Hazard Communication Program HAZARD COMMUNICATION SAFETY PROGRAM 1. Purpose. To provide an effective, written hazard communication program in compliance with company, State and Federal regulatory requirements. Hazard Communication applies to all chemicals and mixtures purchased, manufactured, used, and/or stored by the company to which employees, contractors, tenants or visitors may be exposed. (Note that Laboratories, as defined by OSHA regulations, are not covered under this program.) 2. Scope. This program applies to all operations at Scales Northwest, Inc. facilities and job-sites. This program does not apply to articles, food or beverage items, or consumer products normally purchased at consumer markets, provided they are used as intended by the manufacturer of the material, and the duration and frequency of exposure is as intended based on normal product use. (For example: if window cleaner is used to clean windows, then this program does not apply, however, if it is used for another reason, or blended with another material, then this program applies). 3. Responsibilities. Management (or their designee) must: Perform a hazard determination. The company is required to determine the hazards of any products or chemicals they manufacture and/or sell. Such items require the company to produce and maintain up-to-date Safety Data Sheets (SDS), and provide these to suppliers and customers with initial shipment, when changes occur, or upon request. An SDS must include: Identity of the product, as used on the label (its chemical or common name, and hazardous ingredients or hazardous components) Physical and chemical characteristics (i.e. vapor pressure, flashpoint, ph) Health Hazards (signs, symptoms or associated medical conditions) Primary routes of entry (inhalation, ingestion, absorption) OSHA, ACGIH or other exposure limits known Toxicological information, including carcinogenicity Safe handling precautions (hygiene practices, spill or leak clean-up, etc.) Control measures (PPE, ventilation, etc.) Emergency and First-aid procedures Date of last revision to the SDS Name address and telephone number of the manufacturer, including emergency contact information. Scales NW Hazard Communication Safety Program Page 1 of 9
Ensure a Chemical Inventory List is maintained either for the company as a whole, or for each department or work area. (See FORM for a Chemical Inventory List Template.) Chemical lists must include: The trade-name of the chemical or material as it appears on the SDS The name of the chemical or material (if it is different than the manufacturer s trade name) The manufacturer s name The manufacturer s telephone number Emergency contact information (company name and telephone number) if different than the manufacturer Evaluate the hazards for each chemical or mixture used or stored in the workplace. Determine if the quantity or type of chemical presents a hazard to the employees, the nature of the hazards, and the means that employees will use to protect themselves from these hazards. This information is generally found on the Safety Data Sheet (SDS) for the product. A safety professional or certified industrial hygienist may assist in this evaluation. Maintain a written hazard communication program. This program must contain or describe: A list of hazardous chemicals Access to and maintenance of a current SDS Labeling procedures Protective measures Training program elements Provisions for contractors (multi-employer workplaces) Procedures for evaluating the hazards of any non-routine tasks (e.g. onetime chemical uses) and for evaluating any unlabeled pipes in the work area that contain hazardous chemicals Scales NW Hazard Communication Safety Program Page 2 of 9
Assure labels and other forms of warning are affixed to chemical containers, as appropriate. Full labeling: All containers must be labeled with the chemical name, appropriate hazard warnings and the manufacturer name and address. Vendor labels should be in compliance. Such labels may not be defaced or covered. Shortened labeling: May be used for process materials and must contain the chemical identity (referenced back to the SDS), and appropriate hazard warnings and the SDS. Labels should be on all containers at all times. However, labels are not required for portable containers provided they are immediately used by the employee on that work-shift and remain in the direct control of the employee at all times. All labels must be in legible English. Other languages may be used, provided a label in English is also provided. Pipes or piping systems that contain a hazardous chemical shall be identified to employees by at least one (1) readily accessible label, sign, placard, written operating instructions, process sheet, batch ticket or substance identification system. Assure Safety Data Sheets (SDS) for each chemical used in the workplace are: Readily accessible and available by employees on each work shift Written in English Obtained from the manufacturer or supplier of the chemical or material before it is used at the workplace, if one did not accompany the shipment Kept for the duration of employment plus 30 years if chemical overexposures have occurred Kept for the duration of its use or storage, at a minimum. (It is recommended that all SDS s be kept for the duration of employment of person using the material.) Kept in a single area and filed alphabetically by name (recommended), however, current copies may be kept in each work area Train and inform employees on initial assignment and whenever a new physical, chemical or health hazard is introduced into the workplace, or when non-routine tasks or procedures are required. Training includes: The information required in the OSHA Standard Identification of the work areas where chemicals are used Scales NW Hazard Communication Safety Program Page 3 of 9
The location and availability of the written program, chemical inventory list(s), and MSDS Information on the methods used to detect the presence or release of chemicals in the workplace (monitors, alarm systems, odors, visual appearance, etc.) The physical and health hazard information of the chemicals present The measures employees can take to protect themselves from identified chemical hazards (procedures, personal protective equipment, etc.) The labeling system used in the workplace The details of this program Develop and implement a method of communication between any contractors and the company which describes and outlines: The method used to communicate hazards and precautions The method used to access an MSDS The method used to communicate emergency situations The labeling methods used Review this program annually to assure the above requirements are met. Employees must: Attend Hazard Communication Training upon initial assignment, and when changes to the workplace hazards occur (through process changes or a change of work assignment). Re-label any containers into which hazardous chemicals or mixtures are transferred. Labeling includes the name of the material, manufacturer name and phone number, and appropriate hazard warnings. Such containers do not require labeling if they are portable containers which will be immediately used by the employee on that workshift and which remains in the direct control of the employee at all times Inform management of any changes to chemicals or chemical uses. Safety Officer must (as needed or required): Assist in the development and maintenance of the written program or training requirements. Scales NW Hazard Communication Safety Program Page 4 of 9
Assist in the determination and evaluation of chemical hazards in the workplace. 4. Procedure. General: Determine if hazardous chemicals are present in the workplace Ensure the availability of a Safety Data Sheet (SDS) for each hazardous chemical or mixture in the workplace Ensure a Hazardous Chemical Inventory List is maintained Evaluate the hazards for each chemical or mixture used and/or stored in the workplace Ensure proper labeling of chemical containers Create and maintains a written program Train employees Maintain a process to evaluate and document any new hazards or changes to the workplace that would affect the above requirements, including any non-routine tasks or procedures, or unlabeled piping systems that contain hazardous chemicals. Personal Protective Equipment Requirements: Based on the types of hazardous materials at the workplace, employees must be provided with personal protective equipment. Training must be provided as needed for protective equipment use. Personal Protective Equipment includes: Gloves, Eyewear, Head or Foot protection, Protective Clothing, Respiratory Protection, Hearing Protection and Other Equipment such as Eyebath Stations or Emergency Showers Tools and receptacles for maintenance and disposal must be provided and employees informed in their use. Eyebaths must be approved types (personal eyewash bottles are NOT approved equipment, stations must be either permanently plumbed or portable stations that are capable of delivering a set amount of flushing fluid for 15 minutes.). Scales NW Hazard Communication Safety Program Page 5 of 9
5. Safety Information. Trade Secret Information Trade Secrets are products which, when the chemical identity of the product is revealed, would jeopardize the manufacturer s competitive advantage. Trade secret materials (and requests to reveal trade secret information) must comply with the requirements of OSHA 1910.1200(i) and Appendix D. Trade Secret information must be revealed to a health care professional when either: A medical emergency exists, or In a non-emergency situation, when a healthcare or safety professional, toxicologist or similar person provides a detailed written request and one of the following situations occurs: A hazard exposure evaluation depends upon the information To conduct sampling to determine exposure levels (including medical surveillance or pre-assignment) to potentially exposed employees To provide medical treatment to exposed employees To assess PPE requirements for exposed employees To design or assess engineering controls for exposed employees To conduct health assessment and health-effect studies Signed confidentiality statements may be required. Required Documentation and Records: Safety Data Sheets Chemical Inventory Lists. Training Records. Obsolete SDS s or Discontinued Products: SDS s for products no longer used at company facilities and job-sites are kept on file in a discontinued SDS file for at least 5 years from the last date of use. SDS s for chemicals and products no longer made by the company are kept on file for at least 30 years, and appropriate information is made available upon written request. Scales NW Hazard Communication Safety Program Page 6 of 9
6. Training and Information. All employees and contractors must be made aware of the hazards they may encounter and the precautions they must take to protect themselves from these hazards. Employees or contractors must be trained on initial assignment and whenever any new physical, chemical or health hazards are introduced, when non-routine tasks or procedures are required, or when employees are working with or near unlabeled piping systems that contain hazardous chemicals. Training includes: The information required in the OSHA Standard Identification of the work areas where hazardous chemicals are used The location and availability of the written program, chemical inventory list(s), and SDS. Information on the methods and observations used to detect the presence or release of chemicals (monitors, alarm systems, odors, visual appearance, etc.) including any non-routine tasks that employees may be asked to periodically perform which are beyond their regularly assigned duties The physical and health hazard information of the chemicals present The measures employees can take to protect themselves from identified chemical hazards (procedures, personal protective equipment, etc.) The labeling system used in the workplace The details of this program The requirements of use, handling, storage and disposal of any Personal Protective Equipment 7. Definitions. Article - A product whose use is dependant upon the product s size and shape and which does not constitute a hazard. (i.e. furniture, toys, packaging, etc.) Laboratory - A facility where relatively small quantities of hazardous chemicals are used on a nonproduction basis. The following conditions must be met: Chemical manipulations are carried out on a "laboratory scale Multiple chemical procedures or chemicals are used The procedures involved are not part of a production process, nor in any way simulate a production process "Protective laboratory practices and equipment" are available and in common use to minimize the potential for employee exposure to hazardous chemicals Scales NW Hazard Communication Safety Program Page 7 of 9
MSDS - Material Safety Data Sheets are reference documents that outline the product information, hazards and other required elements for hazardous chemicals or materials. These documents are produced by the manufacturer of the chemical or material and must be maintained at any workplace where they are used or stored. Process Materials - Chemicals that are routinely used in a chemical process or as part of a mixture for a chemical process. 8. Summary. To provide an effective, written hazard communication program, in compliance with company, State and Federal regulatory requirements. Hazard Communication applies to all chemicals and mixtures purchased, manufactured, used and/or stored to which company employees, contractors, tenants or visitors may be exposed. Note that Laboratories, as defined by OSHA regulations, are not covered under this program. Definitions: Laboratory - a facility where relatively small quantities of hazardous chemicals are used on a non-production basis. The following conditions must be met: Chemical manipulations are carried out on a "laboratory scale;" Multiple chemical procedures or chemicals are used; The procedures involved are not part of a production process, nor in any way simulate a production process; and "Protective laboratory practices and equipment" are available and in common use to minimize the potential for employee exposure to hazardous chemicals. Training Requirements: Employees who have exposures or who have potential exposures must be trained: Upon initial assignment When new hazards are introduced into the workplace When tasks or processes change, requiring new or different information be provided Scales NW Hazard Communication Safety Program Page 8 of 9
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