; and Methods that the contractor s OSHA Competent Person and the Facilities Management Department Designated Trained Haz Com Employee will use to inform each other of labeling systems on containers of hazardous chemicals used at or introduced to the workplace by the other employer. Information to Contractors The Purchasing Department will provide contractors with information about FIT Hazard Communication Program requirements as part of all: Invitations to bid (general requirements) Purchase Orders Awards to contractors As specific information before contractor work begins at FIT work locations Invitations to Bid The Purchasing Department shall request in all Invitations to Bid that contractors provide FIT with the hazardous chemical information required by OSHA before granting final approval for contract work. Purchasing shall forward the hazardous chemical information to EHS for review and approval as needed. Purchase Orders The Purchasing Department will state in an addendum to a purchase order for the services of a contractor that all chemicals the contractor proposes to use on the FIT campus must be approved in advance for use by EHS and that all MSDS/SDS sheets for those chemicals must be submitted to EHS by the contractor seven days prior to the start of work at FIT. Contractor Work at College Locations The Facilities Management Department will: Designate a Designated Trained Haz Com Employee to supervise contractor work. Verify that the information described in this procedure has been obtained from the contractor prior to the start of work on campus. This information will include a list of names of chemical products that the contractor intends to use on campus, the anticipated 14

amount of each chemical product the contractor proposes to have on campus, proposed storage locations, and MSDS/SDS sheets for all products that contain hazardous chemicals that the contractor will have on campus during contractor work. Ensure that FIT departments and the contractor exchange information about chemical products, including hazardous chemicals information that are both used on campus and are proposed for use on campus in the specified work area before contract work begins; Provide the contractor with specific information about hazardous chemicals that FIT uses in the campus areas where the contractor's employees may be working and may be exposed under normal operating conditions, or in a foreseeable emergency; Provide written information to any FIT Department Chair or Department Head who supervises FIT employees in areas where chemical product a contractor will use in employee work areas to which the FIT employees may be exposed before work begins. In most case this notice should be made at least 48 hours before work will begin. In case of emergency work this written notice must take place on the day or the next business day following the emergency; and Retain the contractor s lists of hazardous chemicals and MSDS/SDS sheets at either the work location or any other approved location for the duration of the contractor's work. The contractor s Designated Haz Com Employee will: Verify that EHS has reviewed the list of names and amounts of chemical products that the contractor intends to use on campus, and MSDS/SDS sheets, and approved each chemical s use on campus, prior to the start of work on campus. 15

IV. DEFINITIONS Chemical Exposure: Actual or suspected inhalation, skin contact, ingestion, or injection of concentrations of hazardous chemicals that can occur as liquids, gases, vapors, or fumes and that exceed either OSHA, American Conference of Governmental Industrial Hygienists (ACGIH), or College exposure guidelines. Chemical Product: Chemicals and commercial products include, but are not limited to, reagents, dyes, buffers, preservatives, solvents, filtering and absorption media, cleaning agents, disinfectants, detergents, indicators, aerosols, metals, adhesives, drying agents, herbicides, and pesticides. This includes commercial products purchased from local retailers. Designated Trained Haz Com Employee: An FIT employee who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous or dangerous to employees, and who has departmental authorization to take prompt corrective measures to eliminate them. A Designated Trained Haz Com Employee shall attend FIT s basic and classroom-based training in OSHA/PESH Compliance, including annual updates, as well as department specific training annual updates. Functional Facility: The FIT location that stores and uses regulated chemical products that contain hazardous chemicals (other than consumer products and that are used as would a normal consumer), or stores more than 10,000 pounds of any chemical product. Examples include, but are not limited to, classrooms, labs, studios, or storage rooms. Hazardous Chemical: Any chemical that OSHA or NYCDEP list as a toxic or hazardous substance. Label: Any written, printed, or graphic material displayed on or affixed to containers of hazardous chemicals. Material Safety Data Sheet / Safety Data Sheet (MSDS/SDS): A written or printed document supplied by the manufacturer of a hazardous chemical which presents physical and chemical properties, identifies hazards and methods for controlling the exposures, and presents recommendations for use and handling, including the use of personal protective equipment (PPE) and guidance for cleanup of spills. Appendix 1 to this Program provides a detailed review of a MSDS/SDS sheet. New York City of Department of Environmental Protection (NYCDEP): The NYC regulatory agency responsible for protecting workers and the public by preparing the standard addressing the use of hazardous chemicals in the workplace. Occupational Safety and Health Administration (OSHA): The federal regulatory agency responsible for protecting workers by preparing the standard addressing the use of hazardous chemicals in the workplace. Personal Protective Equipment (PPE): Clothing and equipment worn to prevent contact with hazards present in the workplace. Personal protective equipment includes safety glasses, face shields, gloves, 16

safety shoes, hearing protection, hard hats, etc. Public Employees Safety and Health Bureau (PESH): An agency of the NYS Department of Labor with the legislative mandate to enforce OSHA s safety and health standards for New York State s public employees. Trained Haz Com Employee: An FIT employee who, following participation in FIT s initial and classroom-based training in OSHA/PESH Compliance and ongoing annual updates that FIT Human Resources documents, is qualified to work with the chemical products associated with the employee s routine assigned activities. 17

APPENDIX 1 MATERIAL SAFETY DATA SHEETS (MSDS) / SAFETY DATA SHEETS (SDS) FORMS AND REQUIREMENTS The following reviews the contents and use of MSDS/SDS sheets and information relating to hazardous chemicals present in the workplace. Manufacturer Material Safety Data Sheet (MSDS) / Safety Data Sheet (SDS) The OSHA HAZARD COMMUNICATION STANDARD requires manufacturers to prepare an MSDS/SDS sheet for each chemical product that includes the following information: The identity of the hazardous chemical as presented on the manufacturer s label. The chemical and common name(s) of a single-substance hazardous chemical. The chemical and common name(s) of the ingredients of hazardous chemical mixtures that contribute to the hazards. The physical and chemical characteristics of the hazardous chemical. The physical and health hazards of the hazardous chemicals. The primary routes of entry of the hazardous chemicals into the body. The OSHA Permissible Exposure Limit (PEL), the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Value (TLV), and any other exposure limits used or recommended by the preparer of the MSDS/SDS, where available. Information on whether the hazardous chemicals 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 (ARC) Monographs (latest edition), or by OSHA. Precautions for safe handling and use of the hazardous chemicals. Applicable control measures such as engineering controls, work practices, or personal protective equipment. Emergency and first aid procedures. The date of preparation of the MSDS/SDS or the latest revision. 18

APPENDIX 1 (cont.) The name, address, and telephone number of the manufacturer or other responsible party preparing or distributing the MSDS/SDS, who can provide additional information on the hazardous chemicals and appropriate emergency procedures, if necessary. MSDS/SDS Report Formats The OSHA HAZARD COMMUNICATION STANDARD does not specify a format in which hazardous chemicals data are to be reported on MSDS/SDS forms. The formats in which MSDS/SDS data are reported include: Manufacturer MSDS/SDS Sheets - The manufacturer or the supplier provides hazardous chemical data to an employer on in format that contains the information required by OSHA. College MSDS/SDS Sheets - The College compiles hazardous chemicals information directly from MSDS/SDS sheets supplied by the manufacturer or supplier for submission into a MSDS/SDS database system. 19

APPENDIX 2 EXHIBIT 1 20

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APPENDIX 2 EXHIBIT 2 Examples of In-House Labels for identification of containers of hazardous chemicals 29