SAMPLE HAZARD COMMUNICATION PROGRAM
Company Name Hazard Communication Program Purpose The Michigan Occupational Safety and Health Administration (MIOSHA) Right To Know Law and the adopted Occupational Safety and Health Administration (OSHA) Hazard Communication Standard require all employers to establish programs that inform employees about potential hazards in the workplace. This written document complies with that requirement, and describes the Company Name Hazard Communication Program and how to implement it. This program will be available for review by all employees. Scope This program applies to all work operations at Company Name where you may be exposed to hazardous substances under normal working conditions or during an emergency situation. Applicability The following items are exempt from MIOSHA regulations that govern hazard communication: C Any consumer product or hazardous substance used in the workplace in the same manner, duration, and frequency as normal consumer use. For example, cans of spray paint intended for short, one-application use would not be covered by this program. However, routine use of such materials by a professional painter would be covered. Users must understand the hazards of all consumer products and use them in accordance with the precautions on the label or other similar warnings. Any hazardous waste that is subject to regulations established by the Environmental Protection Agency. Tobacco or tobacco products. Wood or wood products when the only hazard is flammability or combustibility. Wood or wood products that have been treated with a hazardous chemical - including wood that may be subsequently sawed or cut, generating dust - are not exempted. Articles (manufactured items that do not release hazardous chemicals under normal-use conditions). Food, drugs, or cosmetics intended for personal use by employees while in the workplace.
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Any drug in final form that is directly administered to patients. Note that when a pharmaceutical is used in a manner not otherwise exempt, this standard applies.
List of Hazardous Chemicals (Name/Job Title) will make a list of all hazardous chemicals and related work practices used at (Company Name) and will update the list as necessary. The list also identifies the corresponding Material Safety Data Sheet (MSDS) for each chemical. The list is maintained by (Name/Job Title) and is available in/at (Location). Hazard Determination (Company Name) will rely on material safety data sheets (MSDSs) obtained from product suppliers to meet hazard determination requirements. MIOSHA Posters Posters identifying the person responsible for maintaining MSDSs and where the MSDSs are located are posted at (Location). Posters notifying employees when new or revised MSDSs are received will be located in the same locations(s). (Name/Job Title) is responsible for ensuring these signs are posted. Material Safety Data Sheets (MSDSs) MSDSs provide you with specific information on the chemicals you use. An MSDS provides data on hazardous ingredients, physical properties, fire and explosive hazards, health hazards, reactivity, spills and leaks, special protection and special precautions. Manufacturers who produce hazardous chemicals or chemical products are required to prepare an MSDS for each product. (Name/Job Title) will maintain a master binder in/at Location with an MSDS for every substance on the list of hazardous chemicals. Additional copies of MSDSs are located in/at (Location) during your workshift and will be provided to you upon request by (Name/Job Title). All new purchases involving hazardous chemicals must be cleared by Name/Job Title. Name/Job Title is responsible for acquiring and updating the master MSDSs binder. If a required MSDS is not received, is incomplete (blank spaces), needs replacement, (Name/Job Title) shall contact the supplier, in writing to request the MSDS. If an MSDS is not received after two such requests, (Name/ Job Title) shall contact the MIOSHA’s Occupational Health Division (OHD) at (517)3358250 or General Industry Safety Division (GISD) at (517) 322-1831 for assistance in obtaining the MSDS. Not later than 5 working days after receipt of a new or revised MSDS, (Name/Job Title) shall complete and post for 10 working days the New or Revised MSDS poster next to the MSDS
Location poster. Labels and Other Forms of Warning C (Name/Job Title) will ensure that all hazardous chemicals at (Company Name) are properly labeled and updated, as necessary. The manufacturer’s original label must provide the identity of the hazardous chemical(s); the appropriate hazard warnings; and the name and address of the chemical manufacturer, importer or responsible party. This label shall not be removed, changed, or defaced in any way unless the container is immediately marked with the required information. If the label is illegible, missing or appears to be deficient, (Name/Job Title) will contact the supplier to obtain complete information or a new label. Each (employee or supervisor) shall be responsible for ensuring that all portable containers used in their work area are labeled with the appropriate identity and hazard warning. When chemicals are transferred from the original (labeled ) container, the secondary (portable) container(s) (e.g., safety cans, bottles, plastic jars) must be labeled with the identity of the hazardous chemical(s) and include the appropriate hazard warning. If you transfer chemicals from a labeled (or original) container to a portable (or secondary) container that is intended only for your immediate use (within your work shift), the container does not need to be labeled. Signs, placards or other written means may be used to indicate the hazardous contents of stationary process containers and their appropriate warnings. These written materials will be made readily available to you during your work shift Information on hazardous contents of pipes and piping systems will be identified by: List means of identification for pipes and piping systems (i.e., label, sign placard, written operating instructions, process sheets, batch ticket, etc.). Natural gas, steam and compressed air lines (with pressures exceeding 25 psig) must be identified in all industrial facilities. ANSI A13.1-1981 recommends the following colorations: blue for low-medium pressure oxygen and compressed air lines, yellow for variable-high pressure oxygen and compressed air lines, and yellow for acetylene and natural gas lines.
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Non-Routine Tasks (Delete section if not applicable) Occasionally, employees are required to perform non-routine tasks, (i.e., clean reactor vessels, enter confined spaces, etc.). Prior to starting work in such areas, each employee will be given information about the hazards of the area or procedure. This information will include: C Specific chemical hazards. C Protection/safety measures the employee can take to lessen risks of performing the task. C Measures the company has taken to eliminate or control the hazard, including: a. Air monitoring, b. Ventilation requirements, c. Use of respirators,
d. Use of attendants to observe procedures, and e. Emergency procedures. It is Company Name policy that no employee will begin performance of a non-routine task without first receiving appropriate safety and health training. Hazardous non-routine tasks we have at our facility include: List hazardous non-routine tasks. Contractor Employees If Company Name exposes any employee of another employer to any hazardous chemicals that we produce, use, or store, the following information will be supplied to that employer: C The hazardous chemicals they may encounter. C Measures their employees can take to control or eliminate exposure to the hazardous chemicals. C The container and pipe labeling system used on-site. C Were applicable MSDSs can be reviewed or obtained. Each contractor bringing chemicals on-site must provide Company Name with the appropriate hazard information on these substances, including the MSDSs for the chemicals to be used and the precautionary measures to be taken to control or eliminate exposure to the chemicals. It is the responsibility of Name/Job Title to ensure that such information is provided and/or obtained prior to any services being performed by the off-site employer. To ensure that this is done, the following procedure will be followed: List all method(s) used to endure the required information is provided or obtained. Information and Training
Everyone who works with or is potentially exposed to hazardous chemicals will receive initial training on the MIOSHA Right To Know Law and adopted federal Hazard Communication Standard and the safe use of those hazardous chemicals by Name/Job Title. Training shall occur at the time of their initial assignment and whenever a new physical or health hazard the employees have not been previously trained about is introduced into their work area. Employee information and training will be in the form of (PICK ONE: categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals). The training plan will emphasize these items: C The requirements of the MIOSHA Hazard Communication Standard and details of the Company Name Hazard Communication written program. C All operations in their work area where hazardous chemicals are present. C Location and availability of the written hazard communication program, the list of hazardous chemicals, and the MSDSs.
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Chemical and physical properties of hazardous materials (e.g., flash point, reactivity) and the methods that can be used to detect the presence or release of chemicals. Physical hazards of chemicals (e.g. potential for fire, explosion). Health Hazards, including signs and symptoms of exposure, associated with exposure to chemicals and any medical condition known to be aggravated by exposure to the chemical. Measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals (e.g., appropriate work practices, personal protective equipment required, proper use and maintenance, work procedures to follow to assure protection when cleaning hazardous chemical spills and leaks). Where MSDSs are located, how to read and interpret the information on both labels and MSDSs and how employees may obtain and use additional hazard information.
Company Name employees will also be informed that: C Company Name is prohibited from discharging, or discriminating against, an employee who exercises his/her rights to obtain information regarding hazardous chemicals used at Company Name. C As an alternative to requesting an MSDS from Company Name, he/she can seek assistance from OHD, at (517) 332-8250, or the GISD at (517) 322-1831, to obtain the desired MSDS. A sign will be posed with the address and telephone number of the Departments responsible for such requests. Name/Job Title will review the training program and advise Name/Job Title on training or when retraining is necessary. As part of the assessment of the training program, Name/Job Title will obtain input from employees regarding the training they have received and their suggestions for improving it. Name/Job Title shall coordinate and maintain records of employee hazard communication training, including attendance rosters.