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Chemical Hazard Communication Program Template
Chemical Hazard Communication Program Template
Chemical Hazard Communication Program
Table of Contents
I.OBJECTIVE AND SCOPE
II.DEFINITIONS
III.RESPONSIBILITIES
A.Chemical Hazard Communication Program Manager
B.Management
C.Supervisors
D.Employees
E.Third Party Contractors
IV.PROCEDURE
A.Container Labeling
1.Incoming Chemicals
2.Chemical Products Manufactured or Packaged at Facility
3.Temporary Containers
B.MSDSs (Material Safety Data Sheets)
C.Hazardous Chemicals List
D.Chemicals in Unlabeled Pipes
E.Non-Routine Tasks
F.Informing Other Employers/Third Party Contractors
G.Program Availability
V.TRAINING
A.Employee Training
B.Employee Testing
C.Training Records
VI.REFERENCES
A.Regulatory Reference
B.NCH Policy Reference
VII.APPENDICES
Appendix A Acknowledgement of Receipt of Chemical Hazard Communication Training
Appendix B Hazardous Chemicals List
Appendix C Company System for Temporary Container Labeling
Appendix D Chemical Hazard Communication Test
VIII.DOCUMENT CONTROL
Chemical Hazard Communication Program
for
[Company Name/Location]
I.OBJECTIVE AND SCOPE
This program is intended to describe the procedures for evaluating, identifying and communicating to affected employees the appropriate information concerning the identity and hazards of chemicals present in the workplace at [Company Name/Location], so that employees may perform their job duties in a safe manner. The Chemical Hazard Communication Program applies to all company functional units, operations and areas where employees may be exposed to hazardous chemicals under normal working conditions or during an emergency situation. The procedures described in this Program are intended to facilitate compliance with applicable governmental regulations. If there is a conflict between this Program and a governmental regulation, the governmental regulation will apply and this Program will be modified. However, all other requirements in this Program apply even if more stringent than governmental regulations.
II.DEFINITIONS
Chemical. Any element, chemical compound or mixture of elements and/or compounds.
Chemical Name. The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name which will clearly identify the chemical for the purpose of conducting a hazard evaluation.
Combustible Liquid. Any liquid having a flashpoint at or above 140 deg. F (60.0 deg. C).
Common Name. Any designation or identification such as code name, code number, trade name, brand name or generic name used to identify a chemical other than by its chemical name.
Compressed Gas.
1. A gas or mixture of gases having, in a closed container, an absolute pressure exceeding 40 psi (pounds per square inch) at 70 deg. F (21.1 deg. C).
2. A gas or mixture of gases having, in a closed container, an absolute pressure exceeding 104 psi (pounds per square inch) at 130 deg. F (54.4 deg. C) regardless of the pressure at 70 deg. F (21.1 deg. C).
3. A liquid having a vapor pressure exceeding 40 psi (pounds per square inch) at 100 deg. F (37.8 deg. C) as determined by ASTM D-323-72.
Container. Any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage tank, tote tank, or the like that contains a hazardous chemical.
Employee. A worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies.
Explosive. A chemical that causes a sudden, almost instantaneous release of pressure, gas, and heat when subjected to sudden shock, pressure, or high temperature.
Exposure or Exposed. An employee, while in the course of employment, is subjected to a chemical that is a physical or health hazard, and includes potential (e.g. accidental or possible) exposure. "Subjected to a chemical in terms of health hazards includes an exposure to any bodily route of entry (e.g. inhalation, ingestion, skin contact or absorption.)
Flammable Liquid. Any liquid having a flashpoint below 140 deg. F (60.0 deg. C).
Flammable Solid. A solid, other than a blasting agent or explosive, that is liable to cause fire through friction, absorption of moisture, spontaneous chemical change, or retained heat from manufacturing or processing, or which can be ignited readily and when ignited burns so vigorously and persistently as to create a serious hazard.
Flashpoint. The minimum temperature at which a liquid gives off a vapor in sufficient concentration to ignite when tested under standardized test protocols.
Foreseeable Emergency. Any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace.
Hazardous Chemical. Any chemical, or mixture of chemicals, which is a physical hazard or a health hazard.
Hazard Warning. Any words, pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the specific physical and health hazard(s), including target organ effects, of the chemical(s) in the container(s). (See the definitions for "physical hazard" and "health hazard" to determine the hazards which must be covered.)
Health Hazard. A chemical for which there is statistically significant evidence based on at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in exposed employees. The term "health hazard" includes, but is not limited to, chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes.
Identity. Any chemical or common name which is indicated on the MSDS for the chemical. The identity used shall permit cross-references to be made among the list of hazardous chemicals, the label and the MSDS.
IPCS. International Program on Chemical Safety, a joint program of three cooperating organizations--the World Health Organization, the International Labor Organization, and the United Nations Environment Program. Main goals of the IPCS are to establish the scientific basis for safe use of chemicals and to strengthen national capabilities and capacities for chemical safety.
Mixture. Any combination of two or more chemicals if the combination is not, in whole or in part, the result of a chemical reaction.
MSDS (Material Safety Data Sheet). A detailed document containing health, safety and environmental information on a hazardous chemical or product that is organized in a standardized format. Examples of such documents include the U.S. OSHA Material Safety Data Sheet and the IPCS International Chemical Safety Card. [The definition above and/or usage of the term MSDS in this Program should be revised as necessary to incorporate the terminology appropriate for this facility and the region in which it is located.]
Organic Peroxide. An organic compound that contains the bivalent -O-O-structure and which may be considered to be a structural derivative of hydrogen peroxide where one or both of the hydrogen atoms has been replaced by an organic radical.
Oxidizer. A chemical, other than a blasting agent or explosive, that initiates or promotes combustion in other materials, thereby causing fire either of itself or through the release of oxygen or other gases.
Physical Hazard. A chemical for which there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive) or water-reactive.
Pyrophoric. A chemical that will ignite spontaneously in air at a temperature of 130 deg. F (54.4 deg. C) or below.
Temporary Container. A portable container, into which a chemical is transferred by an employee, used for temporary storage and/or dispensing by employees. A temporary container may be filled, used, emptied and refilled with different chemicals by employees during a work shift, or it may be used with the same chemical for one or more work shifts. The labeling of each temporary container must be based on its current contents, in accordance with the company system for temporary container labeling.
Unstable (reactive). A chemical which in the pure state, or as produced or transported, will vigorously polymerize, decompose, condense, or will become self-reactive under conditions of shocks, pressure or temperature.
Use (or using a chemical). To package, handle, react, emit, extract, generate as a byproduct, move or transfer.
Water-Reactive. A chemical that reacts with water to release a gas that is either flammable or presents a health hazard.
III.RESPONSIBILITIES
A.Chemical Hazard Communication Program Manager
[Responsible Person] shall exercise overall management of the Chemical Hazard Communication Program for [Company Name/Location]. The Chemical Hazard Communication Program Manager will ensure that the written Program is accurate and up to date. He or she shall review the written Program and revise it as necessary, but in no case less than annually. The Chemical Hazard Communication Program Manager shall also maintain all training records pertaining to this Program unless another employee is designated under the facility Training Plan.
B.Management
Company management shall provide necessary resources to ensure the elimination or minimization of hazards associated with the handling of chemicals by inadequately trained employees and improperly labeled chemicals in the workplace. Company management shall review applicable governmental regulations which apply to operations of [Company Name/Location] and ensure that adjustments or revisions to this Program are made accordingly.
[Facility Manager Name], as Facility Manager, shall ensure that site-specific information, based the type and nature of facility operations, is included in the Program as necessary to ensure that the Program is effective and comprehensive.
C.Supervisors
Supervisors will ensure proper adherence to this program through regular review of actual practices. Supervisors shall themselves follow this Program and ensure that their employees are trained to follow the Program and that they utilize proper work practices as described in the Program.
D.Employees
Employees are responsible for following the procedures described in this Program. Employees shall:
1. know the hazards of the chemicals with which they work.
2. know not to use and to report unlabeled containers.
3. know where and how to get an MSDS.
Employees shall report to their supervisor any deviations from the Program which are observed.
E.Third Party Contractors
Contractor employees shall be responsible for complying with this Program, and conformance shall be verified by [Responsible Person].
IV.PROCEDURE
The following chemical hazard communication procedures are implemented to enhance the safety of our employees and environment, as well as to facilitate compliance with applicable governmental regulations.
A.Container Labeling
Each container of a hazardous chemical that is present in or around the work area must be properly labeled with the identity of the hazardous material, the appropriate hazard warnings, and the name and address of the manufacturer. Appropriate labels must be on all containers, regardless of size. When labeling deficiencies are discovered, employees must notify their supervisor.
1.Incoming Chemicals
Employees will verify, at the time of receiving, that all containers of chemicals and chemical products received at the facility are clearly labeled as to the contents, appropriate hazard warning(s), and the manufacturer's name and address. Upon discovery, employees must ensure that any worn, torn or illegible labels are replaced.
2.Chemical Products Manufactured or Packaged at Facility
[If no chemical products are manufactured or packaged at this facility, the written Program must be revised accordingly.]
For drums and other containers into which chemical products manufactured and/or packaged at our facility are transferred by our employees, [Company Name/Location] uses a company product labeling system that consists of [Description of the company system for labeling containers of chemical products manufactured and/or packaged at this facility, such as a system that requires the application of a company product label to each container.] The supervisor in each department or functional unit will ensure that containers filled with company products by our employees are labeled in accordance with the company product labeling system.
For stationary process tanks or vessels, we use the following method to convey the required chemical identification and hazard information for the contents of each tank or vessel: [Description of hazard communication system used, such as labeling of individual tanks or alternate system, as applicable. If no stationary process tanks or vessels are present in the facility, record the note: NOT APPLICABLE.] The areas or functional units in which such process tanks or vessels are located are:
[List of the areas or functional units in which these process tanks or vessels are located, or record the note: NOT APPLICABLE]
3.Temporary Containers
For temporary containers into which chemicals are transferred by our employees, [Company Name/Location] uses a container labeling system that consists of [Description of facility system for labeling temporary containers.] The supervisor in each department or functional unit will ensure that all temporary containers filled by employees are labeled in accordance with the temporary container labeling system. In addition, the container type and construction must be approved as suitable for containment of the particular chemical(s) involved.
B.MSDSs (Material Safety Data Sheets)
An MSDS contains detailed information about chemicals and associated hazards. MSDSs for all chemicals present in the workplace at [Company Name/Location] will be maintained in such a fashion and in one or more designated locations for employees to view in their work area during their work shift. The MSDSs may be kept in an electronic form that is readily accessible via the internet or other computer system. At least one printed copy of each MSDS shall be kept on site. Printed copies of MSDSs will be kept at [list of location(s) at which printed MSDSs are kept]. Computer access to MSDSs for employees is available at [list of the location(s) and functional units at which employees may access MSDSs via computer]. In addition to chemicals produced by NCH Corporation, these requirements apply to any hazardous chemical obtained from an outside manufacturer that is used or present in the workplace, such as a container of non-NCH paint kept on a storage shelf in the facility. Duplicate copies of each printed MSDS required shall be maintained by [Responsible Person].
[Responsible Person] is responsible for establishing and monitoring the company MSDS program. He/she shall use the following procedures to obtain and update MSDSs:
1. If the initial shipment of a hazardous chemical is received without a proper MSDS, the receiving person must immediately notify [Responsible Person].
2. Before the hazardous chemical is released for use in the facility or for storage in the company warehouse, the supplier, manufacturer or distributor of the product must be contacted and asked to fax or email the missing MSDS and send another copy via mail as a follow up.
3. If, for any reason, the supplier of the hazardous chemical is unable to produce an MSDS upon request, the hazardous chemical will not be released for use and it will be held in [Identification/description of the special holding area for hazardous chemicals without MSDSs] until such time the chemical is either returned to the supplier or the MSDS is received.
The file(s) of MSDSs in the facility file(s) must be maintained and kept up to date. When applicable, an updated version of an MSDS will be obtained and inserted into the facility file(s) to replace the obsolete version(s). Obsolete versions shall also be retained and must not be discarded. When an obsolete MSDS is replaced by an updated copy, the obsolete version will be retained in a separate file of obsolete MSDSs. The file of obsolete MSDSs is located at/in [location of the file of obsolete MSDSs].
C.Hazardous Chemicals List
A list of all hazardous chemicals used by employees at [Company Name/Location] is maintained by [Responsible Person]. For each chemical, the Hazardous Chemicals List shall include:
1.the identity or name that is on the container label and on the appropriate MSDS.
2.the manufacturer or supplier of the chemical.
3.the work area(s) in which the chemical is used or present.
The List may include additional information, such as:
1.specific chemical hazards.
2.date of first use.
3.the manufacturer's telephone number.
4.an emergency number.
5.quantity used each year.
6.maximum quantity on site.
The list is compiled for [Description of how the list is compiled, such as: for individual work areas, for the workplace as a whole, or both and a description of any additional information that is included on the List(s). In addition, the location(s) of where the List(s) are kept is to be included here].
When the initial shipment of a chemical is received, the chemical must be added to the Hazardous Chemicals List. To ensure that any new chemical is added to the List in a timely manner, refer to New Chemical Approval Program.
D.Chemicals in Unlabeled Pipes
Work activities may be performed by employees in areas where chemicals are transferred through unlabeled pipes. Prior to starting work in these areas, the employee shall contact his/her supervisor for information regarding the chemicals in the pipes, potential hazards and required safety precautions. See also the [Company Name/Location] Pipe Marking Program.
E.Non-Routine Tasks
Periodically, employees may be required to perform non-routine tasks that involve chemical hazards. Prior to starting work on such projects, each affected employee will be given information by his/her supervisor about the hazardous chemicals he or she may encounter during such activity. This information will include specific chemical hazards, protective and safety measures the employee should use, and steps the company is taking to reduce the hazards, such as ventilation, respirators, the required presence of another employee or employees, and emergency procedures to be followed.
Examples of non-routine tasks performed by employees of this company are:
TASK
HAZARDOUS CHEMICAL
[Descriptions of non-routine tasks, such as: confined space entry, tank cleaning etc.]
[Identities of hazardous chemicals involved]
F.Informing Other Employers/Third Party Contractors
It is the responsibility of [Responsible Person] to provide other employers and third party contractors who come onto our property with information about hazardous chemicals resulting from our operations that their employees may be exposed to at a job site and suggested precautions for employees. In addition, it is the responsibility of [Responsible Person] to obtain information about hazardous chemicals used by other employers/third party contractors to which our employees may be exposed, and to communicate this information to our appropriate supervisor(s).
Other employers/contractors on site will be informed of the type of chemical hazard labels used by our company. If symbolic or numerical codes are used on the labels, the other employers will be provided with information necessary to understand the labels used for hazardous chemicals for which their employees may have exposure.
Other employers and contractors will also be given access to, or be provided with copies of, MSDSs for hazardous chemicals used by our company to which their employees may be exposed.
In addition, other employers/third party contractors on site will be informed of necessary precautionary measures to protect their employees from chemical exposure that may result from operations performed by our company.
G.Program Availability
Upon request, a copy of this written Chemical Hazard Communication Program shall be made available for review by any employee.
V.TRAINING
A.Employee Training
[Responsible Person] is responsible for ensuring employees receive training required by the Chemical Hazard Communication Program.
Each employee who works with or is potentially exposed to hazardous chemicals will receive initial training on governmental regulations applicable to Chemical Hazard Communication and the requirements of the Program before starting work. Each new employee will satisfactorily complete training that includes the following information:
1.An overview of the OSHA hazard communication standard.
2.The hazardous chemicals present at his/her work area.
3.The physical and health risks of hazardous chemicals in the workplace.
4.Symptoms of overexposure.
5.How to determine the presence or release of hazardous chemicals in the work area.
6.How to prevent or reduce exposure to hazardous chemicals through use of control procedures, work practices and personal protective equipment.
7.Steps the company has taken to reduce or prevent exposure to hazardous chemicals.
8.Emergency procedures and procedures to follow if employees are overexposed to hazardous chemicals.
9.How to read labels and MSDSs to obtain hazard information.
10.Location of the MSDS file and the written Chemical Hazard Communication Program.
Prior to introducing a new chemical hazard into any functional unit of this company or transferring an employee into to a new area, each employee in that functional unit will be given information and training as outlined above for the new chemical and the associated hazards.
Training for employees will occur:
1.at the time of initial job assignment.
2.when a new physical or health hazard the employees have not previously been trained about is introduced into their work area.
3.when an employee is transferred into a different work area with a new physical or health hazard the employee has not previously been trained about.
4.when a problem is discovered with an affected employee's knowledge of the Program indicating that the employee has not retained the requisite understanding or skill.
B.Employee Testing
As a part of the training, affected employees will be required to demonstrate understanding of this Program by completing a written test. An example of a written test is included in Appendix D.
C.Training Records
Training records will be maintained by [Responsible Person] in accordance with the facilitys Training Plan. An example of a training form, Acknowledgement of Receipt of Chemical Hazard Communication Training, is included in Appendix A.
VI.REFERENCES
A.Regulatory Reference
U.S. Occupation Health and Safety Administration 29 CFR 1910.1200 Hazard Communication Standard.
B.NCH Policy Reference
NCH Global Guideline--Chemical Hazard Communication.
VII.APPENDICES
Appendix A Acknowledgement of Receipt of Chemical Hazard Communication Training.
Appendix B Hazardous Chemicals List.
Appendix C Company System for Temporary Container Labeling.
Appendix D Chemical Hazard Communication Test.
VIII.DOCUMENT CONTROL
This Chemical Hazard Communication Program shall be reviewed annually, or as needed if changes to the facility or workplace operations are made, by [Responsible Person].
Document History
Procedure version
Date Approved
Approved by
Reason for Change
Appendix A
Acknowledgement of Receipt of Chemical Hazard Communication Training
My signature below acknowledges that I have received training concerning Chemical Hazard Communication. I understand that this training fulfills the employee training requirement of [List applicable governmental regulation(s)].
The jobsite and classroom training included the following:
1. Understanding the purpose and scope of [List applicable governmental regulation(s)] and the Chemical Hazard Communication Program at [Company Name/Location].
2. Explanation of the existence of governmental regulations.
3. Definition of the terminology "hazardous chemical".
4. Explanation of situations and elements that must be present for a chemical to be considered a health hazard.
5. Explanation and interpretation of labels, what is required on all containers, and supplier labeling systems.
6. Understanding and interpretation of the MSDS (Material Safety Data Sheet) which must be obtained for each hazardous chemical.
7. My responsibilities as an employee of [Company Name/Location]
8. Policies and procedures to follow in case of chemical emergencies or accidental exposure.
______________________________________________________________________
EMPLOYEE NAME (Please print)
______________________________________________________________________
EMPLOYEE SIGNATURE DATE
______________________________________________________________________
COMPANY REPRESENTATIVE DATE
Appendix B
Hazardous Chemicals List
Chemical Identity
Manufacturer
Or Supplier
Areas in Which Chemical Continually or Regularly Present
Hydrochloric Acid--20 Baume
Rhodia Inc.
Raw Material Warehouse, Production, Receiving Dock
ND-150
Chemsearch
Production, Filling, Shipping Dock, Warehouse B
Yield Aerosol
Chemsearch
Maintenance Shop, Warehouse A
Clorox Regular-Bleach
Clorox
Janitorial Closet, Restrooms
Appendix C
Company System for Temporary Container Labeling
A temporary container is a portable container, into which a chemical is transferred by an employee, and is used for temporary storage and/or dispensing by employees. The XYZ Company labels all temporary containers according to the following system:
1. Whenever a hazardous chemical is transferred into a portable container, the employee transferring the chemical shall attach a portable container label to the container.
2. The portable container label is a standard, fill-in-the-blank label, available from the employees supervisor.
3. The employee must record the required information in the blank spaces provided on the label, based on the information from the appropriate MSDS (Material Safety Data Sheet) or the hazard communication label attached to the container used as the source for the transfer.
4. The completed portable container label must include the identity/name of the hazardous chemical and the applicable hazard warnings.
5. Transfers of chemicals into temporary containers must always be made from a labeled container, tank, vessel or pipe. An employee assigned to perform a transfer of a hazardous chemical must always be certain of the identity of the chemical and the applicable hazard warnings prior to transferring the chemical. If uncertain of the identity of the chemical or its hazards, the employee must contact his or her supervisor.
6. A temporary container may be filled, used, emptied and refilled with different chemicals by employees during a work shift, or it may be used with the same chemical for one or more work shifts.
7. Any obsolete labeling on a temporary container, and any labeling that is not appropriate for the current contents of the container, must be removed.
Appendix D
Chemical Hazard Communication Test
1.You know that a product contains hazardous chemicals if the label has which one of the following hazard warnings on it:
a.WARNING.
b.CAUTION.
c.DANGER.
d.All of the above.
2.There are two types of hazards associated with hazardous chemicals. What are they?
a. Health and Physical Hazards.
b. Medical and Mental Hazards.
c. Employee and Employer Hazards.
d. All of the above.
3.If a chemical is designated as a hazardous chemical, what information, by law, has to be on the container label?
a. Identity of hazardous chemical, appropriate hazard warning, manufacturer's name and address.
b. Hazard warning, net contents, poison control phone number.
c. Identity of hazardous chemical, Material Safety Data Sheet, name of product.
d. All of the above.
4.What do you do if a container label has been defaced or removed?
a. Fill out the "destroyed label" form and turn it in to your supervisor.
b. Separate it from the rest of the containers and call your supervisor to contact the manufacturer to request a new label.
c. No action needs to be taken.
d. Both A and C are correct.
5.What does "MSDS" stand for?
a. Men Safely Delivering Sulfur Dioxide.
b. Material Safety Data Sheet.
c. Maintaining Safe Departmental Standards.
d. None of the above.
6.When should an MSDS be consulted?
a. When you need emergency or first aid information.
b. When you need to know information about special protective chemical handling equipment and procedures.
c. When a spill or fire of a hazardous chemical occurs.
d. All of the above.
7.Where should the MSDSs be located?
a. In the break room.
b. In the work area.
c. We don't have any MSDSs.
d. All of the above.
8.Where would you look to find information regarding proper protective gear for applying product?
a. The label.
b. Ask a co-worker.
c. The MSDS.
d. Both A and C are correct.
9.A written plan of your company's Hazard Communication Program is available to you by:
a. A request through my supervisor.
b. My company does not have a written plan.
c. I am given the plan with my paycheck.
d. A written request to the OSHA committee in New Jersey.
10.An evaluation of the hazardous chemicals in your facility has been made by:
a. A supervisor in your facility.
b. The Environmental Protection Agency.
c. The Internal Revenue Service.
d. The OSHA Regulation Authorities.
11.The OSHA Hazard Communication Standard has been developed for what purpose?
a. To make sure employees know about any hazardous chemical they may come in contact with in their work area.
b. To make your facility a safer place in which to work.
c. To train employees on how to read and use product label and MSDS information.
d. All of the above.