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TITLE

CHEMICAL SAFETY PROGRAM

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1.PURPOSE

1.1.The purpose of this policy is to define the requirements for the purchase, use and storage of hazardous materials.

1.2.This program is also intended to ensure the site complies with federal, state, and local regulations, including the OSHA Hazard Communication Standard.

2.SCOPE

2.1.This procedure applies to all employees who work with chemicals or supervise employees working with chemicals at the site.

3.REFERENCE DOCUMENTS

3.1.California Code of Regulations, Title 8, General Industrial Safety Orders, Section 5194, Hazard Communication

3.2.29 Code of Federal Regulations, 1910.1200, Hazard Communication Standard.

3.3.City of Hazardous Material Storage Ordinance.

3.4.The 1994 Uniform Fire Code, as amended by the State of California.

3.5. Safety Handbook (Your Guide To Good Safety).

3.6.

4.DEFINITIONS

4.1.Consumer products - products normally sold at retail. Types of consumer products exempt under the HCS include food, drugs, cosmetics, and alcoholic beverages. Some consumer products such as paint stripper, oven cleaner, and adhesives are frequently found in the workplace. If their use in the workplace is comparable to normal consumer use, they are exempt from the standard. Frequency and duration of use must be examined to make this determination. When use is heavy and the exposure to workers exceeds that of the general public then the requirements of HCS apply.

4.2.Container – any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank or the like that contains a hazardous chemical. Pipes and piping systems are not considered to be containers.

4.3.Employee – A employed individual or on site contract personnel who perform jobs similar to employees.

4.4.S&H – Safety & Health

4.5.ERT – Emergency Response Team. A team of volunteer employees who are trained to respond to site emergencies.

4.6.FM – Factory Mutual

4.7.HCS - the State of California Hazard Communication Standard (California Code of Regulations Title 8, Section 5194).

4.8.Health hazard - a material with properties such as, but not limited to, toxic, corrosive, asphyxiant, cryogenic, etc.

4.9.Hazardous Chemical – any chemical that meets the definition of ‘materials regulated’ in the Hazardous Material Storage Ordinance. Some of the chemicals listed are:

4.9.1.Hazardous and/or extremely hazardous wastes in Section 66680 and 66685 of Title 22 of California Code of Regulations.

4.9.2.EPA pollutants in 40 CFR section 401.15.

4.9.3.A flammable liquid, a class II, IIIA or IIIB combustible liquid by the National Fire Protection Association (NFPA).

4.9.4.A hazardous substance in Title 8, California Code of Regulations, section 339.

4.9.5.Any material that, because of its quantity, concentration, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. .

4.10.Hazardous Chemical Inventory - a list of hazardous chemicals used on site, including the amounts, hazards and locations of storage/use.

4.11.Incompatible chemicals – chemicals that when combined will result in an adverse chemical or physical reaction. Refer to the MSDS for specific information on incompatibility.

4.12.MSDS (Material Safety Data Sheet) - written or printed material describing a hazardous material in detail and prepared in accordance with OSHA requirements and guidelines. It contains information, such as, the percentage of each chemical in the hazardous material, the physical properties, the fire hazards, health hazards, reactivity information, first aid information, etc.

4.13.New hazardous chemical - refers to any chemical not listed on the department hazardous material inventory that was filed with the Operations department.

4.14.Physical hazard - a material with properties such as, flammable, corrosive, radioactive, high pressure, electrical, etc.

4.15.Proposition 65 - also known as the Safe Drinking and Toxic Enforcement Act of 1986, this California State law requires businesses to inform the public (including employees) when their facilities use or store chemicals known to the state of California to cause cancer, birth defects, or other reproductive toxicity.

4.16.Sanitary sewer Septic System drain – facility drains that discharge to the water pollution control plant are part of the sanitary sewer system. All facility sinks (industrial and handwashing), drinking fountains and restrooms are sanitary sewer drains or septic tanks. These drains are generally located inside the building.

4.17.

4.18.Storm sewer drain – these drains are located in the site parking lot and driveways. They collect rainwater and direct it to the City storm water system. All storm drains are located outside of the building.

4.19.User – employee who uses or plans to use a hazardous chemical on site.

5.EQUIPMENT AND SUPPLIES

5.1.Area MSDS books.

5.2.The following personal protective equipment may be required by specific department procedures:

5.2.1.Safety glasses with side shields or goggles.

5.2.2.Face shield

5.2.3.Protective gloves.

5.2.4.Protective apron or coverall.

5.2.5.Chemical- resistant shoes.

5.3.Spill clean up supplies.

6.RESPONSIBILITIES

6.1.It is the responsibility of the Manager/ Supervisor of each department using hazardous substances to:

6.1.1.Implement and maintain a chemical management program as described in this document.

6.1.2.Provide personal protective equipment to employees.

6.1.3.Maintain the department chemical inventory and submit updates to the Operations department.

6.1.4.Maintain the Area MSDS book for the hazardous substances used in the work area.

6.1.5.Ensure employees attend annual chemical safety training.

6.1.6.Review the hazards and safe work practices for the specific hazardous chemicals used into the work area with employees at least annually.

6.2.It is the responsibility of the Operations Department to:

6.2.1.Assist in providing annual chemical safety training.

6.2.2.Provide assistance and guidance to managers and supervisors on chemical safety practices.

6.2.3.Review and evaluate the MSDS of any new chemical or gas.

6.2.4.Maintain a master MSDS filing system.

6.2.5.Maintain a site hazardous material inventory.

6.3.It is the responsibility of the Purchasing Department to:

6.3.1.Procure only chemicals and gases that have been approved by the Operations department.

6.3.2.Require the manufacturer or distributor to provide an MSDS for each new chemical/gas purchased.

6.4.It is the responsibility of each Employee who is authorized to use hazardous substances to:

6.4.1.Comply with the chemical use, storage and disposal requirements of this document.

6.4.2.Follow the safe work practices and procedures for the department, including the use of personal protective equipment and clothing provided by the company.

6.4.3.Maintain and properly use company provided personal protective equipment.

6.4.4.Wear chemically resistant footwear in the work area.

6.4.5.Complete the training requirements specified in this document.

7.EXCEPTIONS

7.1.This program does not apply to:

7.1.1.Hazardous wastes

7.1.2.Tobacco or tobacco products

7.1.3.Biological or radiological agents

7.1.4.Wood or wood products

7.1.5.Foods, drugs, or cosmetics intended for personal consumption by employees while in the workplace.

7.1.6.Consumer products packaged for distribution to, and use by, the general public, provided that employee exposure to the product is not significantly greater than the consumer exposure occurring during the principal consumer use of the product.

7.1.7.The use of a substance in compliance with regulations of the Director of the Department of Pesticide Regulation issued pursuant to Section 12981 of the Food and Agricultural Code

8.PROPOSITION 65 (The Safe Drinking Water and Toxic Enforcement Act of 1986) WARNINGS

8.1.1.These warnings are required to be posted at this site because we use or store chemicals known to the state of California to cause cancer, birth defects, or other reproductive toxicity.

8.1.2.The main lobby and the employee lunchroom are posted with Proposition 65 warning notices.

8.2.A list of chemicals included in the Proposition 65 list can be obtained from the Operations department.

9.MATERIAL SAFETY DATA SHEETS (MSDS)

9.1.This facility relies on chemical manufacturers and distributors to perform a hazard analysis and hazard determination for all chemicals that are brought on site.

9.1.1.This information is provided to the site in a material safety data sheet (MSDS).

9.1.2.The MSDS is used to inform employees of chemical hazards and will be provided to attending physicians in the event of an employee chemical exposure.

9.2.An MSDS must be readily available for each chemical used or stored on site.

9.2.1.Each department must maintain in area-specific MSDS books where chemicals are used or stored.

9.2.2.Supervisor/ managers are responsible for ensuring that an MSDS for each chemical is contained in the area MSDS book.

9.2.3.Employees are encouraged to refer to these books for information on the chemicals that they use.

9.2.4.A master file of MSDS’s is maintained in the Operations department for all chemicals currently in use or used in the past at site.

9.2.5.Managers/ supervisors must submit a copy of any new MSDS’s to the Operations department to be included in this file.

9.3.An MSDS may be copied and distributed to contractors, employees, and outside agencies upon request of the individual. This request should be coordinated with the Operations Department.

9.4.If the employee is unable to locate the MSDS, they should contact the Operations department to obtain assistance.

9.5.If the MSDS is incomplete, the user or the Operations department will request that the manufacturer submit a complete MSDS.

9.5.1.If the manufacturer is unable to provide a complete MSDS within 25 days of the request, Corporation may submit written notification to Cal OSHA.

10.EMERGENCY PROCEDURES

10.1.If more than one cup of a hazardous waste is spilled or released INSIDE the building, employees in the immediate area will be relocated and the ERT will be notified immediately (ext.911).

10.2.If a hazardous waste spill of any size occurs OUTSIDE the building, dike (block) all nearby storm drains if possible, and immediately contact the ERT at ext. 911.

10.2.1.Spill clean up supplies that can be used to block liquid from entering a storm drain are located in ( fill in location )in the building.

10.3.Do not attempt to clean up any spills if you have not been trained to do so.

10.4.Always wear personal protective equipment when cleaning up spills.

10.5.Spill clean up supplies must be readily accessible for all chemical or hazardous waste use and storage areas.

10.5.1.Department supervisors/ managers will inform employees where these supplies are located and ensure the supplies are maintained.

10.6.All employees who are injured due to a chemical exposure will be sent to the Company approved clinic for a medical evaluation.

10.6.1.A copy of the chemical MSDS will immediately be sent to the clinic or hospital (with the employee or via fax) for review.

10.7.A trained ERT is available during normal business hours to respond to chemical emergencies. For specific details, refer to the site Emergency Response Plan.

10.7.1.For chemical emergencies outside of normal business hours, contact Security at ext.911.

10.8.Notification of the County Fire Department will be coordinated by the ERT in the event of a chemical release resulting in an evacuation or a chemical release outside of secondary containment.

11.CHEMICAL INVENTORY

11.1.Each department must maintain a chemical inventory for all chemicals and hazardous wastes used and stored in their area.

11.2.The department inventory must be submitted to the Operations department:

11.2.1.During the first quarter of each year.

11.2.2.When ever a new chemical is added to the department inventory or the quantity of listed chemicals change.

11.3. The Operations department will consolidate the inventories from each department onto a site wide chemical inventory.

11.3.1.The site wide chemical inventory is submitted annually to the County Fire Department by the Operations department.

11.4.The inventory is currently maintained in the Operations department.

11.5.New chemicals are not permitted on site unless they are added to the department chemical inventory (update must be submitted to the Operations department) and have prior approval.

12.PURCHASE OF CHEMICALS

12.1.All chemicals and gases, including research and development chemicals, must be procured using the purchase order system.

12.2.Purchase of existing chemicals.

12.2.1.Chemical purchases will be approved by the Operations department if:

12.2.1.1.The chemical is listed on the department chemical inventory that is on file with the Operations department and
12.2.1.2.The requested chemical quantity falls within the amounts specified on the existing inventory.

12.3.Purchase of new chemicals.

12.3.1.Obtain the Operations department approval and do the following prior to bringing a new chemical on-site:

12.3.1.1.Obtain an MSDS from the manufacturer or distributor and submit a copy to the Operations department.
12.3.1.2.The user and the Operations department to assess the hazards will review the MSDS.
12.3.1.3.Provide a written description of the following to the Operations department:
12.3.1.4. The proposed use, storage and disposal practices of the new chemical.
12.3.1.5.The proposed change to the department chemical inventory.
12.3.1.6.Chemicals must be added to the site Hazardous Material Chemical Hazard Classification List.
12.3.1.7.Obtain the Chemical Hazard Warning label requirements from the Operations department.

12.3.2.The Operations department will review the proposal and

12.3.2.1.Approve the proposal, or
12.3.2.2.Require changes to the proposed use, storage and disposal.

12.3.3.The Operations department prior to bringing the chemical samples on site must approve vendor samples and the associated MSDS’s.

12.3.4.Users should always purchase, specify, and use the least toxic and lowest concentrations of chemicals to accomplish the process task.

13.RECEIVING OF CHEMICALS

13.1.Chemicals will be received at the Receiving dock by the Receiving department.

13.2.Emergency chemical deliveries, conducted outside of normal business hours, must be coordinated with the Operations department and signed for by the manager or supervisor.

13.3.Employees are not allowed to transport chemicals to the site in their personal vehicles or the Company vehicle without pre-approval from their supervisor and the Operations department.

14.LABELING

14.1.Labeling of all original chemical containers is the responsibility of the manufacturer, supplier, or distributor of the product. The warnings on containers shall include the following:

14.1.1.Name of the manufacturer,

14.1.2.Name of the hazardous material,

14.1.3.Components of the hazardous material,

14.1.4.Concentration of the hazardous material,

14.1.5.Any hazardous properties (as specifically as possible).

14.2.Chemical container labels that do not meet the requirements of the previous section must have an in-house chemical hazard identification label affixed in the section entitled “Hazard Identification Labeling System”. Ref. Corporation “GUIDE TO GOOD SAFETY”.

14.3.Containers of hazardous chemicals that are filled from larger labeled containers (example: squirt bottles, tanks) require the following labeling:

14.3.1.In-house chemical hazard identification label,

14.3.2.The chemical identity (chemical name and concentration),

14.3.3.Generic chemical name, if different from chemical name,

14.3.4.A written warning of hazards associated with the chemical.

14.4.All hazardous waste shall be labeled in accordance with the Hazardous Waste Management Program.

14.5.All labels shall be written in English.

15. LABELING SYSTEM

15.1.This is an internal labeling system and is defined in the Corporation “GUIDE TO GOOD SAFETY” Hazardous Material Identification System.

15.2.All Chemical Hazard Identification label requirements, including the assignment of label codes will be coordinated through the Operations department.

15.3.Chemical Hazard Identification labels must never be placed over the original container labels or markings.

15.4.Chemical Hazard Identification labels contain diamond shaped symbols with four color-coded quadrants.

15.4.1.Blue is health hazard

15.4.2.Red is fire hazard

15.4.3.Yellow is reactivity hazard

15.4.4.White is special hazard.

15.5.Each color, except white, has a number from 0 to 4 that specifies the degree of hazard with 4 being the most severe hazard.

15.6.The special hazard section uses letters to specify the hazard.

15.6.1.W – water reactive

15.6.2.X - oxidizer

15.6.3.C – chronic health hazard

15.6.4.An additional identifier is required for chronic health hazards:

15.6.5.Key Target Organs – see LAB safety Label.

15.7.Flammable: A fire hazard. A chemical that catches on fire easily and burns rapidly. A flammable liquid has a flash point below 100 oF. Combustible chemicals are also included in this hazard class. A combustible liquid has a flash point of 100 oF or higher.

15.7.1.Example: flammable liquid – isopropyl alcohol or ethyl acetate.

15.8.Corrosive: A health hazard. A chemical that damages body tissue or causes permanent changes in human tissue upon contact. Corrosive acids and bases can react with each other and must be stored separately.

15.8.1.Corrosive Base: examples are sodium hypochlorite (bleach), sodium hydroxide

15.8.2.Corrosive Acid: examples are hydrochloric acid or sulfuric acid.

15.9.Toxic: A health hazard. A chemical that has the ability to injure the body. The severity of the injury depends on how much material the body absorbs and how long the body is exposed to the chemical.

15.9.1.Examples: methylene chloride, lead

15.10.Oxidizer: A reactivity hazard. A chemical that promotes combustion in other materials by supplying the necessary oxygen to start and maintain a fire, thereby eliminating the need for outside air.

15.10.1.Examples: hydrogen peroxide, nitric acid (>70% concentration)

15.11.Water reactive: A reactivity hazard. A chemical that reacts with water often releasing a gas or creating heat.

15.11.1.Examples: sodium metal, lithium

16.CHEMICAL STORAGE

16.1.Chemicals must be stored in designated and labeled storage locations.

16.1.1.Storage cabinets must be labeled with the hazard class (flammable, acid, base, toxic, or oxidizer).

16.1.2.A good management practice includes labeling the cabinet with the chemicals that are allowed to be stored in the cabinet. This is a recommended, but not required practice.

16.2.Chemicals must be stored by hazard class: flammables stored with other flammables, acids stored with other acids, etc.

16.2.1.This is to prevent potential intermixing of incompatible chemicals.

16.2.2.Chemicals with multiple hazard classes should be stored based on the most likely hazard found in the work area. For example, some adhesives are flammable and toxic and should be stored as a flammable due to potential fire dangers. Consult the Operations department for assistance.

16.3.All storage areas for liquid hazardous chemicals must have secondary containment to minimize the risk in the event of a release.

16.3.1.The containment must be designed to hold at least:

16.3.1.1.One primary container: 110% of the primary container volume.
16.3.1.2.Multiple primary containers: 150% of the largest container or 10% of the aggregate, whichever is greater.

16.4.Construction materials for all storage cabinets, primary containers and secondary containment must be compatible with the chemicals they are intended to contain. For example, flammables must be stored in fireproof (metal) cabinets and acids must be stored in corrosion resistant containment.