UCIH Workgroup – Hazard Communication Assessment Tool by huangyuerongp4

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									Hazard Communication Program Tool
Introduction The Industrial Hygiene and Safety Core Programs workgroup, made up of members of the University of California Industrial Hygiene Task Force, has been tasked with developing tools to assist industrial hygiene and safety professionals in evaluating core health or safety programs. A core health and safety program is a subject matter recognized by industrial hygiene and safety peers that has significant regulatory requirements, or stakeholder expectations. Tools for several programs are being developed. This is the Hazard Communication Program tool. The purpose of this tool is to provide an easy way for an industrial hygienist to evaluate the state of compliance for the Hazard Communication Program at his or her campus, as well as providing methods of evaluation and best practices for Hazard Communication. The Hazard Communication Assessment tool lists the major categories of the required elements of the Hazard Communication Standard. The Federal OSHA and California OSHA requirements for each of the major categories are also listed in greater detail. Since the differences between Federal and California OSHA are minor, they are combined. For each of the elements listed, there are some “best practices”, which have been found to fulfill the provisions of the standard and provide some guidance for the user to implement in their own workplace. Best practices were gleaned from the UC campuses and from the national laboratories. There is also a section which shows some methods used to evaluate each of the program elements. Lastly, there is a section labeled “status” which can be used in whatever manner the user chooses. Some suggestions have included a red/ yellow/ green color scheme or a self ranking to indicate degree of compliance. The workgroup invites comments and suggestions (dinas@lanl.gov): Dina Sassone, LANL Paul Giering, UCR Gordon Miller, LLNL Lisa Cambria, UCI Bill Peck, UCLA Kitty Woldow, UCSC Theresa Cull, LANL Eileen Lloyd, UCSF Michelle Langley, UCSC

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Required Element Hazard Determination

UCIH Workgroup – Hazard Communication Assessment Tool California/Federal Best Practices Methods of Evaluation OSHA Requirements Evaluation of substances Research substances – NA produced in workplace to determination not required. determine if hazardous. Rely on evaluation by Determination of manufacturer of the substance, hazards of mixtures of i.e. the MSDS provided. substances. Investigate the literature for more descriptive information on chemicals and mixtures. Describes how the criteria will be met for: a. Labels and other forms of warning b. Material safety data sheets (MSDS) c. Employee information and training d. Lists of hazardous substances in use in workplace e. Methods used to inform employees of non-routine task f. Methods used to share information on hazardous substances in multi-employer worksites g. Written Hazard Communication Program available on request Written Hazardous Communication Program which addresses Cal OSHA requirements available at EH&S Website and at EH&S office. Available on request from EH&S. Written program addresses all the required elements. Site specific hazard communication information provided in each local area or work place which lists: 1. Person responsible for area program 2. Places where MSDS are kept 3. Chemical inventory location 4. Training records location  Obtain copy from ES&H; assess if items of second column are included.  Obtain copies of written program or verify awareness of it and what it specifies from key personnel (e.g., Shop Foremen, Department Chairs).  Determine if workers can get the written program.  Obtain hazardous chemical list and determine how a supervisor or worker can get it.  Determine how contractors are notified of campus hazards and how campus is notified of hazardous material used by contractors.

Status

Written Hazard Communication Program

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Required element Labels and Other Forms of Warning Cal OSHA requirements Manufacturer labels containers of hazardous substances. Manufacturers labeling does not conflict with HMTA/NFPA Labels conform to requirements of a health specific standard Employer ensures hazardous substances marked with identity and hazard warnings. Employer may use signs etc. for stationary process containers. Employer not required to label portable containers Employer cannot remove or deface existing labels. Employer assures that labels are legible. New labels not needed if existing labels convey the information. Best Practices Labeling information contained in written Hazard Comm. Program. Information provided during training and during inspections and surveys. Responsibility of all employees to retain labels on containers. Labels should indicate the chemical identity, appropriate hazard warning, the name and address of the manufacturer. Secondary containers labeled by person who transfers the chemical. Container labeled with name of chemical, concentration, date transferred, initials of person transferring. Containers that are under control of one person and used only by them in one work shift need not be labeled. Placards can be used on small containers or squeeze bottles. List of abbreviations used must be posted. Label requirements should be maintained by laboratory personnel and verified by the supervisor. Methods of Evaluation  Obtain copy of labeling policy.  Determine title of person (e.g., Shop Foremen) responsible for secondary labeling.  Determine requirements for the contents of primary and secondary labels.  Check primary container labels in field for condition, absence of defacing/removal, sufficient information content in field.  Check secondary container labels in field for legibility, readability, presence and condition in field. Status 

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Required element MSDS Cal OSHA requirements Employer has MSDS for each substance used. MSDS in English and with minimal information listed. Every category should be marked. Complex mixtures (similar hazards, contents) -one MSDS Accuracy of scientific evidence used to make MSDS Manufacturer must provide appropriate MSDS with first shipment Distributors must provide MSDS to others Employer maintains MSDS and they are readily accessible Travel between worksites, MSDS kept at primary workplace. MSDS may be kept in any form and can address a process MSDS readily available to designated representatives, physician Employer obtains MSDS if not provided. Preparer should provide Director of a copy of MSDS Best Practices MSDS received by employer, none produced by manufacturing, etc. Each workplace maintains MSDS sheets at their worksite in a binder format. MSDS available on the UCOP website and other websites. They are accessible by computer. Central hard copies of MSDS kept at some worksites. Responsibility of hazards communication coordinator listed in site-specific plan. Information on MSDS provided during training by supervisors and by EH&S. Methods of Evaluation  Obtain MSDS policy.  Find which people obtain, distribute, and archive MSDSs with what tools and procedures.  Ask employees if they’re aware of hazards of materials they use on spot check basis.  Ask employees if they know how to get material hazard information.  Spot check chemicals in various locations and see if local personnel can find MSDSs for them.  Review MSDS collections in central location or how organization gets and maintains MSDSs.  Ask to see MSDS collections in field or how workers actually can access MSDSs.  Determine how Facilities and other mobile crews obtain MSDSs and level of awareness.  Determine how quickly an Status

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MSDS can be obtained.  Determine that MSDS request does not lead to retaliation.  Determine how medical support staff obtain MSDSs.

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Required element Employee Information and Training Cal OSHA requirements Employers provide training on hazardous substances at initial employee assignment and when new hazard introduced. Information and training should include specific topics. New or revised MSDS received should be provided to employees. Best Practices Training provided by supervisory personnel on the safe use of hazardous chemicals. EH&S personnel train employees in various departments as part of the IIPP training. Copy of Department written program on file with EH&S Training records kept by the Department. EH&S assists in training when requested Employees assigned a new task or non-routine task contact their supervisor or manager for guidance. Supervisor trains on specific hazards of task, protective measures that must be taken, and procedures to be used in case of an emergency or accident. Methods of Evaluation  Obtain HAZCOM training policy.  Determine how training is delivered to 1) new workers, and 2) all workers for newly arrived hazards.  Determine which people deliver HAZCOM training and the tools and procedures used to deliver it (e.g., stand up training by manager or ES&H staff) and ascertain if proof of training is obtained (e.g., testing, training records, certificates).  Identify contents of training delivered by all methods in outline/summary form or by examination of training contents found in records.  Attend training provided by various means, covering the most important training if practical, or review all generally provided and representative examples of locally provided training packages.  Identify how MSDSs and updated MSDSs are provided to workers. Status 

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Required element Trade Secrets Cal OSHA requirements Withholding of chemical identity criteria Disclosure of chemical identity to Doctor or Nurse Disclosure of chemical identity to Health and Safety Professional. Confidentiality agreement Non contractual remedies Disclosure to Director Denial of written request for disclosure Directors duties Best Practices EH&S or medical personnel can obtain information that is withheld by the manufacturer by referring to this standard and providing a written request if necessary. Methods of Evaluation  Obtain trade secret protection policy.  Identify who gets trade secrets in emergency and non-emergency situations.  Identify who retains trade secret MSDSs and related data.  Determine how necessary information on restrictedaccess MSDSs is disseminated without divulging trade secrets. Status

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