This
is a sample written program provided
only as a guide to assist in complying
with 29 CFR 1910.1200, OSHA's Hazard
Communications standard. It is not
intended to supersede the requirements
detailed in the standards. You need
to review the standard for particular
requirements which are applicable
to your specific situation. Employers
will need to delete or add information
relevant to your particular facility
in order to develop an effective,
comprehensive exposure control plan.
This
material and safety and health consultation
services are provided at no cost to
owners, proprietors, and managers
of small businesses by the Illinois
Onsite Safety & Health Consultation
Program, Industrial Services Division,
Department of Commerce and Community
Affairs under a program funded largely
by the Occupational Safety and Health
Administration (OSHA), an agency of
the U.S. Department of Labor.
ONSITE
SAFETY & HEALTH CONSULTATION PROGRAM
Illinois Department of Commerce &
Economic Opportunity
Industrial Services Division
100 West Randolph, Suites 3-400
Chicago, Illinois 60601
Phone: 312-814-2337 Fax: 312-814-7238
TDD: 800-419-0667
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,
we have established the following
written hazard communication program.
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.
A.
HAZARD DETERMINATION PROCEDURES. We
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.
1.
The HCPC will review each MSDS sheet
when received to see that it contains
the required information and has
no blank spaces. The HCPC will ensure
that information concerning the
hazards is transmitted to the appropriate
supervisor.
2. 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:
the Purchasing Department will be
notified to find a new supplier;
or
the HCPC will file a complaint with
the OSHA Area Office.
3.
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.
4. 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.
5. 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 :
in-house using equipment we have
purchased; or
by an independent consulting firm;
or
[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.
B.
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.
C.
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.
1.
Since chemical manufacturers are
required to label their containers,
we will use those already present
labels as our primary means of labeling.
2. 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.
3. 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.
4.
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.
5. 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.
D.
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.
The HCPC will be responsible for obtaining/maintaining
the MSDS and will coordinate these
efforts with the Purchasing Department.
The original copy of the MSDS will
be retrained by the HCP Coordinator
in a Master Book in his office.HCPC
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.
E. 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.
F.
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:
Provide onsite access to material
safety data sheets for each hazardous
chemical the other workers may
be exposed to while working;
Precautionary
measures that need to be taken
to protect workers during normal
operating conditions and in foreseeable
emergencies;
Labeling
system used in our facility.
It
is the contractors responsibility
to train his employees in any hazards.
The contractor must notify the HCP
Coordinator of any hazardous material
being brought onto the site.
G. TRAINING - PROCEDURES/FORMATS.
We will provide employees with information
and training on hazardous chemicals
in their work area at a the time of
their initial assignment and whenever
a new hazard is introduced into their
work area. Employees are to be trained
by the Department Supervisor at the
time they are assigned to work with
a hazardous chemical. This will ensure
that employees have the necessary
information prior to exposure to prevent
the occurrence of adverse health effects.
The training offers an opportunity
to explain to employees not only the
hazards of the chemicals in their
work areas, but also how to use the
information generated in our Hazard
Communication Program. Training will
include an opportunity for employees
to ask questions to ensure that they
understand the information presented
to them. Specifically, the training
will include the following:
The
operations in their work area
where hazardous materials are
present.
Methods
and observations that may be used
to detect the presence or release
of a hazardous chemical in the
work area (visual appearance,
odor, monitoring, etc).
The
physical and health hazards of
the chemicals in the work area.
The
details of our hazard communication
program; the location and availability
of the written program; an explanation
of the labeling system and the
material safety data sheets; and
procedures employees will follow
to obtain and use the information.
The
engineering controls or administrative
controls which have been provided
to eliminate any hazard to employees
(if any).
The
personal protective equipment
required for the employees specific
job (if any).
Retraining
is to be done as directed by the HCPC.
Retraining will be done when a new
hazard is introduced into the work
area, not a new chemical. For example,
if a new solvent is brought into the
workplace, and it has hazards similar
to existing chemicals for which training
has already been done, then no new
training is required. However, if
the solvent is a suspect carcinogen,
and there has never been a carcinogenic
hazard in the workplace before, then
new training on the carcinogenic hazard
must be done in the work areas where
employees will be exposed to it.
LIST
OF HAZARDOUS CHEMICALS
ENTER
CHEMICALS USED IN EACH DEPARTMENT,
ALPHABETICALLY BY DEPARTMENT IN THIS
SPACE AS INDICATED BY THE SAMPLE PROVIDED
