The following Hazard Communication Program has been established for the Company operations in all facility locations. A copy of this written Hazard Communication Program, a Chemical Inventory List and corresponding Material Safety Data Sheets (MSDS) of all chemicals will be kept in a "Right-to-Know Manual" (notebook). The manual will be kept on display in a "Right-to-Know Station"and will be made available for review to all employees. This program is intended as the company's plan for compliance with the Hazard Communication Standard 29 CFR 1910.1200.

ASSIGNMENT OF RESPONSIBILITIES

In order to efficiently coordinate the various activities of this program, a person will be designated for:

a. Labeling of on-site containers.

b. Obtaining and maintaining a file of Material Safety Data Sheets (MSDS) and an inventory-type list of hazardous chemicals present in the workplace.

c. Conducting the training of new employees and a yearly refresher course for all employees.

d. Training employees when new chemicals are introduced into a job or process.

e. Obtaining information on any hazardous materials a contractor may introduce into the company workplace and informing any affected Employees.

f. Designating a Hazard Communication Coordinator for each remote location to assist in complying with this program. The designated Hazard Communication Coordinator will ensure that all requirements outlined in this program are followed at his/her assigned remote location
 

CHEMICAL INVENTORY & LABELING

a. An inventory list is maintained of all known, authorized chemicals for use in the company workplace. Any hazardous chemical brought onto the premises will be included on this list. 

b. All chemicals are stored in their original or approved containers, with a proper label attached. Additionally, when appropriate, the company will use the HMIS (Hazardous Material Identification System) method for storing bulk quantities of chemicals. This system uses alpha-numeric code to classify hazards and specify the required protective equipment. 

c. Any container not properly labeled will be given to the Safety Coordinator for labeling or proper disposal.

d. Employees may dispense chemicals from original containers only in small quantities intended for immediate use. This means that the same person who takes the chemical from its original container must completely use it during the same work shift in which it was taken. Any chemical taken from its original container remaining after the work shift must be either returned to the original container or disposed of in a proper manner.

e. No unmarked containers of any size are to be left in the workplace unattended.

f. Labels applied by the manufacturer or supplier will be relied upon whenever possible, and Supervisors will ensure that these labels are maintained. Containers that are not labeled, or on which the manufacturer's or supplier's label has been removed, will be re-labeled. Each label will contain the following information:

1. The common name and/or chemical name.
2. Reactivity, health and flammability information.
3. Personal Protective Equipment required.

g. Updating label information -- When new MSDS are issued on a chemical, they will be compared to previous data sheets on file and any changes will be noted. Changes which affect labels of on-site containers will result in the re-issue of the affected label with the appropriate changes.

h. The Safety Coordinator will meet with employees who will work with the chemical and will explain the changes and updated information to them. This will be documented in a written manner and will include sign-offs by the employees so instructed.
 

MATERIAL SAFETY DATA SHEETS

Chemicals can have a wide variety of hazards. There are physical hazards such as fire, explosion, radioactivity and reactivity. There are health hazards, from skin rashes to dizziness to serious diseases affecting internal organs to even death. MSDS indicates:

• Chemical name. 

• Manufacturer. 

• Hazards. 

• Exposures. 

• Safe handling instructions. 

• Personal protective equipment to use. 

• How to handle exposures. 

• Spill handling. 

A copy of a MSDS may be obtained by making a written request containing the following information:

1. Employee name.
2. Date of request.
3. Reason for request and MSDS requested.
4. Employee signature.

When an employee submits a request for a MSDS, the request will be filed and noted on a Request Log. The employee will initial the Request Log form to indicate receipt of the MSDS. 

b. When new and significant health or safety information is found, a new MSDS will be issued containing the updated information.

c. Procedures for handling hazardous materials received before an appropriate MSDS is obtained. In these cases, a temporary MSDS will be issued if there is sufficient data to do so. If this information is not known, but the general hazards associated with the chemical are known, appropriate Personal Protective Equipment will be specified. This equipment will be required when handling these chemicals. The appropriate personnel will be instructed on the hazards and safe handling procedures.

In rare cases when there is no information on the chemical, it will not be introduced into a job or process until such information is obtained. It will be isolated from other chemicals and materials until information on its reactivity and compatibility is obtained.
 

EMPLOYEE TRAINING

Employees will be trained to work safely with hazardous chemicals. Training will be conducted by the Safety Coordinator, Competent Person or person designated by the Safety Coordinator. New employees will be given instruction on the Hazard Communication Standard. This instruction is repeated yearly for all employees. 

After the instruction, employees will be given a written test in which they will sign, to ascertain the effectiveness of the instruction and to document the training.

When a new chemical is introduced into the company, or when an employee changes departments or jobs the Safety Coordinator, Competent Person or a designated person will meet with the affected employee and instruct him or her in the potential hazards of any new chemical or chemicals in the new department or job. This training will include the proper safe handling procedures, proper use of required Personal Protective Equipment, and other pertinent information regarding the chemicals. Upon completion of the training, each affected employee will complete and sign a Documentation of Training form. 

Training on the Hazard Communication Standard provides the following information:

a. Requirements of the Hazard Communication Standard.

b. Location and availability of the program, the hazardous chemical inventory list and MSDS files.

c. How to read and use the Material Safety Data Sheet (MSDS).

d. Physical and health hazards associated with chemicals used in the company workplace.

e. Safe work practices, emergency response and proper use of Personal Protective Equipment (PPE).

f. Labeling and warning systems used in the company workplace.
 

PERSONAL PROTECTIVE EQUIPMENT.

When use of specific Personal Protective Equipment is specified on a chemical product label or on the MSDS, employees are required to wear and use this PPE in a proper manner. Any employee who violates PPE requirements is subject to disciplinary action which may include suspension or termination of employment.
 

EMERGENCY RESPONSE

Any suspected injury from exposure to a hazardous chemical, or any spillage of a hazardous chemical, will be reported to the Competent Person, Supervisor or the Safety Coordinator immediately. The Supervisor notified is responsible for ensuring that proper emergency response, cleanup and chemical disposal actions are taken.
 

HAZARDS OF NON-ROUTINE TASKS

In the case of non-routine risks which may expose the employee to chemical hazards, the Supervisor, Competent Person and/or the Safety Coordinator will meet with the employee to explain the specific chemical hazards and precautions or Personal Protective Equipment required to avoid exposure. Review of safe working procedures and use of required PPE will be conducted prior to performing these non-routine tasks. Where necessary, areas will be posted to indicate the nature of the hazard involved.
 

CONTRACTOR NOTIFICATION

The work area Supervisor has responsibility for informing the contractor's representative at the start of the project, or upon assignment, of the hazards associated with chemicals that the contractor's employees may encounter during their work at the company facility. 

This can be accomplished by making the pertinent MSDS available to the contractor's representative. Each contractor will be notified of where the MSDS's are located as well as the chemicals on location. 

Contractors must provide a copy of the MSDS to the appropriate company Supervisor, Competent Person and/or the Safety Coordinator for any chemicals utilized by the contractor that may present an exposure hazard to company employees.