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Safety and Health Training 2.9 Hazard Communication Program

Hazardous Chemical Substances – “Employee right to know”

Purpose

The purpose of this manual is to provide information and training for all employees, and employers who may be exposed to hazardous substances in the workplace. It will also provide information to public safety organizations in compliance with "Community Right to Know" standards.

This procedure applies to all Jackson & Jackson Industrial Contractors Inc. employees and subcontractor employees at Jackson & Jackson Industrial Contractors Inc. worksites.

Program Components

1. A written Hazard Communication Program; a worksite chemical inventory list of all hazardous chemical substances normally used or stored in the workplace. This chemical/substance list must contain the information indicated. Information of how to obtain our clients M.S.D.S. and where they are kept.
2. Safety Data Sheets (SDS) must be obtained from the manufacturers, wholesalers, clients, and/or suppliers for each hazardous chemical/substance. SDS must be stored in at least one central location, organized and maintained in such a manner as to facilitate easy retrieval for reference. These sheets should be readily available for supervisor’s reference and employee/employers review as requested.
3. Employee Training and how employees/employers obtain this information.
   1. General Orientation
      1. The hazards of unlabelled pipes; containers, and the hazards of chemicals in them.
      2. General explanation of SDS; how maintained, where they are stored and how to request information.
      3. General engineering and/or administrative controls pertaining to crafts or the entire worksite should be introduced.
      4. Location and issuing procedures for personal protective equipment.
      5. Review of container/piping labeling and importance of reading labels to all employees and employers.

NOTE: Employees should be encouraged to ask questions whenever in doubt.

2. Specific Orientation
1. Conducted by direct supervision (Foreman).
2. Specific hazardous chemical substances pointed out.
3. A general overview of Engineering and Administrative protective equipment and exposure controls.
4. Inform all employees, and employers of the necessary precautions they will need to take when working around chemicals.
3. Continuing Education
1. Should be a component of the Tool Box Supervisors Safety Meetings and should cover a specific hazardous chemical substance used by the craft. The supervisor should be provided a copy of the SDS for reference and then attached to the Tool Box Safety Meeting Report. All employers working for or around our company needs to be informed of the importance of labeling, and the location of all Safety Data Sheets on the site.

4. The proper labeling and identification of contents of all containers & piping of hazardous chemicals and substances is required. Manufacturers and distributors are required by law to label all containers as well as piping. Employers who use the products must ensure that labels are in place. When items are placed from a labeled container into another container (such as cans, buckets, etc,) the receiving container has to be properly labeled also.
5. A written Hazard Communication Program that is readily available to OSHA, Community Right to Know organizations and all employees/employers of the company.

RESPONSIBILITIES

1. The Project Manager is to insure that the Hazard Communication Standard is complied with and that the requirements outlined in this procedure are implemented.
2. The person in charge of purchasing products for the project, Material Management System Supervisor, Purchasing Agent, Warehouse Manager, Superintendent, Engineer, etc., will have the responsibility to ensure that all purchase orders contain the following notice in a prominent place on the purchase order.

NOTICE
Projects that come under Federal or State "HAZARD COMMUNICATIONS: or "RIGHT TO KNOW" laws must meet the requirements of law in labeling and a Safety Data Sheet must accompany delivery. Failure to comply will give Jackson & Jackson Industrial Contractors Inc. the right to refuse delivery and exercise their option to cancel order.

3. The person who receives the product and the SDS will ensure that a copy of the SDS is forwarded to the person who requested the product and the warehouse supervisor (if the material is to be stored in an area under their responsibility particularly if special storage considerations are required,) and the central location for filing the SDS and/or the Safety Engineer or person to whom the duties of safety on the project is assigned (if different from the central filing location.) The person receiving the product must ensure that the hazard label is in place on all containers received.
4. The Safety Engineer, or the person to whom the duties of safety on the project is assigned, will maintain or oversee the central filing system for the SDS (master copies.) This person will also instruct in the general orientation of new employees/employers as outlined in this procedure. This person will also post a list of all hazardous substances on the project in a location where it can be readily accessible to employees and employers. This list shall be updated as needed (at least quarterly.)
5. The safety person will advise or assist the supervisor in training employees/employers in the safe handling procedures for a product and the proper use of personal protective equipment that may be required. If the project is located within, or adjacent to a client's processing unit, manufacturing unit, etc., and the potential exists for hazardous exposure to Jackson & Jackson Industrial Contractors Inc. personnel, the safety person will obtain a copy of client's Hazardous Communication Program (including copies of all applicable SDS's) in order to properly train Jackson & Jackson Industrial Contractors Inc. employees and employers.
6. Multi-Employer Facility When contractors or any other employers' workers (i.e., painters, electricians, or plumbers) will be working at this workplace, the safety and health manager, James D. Jackson, will:
   1. Provide the other employer(s) with SDSs for any of our chemicals to which their employees may be exposed in the following manner: copy of Jackson & Jackson Industrial Contractors, Inc. SDS and written hazard communication program.
   2. Relay necessary label and/or emergency precautionary information to the other employer(s) in writing
   3. Each contractor bringing chemicals on-site must provide James D. Jackson with the appropriate hazard information on these substances, including the SDSs, the labels used and the precautionary measures to be taken in working with these chemicals.
7. The safety person will monitor and compile documentation of training provided for employees. The safety person will contact the local fire department and insure that the fire chief has a copy of the chemical list, appropriate SDS (as required) and act as the project's representative with outside agencies. The safety representative is also responsible for employee/employer information posing requirements of this procedure.
8. Supervisors (superintendents, general foremen, foremen, etc.,) will insure that their employees are informed and trained regarding hazardous substances used or to which employees/employers under them may be exposed. They will also be responsible for assuring that personal protective equipment needed by their employees is provided, the employees are trained in its use, and that the use of personal protective equipment is enforced.
9. The supervisor should maintain a file for SDS of all hazardous products used in their department, and/or craft to which employees assigned to their supervision may have a potential for exposure and provide the same information to employees/employers who may request to review or copy them. The supervisors will document initial craft orientation and continuing education information and training by the use of Tool Box Safety Meeting sheets that the employees sign, and will forward these to the Safety Engineer or the person to whom the duties of safety on the project are assigned.
10. Employees have the responsibility of reviewing the labels of all products they use and to follow the instructions and to use the personal protective equipment required for the use of these products. If the employee does not know what a product is or how he should handle/use it, he has the responsibility of asking for instructions and/or personal protective equipment required prior to using that product. Intentional disregard of controls and warnings or failure to use personal protective equipment as instructed, will be grounds for termination.
11. A written hazard communication program will be developed, implemented and maintained at each job site Jackson & Jackson Industrial Contractors, Inc. employees work. Jackson & Jackson Industrial Contractors, Inc. shall develop, implement and maintain at each workplace a written hazard communication program that describes how labels and other forms of warnings. SDS and employee information will be met.

References:

If information or a Safety Data Sheet is not available on a product from the vendor or the client, then other sources may need to be consulted:

1. Request information and SDS from the manufacturer. The manufacturer's address can usually be obtained from a product's label.
2. Many times a toll free phone number is published which can be used to request SDS.
3. Contact Jackson & Jackson Industrial Contractors Inc. Corporate Safety and Health Department for assistance if unable to obtain adequate information.

Definitions

Chemical Name

Means 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 that will clearly identify the chemical for the purpose of conducting a hazard evaluation.

Common Name

Means any designation of 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.

Chemical Manufacturer

Means an employer in Standard Industrial Classification (S/C) Codes 20 through 39 with a workplace where chemicals are produced for use or distribution.

Designated Representative

Means the individual or organization to whom an employee gives written authorization to exercise the employee's rights under this act.

Distributor

Means any business, other than a chemical manufacturer or importer, that supplies hazardous chemicals to other distributors or to purchasers.

Employee

Means any person who may be or may have been exposed to hazardous chemicals in the person’s workplace under normal operating conditions or foreseeable emergencies. Office workers, ground maintenance workers, security personnel, or nonresident management are not included unless their job performance routinely involves potential exposure to hazardous chemicals.

Expose or Exposure

Means that an employee is subject to a hazardous chemical in the course of employment through any route of entry, including inhalation, ingestion, skin contact, or absorption, and includes potential, possible, or accidental exposure.

Fire Chief

Means the elected or paid administrative head of a fire department.

Hazardous Chemical

Means any element, chemical, compound or mixture of elements or compounds that in its present state or when used is a physical hazard or health hazard as defined by the OSHA Standard 29 CFR, Section 1910.1200(c), or a hazardous substance as defined by the OSHA Standard 29 CFR, Section 1910.1200(d)(3).

Label

Means any written, printed, or graphic material displayed on or affixed to containers of hazardous chemicals.

Safety Data Sheet (SDS)

Means a document containing chemical hazard and safe handling information, provided that after November 25, 1985, SDS means a document prepared in accordance with the requirements of the OSHA Standard for that document.

OSHA Standard

Means the Hazard Communication Standard issued by the Occupational Safety and Health Administration in 48 Federal Register 53280 et seq. (November 25, 1983), to be codified under Title 29 of the Code of Federal Regulations (CFR) Section 1910, 1200.

Workplace or Worksite

Means an establishment at a geographical location containing one or more work areas.

Hazard Communication Written Program

General

1. This program has been prepared to comply with the requirements of the Federal OSHA standard 1926.59 and to insure that information necessary for the safe use, handling and storage of hazardous chemicals is provided and made available to employees and employers.
2. The program includes guidelines on identification of chemical hazards and the preparation and proper use of container labels, pipe labeling, placards and other types of warning devices.
   1. Chemical Inventory
      1. Jackson & Jackson Industrial Contractors Inc. maintains an inventory of all known chemicals in use on the worksite. A chemical inventory list is available from Safety Director or in Tool Room.
      2. Hazardous chemicals brought onto the worksite by Jackson & Jackson Industrial Contractors Inc., as well as any from its employers will be included on the hazardous chemical inventory list.
   2. Container Labeling
      1. All chemicals on site will be stored in their original or approved containers with a proper label attached, except small quantities for immediate use. Any container not properly labeled should be given to Safety Director for labeling or disposal.
      2. Workers may dispense chemicals from original containers only in small quantities intended for immediate use. Any chemical left in small quantities intended for immediate use. Any chemical left after work is completed must be returned to the original container.
      3. No unmarked containers of any size are to be left in the work area unattended.
      4. Jackson & Jackson Industrial Contractors Inc. will rely on manufacturer applied labels whenever possible, and will ensure that these labels are maintained. Containers that are not labeled or on which the manufacturer's label has been removed will be relabeled. Unlabeled piping will not be opened with out information on contents of it, and the hazards that apply to it.
      5. Jackson & Jackson Industrial Contractors Inc. will ensure that each container is labeled with the identity of the hazardous chemical contained and any appropriate hazard warnings.
   3. Safety Data Sheets (SDS)
      1. Employees/Employers working with a Hazardous Chemical may request a copy of the safety data sheet (SDS). Requests for SDS's should be made to Safety Director.
      2. SDS should be available and standard chemical reference may also be available on each site to provide immediate reference to chemical safety information.
      3. An emergency procedure to gain
         access to SDS's information will be established.
   4.  Employee/Employer Training
      1. Employees will be trained to work safely with hazardous chemicals. Employee/Employer training will include.
      2. Methods that may be used to detect a release of a hazardous chemical(s) in the workplace.
      3. Physical and health hazards associated with chemicals.
      4. Protective measures to be taken.
      5. Safe work practices, emergency responses and use of personal protective equipment.
      6. Information on the Hazard Communication Standard including Labeling, Warning Systems, and an explanation of Material Safety Data.
      7. All piping with out labeling will not be opened with out the proper information of its contents and safety measures to be taken.
   5. Personal Protective Equipment (PPE)
      1. Required PPE is available from Safety Director. Any employee or employer (working for Jackson & Jackson) found in violation of PPE requirements will be subject to disciplinary actions up to and including discharge.
   6. Emergency Response
   1. Any incident of over exposure or spill of a hazardous chemical substance must be reported to Safety Director at once.
   2. The foremen or the immediate supervisor will be responsible for insuring that proper emergency response actions are taken in leak and/or spill situations.
   5. Hazards of Non-Routine Tasks
      1. Supervisors will inform employees/employers of any special tasks that may arise which would involve possible exposure to hazardous chemicals.
      2. Review of safe work procedures and use of required PPE will be conducted prior to the start of such tasks. Where necessary, areas will be posted to indicate the nature of the hazard involved.
   6. Informing Other Employers
      1. Other on site employers is required to adhere to the provisions of the Hazard Communication
      2. Standard and Labeling Policy.
      3. Other on site employers will be responsible for providing necessary information to their employees.
   7. Posting
      1. Jackson & Jackson Industrial Contractors Inc. has posted information for employees/employers at this job site on the Hazard Communication Standard. This information can be found at Main Office/Tool Room

The Hazard Communications Standard

The purpose of this standard is to make sure that information on working safely with hazardous chemicals on the job site is given to all workers.

The standard requires manufacturers and distributors of chemicals to properly label chemical containers and to provide Material Safety Data Sheets to down stream users of their products.

Employers must have a written Hazard Communication Program, a Chemical Inventory List for each work site and must train workers about chemicals and make available information on the chemicals in use in their work places.

Employers must provide training to workers in the provision of the Hazard Communication Standard, Physical and Chemical Properties of Chemicals in use, Protective Measure for Workers in using these chemicals in normal and non-routine tasks, and appropriate personal protective equipment, safe work procedures and first aid measures. This training must be provided initially and when new chemical hazards are brought into the work place.

Employers must also ensure that all chemical containers are labeled and train employees in the labeling, hazardous warning and monitoring (if any) systems in use at the job site.

Employees have the right to review the written Hazard Communication Program and Chemical List for their job site. Employees can also request a copy of the Safety Data Sheet for any chemical they are using. Your foreman will tell you who to talk to in order for you to review programs, obtain SDS's or receive more information.

Working safely with chemicals is a two way street. Your employers will provide you with access to the needed information but it’s up to you to handle chemicals safely, and to use the proper protective equipment and safe work procedure whenever you are working with chemicals.

Safety Data Sheets

1. The Hazard Communication Standard required that manufacturers, distributors and suppliers of hazardous chemicals provide copies of Safety Data Sheets (SDS) to customers.
2. Employers must have a Safety Data Sheet for each hazardous chemical in use. SDS's must be made available upon request to employees, employee representatives, OSHA, state and community emergency planning groups, and also fire departments.
3. SDS provide both the employer and employee with information necessary for working safely with a specific chemical.
4. When a SDS is needed, contact the manufacturer, distributor or supplier in writing.
5. If a SDS is not available from a manufacturer, OSHA should be notified in writing.
6. SDS files and/or SDS information can be maintained in any format.
7. An SDS file should be maintained at the job site and in the company's home office.
8. Employers may also want to obtain a standard chemical reference guide.
9. An emergency procedure can be established using the fastest and most accessible means of communication during normal working hours for hazard chemical information.
10. A generic SDS is available from a variety of sources for use in place of SDS's requested but not yet received.

NOTE:

According to an OSHA report on enforcement of the Hazard Communication Standard in the manufacturing industry, the lack of SDS's, a chemical list and a written program account for the majority of citations issued since 1984. It is important that the paperwork requirements of this standard be maintained in an up-to-date manner if citations are to be avoided.

NOTE:

All Jackson & Jackson Industrial Contractors Inc. employees speak and understand English.

Appendices:

Our company has attached the following appendices to this written plan:

1. Hazard Communication Training Session

2. HCS Jobsite Poster

3. HCS Jobsite Poster