Hazard Communication Plan

The Hazard Communication Standard
29 CFR Part 1910.1200
North Colonie Central School District
Updated: April2015
Prepared with the Assistance of:
The Health-Safety-Risk Management Service Capital Region BOCES School Support Services Suite 102, 900 Watervliet-Shaker Road, Albany, NY 12205 Hazard Communication Program Introduction & District Contacts
'-----­
The intent of this program is to disclose to employees the potential exposure to toxic substances.
There may be a potential danger to the health of employees throughout the school district if
significant exposure to toxic substances is encountered during the course and scope of employment.
The result of this exposure may be immediate (acute) or may not be realized for many years or
generations (chronic). It is considered the duty of the Superintendent, or their designees, to give
each employee notice of his/her exposure to toxic substances that pose known and suspected
health hazards and may cause serious illness or physical harm to the employee.
Employees are frequently in the best position to be aware of the symptoms of toxicity, if they are
first made aware of the nature of the toxic substances they are working with. Employees have an
inherent right to know about the known and suspected health hazards that may result from
working with toxic substances so they may make more knowledgeable and reasoned decisions with
respect to any personal risks of their employment and the need for corrective action. Therefore, the
intention of this Hazard Communication Program is to ensure that employees be given information
concerning the nature of the toxic substances with which they work and full information
concerning the known and suspected health hazards of such toxic substances.
•
The Overseers and Contact Persons for Hazard Communication Questions and Information,
of the
•
The written Hazard Communication Program, Chemical Inventories and Safety Data Sheets
in the
locations:
•
Hazard Communication training is scheduled through:
• Assistant Director of Facility/Health & Safety
•
Training provided by:
• Assistant Director of Facility/Health & Safety andjor
• Health/Safety/Risk Management Service, Capital Region BOCES
•
Training records are maintained collectively by:
• Human Resources Department, Goodrich Building
• Assistant Director of Facilities/Health & Safety, Maintenance Shop
*Safety Data Sheets (SDS) also include Material Safety Data Sheets (MSDS).
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Statement of Intent
This Hazard Communication Program is written to inform the employees that the hazards of all
chemicals andjor chemical products present, entering and used throughout the school district have
been evaluated and that information concerning the hazards has been transmitted to employees
who may be exposed to such chemicals. This program is written to fulfill the requirements of the
Occupational Safety and Health Administration, CFR 1910.1200 and to fulfill the requirements of
the New York State Official Compilations of Codes, Part 820 of Title 12, commonly known as, the
Right To Know Law. A copy of this written program is maintained in each work site as required.
Objectives
To accomplish the goals of this program, the following actions are necessary:
1. Complete a written Hazard Communication Program, represented by this document
2. Take an inventory of all harmful and toxic chemical products in the school district, noting
locations and departments of product storage and use.
3. Request and collect Safety Data Sheets for all chemical products used on-site. These Safety
Data Sheets must be made available to all employees.
4. Establish procedures and persons responsible for overseeing labeling procedures, which are
required to be implemented under the Hazard Communication Standard.
5. Offer a training program for employee awareness and information.
6. Post notice to employees regarding their rights under the law.
7. Notify local fire department, or other emergency response groups and the community
regarding hazardous materials located in the workplace.
8. Notify contractors who work in the school of disclosure requirements for products they may
bring into the building.
9. Keep Hazard Communication Records on file for a period of 40 years from the date of
occurrence, including attendance sheets from employee training sessions.
10. Train new employees prior to working with chemical products in their job.
Globally Harmonized System (GHS)
Globally Harmonized System Overview: On March 20, 2012 the United States Occupational
Health and Safety Administration (OSHA) revised the Hazard Communication Standard (HCS) to
formally adopt the Globally Harmonized System (GHS). Your "Right to Know" has become your
"Right to Understand" with the Hazard Communication Standard's 2012 adoption of the Globally
Harmonized System (GHS) of classification and labeling of chemicals.
According to Occupational Safety and Health Administration (OSHA), the new GHS system will
benefit workers by reducing confusion about chemical hazards in the workplace, facilitating safety
training and improving understanding of hazards.
The GHS system will require manufacturers to label and create "safety data sheets" (SDS), formerly
called material safety data sheets (MSDS), that are meant to be easier to read and understand. This
system is already in use in many countries, so the revision to the federal OSHA Hazard
Communication Standard will align with the GHS system that is being used internationally.
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OSHA is requiring that employees be trained on the new label elements (e.g., pictograms and signal
words) and SDS format before the end of 2013. During this transition period, both styles of data
sheets (MSDS or SDS), and both styles oflabels and pictograms may be used.
Major Changes to the Hazard Communication Standard
• Hazard classification: Chemical manufacturers and importers are required to determine
the hazards of the chemicals they produce or import. Hazard classification under the new,
updated standard provides specific criteria to address health and physical hazards as well as
classification of chemical mixtures.
• Labels: Chemical manufacturers and importers must provide a label that includes a signal
word, pictogram, hazard statement, and precautionary statement for each hazard class and
category.
• Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in
presentation of important protection information.
• Information and training: To facilitate understanding of the new system, the new standard
requires that workers be trained by December 1, 2013 on the new label elements and safety
data sheet format, in addition to the current training requirements.
• Other Deadlines: By June 1, 2015, chemical manufacturers, importers, distributors, and
employers must comply with all modified provisions of the final rule; December 1, 2015, is
the deadline for distributors to ship containers labeled by the manufacturer's old system. By
June 1, 2016, employers must update alternative workplace labeling and hazard
communication programs as necessary, and provide additional worker training for the
physical and health hazards.
Updated Definitions
A hazardous chemical is any chemical which is classified as a physical hazard or a health hazard, a
simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
A health hazard is a chemical which is classified as posing one of the following hazardous effects:
acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye
irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive
toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard.
A physical hazard is a chemical that is classified as posing one of the following hazardous effects:
explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive;
pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure;
or in contact with water emits flammable gas.
A pictogram is a composition that may include a symbol plus other graphic elements, such as a
border, background pattern, or color, that is intended to convey specific information about the
hazards of a chemical. Eight pictograms are designated under this standard for application to a
hazard category.
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Safety Data Sheets ~
This school district has obtained the necessary Safety Data Sheets related to chemicals and chemical
products used throughout the school district. Access to Safety Data Sheets is available through
online access using MSDSonline as well as your district's binder(s).
Using the Internet to Locate Safety Data Sheets:
This service is free to school districts who participate in the Capital Region BOCES,
Health/Safety/Risk Management Service. Just follow steps 1-7 below.
Powered By
.,+;,, MSDSonline"
1. Go to website http:/lwww.msdsonline.com. to complete the "Customer Login" box using our
username and password as follows:
• Username = capitalregion
• Password = safety Customer Login !
Usemam,
~
Passwon
17 Remember Username
Log
I~
I
2. Click on the "Log In" button;
3. Click on the "MSDS Search" or "Safety Center" tabs located on the top left of the screen;
4. Search for MSDSs by typing in either the "Product'' name or "Manufacturer" name as shown
in the box below:
Product
I
Manufacturer
i
5. Click on "Search" button;
6. Scroll down to find your MSDS/SDS;
7. Under the "View" column, click on the PDF to read and/or print out the SDS.
5
Safety Data Sheet Section Headings ·..~
These safety data sheet sections are required to be listed in the following, specific order:
1. Identification
2. Hazard(s) Identification
3. Composition/information on ingredients
4. First-aid measures
5. Fire-fighting measures
6. Accidental release measures
7. Handling and storage
8. Exposure controls/personal protection
9. Physical and chemical
10. Stability and reactivity
11. Toxicological information
12. Ecological information
13. Disposal considerations
14. Transport information
15. Regulatory information
16. Other information, including date of preparation or last revision
Sample Safety Data Sheet:
SAFETY DATA SHEET
1. PRODUCT IDENTIFICATION
Hydrog-1'>-xlc:le~.t.-~
J.ly~~ ~.-\ciu~ SdWQn~;r(I..<Q'>...,._._I
L'N:t01"'
f-'.=rdCbw.5.1.8
~gooupll
NuGir111'Bt1Qn Toc:hoOToglts, LLC
om..o.
100 ~os:!&lor~:~l cc,l~r
Reohnort
($00) o4:t4-S300 (CHEMTREC) ('707) a:iQ..iloa.tl (~U~ lri~nn.0.~0'1) P~rli:. CA~g::za.lJSA. fubtw1)'10,2J10
N~
-..on;·
2. CCMPOSmON o~~nd INFORMATION ON INGREDIENTS
"" I
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~"""""'~_,......,.........,.....,,.o.c.-.,.,_.,.--.......,.,...,.;~;,co.•:tt:Ooo•""""",.,......,..,.,._,_,_.,.
-""""""''-n-d_o',.,C"R-tl>e""3t>~~"'l:>oo;,.ra,....,""""'~l:yrnoCI"R,.CI.I~JI"'::r>eJ~--..
"-JI$Z~=
>;.n~31rr~illllrtrlR.,.j:,__w.:~:ofll!)l"-
3. HAZARD IDENTIFICATION
EU l.ABEUNC AND ct..ASSIFlCATION: Thio. p<tldvd rn~ lhc (!d"miWn ~;~r Ute r::>lloning hll;:ard ~<IS do:f~~ Dy
!h~ E.l~
E:conomlr.C:.mmuni!y Gui:fo.to~
6
Each SDS is kept on file for as long as the material is used within the school district. When a
product is no longer used in the school district, or a more recent edition replaces an SDS, the former
SDS is removed from the binder and placed in an "Out of Date" file. The date when the use of the
material is discontinued will be marked on the SDS.
Safety Data Sheet Request Procedure
All purchase orders sent to vendors by district personnel should contain wording similar in nature
to the following statement:
Safety Data Sheets must be sent to the same person and address whose name appears
on the purchase order under "Ship Materials To" for all chemicals and for chemical
products containing toxic substances, as required by Federal Labor Law (29CFR 19100).
An order will not be processed for payment until the required Safety Data Sheet has
been received.
At minimum, the purchase order should be stamped: "Safety Data Sheet Required". Safety Data
Sheets should be periodically updated by requesting a new copy from the manufacturer.
When SDS's are not received from the manufacturer or supplier the following steps shall be taken:
1. Send a letterI email to the supplier requesting a copy of the appropriate SDS. Keep a copy of
this letter/email on file.
2. Send a follow-up second letter/email if the SDS is not received within 30 days of the
request.
3. lfSDS's are not received within 10 days of the second request, a complaint will be filed with
the New York State Department of Labor. A copy of the complaint will be sentto the
supplier of the toxic substance.
GHS Label Information
Some GHS label elements have been standardized (identical with no variation) and are directly
related to the hazard level. Other label elements are harmonized with common definitions and/or
principles. The standardized label elements included in the GHS are:
• Symbols (hazard pictograms): Convey health, physical and environmental hazard information, assigned to a GHS hazard class and category. • Signal Words: "Danger" or "Warning" are used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category. • Hazard Statements: Standard phrases assigned to a hazard class and category that describe
the nature of the hazard.
The symbols, signal words, and hazard statements have all been standardized and assigned to
specific hazard categories and classes, as appropriate. Other GHS label elements include:
• Precautionary Statements and Pictograms: Measures to minimize or prevent adverse effects.
• Product Identifier (ingredient disclosure): Name or number used for a hazardous product on
a label or in the SDS.
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• Supplier identification: The name, address and telephone number should be provided on the
hlcl
.
• Supplemental information: non-harmonized information.
Labels are meant to provide essential information about the hazards of using a chemical product
The label is not intended to be either the sole or most complete source of information regarding the
nature or identity of hazardous chemicals in the workplace. Although the SDS is the main source of
information regarding the hazards of a material, the most visible form of warning are labels,
warning signs and placards. As of June 1, 2015, all labels will be required to have pictograms, a
signal word (i.e., Danger; Warning), hazard and precautionary statements, the product identifier,
and supplier identification.
There are two types of container labels:
• Labels on Shipped Containers: Shipped Container labels must contain the product
identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s),
name, address, and telephone number of the chemical manufacturer, importer, or other
responsible party.
• Workplace Labels: Workplace Labels must contain the Shipped Container Label or the
product identifier and words, pictures, symbols, or combination of those, which provide
general information regarding the hazards of the chemicals.
Sample Shipped Container Label:
.&_ w
A
ToxiFlam (Contains: XYZ)
Danger! Toxic If Swallowed, Flammable Liquid and Vapor
~
D\01 col cal. drink or usc toba-c-~;-o wbco u;:in.; dlis prodo ct. '\\'a.;h bamds dtorough]y after handling. Keep
oolai11C'r ri.ghdy dosed. Kc:-tp a>.'·<l)' from bcar/spark;l(lpen flame.- No mto~io&- We--&" protttri.,..e ~oves :aDd
r~ye.i'far;-e prolec~ion. Groond eo:11aine• and rtecti,'"in_e. CCLuipmcl'l.T. F;~:e clq)los:ioo-proof e:lectricali eqiJlipmt:nt.
Tal:e prec-aut.iomcy mea.<:Ur'C$ ~n_q static- discbnr,g.c. Usc onl~· non·$p~i:~,gtoo~s. Store in rooU•'wdl­
,,totil.atcd place.
IF SWALLOWED: Immediately-call a POISON CO~'TROL ~TER ordoctorl'Physjctan.. Rjnsc- moolh.
in case of tire. we tt":UeT fo$. ~..ry chemical. co~ . 'or ·~cobol" fo;un.
Sec Mru:crial Safety Data Shect for furt.he; detaih; rcsar.di:~,g .!>afc u.-:;:e of this pro&ct MyCompany, MySkeet, MyTawn. NJ 00000,
Te~:
444 999 9999 Sample Workplace Label:
My Product Warning! Causes Skin and Eye irritation Suspected of causing cancer by inhalation Contains: XYZ 8
Workplace labels ensure proper identification of all hazardous products, and therefore aid in
protecting school employees who may come in contact with containers of hazardous chemicals. All
instructional and non-instructional departments should be supplied with standard procedures and
materials to properly implement this labeling system.
Hazard warning considerations for labels are:
1 PhWSICa
. lH azards:
li_xplosives
Gases Under
Pressure
Pyrophoric Liquids
Flammable Gases
Flammable
Liquids
Pyrophoric Solids
Flammable Aerosols
Flammable Solids
Oxidizing Gases
Self-Reactive Substances
Self-Heating
Substances
Oxidizing Liquids
Oxidizing Solids
Organic Peroxides
Substances which, in contact
with water, emit flammable
gases
Corrosive to Metals
2 Health Hazards·
Acute Toxicity
Skin
Serious Eye
Corrosion/Irritation Damage/Eye
Irritation
Carcinogenicity
Reproductive
Target Organ
Toxicology
Systemic Toxicity
- Single Exposure
3 Environmental Hazards·
Hazardous to the Acute aquatic
Aquatic
toxicity
Environment
Chronic aquatic
toxicity
Respiratory or
Skin
Sensitization
Target Organ
Systemic Toxicity
-Repeated
Exposure
Bioaccumulation
potential
Germ Cell
Mutagenicity
Aspiration
Toxicity
Rapid
degradability
4. Simple Asphyxiant
5. Combustible Dust
6. Pyrophoric Gas
7. Hazard Not Otherwise Classified
The above information will be derived from the Safety Data Sheet provided by the manufacturer,
supplier or importer. If the Safety Data Sheet provides insufficient information, other qualified
sources can be contacted for this information, such as the manufacturer, fire department and your
school district's BOCES Health/Safety/Risk Management Service.
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GHS PictogramjHazard Identification Chart H:CS Pictograms and Hazards
Health Hazard
Flame
Exclamation !'lark
~
~
<J>
• Carcinogen
• r. .1 utagenicity
•
Reproductive Toxiciry
• Irritant (skin and eye)
• Flammables
• Pyi"'phorics
• Skin Sensitizer
• Acute T oxici"tV
• Self-Heating
• Respirator"Y Sensitize I"'
• Emits Flammable Gas
• Tal"'getOrgan Toxicity
• Aspiration Toxicity
• Self Reactives
.
0 rganic Pei"''xid-es
Corrosion
• r·rarcotic Effects
• Respiratory Tract Irritant
• Hazardous to Ozone Layer
(lion-Nandato"Y)
'
I
Exploding Bomb
Gas Cylinder
0
• Gases Under Pressure
Flame over Circle
~
• Ox.idizel"S
~
.
0
• EyeDamage
• Explosives
• Seclf-Reactives
• Corrosive to Metals
• Organic Peroxides
• Skin Cor-rosion/Burns
Environment
(rlon-Nandatory)
~
• Aquatic Toxicity
Skull and Crossbones
<&
• Acute Toxidty (fatal ·01"' toxic)
I
'
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Employee Rights The General Duty Clause of the Federal Occupational Health & Safety Act (Public Law 91-596,
Section 5(a)(1), states:
Each employer shall furnish each ofhis employees' employment in a place of
employment which is free from recognized hazards that are causing or are likely to
cause death or serious physical harm to his employees.
The overall intent of "Right-to-Know" legislation is to provide employees with information about
the known and suspected health hazards that may result from working with toxic substances. The
employees have an inherent right to this information so they may make more knowledgeable and
reasoned decisions with respect to any personal risks of their employment and the need for
corrective action.
Employees have the right to:
1. Have access to information, including the HAZCOM written plan, inventory and SDS file.
2. Make photocopies of that information to keep on hand in their department.
3. Be informed of the hazardous products used in their jobs by reviewing the inventory.
4. Be informed of the potentially hazardous ingredients found in those products (see SDS).
5. Be informed of the hazards associated with overexposure to those ingredients (including
health hazards, fire hazards, etc.).
6. Be informed of the specific proper procedures for handling those products containing
potentially harmful ingredients.
7. Be provided with protective gear, ventilation and proper equipment when needed.
8. Refuse to work with a toxic substance if they have not been provided with any of the above
information upon request. In the event the employer does not possess an SDS for a specific
substance for which a good faith effort has been made to secure an SDS, the employee and
the employer must agree on safe handling procedures or replace the product with a safer
alternative.
9. File a complaint, as a last resort, with the Department of Labor if the above conditions have
not been met. The employee should first try to solve the problem with the school district
before filing a complaint.
10. Be protected from discrimination as a result of their use of any of these rights under the
HAZCOM Standard.
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Poster
Each school building in the school district will post a sign in the workplace. The sign will alert all
employees of their rights under the law, and will inform them of the name and location of the
Compliance Officer for the school.
U HAVE A
RIGHT TO KNO
I. Your employer must inform
you of the health
effects and hazards
of toxic substances
at your
worksite.
Learn all you can about toxic substances on your job. For more Information. contact: THE RIGHT TO KNOW LAW WORKS FOR YOU.
NEW YORK STATE DEPARTMENT OF HEALTH
Note: Although a poster is not specifically mentioned in the OSHA Hazard Communication Standard,
the Federal Occupational Safety & Health Act of 1970 (29 CFR 1903.2) requires that each employer
post a notice furnished by the Department of Labor informing employees of the protections and
obligations provided for under the Act.
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