Procedure:HS011.01 / Title: Hazard Communication
Originator:Collier / Revision Date: July 2009

Saving The Smart Way

Universal Thermal Covers

812 N. Main St.

Baytown, Texas 77520

Phone: 281- 427-4519

SAFETY POLICY AND PROCEDURE
Procedure:HS011.01 / Title: Hazard Communication
Originator:Collier / Revision Date: July 2009

Page 1 of 20

Procedure:HS011.01 / Title: Hazard Communication
Originator:Collier / Revision Date: July 2009

TABLE OF CONTENTS

Hazard Communication

  1. Purpose
  2. Exceptions
  3. Authority and Accountability
  4. Management or Designee Responsibilities
  5. Employees

1.)Responsibilities

2.)Employee Rights

  1. Goals
  2. Hazard Evaluation
  3. Hazard Determination
  4. Material Safety Data Sheets (MSDS)

1.)Procedures

2.)Content

3.)Exposure Incidents

4.)Trade Secrets

5.)Glossary of Terms Found in MSDS’s

  1. Workplace Chemical List

1.)Up-dating the List and Insuring that it is Correct

2.)Adding a New Chemical

3.)Receiving an updated MSDS

  1. Labels and Other Forms of Warning

1.)Container Labeling

2.)Pipe Marking

  1. Hazardous Non-Routine Tasks
  2. Emergency Response

1.)Spills

2.)Fires

3.)First Aid

4.)Waste Disposal

  1. Multi-Employer Workplace Informing other Company’s Employees (Contractors, Temporary Services, etc.)
  2. Training
  3. Training Content
  4. Documentation
  5. Performance Evaluation
  6. Disciplinary Procedures

1.)Verbal Warning

2.)Written Warning

3.)Disciplinary Leave

4.)Termination

5.)Documentation

  1. Program Evaluation

Hazard Communication Program

A.Purpose

The purpose of this program is to inform interested persons, including employees thatUniversal Thermal Covers is complying with the OSHA Hazard Communication Standard, by compiling a hazardous chemicals list, by using material safety data sheets (MSDSs), by ensuring that containers are labeled, and by providing our employees with training and information availability.

This Hazard Communication (Right-To-Know) program is designed to transmit information regarding the chemical hazards of materials used in the workplace. This outline is designed to provide a brief summary of information that is covered in detail in this program.

  • Material Data Safety Sheets (MSDS's): All users must keep on file a copy of the MSDS of every chemical used in that area. It must be available to every employee during every shift. The original MSDS is kept in the main office.
  • Labeling and Other Forms of Warning: All containers of chemicals must be labeled. These labels must include at least the name of the chemicals and appropriate hazard warnings.
  • List (Inventory) of Chemicals: Each user department must keep a current working list of all chemicals in use and storage. The lists are called the Workplace Chemical List.
  • Hazardous Non-Routine Tasks: The supervisor must review with the employee-required cautions to complete non-routine hazardous tasks in a safe manner.
  • Multi-Employer Workplace: Universal Thermal Covers is required to inform other employers' employees (the employees of other employers who work at our facility, i.e., vendors, contractors, temporary help) about the hazards of the chemicals in the workplace in which they will be working, including but not limited to chemicals, contents of pipes in the vicinity, stationary process containers, etc. They are required to inform Universal Thermal Covers of any hazardous chemicals they will import into the workplace.
  • Chemical Disposal-Waste: All hazardous chemical wastes must be disposed by a waste disposal company and in accordance with all state and federal regulations.
  • Employee Information and Training: New employees will receive Hazard Communications training by management or designee at the health and safety orientation training. Prior to entering the work area, each new employee will receive detailed job specific chemical training from his or her supervisor. All current employees will receive annual updated training.

B.Exceptions

The following items are not covered by OSHA regulations governing chemical health hazard communication and, by extension, are excluded from this document unless specified otherwise:

  • Any consumer product or hazardous substance used in the workplace in the same manner, duration, and frequency as normal consumer use. For example, cans of spray paint this program would not cover intended for short one-application use. However, routine use of one or more of such materials by a technician or craftsperson would be covered. Users must understand the hazards of consumer products and use them in accordance with the guidance specified on container labels or other similar warnings.
  • Any hazardous waste that is subject to regulations established or by the Environmental Protection Agency.
  • Tobacco or tobacco products.
  • Wood or wood products when the only hazard is flammability or combustibility. Wood or wood products that have been treated with a hazardous chemical-including wood that may be subsequently sawed, sanded, cut (generating dust), or burned--are not exempt.
  • Articles, that is, manufactured items that do not release hazardous chemicals under normal-use conditions. If an article is used in a manner different from its intended use or if it is machined, heated, or otherwise handled in a manner that might lead to exposure or cause a hazard, it may no longer be considered an article.
  • Food, medications, or cosmetics intended for personal use by employees while in the workplace.
  • Any prescription drug in final form that is administered to patients. Note that when a pharmaceutical is used in a manner not otherwise exempt, this standard program applies.

C.Authority and Accountability

Management or designeeof Universal Thermal Coversaccepts the responsibility for providing resources and guidance for the development and implementation of the health and safety. Management or designee shall be responsible and will be held accountable for the overall implementation of the working plan.

Management or designee has the authority to delegate any or all portions of the plan to subordinates, but will be held responsible for the performance of the plan. Management or designee also has the authority to approve or carry out disciplinary actions against those that violate policies, procedures or rules.

All managers or supervisors shall be responsible and will be held accountable to ensure that all employees under their control follow all health and safety policies, procedures, and rules established by the company. They shall be responsible for administering training and guidance to employees under their direction. All managers or supervisors have the authority to reprimand and recommend disciplinary actions against employees that violate the health and safety policies of the company.

Employees shall be responsible and will be held accountable for providing this company with a commitment to the health and safety program, abiding by the policies, procedures, rules set forth by the program, and becoming actively involved in the program to assist in providing a safe and healthful work place for all involved.

D.Management or Designee Responsibilities

Management or designee will be held accountable to ensure that all responsibilities below are carried out.

  • Inform employees of the location of a copy of this program, MSDS’s and the chemical inventory list for all hazardous chemicals used in the facility. Ensure these documents are always accessible to all employees
  • Ensure that there is an MSDS present for each hazardous chemical in the facility and is on the chemical inventory list.
  • Ensure that each container in the facility is properly labeled.
  • Conduct or arrange training programs for all affected employees.
  • Maintain records required under this program.
  • Exchange MSDS’s and any other required hazard information with affected contractors prior to construction and renovation projects. Ensure contractor compliance during such projects.
  • Keep chemical inventory list current.

E.Employees

1.)Responsibilities:

Universal Thermal Covers employees who work with hazardous chemicals are expected to:

  • Follow all procedures and policies relating to the use, transportation, storage, and disposal of hazardous materials.
  • Report all hazardous conditions to their supervisor immediately.
  • Report any job related injury or illnesses to their supervisor and seek treatment as soon as possible.
  • Refrain from the operation of any equipment involving hazardous chemicals without proper instruction and authorization.
  • Wear or use all prescribed personal protective equipment (PPE).
  • Attend all required training and information sessions.
  • Request information and training when you’re unsure about how to handle unfamiliar or hazardous chemicals.

2.)Employee Rights:

Employees have specific rights, which are listed below:

  • Employees have the right to information regarding known or suspected hazards of chemicals to which they are exposed. This information shall be disseminated by:
  • Labeling of containers, which will identify the substance and the appropriate hazard warnings. Neither employers nor employees shall remove or deface existing, as received from Chemical Suppliers, labels unless they immediately replace the label with the required information.
  • Material Safety Data Sheets, which will be readily available to employees and will be made available to an employee within five working days of a request.
  • Training which details how to work safety with the hazardous substances. This instruction will be performed during the initial employment and whenever a new "hazard" is introduced into the work environment.
  • Employees have the right to be informed of the location of operations where hazardous chemicals are present.
  • NIEHS will not require employees to work with an unidentified hazardous substance unless health and safety information, and specific training, if needed, have been provided.
  • Employees may issue any complaints regarding this regulation with OSHA.
  • An employer may not discharge, discipline or otherwise discriminate against any employee or prospective employee because that person or their representative has exercised any right granted by the Act, made a claim, filed a complaint, or testified in any proceeding related to this Act. Nor shall any position, seniority or any other benefits be lost for such reasons.
  • No employer shall request or require that an employee, former employee, or applicant for employment waive any rights granted under this Act.

Note: The employee rights shall be posted on the Safety Notice Bulletin Boards.

F.Goals of Right to Know

  • To help you reduce the risks involved in working with hazardous materials;
  • To transmit vital information to employees about the potential hazards of substances in the work place;
  • To reduce the incidence and cost of illness and injury resulting from hazardous substances;
  • To encourage a reduction in the volume and toxicity of hazardous substances used in the workplace.

G.Hazard Evaluation

Before any hazardous chemical is used at our facility management or designee will evaluate it. This evaluation will identify the degree and type of physical hazards and any health hazards associated with the chemical. Universal Thermal Covers will use supplier MSDS’s to determine hazards. Once the degree and type of hazard is understood, management or designee will assign appropriate personal protective equipment to be used, when engineering controls are not feasible or during emergencies.

When a new MSDS is received from a supplier it will be reviewed for any changes in health and safety information. If any changes have occurred the new information will be immediately communicated to the employees and all MSDS files and labeling information will be updated accordingly. All hazard determination information will be kept indefinitely for the purpose of medical exposure information.

If it is determined that an “Imminent Danger” exits, by OSHA all employees will immediately be notified of the danger. Universal Thermal Covers will not permit an employee, other than an employee whose presence is necessary to avoid correct, or remove the imminent danger, to operate equipment or engage in a process, which has been tagged by the department, and which is the subject of an order issued by the department identifying that an imminent danger exists.

H.Hazard Determination

Chemical manufacturers and importers are required to assess the physical and health hazards associated with the chemicals they produce. This information must be conveyed to your employer by means of labels and Material Safety Data Sheets (MSDS). The Hazard Communication Rules specify how the hazard determination must be done. A hazardous chemical includes:

  • Chemicals that are presently regulated and considered hazardous
  • Evaluation of the scientific evidence to determine the chemical(s) effect on animals or humans

I.Material Safety Data Sheets (MSDSs)

The MSDSs we use are fact sheets for chemicals, which pose a physical, or health hazard in the workplace. MSDSs provide our employees with specific information on the chemicals they use. Management or designee will be responsible for obtaining/maintaining the MSDSs at our facility. He/she will contact the chemical manufacturer or vendor if additional research is necessary.

Copies of the material safety data sheets are kept at the following location(s) in our facility:

  • MSDS Book at The Right To Know Compliance Centers
  • The main office.

1.) Procedures:

These procedures are followed:

  • Obtain and label one or more three ring binders and label “MSDS’s”. Place all new MSDS’s in the binder(s). File MSDS’s alphabetically and by use, location or other suitable category.
  • Check all deliveries of chemicals for the MSDS(s). An MSDS should accompany the first shipment of all new or re-formulated chemicals.
  • When a chemical is received with an MSDS, place it in the binder and add the product name to the Workplace Chemical List. Remove any old or out-of-date MSDS for the same or similar product that is no longer in stock and place them in the obsolete MSDS binders.
  • If a chemical is received without an MSDS, check the MSDS binder to determine if it already contains the MSDS. If not, immediately request one from the supplier. Store the chemical separately, label “DO NOT USE” and do not use until the MSDS is received.
  • MSDSs can also be obtained from the manufacturer or suppliers web site or by send a request letter to the manufacturer or supplier putting a copy of this letter in the MSDS book until the MSDS is received.
  • Inform all employees of the location of the MSDS binder.

2.) Content:

Contents of MSDS’s may differ somewhat in format and content, however all should contain the following:

  • Substance identification - names, synonyms, manufacturer contact information, and index numbers
  • List of active and inert ingredients - components and contaminants
  • Exposure limits - ACGIH, TLV, OSHA PEL, etc
  • Physical data – boiling, melting points, vapor pressure, evaporation rate, specific gravity or density, water solubility, physical description
  • Fire and explosion data – LEL, flashpoint, flammability, class of hazardous atmosphere, firefighting media and methods, including fire extinguishers, etc
  • Transportation requirements, if any
  • Toxicity and health hazard data - including target organ, specific acute and chronic health effects, potential cancer risk, first aid and emergency medicine.
  • Storage and disposal - including reporting requirements
  • Spill and emergency response procedures
  • Measures to protect employees including personal protective equipment, safety shower and eyewash, etc

3.)Exposure Incidents:

If an employee is exposed to a chemical and the exposure results in an illness or injury that requires treatment by medical personnel:

  • Ensure that medical personnel see the individual immediately
  • Provide a copy of the MSDS to the medical personnel involved. Along with the MSDS provide any additional information you have on the chemical and when, where and how it was used.

4.)Trade Secrets:

  • Chemical manufacturers or employers may withhold the actual chemical identity if they are protecting a bona fide trade secret.
  • Chemical manufacturers or employers must release the actual chemical identity to health professionals under both emergency and non-emergency conditions.
  • The rules provide specific conditions for trade secret release and for holding the information confidential.

J.Workplace Chemical List

OSHA requires that all employers maintain a list of all hazardous chemicals in use or stored for use. The list must match with the Material Safety Data Sheet's name or identifier. Management or designee will be responsible for maintaining and updating the Workplace Chemical List (WCL) on an ongoing basis.

1.)Up-dating the list and insuring that it is correct:

  • If you do not have the most current Workplace Chemical List contact management or designee for a computer printout.
  • Management or designee will compare the WCL with the actual chemicals in use or stored in each area.
  • As employees find new chemicals or products not on the list or in the MSDS binder, they should add them directly to the workplace chemical list and return it management or designee so all necessary documents maybe updated or received.
  • Compare your revised list to the MSDS's in your area. If MSDS's are missing, contact management or designee.
  • When chemicals or repurchased management or designee shall get an updated MSDS, especially if the current date is older than 1990. If a FAX copy is received while waiting for an original in the mail. He will make sure the FAX copy is legible and put in the binder.
  • Once the MSDS has been received, management or designee will check the document to ensure that it is legible and complete with all pages. If not he or she shall obtain a new copy from the manufacturer or the distributor.
  • In the event a product must be disposed of, the contents must be determined prior to proper disposal. Management or designeeshall Document the attempts to acquire the MSDS, and if the company no longer exists or the MSDS is not available, documentation of attempts to obtain an MSDS will be kept on file and maintained in lieu of an MSDS. Also a copy of the letter and the returned envelope, which were sent to the distributor or manufacturer in requesting an MSDS, shall be kept on file when applicable.

2.)Adding a new chemical:

  • When new chemicals or purchase management or designee shall be responsible for added them to the workplace chemical list and insuring that they or put in the MSDS binders.
  • When a new chemical product or brand, is purchased the purchase department shall add a message asking for any and all MSDS’s be sent with each shipment.
  • If the new product introduces any new hazards management or designee shall train all affected employees on this new information immediately.

3.)Receiving an updated MSDS: