SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM
Prepared by ISSA 7373 N. Lincoln Avenue Lincolnwood, IL 800-225-4772 www.issa.com info@issa.com Notice to the Reader: All workplaces where employees are exposed to hazardous chemical products must have a written hazard communication program that describes how the OSHA Hazard Communication Standard (29 CFR 1910.1200) will be implemented in that facility. (The only facilities that do not have to comply with the written plan requirements are work operations where employees only handle sealed containers such as distribution facilities.) The following Sample Written Hazard Communication Program is based on the requirements of the OSHA Hazard Communication Standard, 29 CFR 1910.1200(e). The intent of this sample is to provide an easy-to-use format that employers can tailor to the specific requirements of their businesses. Although such general guidance is helpful, the user must remember that the written program must reflect the particulars of their workplace and general work operations. Therefore, users of this sample program must adapt it to address the specifics of their facilities and operations. For example, the written plan must list the chemicals present at the workplace, indicate who is to be responsible for various aspects of the program at the facility, and indicate how written materials will be made available to employees. It is important to note that preparation of a written hazard communication plan is more than just a paper exercise—all of the elements of the plan must be implemented in the workplace in order to be in compliance with the Hazard Communication Standard.
SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM
1. General Company Policy The purpose of this written hazard communication program is to inform our employees how our company is complying with the OSHA Hazard Communication Standard, Title 29 Code of Federal Regulations 1910.1200, including the maintenance of a list of hazardous chemicals present in the workplace, methods we will use to inform employees of the hazards of non-routine tasks (such as the cleaning of a tank), the availability and use of MSDSs, ensuring that containers of hazardous chemical products are labeled, and providing our employees with appropriate information and training.
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This program applies to all work operations in our company where employees may be exposed to hazardous chemicals under normal working conditions or during an emergency situation. [Insert Name of Responsible Person or Position] is the hazard communication program coordinator, who has overall responsibility for the program. [Insert Name of Responsible Person or Position] will review and update the program, as necessary. Copies of the written program may be obtained from [Insert Name of Responsible Person or Position] during normal business hours. Under this hazard communication program, employees will be informed of the requirements of the Hazard Communication Standard, the hazardous properties of chemicals with which they work or to which they might otherwise be exposed, safe handling procedures, and measures employees can take to protect themselves from the hazards presented by the chemicals. Employees will also be informed of the hazards associated with non-routine tasks, such as the cleaning of reactor vessels, and the hazards associated with chemicals in unlabeled pipes. 2. List of Hazardous Chemicals [Insert Name of Responsible Person or Position] will make a list of all hazardous chemicals and related work practices used in the facility, and will update the list as necessary. The list of hazardous chemicals identifies all of the chemicals used in our work place. A separate list is available for each work area and is posted there. The list identifies hazardous chemicals using the same identity that is used on the MSDS. The list of hazardous chemicals is maintained with the written hazard communication program, both of which are available from [Insert Name of Responsible Person or Position]. 3. Material Safety Data Sheets (MSDSs) MSDSs provide you with specific information regarding the chemical products employees use or to which employees otherwise might be exposed. [Insert Name of Responsible Person or Position] will maintain a binder in his office with an MSDS for every hazardous chemical on the list of hazardous chemicals. [Insert Name of Responsible Person or Position] will ensure that each work site maintains MSDSs for the hazardous chemicals in each work area. MSDSs will be made readily available to employees at their work stations. [Insert Name of Responsible Person or Position] is responsible for acquiring and updating MSDSs. He will contact the chemical manufacturer or vendor if additional information is necessary or if an MSDS has not been supplied with an initial shipment.
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4. Labels and Other Forms of Warning [Insert Name of Responsible Person or Position] will ensure that all containers of hazardous chemicals in the plant are properly labeled and updated, as necessary. Labels should list at least the identity (i.e., brand name or trade name), appropriate hazard warnings, and the name and address of the manufacturer, importer or other responsible party. Containers that are shipped from the plant will be checked by the [Insert Name of Responsible Person or Position] to make sure all containers are property labeled. If there are a number of stationary containers within a work area that have similar contents and hazards, signs will be posted on them to convey hazard information. On stationary process equipment, regular process sheets, batch tickets, blend tickets, and similar written materials will be substituted for container labels when these documents contain the same information as labels. These written materials will be made readily available to employees during the work shift. If employees transfer hazardous chemicals from a labeled container to a portable container that is intended only for their immediate use, no labels are required on the portable container. Pipes or piping systems will not be labeled but their contents will be described in training sessions. 5. Non-Routine Tasks When employees are required to perform hazardous non-routine tasks (e.g., cleaning tanks, entering confined spaces, etc.), a special training session will be conducted to inform them of the hazardous chemicals to which they might be exposed and their hazards, and the precautions that must be taken to reduce or avoid exposure. 6. Employee Information and Training Everyone who works with or is potentially exposed to hazardous chemicals will receive initial information and training on the Hazard Communication Standard and the safe use of those hazardous chemicals. [Insert Name of Responsible Person or Position] will conduct these training sessions. A program that uses both audiovisual materials and classroom-type training has been prepared for this purpose. Whenever a new hazard is introduced, additional training will be provided. Regular safety meetings will also be used to review the information presented in the initial training. Foremen and other supervisors will be extensively trained regarding hazards and appropriate protective measures so they will be available to answer questions from employees and provide daily monitoring of safe work practices.
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The information and training program will emphasize these items: The requirements of the Hazard Communication Standard; Any operations in the work areas where hazardous chemicals are present; The location and availability of the written hazard communication program, including the list of hazardous chemicals, and MSDSs; Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as visual appearances or odor of released hazardous chemicals); The physical and health hazards of the chemicals in the work areas; The measures employees can take to protect themselves from these hazards, including specific procedures the company has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and The details of this written hazard communication program including an explanation of the labeling system and MSDSs, and how employees can obtain and use the appropriate hazard information.
[Insert Name of Responsible Person or Position] or his/her designee will review the employee information and training program and advise the plant manager on training or retraining needs. Retraining is required when the hazard changes or when a new hazard is introduced into the workplace. It will be company policy to provide information and training regularly in safety meetings to ensure the effectiveness of the program. As part of the assessment of the information and training program, [Insert Name of Responsible Person or Position] will obtain input from employees regarding the training they have received, and their suggestions for improvement. 7. Contractor Employers [Insert Name of Responsible Person or Position] will advise outside contractors of any chemical hazards that may be encountered in the normal course of their work on the premises, the labeling system in use, the protective measures to be taken, and the safe handling procedures to be used. In addition, [Insert Name of Responsible Person or Position] will notify these individuals of the location and availability of MSDSs. Each contractor bringing chemicals on-site must provide [Insert Name of Responsible Person or Position] with
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the appropriate hazard information for these substances, including MSDSs, labels, and precautionary measures to be taken when working with or around these chemicals. 8. Additional Information All employees, or their designated representatives, can obtain further information on this written hazard communication program, the Hazard Communication Standard, applicable MSDSs, and lists of hazardous chemicals from [Insert Name of Responsible Person or Position].
The Department of Labor’s Occupational Safety and Health Administration (OSHA) and ISSA have established an alliance to enhance the safety and health of workers throughout the cleaning industry. As part of this alliance, ISSA and OSHA will work together to communicate to the cleaning industry ways they can improve the safety and health of their employees and otherwise protect them from workplace hazards.
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