CPL 2-2.38D Appendix D, Guide for Reviewing MSDS &hellips;CPL 2-2.38D, App D
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CPL 2-2.38D - Appendix E
Sample Hazard Communication Programs (A & B)
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
NOTE: The following model programs are provided only as guidelines to assist in complying with 29 CFR 1910.1200. They are not intended to supersede the requirements of 29 CFR 1910.1200. Employers should review the Hazard Communication Standard for particular requirements which are applicable to their workplaces.
SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM (A)
Company Policy
To ensure that information about the dangers of all hazardouschemicals used by (Name of Company) are known by all affected employees, the following hazardous information program has been
established:
All work units of this company will participate in the hazard communication program. This written program will be available in the (location) for review by any interested employee.
The (person/position) will verify that all containers received for use will be clearly labeled as to the contents, note the appropriate hazard warning and list the name and address of the manufacturer.
The (person/position) in each section will ensure that all secondary
containers are labeled with either an extra copy of the original manufacturer's label or with labels that have the identity and the appropriate hazard warning. For help with labeling, see (person/position).
On the following individual stationary process containers, we are
using (description of labeling system used) rather than a label to convey the required information.
We are using an in-house labeling system which relies on (provide a description of any in-house system which used numbers or graphics to convey hazard information.)
The (person/position) will review the company labeling procedures every (provide a time period) and will update labels as required.
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
The (person/position) is responsible for establishing and monitoring the company MSDS program. He/she will make sure procedures are developed to obtain the necessary MSDSs and will review incoming
MSDSs for new or significant health and safety information. He/she will see that any new information is passed on to affected employees. The procedure below will be followed when an MSDS is not received at the time of initial shipment:
(Enter procedure to be followed here.)
Copies of MSDSs for all hazardouschemicals to which employees are
exposed or are potentially exposed will be kept in (state location).
MSDSs will be readily available to all employees during each work shift. If an MSDS is not available, contact (person/ position).
MSDSs will be readily available to employees in each work area using the following format:
When revised MSDSs are received, the following procedures will be followed to replace old MSDSs:
(Describe procedures.)
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
The (person/position) is responsible for the Hazard Communication Program. He/she will ensure that all program
elements specified below are carried out.
Prior to starting work, each new employee will attend a health and
safety orientation that includes the following information and training:
Steps the company has taken to reduce or prevent exposure
to hazardouschemicals.
Procedures to follow if employees are overexposed to hazardouschemicals.
How to read labels and MSDSs to obtain hazard information.
Location of the MSDS file and written hazard communication program. [If you are using an electronic access method such as a database or on-line service you will need to ensure that your employees know how to utilize the system to retrieve MSDS's - ILPI]
Prior to introducing a new chemicalhazard into any section of this company, each employee in that section will be given information and training as outlined above for the new chemical hazard. The training format will be as follows:
Periodically, employees are required to perform non-routine tasks which are hazardous. Some examples of non-routine tasks are: confined space entry, tank cleaning, and painting reactor vessels. Prior to starting work on such projects, each affected employee will be given information by the (person/position) about the hazardouschemicals he or she may encounter during such activity. This information will include specific chemical hazards, protective and safety measures the employee can use, and steps the company is taking to reduce the hazards, including ventilation, respirators, the presence of another employee (buddy systems), and emergency procedures.
Examples of non-routine tasks performed by employees of this
company are:
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
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Informing other Employers
It is the responsibility of (person/position) to provide other employers with information about hazardouschemicals their employees may be exposed to on a job site and suggested precautions for employees. It is the responsibility of (person/ position) to obtain information about hazardouschemicals used by other employers to which employees of this company may be exposed.
In addition to providing a copy of an MSDS to other employers, other employers will be informed of precautionary measures needed to be taken to protect their employees who are exposed to operations
performed by this company.
Also, other employers will be informed of the hazard labels used by
the company. If symbolic or numerical labeling systems are used, the other employees will be provided with information to
understand the labels used for hazardouschemicals for which their employees may have exposure.
The following is a list of all known hazardouschemicals used by our employees. This list includes the name of the chemicalmanufacturer,
the work area the chemicals are used in, the dates of use, and the quantity used. Further information on each chemical may be obtained from the MSDSs which are located (state location).
Hazardous Chemical Inventory
Chemical
Manufacturer
Work Area
Start Date
Finish Date
Quantity
(Include here the chemical list developed during inventory. Arrange this list so that you are able to cross-reference it with your MSDS file and labels on your containers. Additional information such as the manufacturer's telephone number, an emergeny number, scientific name, CAS number, the associated task ec., could be included and might be found useful to employees and the employer.)
When new chemicals are received, this list is updated (including date the chemicals were introduced), within 30 days of introduction into the workplace. To ensure that the chemical is added in a timely manner, the following procedures shall be followed:
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
Chemicals in Unlabeled Pipes
Work activities are sometimes performed by employees in areas where chemicals are transferred through unlabeled pipes. Prior to starting work in these areas, the employee shall contact
(person/position) for information regarding:
The chemical in the pipes.
Potential hazards.
Safety precautions to be taken.
(Include here the chemical list developed during inventory. Arrange this list so that you are able to cross-reference it with your MSDS file and labels on your containers. Additional information such as the manufacturer's telephone number, an emergeny number, scientific name, CAS number, the associated task ec., could be included and might be found useful to employees and the employer.)
Program Availability
A copy of this program will be made available, upon request, to employees and their representatives.
Notes for Chemical Manufacturers, Importers, and Distributors
Hazard Determination - Chemicalmanufacturers and importers are to detail the methods they will use to conduct a hazard determination for the chemicals produced or imported in their work places. The procedures should identify the system in place to conduct hazard determinations. The system should identify the person or department responsible for conducting the hazard determination and the research strategy involved. Chemical manufacturers which
rely on information from upstream suppliers should state this in their written program.
Transmittal of MSDSs - Chemicalmanufacturers, importers, and distributors should develop a system to ensure that material safety data sheets are transmitted to customers. The
system should identify the person or department responsible for ensuring the transmittal of material safety data sheets and should include a method to ensure that transmittal is accomplished as required by 29 CFR 1910.1200.
Updating Labels/MSDSs - A system should be detailed assigning responsibility and periodic review of scientific information required to update material safety data sheets and labels as
required by 29 CFR 1910.1200.
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
11. Does the training program provide information on appropriate first aid, emergency procedures, and the likely symptoms of overexposure?
12. Does the training program include an explanation of labels and warnings that are used in each work area?
13. Does the training describe where employees obtain data sheets and how employees use them?
14. Is a system in place to ensure that new employees are trained before beginning work?
15. Is a system in place to identify new hazardouschemicals before they are introduced into a work area?
16. Is a system in place to inform employees of the hazards associated with newly introduced chemicals?
SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM (B)
Introduction:
The Hazard Communication Standard requires you to develop a written hazard communication program. The following is a sample hazard communication program that you may use as a guide in
developing your program.
Our Hazard Communication Program
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
This program applies to all work operations in our company where you may be exposed to hazardouschemicals under normal working conditions or during an emergency situation.
The safety and health (S&H) manager, Robert Jones, is the program coordinator, acting as the representative of the plant manager, who has overall responsibility for the program. Mr. Jones will review and update the program, as necessary. Copies of the written program may be obtained from Mr. 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.
The safety and health manager will make a list of all hazardouschemicals and related work practices used in the 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 MSDS for each chemical. A master list of these chemicals will be maintained by, and is available from Mr. Jones' office, Room SD-10.
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
MSDSs provide you with specific information on the chemicals you use. The safety and health manager, Mr. Jones, will maintain a binder in his office with an MSDS on every substance on the list of hazardouschemicals. The plant manager, Jeff O'Brien, will ensure that each work site maintains MSDSs for the hazardous chemicals in each work area. MSDSs will be made readily available to you at your work stations during your shifts.
The safety and health manager, Mr. Jones, is responsible for acquiring and updating MSDSs. He will contact the chemicalmanufacturer or vendor if additional research is necessary or if an MSDS has not been supplied with an initial shipment. All new procurements for the company must be cleared by the
safety and health manager. A master list of MSDSs is available from Mr. Jones in Room SD-10.
Labels and Other Forms of Warning
The safety and health manager will ensure that all hazardouschemicals in the plant are properly labeled
and updated, as necessary. Labels should list at least the chemical identity, appropriate hazard warnings, and the name and address of the manufacturer, importer or other responsible party. Mr. Jones will refer to the corresponding MSDS 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 property 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 hazard information. On stationary process equipment, regular process sheets, batch tickets, blend tickets, and similar written materials will be substituted for container labels when these documents contain the same information as labels. These written materials will be made readily available to you during your work shift.
If you 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. Pipes or piping systems will not be labeled but their contents will be described in training sessions.
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 of the hazardouschemicals to
which you might be exposed and the precautions you must take to reduce or avoid exposure.
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.
Everyone who works with or is potentially exposed to hazardouschemicals will receive initial training
on the Hazard Communication Standard and the safe use of those hazardous chemicals. The safety and health manager will conduct these training sessions. 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 program will emphasize these items:
A summary of the standard and this company's written program.
The health hazards, including signs and symptoms of exposure, of the chemicals in work area and any medical condition known to be aggravated by exposure to these chemicals.
Procedures to protect against chemical hazards (e.g., required personal protective equipment, and its proper use and maintenance; work practices or methods to ensure appropriate use and handling of chemicals; and procedures for emergency response).
Work procedures to follow to assure protection when cleaning hazardouschemical spills and leaks.
The location of the MSDSs, how to read and interpret the information on labels and MSDSs, and how employees may obtain additional hazard information.
The safety and health manager or his/her designee will review the employee training program and advise the plant manager on training or retraining needs. Retraining is required when the hazard changes or when a new hazard is introduced into the workplace. 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 improvement.
Contractor Employers
The safety and health manager, Robert Jones, upon notification by the responsible supervisor, will advise outside contractors, in person, of any chemicalhazards 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, Mr. Jones will notify these individuals of the location and availability of MSDSs. Each contractor bringing chemicals on-site must provide Mr. Jones
with the appropriate hazard information for these substances, including MSDSs, labels, and precautionary measures to be taken when working with or around these chemicals.
Additional Information
All employees, or their designated representatives, can obtain further information on this written program, the hazard communication standard, applicable MSDSs, and chemical information lists at the safety and health office, Room SD-10.
This version of the inspection procedures for the OSHA HazCom Standard is no longer valid. It is presented here solely for historical purposes and has been replaced by CPL 02-02-079 effective July 9, 2015. The subjects of the Appendices have also changed.