SAMPLE
WRITTEN
HAZARD COMMUNICATION PROGRAM
This
is a sample written hazard communication
program provided only as a guide to assist
in complying with 29 CFR 1910.1200, OSHA's
Hazard Communication Standard. It is not
intended to supersede the requirements
detailed in the Standards but only as
an aid in developing your program so they
meet the requirements of this Standard.
Review the standard for particular requirements
which are applicable to your specific
situation. This sample program MUST be
tailored to fit your facility.
INTRODUCTION
We
are responsible for protecting our employees
from all hazardous chemicals known to
be present in our workplace. We will provide
our employees a reasonable safe place
in which to work and instruct employees
in safe work practices. Employees have
a responsibility to learn and follow the
sensible procedures we have established
to ensure basic awareness of hazards in
our workplace.
To
ensure that all avenues are addressed,
the following written hazard communication
program has been established for (INSERT COMPANY NAME HERE).
(INSERT
NAME OF PERSON OR JOB TITLE OF PERSON
DESIGNATED HERE)
has been designated as our Hazard
Communication Program Coordinator (HCPC)
and will be responsible for seeing that
all aspects of our program are carried
out in the fashion intended. A copy of
the program will be available in the HCP's
office for review by all employees. In
general, our program includes the following
elements.
I.
HAZARD DETERMINATION PROCEDURES.
We will rely upon the manufacturer
to evaluate the various hazards of the
chemicals they supply to us. The HCPC
will accept the information provided on
the Material Safety Data Sheets (MSDS).
The Material Safety Data Sheet is to address
essentially everything that is known about
the chemical.
The
HCPC will review the information on the
MSDS and will ensure that information concerning
the hazards is transmitted to the appropriate
supervisor.
(a)
The HCPC will review each MSDS sheet when
received to see that it contains the required
information and has no blank spaces.
(b)
The HCPC will write to the supplier for
any missing information. If the supplier
will not respond within 30 days, (SELECT
ONE OF THESE OPTIONS (1) the Purchasing
Department will be notified to find a
new supplier; or (2) the HCPC will file
a complaint with the OSHA Area Office).
(c)
The HCPC will send a copy of the MSDS
to the appropriate Department Supervisor
and will retain the original in a Master
MSDS Book which is kept in the HCP office.
(d)
Every two years, the HCPC will request,
in writing, an updated version of the
MSDS from the manufacturer to ensure that
the MSDS has been updated if new and significant
health information is found. The HCPC
will review the new MSDS and distribute,
as needed, if any changes are found.
(e)
The HCPC will arrange to have monitoring
completed for any questionable hazardous
material in the workplace. Monitoring
will be conducted
SELECT ONE OR MORE OF THESE OPTIONS
(1) in-house using equipment we have purchased;
or (2) by an independent consulting firm;
or (3) [at no cost] by the Illinois Onsite
Safety & Health Consultation Program.
Every
attempt will be made by the company to
provide engineering controls or administrative
controls to eliminate any hazard to our
employees.
2.
LIST OF HAZARDOUS CHEMICALS. An
inventory of hazardous materials used
in our operation for which there must
be Material Safety Data Sheet is listed
at the end of this written program. The
hazardous materials are listed alphabetically
by department. Further information such
as physical and chemical hazards for the
materials listed can be obtained from
the MSDS sheets located in the Supervisor's
office or by contacting the HCPC Coordinator.
Any
new chemical intended to be purchased
must be reviewed by the HCPC to see if
a MSDS is needed. Purchasing will automatically
request a copy of the MSDS at the time
the purchase order is placed. Upon receipt,
the MSDS will be given to our HCP Coordinator
for review.
3. PROCEDURES - LABELS
AND OTHER FORMS OF WARNING.
All
containers in the workplace are to be
labeled in order to provide an immediate
visual warning about the hazards of the
chemical in the container.
The
HCP coordinator and the Department Supervisor
are responsible for ensuring that all
containers in the plant are labeled.
(a)
Since chemical manufacturers are required
to label their containers, we will use
those already present labels as our primary
means of labeling.
(b)
If chemicals covered under this program
are transferred from the original shipping
container to another container for an
employee's use, those containers will
be labeled with a secondary label. Our
secondary or back-up labeling system will
consist of using a label similar to the
label supplied by the vendor. This will
assist employees in easily identifying
the product involved with less chance
of error.
(c)
The Receiving Supervisor will ensure that
all containers of chemicals are correctly
labeled at the time they are received
in the plant and before delivery to the
appropriate department. The supervisor
will check to make sure that the container
is clearly labeled as to its contents
and has the appropriate hazard warnings.
Any container which does not have this
information may be returned to the supplier
at the supplier's expense.
(d)
Each Department Supervisor will ensure
that all containers of chemicals used
in his department are correctly labeled
and that labels are not removed from any
container or defaced in any manner.
(e)
Empty containers are not to be re-used
to store other materials unless the container
has been cleaned, the old label removed,
and a new label affixed in its place.
Prior to re-use, the container must be
approved by the HCP Coordinator.
4.
PROCEDURES - MATERIAL SAFETY DATA SHEETS.
Material Safety Data Sheets (MSDS)
for each hazardous chemical in the workplace
are readily accessible to employees when
they are in the work areas during each
work shift.
(a)
The HCPC will be responsible for obtaining/maintaining
the MSDS and will coordinate these efforts
with the Purchasing Department.
(b)
The original copy of the MSDS will be
retrained by the HCP Coordinator in a
Master Book in his office. He will give
a copy to the respective Department Supervisor
who will maintain a copy of the MSDS in
the work area at all times. Any employee
in the work area will have ready access
to the copy retained by the Department
Supervisor.
5.
METHODS TO INFORM EMPLOYEES ABOUT HAZARDS
OF NON-ROUTINE TASKS/PIPING. At
the current time, no employee is expected
to perform any non-routine hazardous task.
If at any time policy were to change,
or if employees are given non-routine
tasks, the employee should contact the
HCP Coordinator. Each employee assigned
to a non-routine task will receive a safety
briefing of the hazards associated with
non-routine work tasks from the Department
Supervisor and the HCP Coordinator.
(USE THIS PARAGRAPH ONLY AFTER YOU HAVE EVALUATED
YOUR OPERATION AND DETERMINED THAT YOU
HAVE NO PROCESSES WHICH REQUIRE NON-ROUTINE
TASKS (I.E. ANY SPECIAL JOB WHICH OCCURS
INFREQUENTLY, SUCH AS CONFINED SPACE ENTRY)
[FOR EMPLOYEES USING DRAW STATIONS (A FILL STATION
FOR DRAWING LIQUIDS CLOSE TO MANUFACTURING
OPERATIONS FROM A REMOTE PUMPING AREA)].
All pipelines for our drawing stations
will be marked as close as possible to
the valve being used to draw the liquid
with the contents of the pipe.
6.
METHODS TO INFORM CONTRACTORS ABOUT
HAZARDS. To assist in evaluating
potential exposures to ensure that a contractor's
employees are provided with information
regarding potential hazards prior to entering
the worksite, our HCP Coordinator will
be notified whenever a construction project
is planned by the person responsible for
the project. It is the responsibility
of the HCP Coordinator to provide contractors
with the following information:
