General Company
Policy
The purpose of this notice
is to inform you that our company is complying with the
OSHA Hazard Communication Standard, Title 29 Code of Federal
Regulations 1910.1200, by compiling a hazardous chemical
list, by using SDSs, by ensuring that containers are labeled,
and by providing you with training.
This program applies to all
work operations in our company where you may be exposed
to hazardous substances under normal working conditions
or during an emergency situation.
The safety manager, Roberta
Jones, is the program coordinator, acting as the representative
of the plant manager, who have overall responsibility for
the program. Ms. Roberta Jones will review and update the
program, as necessary. Copies of the written program may
be obtained from Ms. Jones in Room SD-10.
Under this program, you will
be informed of the contents of the Hazard Communication
Standard, the hazardous properties of chemicals with which
you work, safe handling procedures, and measures to take
to protect yourselves from these chemicals. You will also
be informed of the hazards associated with non-routine tasks,
such as the cleaning of reactor vessels, and the hazards
associated with chemicals in unlabeled pipes.
List of Hazardous
Chemicals
The safety manager will make
a list of all hazardous chemicals and related work practices
used in this facility, and will update the list as necessary.
Our list of chemicals identifies all of the chemicals used
in our ten work process areas. A separate list is available
for each work area and is posted there. Each list also identifies
the corresponding SDS for each chemical. A master list of
these chemicals will be maintained by, and is available
from, Ms. Jones in room SD-10.
Safety Data Sheets
(SDSs)
SDSs provide you with specific
information on the chemicals you use. The safety manager,
Ms. Jones, will maintain a binder in her office with an
SDS on every substance on the list of hazardous chemicals.
The SDS will contain the section numbers and headings, and
associated information under each heading, in the order
specified by the OSHA Hazard Communication Standard per
the Global Harmonized System. The
plant manager, Jeff O'Brien, will ensure that each work
site maintains an SDS for hazardous materials in that area.
SDSs will be made readily available to you at your workstations
during your shifts.
The safety manager, Ms. Jones,
is responsible for acquiring and updating SDSs. She will
contact the chemical manufacturer or vendor if additional
research is necessary or if an SDS has not been supplied
with an initial shipment. All new procurements for the company
must be cleared by the safety manager. A master list of
SDSs is available from Ms. Jones in Room SD-10.
Labels and Other
Forms of Warning
The safety manager will ensure
that all hazardous chemicals in the plant are properly labeled
and updated, as necessary. Labels should include the product
identifier; signal word; hazard statement(s); pictograms;
precautionary statement(s): and the name, address and telephone
number of the chemical manufacturer, importer, or other
responsible party. Ms.
Jones will refer to the corresponding SDS to assist you
in verifying label information. Containers that are shipped
from the plant will be checked by the supervisor of shipping
and receiving to make sure all containers are properly labeled.
If there are a number of stationary
containers within a work area that have similar contents
and hazards, signs will be posted on them to convey the
hazard information. On our stationary process equipment,
regular process sheets, batch tickets, blend tickets, and
similar written materials will be substituted for container
labels when they contain the same information as labels.
These written materials will be made readily available to
you during your work shift.
If your transfer chemicals
from a labeled container to a portable container that is
intended only for your immediate use, no labels are required
on the portable container.
Non-Routine Tasks
When you are required to perform
hazardous non-routine tasks (e.g., cleaning tanks, entering
confined spaces, etc.), a special training session will
be conducted to inform you regarding the hazardous chemicals
to which you might be exposed and the proper precautions
to take to reduce or avoid exposure.
Training
Everyone who works with or
is potentially exposed to hazardous chemicals will receive
initial training on the Hazard Communication Standard and
the safe use of those hazardous chemicals by the safety
manager. A program that uses both audiovisual materials
and classroom type training has been prepared for this purpose.
Whenever a new hazard is introduced, additional training
will be provided. Regular safety meetings will also be used
to review the information presented in the initial training.
Foremen and other supervisors will be extensively trained
regarding hazards and appropriate protective measures so
they will be available to answer questions from employees
and provide daily monitoring of safe work practices.
The training will emphasize
these items:
- Summary of the standard
and this written program.
- Chemical and physical properties
of hazardous materials (e.g., flash point, reactivity)
and methods that can be used to detect the presence or
release of chemicals (including chemicals in unlabeled
pipes).
- Physical hazards of chemicals
(e.g., potential for fire, explosion, etc.).
- Health hazards, including
signs and symptoms of exposure, associated with exposure
to chemicals and any medical condition known to be aggravated
by exposure to the chemical.
- Procedures to protect against
hazards (e.g., personal protective equipment required,
proper use, and maintenance; work practices or methods
to assure proper use and handling of chemicals; and procedures
for emergency response).
- Work procedures to follow
to assure protection when cleaning hazardous chemical
spills and leaks.
- Where SDSs are located,
how to read and interpret the information on both labels
and SDSs and how employees may obtain additional hazard
information.
The safety manager or designee
will review our employee training program and advise the
plant manager on training and retraining needs. Retraining
is required when the hazard changes or when a new hazard
is introduced into the workplace, but it will be company
policy to provide training regularly in safety meetings
to ensure the effectiveness of the program. As part of the
assessment of the training program, the safety and health
manager will obtain input from employees regarding the training
they have received, and their suggestions for improving
it.
Contractor Employers
The safety manager, Roberta
Jones, upon notification by the responsible supervisor,
will advise outside contractors in person of any chemical
hazards that may be encountered in the normal course of
their work on the premises, the labeling system in use,
the protective measures to be taken, and the safe handling
procedures to be used. In addition, Ms. Jones will notify
these individuals of the location and availability of SDSs.
Each contractor bringing chemicals on-site must provide
us with the appropriate hazard information on these substances,
including the labels used and the precautionary measures
to be taken in working with these chemicals.
Additional Information
All employees, or their designated
representatives, can obtain further information on this
written program, the hazard communication standard, applicable
SDSs, and chemical information lists at the safety office,
Room SD-10.