Circular 94-02 Appendix A: Written Hazard Communication Plan
Please note: This written Hazard Communication Plan applies to all Indian Health Service (IHS) employees, including those assigned to Public Law (P.L.) 93-638 facilities. The Hazard Communication Standard (HCS) and implementing regulations apply to Indian Self-Determination Act, P.L. 93-638 and to Title V urban program contractors as employers.
The purpose of the _______________________________ (1) written Hazard Communication Plan is to ensure that the hazards of all chemicals in this facility are evaluated, and that information concerning their hazards is conveyed to effected employers and employees. This information is conveyed by means of a comprehensive hazard communication program that includes:
- Compiling a hazardous chemical inventory list.
- Ensuring correct labels and other forms of warnings.
- Maintaining a file of material safety data sheets.
- Conducting employee training.
The HCS originates from the "Right to Know" law passed by the Congress in the 1980s. The Standard was first passed by the Occupational Safety and Health Administration (OSHA) in 1985 and originally covered 14 million workers in chemical manufacturing. There was demand for broader coverage, however, and in 1987 OSHA expanded the Hazard Communication Standard to cover over 32 million workers in all companies. The Standard requires all hazardous chemical containers to be labeled, and to provide buyers with material safety data sheets for each chemical. Employers must train employees about any chemical hazard which they may be reasonably expected to be exposed to in their work environment. Hazardous chemicals must be identified, their hazards known, and a plan for their use and training developed.
- METHODS OF IMPLEMENTATION:
The ___________________________________________ (2) has used the IHS Hazard Communication Program circular in establishing a written Hazard Communication Plan. The Plan is the written record of what this facility has done to comply with the Hazard Communication Standard and documents the steps taken: labels and other forms of warning, hazardous chemical inventories, material safety data sheets, employee information and training. It also identifies the people responsible for the program in this facility.
The Service Unit Director or Health Director is responsible for this facility's compliance and for ensuring that all department heads comply with the requirements of this Plan. The Director has appointed _______________________________ (3) as the Hazard Communication Officer who is responsible for many of the required activities as well as adapting this written Hazard Communication Plan to meet the needs of this facility.
A labeling system has been developed and implemented to ensure that all containers of hazardous chemicals are marked with the identity of the chemical, an appropriate hazard warning, and on shipped containers, the name and address of the manufacturer or other responsible party (e.g., importer or supplier).
The "identity" is any chemical term or common name that appears on the label, the material data safety sheets (MSDS), and the list of hazardous chemicals, and is the link between these three sources of information.
The "hazard warning" is a brief statement of the hazardous effects of the chemical, but does not by law have to include precautionary statements or other information; i.e., a warning could say that it attacks the lungs but may not indicate that inhalation is the hazard.
Several materials that may be in use have specific health standards that include special handling methods and protective clothing, and may include specific label requirements. The substances in use here are___________________________________ (4) (e.g. asbestos, ethylene oxide, etc.) See Appendix B for more information.
Containers that are very small, such as vials or test tubes, or areas that have diffuse chemical emissions, such as welding, motor emissions, vehicle bay exhaust, and dental clinic areas, are labeled using an alternative system. The alternative system in use here is ________________________________________ (5). (The facility may use signs, placards process sheets, batch tickets, or other such written material in place of a label.) This alternative system identifies which container the label refers to and is available to employees at all times.
Department heads or their appointees are responsible for ensuring that labels or other forms of warning are in place on all incoming new containers. The manufacturer is legally responsible for labeling all chemicals but, once accepted, the facility is responsible for the labels. The department head will either refuse to accept an unlabeled container or relabel it in the department.
The Hazard Communication Officer is responsible for ensuring that the facility conducts spot checks every ________ (6) months to see that hazardous chemical labels are legible, written in English, and prominently displayed on the container. When old containers' labels corrode, fall off, or become unreadable, they are relabeled. A new label may be duplicated from an identical container or the department may come up with their own new label. See Appendix C for some samples of our labels.
Department heads or their appointees are responsible for updating label information as it is developed and for relabeling smaller containers when a large container needs to be broken down.
If the department finds old containers of chemicals that were purchased before these requirements went into effect, the department head will request label information from the manufacturer. If this is unsuccessful, the chemical will be disposed of.
Portable containers that are filled from labeled containers are not required to be labeled, as long as they are intended only for the immediate use by the employee who performs the transfer of the chemical. Unless the one worker can use the entire amount of the chemical in one work, shift, it must be labeled. A second worker must never be given an unlabeled hazardous chemical. For simplicity, frequently used portable containers may be designated and labeled for one specific chemical and reused only with that chemical.
Labeling is not required for chemicals labeled under the Consumer Product Safety Act if an employee has the same degree of exposure as he/she would have at home. However, if the employee works with the chemical extensively, it is treated as a hazardous chemical.
- List of Hazardous Materials
A list was developed of all the hazardous materials present in this facility.
Department heads or their appointees first compiled a complete list of all the chemicals in their department. The list include all cleaning supplies, vendor samples, and chemicals used in day-to-day operations.
The Hazard Communication Officer ensure that each department developed hazardous chemical inventory lists in which all the chemicals were checked against OSHA designated lists, EPA lists, Appendix E, or the material safety data sheet information sent by the manufacturer to determine if they were hazardous. These are the chemicals for which the facility must have material safety data sheets. If the chemical was not designated as a hazardous chemical, it was removed from the inventory. The departmental lists are updated annually as new hazardous chemicals are added or eliminated. The lists are used for training workers in that department. They are found in each department and are available to any employee within the department upon request.
The Hazard Communication Officer maintains a master inventory list for the entire facility composed of each department's hazardous chemical list. The master list is provided to employees upon request.
Information concerning the chemical (where the chemical was used and for how long) is included on the list. This provides a simple way to comply with the OSHA regulation, Employee Access to Medical Records (29 CFR 1910.20) which says that facilities must keep information on discontinued chemicals for 30 years. Storing these lists takes up much less space than storing files of MSDS.
- Material Safety Data Sheets (MSDS)
The MSDS is the method for transmitting a wide variety of information from the chemical manufacturer to the user. This information includes the identity of the chemical, its health hazards or carcinogenicity, physical and chemical properties, physical and health hazards, routes of entry and exposure limits, precautions and engineering controls, first aid procedures, date of preparation, and manufacturer's name, address, and phone number.
Employees are not allowed to use any hazardous chemical for which there is no MSDS on file. An MSDS provides information needed to ensure that proper protective measures are implemented prior to exposure.
Departments that may manufacture hazardous chemicals have developed MSDSs for them. One example of "manufacturing" may be in the pharmacy when drugs are combined to form new agents. For untested mixtures, it is acceptable to staple together the MSDSs for each of the hazardous ingredients to represent the MSDS for the whole mixture.
A file has been compiled in each department containing an MSDS for every hazardous chemical that is used in that department. A master MSDS file of the facility's hazardous chemicals is maintained by the Hazard Communication Officer and is kept in ___________________________________________ (7).
When a chemical does not have an MSDS, the department head orders one from the manufacturer with the record of request kept in the files of the Hazard Communication Plan. A copy of the MSDS is sent to the Hazard Communication Officer. If the manufacturer or distributor does not send an MSDS, it is the department head's responsibility to discontinue using the chemical.
The MSDS files must be complete as they are used as a primary source of information during employee training. The MSDS files are immediately available to all employees during work hours and are kept in notebooks in the work areas.
Department heads or their appointees are responsible for cross-checking the MSDSs sent by the manufacturer to determine if the chemical is hazardous and if it is a chemical the department uses or a duplicate of an already existing MSDS.
Department heads or their appointees are responsible for looking over new MSDSs to check for obvious inaccuracies and writing to the manufacturer to request a corrected MSDS when an inaccuracy is found. Inaccurate MSDSs are never changed or added to at this facility. Inaccuracies checked for include:
- Blank entries
- No revision date
- An MSDS using OSHA Form 20 (an obsolete form)
- The identity not the same as on the label
- Not stating whether or not it is a carcinogen, (N/A is not acceptable)
- Lack of complete health hazard information
(OSHA found 90 percent of a sampling of MSDSs they looked at were inadequate.)
Areas with chemical emissions from welding operations, motor emissions, vehicle bay exhaust, dental labs, etc., have an MSDS also. Employee exposure to any air emissions that are created in the facility are accounted for.
- Employee Information and Training
The use of labels and MSDSs is only successful when workers understand how to use this information to avoid or minimize exposure and the occurrence of adverse effects. Training is critical in an effective hazard communication program. All workers who may be exposed to hazardous chemicals under normal conditions or foreseeable emergencies must be trained. Employees such as office workers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. However, if there is some question as to whether an employee has a potential for exposure, he/she is included in the training.
At the time of assignment, training is provided by the employee's supervisor on tasks in which hazardous chemicals are used and is provided again whenever a new hazard is introduced to the work area. Training is tailored to the educational and language level of the employee, and is offered during the normal work shift. The training is interactive and covers the following:
- The requirements of the Hazard Communication Standard are reviewed: what it is and what it does for them (i.e., it ensures that the hazards of all chemicals produced are evaluated, and that information concerning these hazards is communicated to employers and employees via labeling, MSDSs, and training.
- The correct way to interpret a label is taught, which enables workers to modify their handling of a chemical accordingly. This section includes an analysis of the different varieties of labels such as all text, numerically-coded/colored, and pictures of hazards. See Appendix C for more information on labels.
- A review is given of this facility's Written Hazard Communication Plan and of its documentation of compliance with the Hazard Communication Standard, including where to find the Plan.
- The specific hazardous chemicals in their work area are explained. This is the largest section of the training program and includes:
- Specific details on what chemicals the employees have contact with, and how to safely handle those chemicals. The MSDSs of chemicals in their department and chemicals they may encounter are reviewed for information and discussed. These chemicals include those in unlabeled pipes. Chemicals may be broken down by groups for discussion in order to save time and avoid repetition.
- How to detect the presence or release of the chemical (visual appearance, odor, or monitoring devices).
- Complete description of the physical and health hazards of the chemicals in the work area.
- Proper use of protective equipment is explained and questions are answered. The supervisor demonstrates how to use the equipment, clearly explains when it is to be used, and discloses where the equipment is kept and the facility's policy regarding its use. If an employee does not use required equipment and suffers an injury, the facility is responsible for not enforcing its use. The Hazard Communication Officer determines if the proper safety precautions are being used when hazardous materials are present and the supervisor orders equipment that is needed to safely handle any hazardous materials in the department.
- An explanation is given of first aid and emergency procedures to be used in the event of exposure or overexposure to hazardous chemicals employees work with. The employees are reminded that this information can be found on MSDSs.
- Documentation of which employees have received training and when they received it is taken care of by a certification form that employees sign after the training. See Appendix D.
- The OSHA's Subpart Z, Toxic and Hazardous Substances, requires special consideration for some chemicals. For more information see Appendix B.
Any other books or materials the instructor feels are useful including a chemical dictionary may be used to answer employee's questions. The instructor may use handouts, diagrams, or chalkboards to convey the information.
Contractors are informed by the ___________________________________________ (8) of chemical hazards that they are likely to encounter in the normal course of their work.
Employees assigned non-routine tasks are trained by their supervisor before they are allowed to work at that task. The employees are told the chemical hazards associated with the tasks to be performed and the appropriate protective measures they must take.
- Chemical Hygiene Plan
Our regulated laboratory has developed a written plan of action that outlines how employees are being protected from the health hazards of chemicals they work with. This Chemical Hygiene Plan (CHP) is made available to employees as well as to OSHA.
The CHP includes:
- Standard operating procedures to be followed when handling hazardous chemicals.
- Criteria that will be used to determine and implement control measures to reduce employee exposure to hazardous chemicals, particularly those chemicals that are extremely hazardous.
- A requirement that fume hoods and other protective equipment are functioning properly.
- Provisions for employee training.
- Circumstances under which a particular lab operation, procedure, or activity requires prior approval from the employer before implementation.
- Provisions for medical consultation and medical examinations.
- Designation of personnel in charge of implementation of CHP.
- Provisions for additional employee protection for work with particularly hazardous substances, such as carcinogens, reproductive toxins, etc.
The ____________________________________ (9) reviews and evaluates the effectiveness of the CHP annually and updates it as necessary.
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