Hazard Communication Program

Preface

Chemicals can pose a wide range of health hazards (such as irritation, sensitization, and carcinogenicity) and physical hazards (such as flammability, corrosion, and reactivity). OSHA's Hazard Communication Standard 29 CFR 1910.1200 is designed to ensure that information about these hazards and associated protective measures is provided to workers and employers. This is accomplished by requiring chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import, and to provide information about them through labels on shipped containers and more detailed information sheets called material safety data sheets (MSDS's). All employers with hazardous chemicals in their workplaces must prepare and implement a written hazard communication program, and must ensure that all containers are labeled, employees are provided access to MSDS's, and an effective training program is conducted for all potentially exposed employees.

The standard establishes the workers the right-to-know the hazards and identities of the chemicals they are exposed to in the workplace. When workers have this information, they can effectively participate in their employers' protective programs and take steps to protect themselves. The standard gives employers the information they need to design and implement an effective protective program for employees potentially exposed to hazardous chemicals. Together these actions will result in a reduction of chemical source illnesses and injuries in workplaces.

Requirement

OSHA 29 CFR 1910.1200 (General Industry) holds employers accountable for: evaluating the potential hazards of chemicals and communicating information concerning hazards and appropriate protective measures to employees. This may include, but is not limited to, provisions for:

• Developing and maintaining a written hazard communication program for the workplace,
• Developing lists of hazardous chemicals.
• Labeling of containers of chemicals in the workplace as well as of containers of chemicals being shipped to other work places.
• Preparation and distribution of material safety data sheets to employees and downstream employers
• Development and implementation of employee training programs regarding hazards of chemicals and protective measures.

Hazard Determination

Chemical hazards can be separated into two (2) groups; those that pose a physical threat and those that pose a health threat. There are of course those chemicals that can pose both physical and health hazards, and most do. In evaluating the physical hazards of chemicals generally characteristics such as flammability, corrosion, explosivity and reactivity are judged from information on Material Safety Data Sheets (MSDS's) and other authoritative references, cited previously. Evaluating health hazards associated with chemicals in the workplace generally involves determinations as to whether exposure effects are either acute or chronic. "Acute" effects usually occur rapidly as a result of short-term exposures, and are of short duration. "Chronic" effects generally occur as a result of long-term exposure, and are of long duration.

Safety hazards related to the physical characteristics of a chemical can be objectively defined in terms of testing requirements, such as flammability. Health hazard definitions are less precise and more subjective. Health hazards may cause measurable changes in the body such as decreased pulmonary function. These changes are generally indicated by the occurrence of signs and symptoms in the exposed employees such as shortness of breath or a non-measurable, subjective feeling. Employees exposed to such hazards must be apprised of both the change in body function and the signs and symptoms that may occur to signal that change. The goal of precisely defining every possible health effect that may occur in the workplace as a result of chemical exposures cannot realistically be accomplished. This does not negate the need for employees to be informed of such effects and protected from them.

The hazard determination requirement is performance- oriented. Chemical manufacturers, importers, and employers evaluating chemicals are not required to follow any specific methods for determining hazards, but they must be able to demonstrate that they have adequately ascertained the hazards of the chemicals produced or imported in accordance with the criteria set forth in the Hazard Communication Standard.

Hazard determinations are based on 4 (four) criteria:

• "Carcinogenicity:" - a determination by the National Toxicology Program, the International Agency for Research on Cancer, or OSHA that a chemical is a carcinogen or potential carcinogen will be considered conclusive evidence for purposes of this section. However, all available scientific data on carcinogenicity must be evaluated in accordance with the provisions of this Appendix and the requirements of the rule.
• "Human data:" Where available, epidemiological studies and case reports of adverse health effects shall be considered in the evaluation.
• "Animal data:" Human evidence of health effects in exposed populations is generally not available for the majority of chemicals produced or used in the workplace. Therefore, the available results of toxicological testing in animal populations shall be used to predict the health effects that may be experienced by exposed workers. In particular, the definitions of certain acute hazards refer to specific animal testing results.
• "Adequacy and reporting of data." The results of any studies which are designed and conducted according to established scientific principles, and which report statistically significant conclusions regarding the health effects of a chemical, shall be a sufficient basis for a hazard determination and reported on any material safety data sheet. In vitro studies alone generally do not form the basis for a definitive finding of hazard under the Hazard Communication Standard since they have a positive or negative result rather than a statistically significant finding.

Employees exposed to chemicals with associated health hazards shall be evaluated on the basis of objective information furnished by MSDS's (Material Safety Data Sheets) and technical publications. Health effects shall be evaluated on the basis of "acute" and "chronic", exposure categorization as defined by the American National Standards Institute (ANSI) (Z 129.1 - 1982), Occupational Safety and Health Administration (OSHA) and National Institute of Safety and Health (NIOSH).

Material Safety Data Sheets (MSDS's)

Employers shall maintain copies of any material safety data sheets that are received with incoming shipments of the sealed containers of hazardous chemicals. No chemical shall be used if an MSDS is not on file for that particular chemical. MSDS's will be readily accessible during each work shift to employees when they are in their work area(s). This applies to any chemical, which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency. MSDS's for chemicals that may be encountered at host employers must be made available for review by the host employer.

Material Safety Data Sheets shall conform to the requirements and specifications of the Occupational Safety and Health Administration. Each material safety data sheet shall be in English (although the employer may maintain copies in other languages as well), and shall contain at least the following information:

• The identity used on the label, and, except as provided for in the Hazard Communication Standard on trade secrets.
• If the hazardous chemical is a mixture which has been tested as a whole to determine its hazards, the chemical and common name(s) of the ingredients which contribute to these known hazards, and the common name(s) of the mixture itself; or, If the hazardous chemical is a mixture which has not been tested as a whole.
• The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise 1% or greater of the composition, except that chemicals identified as carcinogens shall be listed if the concentrations are 0.1% or greater.
• The chemical and common name(s) of all ingredients which have been determined to be health hazards, and which comprise less than 1% (0.1% for carcinogens) of the mixture, if there is evidence that the ingredient(s) could be released from the mixture in concentrations which would exceed an established OSHA permissible exposure limit or ACGIH Threshold Limit Value, or could present a health risk to employees.
• The chemical and common name(s) of all ingredients which have been determined to present a physical hazard when present in the mixture.
• Physical and chemical characteristics of the hazardous chemical (such as vapor pressure, flash point, specific gravity etc.).
• The physical hazards of the hazardous chemical, including the potential for fire, explosion, and reactivity.
• The health hazards of the hazardous chemical, including signs and symptoms of exposure, and any medical conditions which are generally recognized as being aggravated by exposure to the chemical.
• The primary route(s) of entry.
• The OSHA permissible exposure limit, ACGIH Threshold Limit Value, and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the material safety data sheet, where available.
• Whether the hazardous chemical is listed in the National Toxicology Program (NTP) Annual Report on Carcinogens (latest edition) or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs (latest editions), or by OSHA.
• Any generally applicable precautions for safe handling and use which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, including appropriate hygienic practices, protective measures during repair and maintenance of contaminated equipment, and procedures for clean-up of spills and leaks.
• Any generally applicable control measures which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, such as appropriate engineering controls, work practices, or personal protective equipment.
• Emergency and first aid procedures. The date of preparation of the material safety data sheet or the last change to it.
• The name, address and telephone number of the chemical manufacturer, importer, employer or other responsible party preparing or distributing the material safety data sheet, who can provide additional information on the hazardous chemical and appropriate emergency procedures, if necessary.

MSDS Access

Physical access to MSDS's shall be available at each location and in the Corporate Safety Manager or designee's office.

The Corporate Safety Manager is responsible for the administration of this Hazard Communication Program, which includes reviewing MSDS's for completeness and consistency of information. If a MSDS is missing or incomplete, a new MSDS will be requested of the manufacturer or distributor.

A complete list of hazardous materials is located in the Corporate Safety Manager's office. Each location will have MSDS's for every chemical used at that location.

Chemical inventories shall be conducted on an annual basis. Department Managers/Supervisors shall review the chemical inventory in their locations on a monthly basis and report any inconsistencies or discrepancies to the administrator of the Hazard Communication Program.

Material Safety Data Sheets shall be reviewed periodically to determine whether the distributor or manufacturer has released a revised or updated version.

Hazard Recognition

Hazardous and toxic substances can be defined as those chemicals present in the workplace, which are capable of causing harm. In this definition, the term chemical includes dusts, mixtures, and common materials such as paints, fuels, and solvents.

OSHA currently regulates exposure to approximately 400 substances. The OSHA Chemical Sampling Information file contains listing for approximately 1500 substances; the EPA's TSCA Chemical Substances Inventory lists information on more than 62,000 chemicals or chemical substances; some libraries maintain files of Material Safety Data Sheets for more than 100,000 substances. It is not possible to address the hazards associated with each of these chemicals. Review the reference library associated with program for more detailed information.

Labeling

The employer shall ensure that each container of hazardous chemicals in the workplace is labeled, tagged or marked with the following information:

Identity of the hazardous chemical(s) contained

Appropriate hazard warnings, or alternatively, words, pictures, symbols, or combination thereof, which provide at least general information regarding the hazards of the chemicals, and which, in conjunction with the other information immediately available to employees under the hazard communication program, will provide employees with the specific information regarding the physical and health hazards of the hazardous chemical.

It is Bodine's policy not to release or permit the use of any hazardous substances for use until the following label information is verified:

• Container labels are clearly legible and accurately identify contents.
• Appropriate primary hazard warnings and secondary hazards are noted.
• The name and address of the manufacturer or distributor is listed.
• Each department manager/supervisor shall ensure employees are aware of the hazards associated with the materials they use.

Shipping & Receiving

The following procedures are to be used when Bodine receives chemicals:

• The receiving person shall inspect and verify that the quantities specified on the Bill of lading/manifest matches the quantities received.
• Receiving personnel shall verify that MSDS information is available and accessible prior to a product or chemical's release into the workplace. If it is discovered that MSDS information is not available the Hazard Communication Program Administrator shall be notified immediately.
• The receiving person shall notify the Program Administrator of all shipments received and will distribute copies of newly received MSDS's to the Program Administrator's office. The Program Administrator shall update the Chemical Database or Control book and distribute MSDS's to their appropriate locations.
• The receiving person shall verify that the information on the container label corresponds to the information on the MSDS. The appropriate hazard warning label i.e., corrosive, flammable, oxidizer etc. shall be verified or marked if necessary, prior to the material being distributed for use. All discrepancies shall be noted and the Program Administrator notified of findings.

Chemical Transfers To Secondary Containers

Bodine labels all secondary containers with the appropriate classification prior to distribution. Portable secondary containers that remain under the control of one person and the contents are intended for immediate use, are not required to be labeled, however employees are encouraged to do so.

In the event a secondary container is discovered which is not labeled, positive identification of its contents shall be made and the container shall be appropriately labeled. In the event the contents of a secondary container cannot be positively identified, measures for its appropriate identification or disposal shall be made.

Bulk Containers

Torn or damaged labels will be replaced immediately.

Bulk containers shall retain the DOT hazard label until the container is empty and cleaned. Bulk containers are considered any container, which holds 55 gallons or more (29 CFR 1910.1201).

Training

Bodine provides training to all employees who work with or around hazardous materials. This training addresses how to identify and evaluate chemicals found in their work areas and includes basic spill control procedures for spills involving quantities, which are routine in nature. Routine quantities are quantities of hazardous substances, which are fully characterized, do not present and imminent threat to human health, and do not exceed the quantity used on a day-to-day basis.

A copy of this Hazard Communication Program is available for review by all employees. Further, copies of MSDS's and access to MSDS databases are located throughout the facility for use and review by employees. All employees are trained in how to read and understand the information on an MSDS. If an employee has not received training or does not understand how to read a MSDS, the employee is instructed to contact their Manager/Supervisor who will arrange for MSDS training.

The Corporate Safety Manager is responsible for the Employee Training Program. This training shall include:

• Requirements of Hazard Communication Standard (29 CFR 1910.1200).
• Chemicals present in their workplace and labeling requirements.
• Location of Hazard Communication Program and MSDS's.
• Physical and health effects of hazardous chemicals in the workplace.
• Techniques to determine the presence or release of hazardous chemicals in the work place and how to clean up small spills safely.
• How to reduce or prevent exposure through engineering controls, work practices and personal protective equipment.
• Steps taken by the company to prevent exposure to chemicals found in the workplace.
• Emergency procedures.
• How to read labels and MSDS's.
• Routine first aid.

Following a training class, all employees shall sign a form acknowledging that they have received training and understand our company's policy for identifying and evaluating chemicals in their workplace. Documentation of employee training is maintained in the Company Training Database.

Prior to any new chemical hazard being introduced into the workplace, each employee will be given the appropriate information to insure the safe use and distribution of the chemical.

Hazardous Chemical Database

A database of the hazardous chemicals used by Bodine employees is part of this Hazard Communication Program and will be maintained by the Corporate Safety Manager or designee. Specific information for each chemical can be found on container labels and their respective MSDS.

Non-Routine Tasks

Employees may be required to perform tasks that are non-routine and may pose alternative hazards than those found during the course of their normal workday. Prior to beginning any hazardous non-routine task, the Manager/Supervisor shall inform the employee of the safe handling methods for each chemical to be used. Due to the nature of Bodine's work, hazards associated with Non-Routine tasks may not be identified until the work site is evaluated upon arrival. Specific chemical hazards must be noted on the Hazard Assessment Form, which will include a review of MSDS's and required PPE.