HAZARD COMMUNICATION PROGRAM GUIDE
Developed by: Hortica Loss Control Department
The information set forth in this material is made available for informational purposes only and may not completely apply to your business or operations. By using or material you expressly acknowledge that no relationship, duty, or obligation is created between you and Hortica - The Florists' Mutual Insurance Company ("Hortica") or its subsidiaries. Further, Hortica makes no warranties or representations as to the accuracy of the information contained in this material, nor does Hortica assume any responsibility or duty for your workplace safety programs or the compliance of said programs with any applicable state, federal or local laws. Hortica assumes no liability for your use of this material.
Instructions for completing the Hazard Communication Program Guide.
Replace the words “COMPANY NAME” with the name of your company.
Replace “JOHN DOE” with the name of the individual responsible for those specific duties described.
Replace capitalized job titles with the appropriate titles of those designated to perform the specific duties described.
Insert your company info into Appendix A
This Hazard Communication Program Guide was created by the Hortica Loss Control Department to assist our customers in establishing their own Hazard Communication Program. This program guide was developed using Federal Standards and may not include all of the requirements of some state funded Occupational Safety and Health Administrations.
Remember this program needs to fit your specific work practices and company policies. Make sure to review the information provided in this template and make any necessary changes to accomplish this. Once completed, this document can be used by OSHA during an inspection. It is important that you are following the policies that are outlined in your written programs.
COMPANY NAME
HAZARD COMMUNICATION PROGRAM
PURPOSE
To ensure that our employees know the hazards associated with the chemicals they are working with and the proper protective measures needed to prevent their adverse effects.
To identify hazardous substances present in the workplace and make sure they are properly marked and labeled.
To allow COMPANY NAME to provide a safe workplace free from hazards.
I. HAZARD DETERMINATION and IDENTIFICATION
COMPANY NAME will rely on appropriate hazard determination by manufacturers, importers and distributors for the substances they manufacture or sell.
II. HAZARDOUS SUBSTANCE INVENTORY
1)SAFETY COORDINATOR, JOHN DOE, will maintain a list of all hazardous substances used and generated in the facility, and update the list as necessary. The hazardous substance list will be updated upon receipt or generation of new hazardous substances at the facility. The master list will be maintained at the COMPANY NAME main office.
The hazardous substances will be listed alphabetically by common name. The material safety data sheets (MSDS/ SDS) will also be organized alphabetically by common name. As new products are acquired, they will be inserted alphabetically into the existing list. The substances which are not in containers will also be included on the inventory list. Ex. Welding fumes, dusts, etc.
2)All department supervisors will maintain a current list of all hazardous substances used in their departments. These lists will be located within the department and will be made available to employees.
3)Department supervisors are responsible for reporting to the Safety Coordinator, any chemicals coming in to their departments which do not appear on the chemical inventory. The Safety Coordinator will then determine if the chemical is hazardous, and will ensure that the purchasing department requests MSDS/ SDS’s and labeling.
4)The RECEIVING FOREMAN is responsible for sending all new MSDS/ SDS information received to the COMPANY NAME/SAFETY DEPARTMENT.
III. LABELS
JOHN DOE is responsible to ensure that all hazardous substances in the facility are properly labeled. Labels should list at least the chemical identity, appropriate hazard warnings and the name and address of the manufacturer.
Immediate use containers (small quantity containers into which materials are drained for use by a single employee, for a single shift) do not require labeling. All other in-house containers must meet above label requirements, referring to label information supplied by the manufacturer.
If the label provided by the manufacturer is not appropriate, JOHN DOE will notify the Safety Coordinator, who will then notify the manufacturer of the discrepancies in labeling.
JOHN DOE will check on a regular basis to ensure that all containers in the facility are labeled and that the labels are up-to-date.
All employees are responsible for seeing that all containers are labeled properly and remain legible. Original chemical containers must have the manufactures label adhered to them. Defacing labels or using them improperly is prohibited. If a label is missing or is no longer legible it is the responsibility of all employees to notify JOHN DOE who will contact the manufacture to obtain a new label for the container.
IV. MATERIAL SAFETY DATA SHEETS / SDS
JOHN DOE will be responsible for maintaining a MSDS/ SDS library on each hazardous chemical in the workplace.
The purchasers of new substances will request a MSDS/ SDS on all orders of new products. Upon receipt, a copy of the MSDS/ SDS will be given to JOHN DOEin order for the master MSDS/ SDS list to be updated.
If MSDS/ SDS’s are not received with the initial shipment, the purchaser should informJOHN DOE who will request the MSDS/ SDS using the sample form letter in Appendix A. A copy of this letter will remain on file until the MSDS/SDS has been received. If the MSDS/ SDS is not received within 30 days a decision will be made regarding alternate suppliers and/or discontinuation of the chemical’s use. JOHN DOE is responsible for providing interim hazard information for all chemicals that do not have a MSDS/ SDS.
The department supervisors will maintain a file of MSDS/ SDS’s for all of the hazardous substances used in their departments. The exact file location will be communicated to the employees.
It is the department supervisor’s responsibility to update that job site’s inventory list as they are provided by the Safety Coordinator. Each job site will be provided with a compilation of MSDS/ SDS’s for chemicals used at that site.
Employees will have unrestricted access to the MSDS/ SDS’s and the written Hazard Communication Program during all work hours. The MSDS/ SDS’s are written in English. JOHN DOE OR BILINGUAL SUPERVISORS are available to translate the information verbally to our Spanish-speaking employees.
Copies of MSDS/ SDS’s will be kept in the following areas:
Choose 1 or more locations accessible by employees
Main office
Maintenance Shop West Wall
Chemical Room Outer Wall In GreenhouseRange #1
Break Room
V. EMPLOYEE TRAINING
1) Before starting work with hazardous substances, each employee will attend a hazard communication training session where they will receive information on:
a)Policies and procedures related to the Hazard Communication Standard which includes information on accessing the standard.
b)How to read, interpret and locate a MSDS/ SDS, label and pictograms.
c)Our in-house labeling procedures and requirements
d)Physical and health hazards of hazardous substances in their work area.
e)Procedures and observations to identify the presence of a release.
f)Work practices that may result in exposure.
g)How to prevent or reduce exposure (e.g. engineering controls such as localized exhaust/ventilation, personal protective equipment (PPE), etc.)
h)Procedures to follow if a spill or exposure occurs.
2)JONN JOHN DOE/Safety Coordinator will present hazard communication training to all employees. This training will be conducted prior to the employee working with or near any known hazardous chemical or substance.
3) The format of the training session will be in video format and lecture. The training will be in language that the employee can understand.
4)Each employee will sign a form documenting that they have received the training.
5) The Safety Coordinator will monitor and maintain records of employee training and schedule additional training whenever a new hazard is introduced into the workplace.
VI. RECORD KEEPING
1) All MSDS/ SDS’s will be kept for a period of 30 years after the use of the substance has been discontinued.
2) The inventory lists will be kept for 30 years. (The OSHA Standard 1910.20 Access to Employee Exposure and Medical Records requires that “exposure records” on an employee be kept for a period of 30 years beyond the duration of employment.) If the ?
VII. GLOBALLY HARMONIZED SYSTEM (GHS) IMPLEMENTATION
1)As of December 1, 2013 all employees will be trained on the new GHSpictograms, label elements andSDS format. After this date all newly hired employees will receive all applicable training.
2)We will update our MSDS’s as new Safety Data Sheets (SDS) become available from the manufacturer. By June 1, 2016 all our MSDS’s will be updated with the new SDS format. We will provide additional employee training for newly identified physical or health hazards listed on the updated SDS’s, if necessary.
VIII. PROGRAM REVIEW
We will review this program annually to make sure that it remains current and relevant to our company policies and employees. This review will make sure that our company is remaining in compliance with the policies that are outlined in our Hazard Communication Program and that there haven’t been any changes that would require the program to be updated (e.g. new chemicals, new hazards, etc.)
Sample Form Letter for MSDS Request
Appendix A: Sample Form Letter for MSDS Request
Date of your request
(Name of manufacturer/distributer you need the MSDS/SDS from)
(Their address)
(City, state, zip code)
(Their fax number if you make this request)
Subject: Material Safety Data Sheet Request (MSDS)
Please send us the (MSDSs) for the following product(s):
(1)
(2)
(3)
Our business needs the MSDS/SDS(s) listed above to comply with the Chemical Hazard Communication Standard. Please make sure that the MSDS(s) you send us meet the requirements of the content and distribution of material safety data sheets (MSDSs) and label information, CFR 1910.1200, OSHA Hazard Communication Standard.
Whenever possible please send this information to me at (email address) or (fax number). If this is not possible the information can be mailed to me at the address listed below.
Thank you for your immediate response.
Sincerely,
Your name
Your company's name
Business address
Revised text including new GHS-HCS standard.