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Written Hazard Communication Program

(Note to plan developer: Items marked in red are indications of items that require you to change them to accommodate your specific situation.)

Date Adopted: XX/XX/XXXX

This program was developed by XYZ Company in order to provide a work place safe from hazardous chemical exposure for its employees and in order to comply with OSHA 1910.1200. This plan was approved and adopted by the management of XYZ Company. The safety director for XYZ Company is the person designated to be responsible for the implementation and updating of this plan.

This program shall remain in the office of the shift supervisor available for review by any employee at any time.

A. List of Hazardous Chemicals in the Work Area:

(Note to plan developer: Insert here a comprehensive list of all chemicals in the workplace that may be considered hazardous and the work area in which they are used and/or stored.)

B. Employees Covered by this Program

1. Every Employee of XYZ Company is Covered by this Program.

2. Every Employee of Every Other Company Who Performs Work Within This Facility is Covered by this Program

3. Special Provisions for Employees of Other Employers Working Within This Facility

It is the responsibility of the operations manager to inform employers of employees working in this facility who are not employees of XYZ Company of the training requirements for their employees before they perform work in this facility

Employers of these employees must certify that these employees have received Hazard Communication training conforming to HCS 2012

Employers of these employees must provide information to the safety director to determine if their employees have been properly trained in each form of labeling used in this facility

Employers of these employees must certify that these employees have received Hazard Communication training covering the chemical terms and concepts found on labels and SDSs in this facility

Employers of these employees must ensure that their employees have successfully completed the "Site Specific Training Course for Employees of External Employers"

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C. Labels and Other Forms of Warning:

1. Labels on Containers of Hazardous Chemicals Leaving the Workplace:

The individual responsible for developing and affixing the proper label to each container of hazardous chemicals leaving the workplace is the person designated as the HCS Label Manager.

The HCS Label Manager is responsible to follow the instructions and guidelines in 1910.1200 Appendix C "Allocation of Label Elements", a copy of which is incorporated into this program, and develop the proper label to include: o Product identifier;o Signal word;o Hazard statement(s); o Pictogram(s);o Precautionary statement(s); and,o Name, address, and telephone number of the chemical manufacturer, importer, or other

responsible party.

2. Labels on each container of hazardous chemicals NOT leaving the workplace (Generally called workplace labeling or in-house labeling) Workplace Labeling:

(Note to plan developer: In this section you have some choices that must be made by management.Management may decide to use GHS labels or they may adopt another form and format of labeling. Many people us the NFPA 704 labeling system or the Hazardous Material Information System (HMIS). Some develop their own form and format. Whatever system is used must be compatible with the Globally Harmonized System (GHS).

If you choose to use the GHS System then it would be the same as the above section for chemicals to be shipped. So just change that heading from "Labels on Containers of Hazardous Chemicals Leaving the Workplace" to "Labels on Containers of Hazardous Chemicals".

If you choose to use the NFPA 704 system then use the following:)

XYZ Company has adopted the NFPA 704 labeling system for workplace labeling of Containers of Hazardous Chemicals.

The individual responsible for developing and affixing the proper label to each container of hazardous chemicals is the person designated as the HCS Label Manager.

The HCS Label Manager is responsible to ensure that the use of this system is compliant with the GHS. The Label Manager shall follow these guidelines:

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HAZARD HEALTH FLAMMABILITY INSTABILITY

4

Very short exposure could cause death or serious residual injury even though prompt medical attention was given.

Will rapidly or completely vaporize at normal pressure and temperature, or is readily dispersed in air and will burn readily.

Readily capable of detonation or of explosive decomposition or reaction at normal temperatures and pressures.

3

Short exposure could cause serious temporary or residual injury even though prompt medical attention was given.

Liquids and solids that can be ignited under almost all ambient conditions.

Capable of detonation or explosive reaction, but requires a strong initiating source or must be heated under confinement before initiation, or reacts explosively with water.

2

Intense or continued exposure could cause temporary incapacitation or possible residual injury unless prompt medical attention is given.

Must be moderately heated or exposed to relatively high temperature before ignition can occur.

Normally unstable and readily undergo violent decomposition but do not detonate. Also: may react violently with water or may form potentially explosive mixtures with water.

1

Exposure could cause irritation but only minor residual injury even if no treatment is given.

Must be preheated before ignition can occur.

Normally stable, but can become unstable at elevated temperatures and pressures or may react with water with some release of energy, but not violently.

0 Exposure under fire conditions would offer no

Materials that will not burn. Normally stable, even under fire exposure conditions, and are not

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hazard beyond that of ordinary combustible materials.

reactive with water.

From available data determine the hazards associated with the chemical and their relative severity. Available data means the normal research materials used by this facility to include (Note to plan developer: name references you have for this purpose) and necessary internet research. The Label Manager should maintain a record of the source material used to determine the label elements.

o Identify the hazards of the chemical and the relative degree of severity of the health, flammability, and instability hazards. Indicate hazard severity by the numerical rating ranging from zero (0) indicating a minimal hazard, to four (4) indicating a severe hazard. The hazards are arranged in the color coded ‐diamonds: blue for health, red for flammability, and yellow for instability, and white for special hazards. The only authorized symbols are the W and OX symbols described above. Many people ask about a "corr" for corrosive or "acid" for acids, but these hazards are already taken into account in the health rating. (Note to plan developer: Some users modify this system in order to use the white section for PPE instead of special hazards. Management must adopt this change if that is what they want.

If you choose to use the Hazardous Materials Information System then use the following under Workplace Labeling:)

XYZ Company has adopted the Hazardous Materials Information System (HMIS) labeling system for workplace labeling of Containers of Hazardous Chemicals.

The individual responsible for developing and affixing the proper label to each container of hazardous chemicals is the person designated as the HCS Label Manager.

The HCS Label Manager is responsible to ensure that the use of this system is compliant with the GHS. The Label Manager shall follow these guidelines:

o The Hazardous Materials Information System (HMIS) is a color and number coded system. The system uses a color-coded square with four rows in which numbers are used to signal the degree of health hazard, flammability hazard, and reactivity hazard. A letter in the bottom row is used to indicate the personal protective equipment that should be used with the chemical.

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HealthThe Health section conveys the health hazards of the material. The blue Health bar has two spaces, one for an asterisk and one for a numeric hazard rating.

If present, the asterisk signifies a chronic health hazard, meaning that long-term exposure to the material could cause a health problem such as emphysema or kidney damage. The numeric hazard assessment procedure is different than that used by NFPA. Here are the numeric rankings for the HMIS system:

4 Life-threatening, major or permanent damage may result from single or repeated overexposures.

3 Major injury likely unless prompt action is taken and medical treatment is given.

2 Temporary or minor injury may occur.

1 Irritation or minor reversible injury possible.

0 No significant risk to health.

FlammabilityThe criteria used to assign numeric values (0 = low hazard to 4 = high hazard) are identical to those used by NFPA 704. In other words, in this category, the systems are identical.

4 Flammable gases, or very volatile flammable liquids with flash points below 73 °F, and boiling points below 100 F. Materials may ignite spontaneously with air.

3Materials capable of ignition under almost all normal temperature conditions. Includes flammable liquids with flash points below 73 °F and boiling points above 100 °F, as well as liquids with flash points between 73 °F and 100 °F.

2 Materials which must be moderately heated or exposed to high ambient temperatures before ignition will occur. Includes liquids having a flash point at or

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above 100 °F but below 200 °F.

1 Materials that must be preheated before ignition will occur. Includes liquids, solids and semi solids having a flash point above 200 °F.

0 Materials that will not burn.

Physical HazardReactivity hazards are assessed using the OSHA criterion of physical hazard. Seven such hazard classes are recognized:

Water Reactives Organic Peroxides Explosives Compressed gases Pyrophoric materials. Oxidizers Unstable Reactives

This version replaces the now-obsolete yellow section titled Reactivity. As with the Health and Flammability sections, the level of hazard is indicated using numeric values (0 = low hazard to 4 = high hazard):

4 Materials that are readily capable of explosive water reaction, detonation or explosive decomposition, polymerization, or self-reaction at normal temperature and pressure.

3Materials that may form explosive mixtures with water and are capable of detonation or explosive reaction in the presence of a strong initiating source. Materials may polymerize, decompose, self-react, or undergo other chemical change at normal temperature and pressure with moderate risk of explosion.

2Materials that are unstable and may undergo violent chemical changes at normal temperature and pressure with low risk for explosion. Materials may react violently with water or form peroxides upon exposure to air.

1Materials that are normally stable but can become unstable (self-react) at high temperatures and pressures. Materials may react non-violently with water or undergo hazardous polymerization in the absence of inhibitors.

0 Materials that are normally stable, even under fire conditions, and will not react with water, polymerize, decompose , condense, or self-react. Non-explosives.

Personal ProtectionThis is the largest area of difference between the NFPA 704 and HMIS systems. In the NFPA system, the white area is used to convey special hazards whereas HMIS uses the white section to indicate what personal protective equipment (PPE) should be used when working with the material.

HMIS uses a letter coding system for this section. This presents a major problem since employees must memorize what the letters stand for. It is much better to modify this system to list the PPE instead of having employees try to remember code letters or consult a chart.

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Also, the "custom letter codes" aspect is particularly dangerous for visitors and contractors who may not remember/recognize that these could vary from job site to job site.

Presented below is the lettering scheme along with a series of graphics meant to reinforce the meaning of each letter:

HMIS Letter Required Equipment

A

B

C

D

E

F

G

H

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I

J

K

From available data determine the hazards associated with the chemical and their relative severity. Available data means the normal research materials used by this facility to include (Note to plan developer: name references you have for this purpose) and necessary internet research. The Label Manager should maintain a record of the source material used to determine the label elements.

Identify the hazards of the chemical and the relative degree of severity of the health, flammability, and physical hazards. Indicate hazard severity by the numerical rating ranging from zero (0) indicating a minimal hazard, to four (4) indicating a severe hazard. The hazards are arranged in the color coded section: blue for health, red for ‐flammability, and orange for physical hazards. The white section indicates required PPE. (Note to plan developer: Some users modify this system in order to use the white section for PPE instead of special hazards. Management must adopt this change if that is to show specific PPE required rather than a letter code as explained above. If management determines to follow this recommendation you should note it here.)

(Note to plan developer: Some employers choose to adopt both NFPA 704 and HMIS as their workplace labeling systems. This is sometimes done because the two systems are similar and therefore do not present a large training burden or burden on employees to remember. It is seen as an advantage because many hazardous chemicals used in your facility will come with one of these labeling systems already on them. In that case, if you have not adopted both systems you would have to remove the system that was not adopted and replace it with the one you did adopt.)

(Note to plan developer: DOT labels are already on hazardous chemical containers that are shipped to your facility. Often only employees involved in shipping and receiving are trained to understand DOT labels. If these labels are left on containers in your workplace your employees should be trained to understand them. In that case, you would designate those procedures here.)

3. Other Forms of Warning:

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Hazards of Non-routine Tasks - Hazards associated with any tasks within this facility that are not covered by this plan are covered by another plan or program. (Note to plan developer: This statement must be made as a result of a thorough evaluation to ensure that it is correct.)

Hazards Associated with Chemicals Contained in Unlabeled Pipes - All pipes containing hazardous chemicals within this facility have been marked by color coded striping approximately every 15 feet on the pipe. A color code cross reference is contained in every SDS manual with corresponding SDSs.

(Note to plan developer: If your facility utilizes other forms of warning besides labels you should insert an explanation here.)

D. Safety Data Sheets

1. Maintenance and Availability of Safety Data Sheets (SDS)

No hazardous chemical will be accepted by this facility unless it is accompanied by a Safety Data Sheet (SDS). Upon receipt of any hazardous chemical for which a Safety Data Sheet (SDS) has not been previously reviewed and incorporated into this facilities Hazard Communications System the chemical shall remain in secure storage allowing no employees to be exposed to it. The receiving supervisor shall immediately notify the safety director and provide the safety director with a copy of the SDS. The safety director shall insure proper training of potentially exposed employees and incorporation of the SDS into the facility's SDS system before the hazardous chemical is used in the facility.

When an updated SDS is received the safety director shall review it and determine if new information requires immediate action to protect employees. The safety director shall insure that the existing SDS is replaced with the new one as soon as reasonably practicable. He/She shall also determine, plan, and implement any additional training requirements resulting from the new information on the SDS.

(Note to plan developer: The location of SDSs in the workplace varies from facility to facility. Sometimes they are kept in the individual work areas in which they are used. Sometimes they are kept in 1 central location. The following is offered as an example and would have to be made site specific by you.)

Safety Data Sheets (SDS) shall be maintained in the 6 (or however many there are in your workplace) designated work areas. Only the SDSs used in that work area will be kept there. All SDSs for the specific work area shall be maintained in a binder clearly marked "Safety Data Sheets (SDS)". The binders shall be located in the designated and marked Safety Data Sheet Station for each designated work area.

All employees shall have access to all SDSs at all times. Any employee who desires to review a SDS before exposure or continued exposure to any hazardous chemical may do so without any further exposure to that chemical prior to attaining the information they desire. In the event an employee reviews a SDS but still does not understand the hazard data they are seeking they may consult with their supervisor for help prior to any further exposure to that chemical. Once an employee desires hazard data for a chemical they

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may be exposed to they will not be required to work in any fashion that may expose them to that chemical until they receive the hazard data they are seeking.

(Note to plan developer: If you do not manufacture hazardous chemicals you do not need to enter guidelines for developing Safety Data Sheets here.)

2. Development of Safety Data Sheets (SDS)

Safety Data Sheets will be developed by the employee with the highest level of knowledge of the hazards of the chemical. (Note to plan developer: Specify who that person is here.)

Safety Data Sheets shall be developed in accordance with Appendix D of 1910.1200 a copy of which is attached to this document.

E. Employee Information and Training

1. Training Frequency:

All employees shall receive the standard hazard communication course annually.

All employees shall receive hazard communication update training when any hazard or hazard information pertinent to their work area changes.

All employees shall receive hazard communication refresher training at any time they demonstrate a lack of the knowledge necessary to work safely with a hazardous chemical. The content of this training shall be determined by the need demonstrated.

2. Training of Outside Employees:

All persons performing work within this facility who are not employees of XYZ Company must successfully complete the course "Site Specific Training Course for Employees of External Employers"

3. The Annual Hazard Communication Course Content

Chemical Terms and Conceptso CAS numbero PELo TLVo pHo Melting Point/Freezing Pointo Initial Boiling Point and Boiling Rangeo Flash Pointo Evaporation Rateo Flammability (solid, gas)o Flammable or Explosive Limitso Vapor Pressure

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o Vapor Densityo Relative Densityo Solubilityo Partition Coefficient: n-octanol/watero Auto-Ignition Temperatureo Decomposition Temperatureo Viscosityo Reactivityo Chemical Stabilityo Possibility of Hazardous Reactionso Conditions to Avoid (e.g., static discharge, shock, or vibration)o Incompatible Materialso Hazardous Decomposition Productso Toxicological Effects o Routes of Exposureo Symptoms Related to Physical, Chemical and Toxicological Characteristicso Delayed and Immediate Effects of Exposureo Chronic Effects of Exposureo Numerical Measures of Toxicityo Carcinogenso Ecotoxicity o Persistence and Degradabilityo Bioaccumulative Potentialo Mobility in Soilo Other Adverse Environmental Effects o Disposal of Hazardous Wasteo UN Numbero UN Proper Shipping Nameo Transport Hazard Classo Packing Groupo Environmental Hazards in Shippingo Transport in Bulk o Special Precautions in Transporto Applicable Safety, Health and Environmental Regulations

Hazard Identification

Hazard Classificationo Signal Wordo Hazard Statemento Symbolo Precautionary Statements o Hazard Symbols o Hazards Not Otherwise Classified o Statement of ingredient(s) of unknown acute toxicityo Trade Secrets

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Labelso Labels for Containers Leaving the Workplace

The Globally Harmonized System (GHS) o Labels for Containers Not Leaving the Workplace

GHS NFPA 704 (if adopted for your facility) HMIS (if adopted for your facility) DOT (if adopted for your facility)

Safety Data Sheetso Design

Sections Content

o Location Work Areas

o Availabilityo At All Times to Employees

Employees Should Not Continue to Use the Chemical Until They Get the Hazard Information They Seek

o Available to OSHA Upon Requesto Available to Employee Representative Upon Written Request

4. Hazard Communication Refresher Course Content

The content of refresher training shall be determined by the supervisor or safety director based upon the demonstrated failure of the employee to have the knowledge necessary for safe work

5. Site Specific Training Course for Employees of External Employers Course Content

This course shall include all aspects of Hazard Communication training outlined in this plan that the employee has not already received from his/her employer. When said employee has received proper Hazard Communication training from their employer this course would be limited to site specific information.

The content of this course shall include all Hazard Communication information specific to this facility including:

o Labeling used at this facility for which the student has not received prior trainingo A review of the list of hazardous chemicals in this facilityo The location of SDSs in this facilityo A review of facility emergency procedureso A review of the SDSs for chemicals the student may be exposed to