Table Of Contents I. Hazard Communication Management Plan
Table of ContentsI. Hazard Communication Management PlanPolicyPurposeII. Hazard Communication ProgramCompliance Plan LocationHazardous Chemical Inventory ListSDS Location/AvailabilityIII. Labels and Other Forms of WarningsGeneral RequirementsSample LabelGHS Pictograms and Hazard ClassesSolid MetalIn-House Labeling SystemLabeling of Portable ContainersLabeling of Stationary ContainersTraining RequirementsUpdating LabelsIV. Hazard Determination ProceduresHazard Determination PolicyHazardous Chemical ExemptionsV. Employee Information & TrainingEmployee Information & Training PolicyEmployees Requiring TrainingIn-House Labeling of Chemical ContainersElements of Our Training ProgramVI. Employees Rights Under the OSHA StandardEmployee RightsInstructions for using SDSVII. Multiple Employer Notification ProceduresContractor/Owner PolicyContractor/Subcontractor PolicyVIII. Special Exemptions & ProceduresSealed ContainersLaboratoriesNon-Routine TasksRetail Operations1 PagePage 2Page 3Page agePagePage6789101010101011Page 12Page 13Page 13PagePagePagePagePage1415151516Page 17Page 18Page 18Page 20Page 21Page 21PagePagePagePagePage2223232324
I.Hazard Communication Management Plan2 Page
HAZARD COMMUNICATION MANAGEMENT PLANPolicyEmployees are our organization's most important assets - their safety and health our greatestresponsibility.It is the policy of this organization that every employee is entitled to a safe and healthful place towork.When employees enter our employ, they have a right to know what hazardous chemicals theywork with or could be exposed to, and what they can do to avoid injury or illness when workingwith these chemicals. We will be providing information and training in order to reduce thepossibility of accidental exposure and to comply with the OSHA Hazard CommunicationStandard.PurposeThe Occupational Safety and Health Administration Hazard Communication Standard requiresthat all employers develop and implement a written hazard communication program. Thisprogram is designed to describe how the OSHA Hazard Communication Standard requirementsare met in this organization.OSHA's primary intent in issuing this standard is to ensure that employees will receive as muchinformation as needed concerning the hazards in their workplace, and that this information willbe presented to our employees either prior to starting work, when changing jobs, or when newhazards are introduced into their work area.The purpose of this program is to ensure that: All employees are aware of our Hazard Communication Program and that it is available toall employees, designated representatives, and OSHA.All hazards of chemicals are evaluated.All hazardous chemicals used in the workplace are labeled, and that a list of chemicals isposted.That Safety Data Sheets are available for all hazardous chemicals.That employees receive information and training so that they are informed of therequirements of the standard and trained about hazards in their workplace.That all persons involved in non-routine tasks are informed of the hazards of such tasks.That exchange of information takes place with owners and subcontractors regardinghazardous chemicals.3 Page
II.Hazard Communication Program4 Page
HAZARD COMMUNICATION PROGRAMThe Hazard Communication Compliance Plan for our organization is in written form and is keptat the location noted below. Employees, their designated representatives, and OSHA can readthe program at any time during working hours.Our Compliance Plan is located at:101 E. Woodlawn Avenue, Elmira, New York 14901Hazardous Chemical List (s)A complete listing of all hazardous chemicals used by each project site will be kept at thatparticular jobsite.The Superintendent is responsible for keeping the Hazardous Chemical List up to date. Allpurchase orders shall include a requirement that an SDS be sent with the first delivery or beforereceipt of such material.Safety Data Sheets (SDS)Each project site will maintain site specific Safety Data Sheets or utilize our online SDS provider3E.Employees are encouraged to review these Safety Data Sheets.Copies of SDS's can be obtained by employees by request to the Superintendent or by contactingour online SDS provider 3E at 1-800-451-8346. An explanation of the SDS will be given to theemployee if requested.5 Page
III.Labels and Other Forms of Warnings6 Page
LABELS AND OTHER FORMS OF WARNINGStreeter Associates, Inc. policy regarding labeling is that all materials shall be left in theiroriginal containers, unless it is absolutely necessary to transfer the materials.General RequirementsChemical manufacturers, importers and distributors are required to label all containers ofhazardous chemicals. The labels, tags, or markings must include: Product IdentificationSupplier/Manufacturer IdentificationPrecautionary StatementsSymbols called “Hazard Pictograms”Signal WordsHazard StatementsSupplementary InformationAll hazardous material containers delivered to this workplace must have appropriate labels. If acontainer is not labeled, then the Hazard Communication Coordinator (HCC) or Supervisorshould be notified and a request will be sent to the manufacturer for a proper label.Labels on incoming containers of hazardous materials shall not be removed or defaced.7 Page
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GHS Pictograms and Hazard Classes Oxidizers ts flammable gasOrganic peroxides Explosives (1.1-1.4)Self-reactivesOrganic peroxides Acute toxicity(severe) Corrosive to metalsSkin corrosionSerious eye damage Gases under pressure Aquatic toxicity(acute)Aquatic toxicity(chronic) Acute toxicity(harmful)Skin/eye irritationSkin sensitizationSpecific target organtoxicity (single)Hazardous to theozone layer 9 P a g CarcinogenicityRespiratorysensitizationToxic to reproductionSpecific target organtoxicity (repeated)eGerm cellmutagenicityAspiration hazard
Solid MetalSuppliers of solid metal materials which may emit hazardous substances when worked upon arerequired to supply labels with the first shipment of that material.In-House Labeling SystemMaterials shall be left in their original containers whenever possible. If this is not possible,the following “In-House Labeling System” must be used.The only exception to this is when a portable container is filled and used by a singleemployee on a single shift with no product transferred to another employee or anothershift.When materials are transferred from a labeled container to another container, the receivingcontainer must be labeled. All labels developed in-house will derive their information from thelabels of the incoming containers and the safety data sheets. All labels developed in-house are tobe based upon the system indicated below. The following information will be provided on thein-house labels: Product IdentificationSupplier/Manufacturer IdentificationPrecautionary StatementsSymbols called “Hazard Pictograms”Signal WordsHazard StatementsSupplementary InformationLabeling of Portable ContainersPortable containers into which hazardous chemicals have been transferred need not be labeled if thatcontainer is used immediately (within the one day and used by the employee who performed the transfer).Stationary ContainersSigns and placards may be used on in-house stationary containers in lieu of labels as long as the labelingrequirements are met. Operating procedures, process sheets, batch tickets, and other written materials canbe used as substitutes for individual container labels on stationary process equipment. However, thesewritten materials must contain the same information as required on the labels and must be readilyaccessible to the employees. Pipes and piping systems do not have to be labeled; however, hazardinformation must be available in the SDS files.Training Requirements10 P a g e
All employees are to receive training on the in-house labeling system so that they can interpret andunderstand the labels and information provided. This training will be provided by the HazardCommunication Coordinator or Supervisors and all employees are required to attend.Updating LabelsAs we are not a manufacturing facility, labels will be updated as reflected on the manufacturers' labels andrelated SDS.All portable containers will have a complete label. The only exceptions are portable containersfilled and used by a single employee on a single shift with no product transferred to anotheremployee or another shift.11 P a g e
IV.Hazard Determination Procedure12 P a g e
HAZARD DETERMINATION PROCEDUREHazard Determination PolicyChemical manufacturers and importers are required to evaluate the hazards of the chemicalswhich they manufacture. These health hazard determinations are to be based upon scientificevidence. The evidence must be statistically significant and must be based on at least onepositive study conducted in accordance with established principles. This health hazardinformation will appear on the Safety Data Sheet. The Hazard Communication Standard requiresthat chemical manufacturers, importers, and distributors provide Safety Data Sheets with the nextshipment of their hazardous chemicals by September 23, 1987.Therefore, no hazard determination will be conducted by our organization.It is our organization's policy to rely on the MSDS received for information concerning thehazardous chemicals we work with.If hazard determination is needed because we generate a chemical for which we have no SDS, itis our company's policy to contact our online SDS provider 3E at 1-800-451-8346.Hazardous Chemical ExemptionsThe following substances are exempt from the Hazard Communication Standard and, therefore,no hazard determination will be performed upon the following products: Hazardous Waste - subject to regulations issued by the Environmental Protection Agency.Tobacco or Tobacco Products.Wood or Wood Products.Articles which would not emit a hazardous substance if worked upon.Food, Drugs, Cosmetics, or Alcoholic beverages packaged for consumers.Food, Drugs, or Cosmetics for personal consumption.Consumer or hazardous substances used in the same manner, frequency, and duration asdoes a normal consumer. OSHA intends to read this exemption narrowly. The HCC ORSUPERVISOR or supervisor will therefore, determine if the frequency and duration of achemical's use is comparable to that of consumer use. The HCC OR SUPERVISOR orsupervisor will obtain a material safety data sheet where it is determined that theseproducts are used more frequently than would a normal consumer.Solid drugs such as tablets, capsules, and pills.13 P a g e
V.Employee Information and Training14 P a g e
EMPLOYEE INFORMATION AND TRAINING POLICYA combination of training and written materials will be used for informing and trainingemployees. Although it is not necessary to review every specific SDS with employees, they mustbe informed of the location of the written Hazard Communication Program and SDS's and howthey can obtain a copy of an MSDS. Most of all, they must be informed of the hazards of thechemicals they work with and how they can protect themselves from exposure.Superintendents are responsible for making sure that employees are informed about the HazardCommunication Program and that SDS's are available to any employee on any workshift, thatprotective equipment is available and used, and that engineering controls, such as ventilation arein place and operating properly. SDS’s can be obtain 24 hours a day, 7 days a week, 365 days ayear by calling our online SDS provider 3E at 1-800-451-8346.Employees Requiring TrainingThe determination of which employees will be selected to receive Hazard CommunicationTraining will be based upon their exposure. Those employees who have actual as well aspotential exposure to hazardous chemicals will receive training. It is our intent to ensure thatemployees receive information about all chemicals in their work areas, and that they are preparedto deal with any unexpected releases or emergency situations, as well as, exposures during thenormal course of employment. Certain personnel will be excluded from Hazard Communicationtraining that are not exposed to hazardous chemicals.The Hazard Communication Standard has special training provisions for personnel who handlesealed containers of hazardous chemicals, laboratory personnel, and for those personnel who maybe exposed to hazardous chemicals from other employers. Special training requirements are inSpecial Exemptions and Provisions.Training must be provided to all affected employees when:1. The program is initially implemented.2. A new employee starts work.3. An employee is transferred to a location that uses different chemicals.4. A new hazard is introduced into the work area or new information becomes available onsubstances used.Employees must be trained on how to understand and use an SDS to obtain information about thechemicals they work with.In-House Labeling of Chemical Containers15 P a g e
All containers of hazardous chemicals must be labeled by the chemical supplier. A standard inhouse labeling system will be used at our jobsites for transfer of chemicals to portable containers.Specific instructions are in Section 3 Labels and Other Forms of Warnings. This system must beexplained to the employees.Elements of our Training ProgramTo help management to inform and train employees, the training program includes:1. Requirements of the Hazard Communication Standard2. Hazard Communication Management Plan3. Employee Rights4. The location of our company's Hazard Communication Program, SDS's and ChemicalInventory List5. Instructions for using Safety Data Sheets6. Detection of Hazards, Non-Routine Tasks, & Emergency Procedures7. The measures employees can take to protect themselves from any chemical or physicalhazards, including information on work practices, emergency procedures and personalprotective equipment required by the employer.*8. Training Introduction9. Instructions for using and understanding our in-house labeling systemManagement/Supervision must become thoroughly familiar with this material so that they areprepared to answer employee’s questions. The HCC OR SUPERVISOR will assist you in anyway.16 P a g e
VI.Employee Rights under the OSHA Standard17 P a g e
EMPLOYEE RIGHTS UNDER THE OSHA STANDARDEmployee RightsThe purpose of the OSHA Hazard Communication Standard is to ensure that you understand thehazards of the chemicals you work with and know how to safely use those chemicals. Under thisstandard you are given certain rights as follows: The right to request in writing and obtain information on hazardous chemicals you comein contact with.The right to be informed of the hazardous chemicals used in your work area.The right to have access to our organization's written Hazard Communication Program.The right to file a complaint with OSHA if you believe that you have been discriminatedagainst by exercising your rights under this law.The Chemical Inventory List, Hazard Communication Program, and SDS's are available for yourreview for your specific project and are located at each individual project siteA Chemical Inventory List will be at each project site with the SDS. Our company program hasbeen developed in an effort to create as safe a workplace as possible. We ask your cooperation inobtaining this objective.Instructions For Using Safety Data SheetsSpecific information on the physical properties of hazardous chemicals must be supplied, onrequest, to employees in the form of a Safety Data Sheet. A SDS is required for each hazardouschemical in the work area. These SDS's are to be supplied by the chemical manufacturer orsupplier, and their contents are to be based on the results of specific testing procedures designedto determine the toxic and hazardous characteristics of each material.The information contained in the SDS's is there to inform you of the properties of the chemicalswhich you work with, and to explain how the materials may be handled safely. This knowledgeallows you to protect yourself against any hazards the materials may pose to your health.The standard SDS as required by OSHA incorporates the global harmonized system format. TheSDS includes 16 specific sections as follows:Section 1 – IdentificationSection 2 – Hazard(s) identificationSection 3 – Composition / Information on IngredientsSection 4 – First-aid MeasuresSection 5 – Fire-fighting Measures18 P a g e
Section 6 – Accidental Release MeasuresSection 7 – Handling and StorageSection 8 – Exposure Controls /Personal ProtectionSection 9 – Physical and Chemical PropertiesSection 10 – Stability and ReactivitySection 11 – Toxicological InformationSection 12 – Ecological Information*Section 13 – Disposal Consideration*Section 14 – Transport Information*Section 15 – Regulatory Information*Section 16 – Other information including date of preparation of last revisionSection in bold lettering should always be reviewed employees prior to use.*Sections outside of OSHA‘s jurisdiction but inclusion of these sections is necessary for a GHScompliant SDS19 P a g e
VII.Multiple Employer Notification Procedures20 P a g e
MULTIPLE EMPLOYERNOTIFICATION PROCEDURESContractor/Owner PolicyThe written Hazard Communication Program requires that Safety Data Sheets be available forthe Owner and Owner's Employees.Each project site will have SDS’s for that specific site available for review at the project site orby calling the main office at 607-734-4151 and requesting the SDS from the HazardCommunication Coordinator. They can also be obtained by calling our online SDS provider 3Eat 1-800-451-8346.It will be each Superintendent's responsibility to inform the Owner's Representative ofprecautionary measures that need to be taken to protect employees during the normal workdayand in foreseeable emergencies and to obtain the same information from the Owner and dulytrain all Streeter Associates, Inc. employees involved.It will be each Superintendent's responsibility to inform the Owner's Representative of thelabeling system used by Streeter Associates, Inc. and to obtain the same information along withalarm warning system information from the Owner and duly train all employees involved.It is the responsibility of the Superintendent to procure and disseminate the necessaryinformation.Contractor/Subcontractor PolicyContractor-Subcontractor information exchange will also be required when the exposure of theother employers' employees may occur. This information will be in turn shared with the Owner'sRepresentative.All written communication regarding the Hazard Communication will be duplicated so that theHazard Communication Coordinator as well as the Superintendent will have an up-to-date file.It is emphasized that the exchange of information is limited to those situations where theexposure of the other employers' employees may occur.21 P a g e
VIII.Special Exemptions & Procedures22 P a g e
SPECIAL EXEMPTIONS AND PROVISIONSSpecial SituationsThere are several circumstances where the law is modified to address situations where a straightinterpretation of the standard would not be applicable. These special situations are as follows:1. Sealed ContainersIn operations such as warehousing, retail sales, or material management, where employees onlyhandle containers which are sealed, the following aspects of the Hazard Communication Planwill apply: Labels on incoming containers cannot be removed or defaced.Safety Data Sheets which are received with incoming containers must be kept andmaintained.If requested by employees, material safety data sheets can be obtained.Safety Data Sheets must be accessible to employees.This organization will provide an information and training program which is sufficient toprotect employees from hazard presented by the contents of sealed containers should theyspill or leak.2. LaboratoriesFor laboratory operations, the following aspects of the Hazard Communication Plan will apply: Labels on incoming containers cannot be removed or defaced.Safety Data Sheets that are received with incoming containers must be kept andmaintained.Employees will be apprised of the hazards of the chemicals through an appropriateinformation and training program.3. Non-Routine TasksThis section applies to jobs that are not performed on a routine basis and that may involvecontact with a hazardous chemical.Supervisors will determine what hazards are present or may be created by the task. TheSuperintendent is responsible for informing employees of all hazards presented by non-routinetasks. Superintendents will make sure that any special equipment, such as portable ventilators,etc., and/or personal protective equipment is available and used to perform the work safely.23 P a g e
4. Retail OperationsRetail operations which sell hazardous chemicals to commercial customers will provide amaterial safety data sheet to those customers if requested. A sign will be posted indicating thatSDS's are available to commercial customers.Chemical manufacturers, importers, and distributors do not need to provide SDS's to retailoperations which have informed them that the retail distributor does not sell theproduct to commercial customers or open the sealed containers on24 P a g e
Safety Data Sheets (SDS) Each project site will maintain site specific Safety Data Sheets or utilize our online SDS provider 3E. Employees are encouraged to review these Safety Data Sheets. Copies of SDS's can be obtained by employees by request to the Superintendent or by contacting our online SDS provider
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a GHS hazard class and category. Signal Words: "Danger" or "Warning" are used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category. Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard.
What is Hazard Classification? Hazard classification is the process of evaluating the full range of available scientific evidence to determine if a chemical is hazardous, as well as to identify the level of severity of the hazardous effect. When complete, the evaluation identifies the hazard class(es) and associated hazard category of the chemical.
Hazard Communication Program – 9/3/2020 5 Appropriate pictogram showing the chemical’s hazard class. Appendix A shows the pictograms that are associated with each hazard class. Hazard statement describing the nature of the hazard Precautionary statement recommending the steps to be taken to safely use, handle, store
Division 1.2 - Explosives that have a projection hazard but not a mass explosion hazard. Typical examples are certain power charges. c. Division 1.3- Explosives that have a fire hazard and either a minor blast hazard or a minor projection hazard or both, but not a mass explosion hazard. Typical examples are
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