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4108 - Hazard Communication Program
This section has been written in order to comply with the OSHA Hazard Communication Standard, Title 29 Code of Federal Regulations 1910.1200, and UOSH General Title 34 Chapter 6.
This program applies to departments with employees who may be exposed to hazardous substances under normal conditions or during an emergency situation. Such department shall keep a copy of this program for affected employees.
The Department Director is responsible for implementation of this program.
Under this program, hazardous chemical lists and Safety Data Sheets (SDSs) are compiled, containers are properly labeled, and training is provided to employees.
Hazardous Chemicals List
Each Department Director makes a list of all chemicals used in the department, and updates it as necessary. This list is posted in a location where it will be likely for all department employees to see it. On the list, note that further information about each noted chemical may be obtained by reviewing the individual SDSs located within the department. The location of the SDSs is disclosed on the list.
Safety Data Sheets (SDS)
SDS's provide specific information on chemicals used. Department Directors should ensure that each work site within their department maintains an SDS for hazardous materials in that area.
Department Directors are responsible for acquiring and updating SDS's for their departments. They should contact the chemical manufacturer or vendor if additional research is necessary or if an SDS has not been supplied with an initial shipment. Purchase bid specifications should require the provision of SDS's. Please make a note of the date on the receipt of any SDS, especially if there is not a date of last revision on the SDS itself. SDS's should be reveiwed annually to make sure they remain up-to-date. As manufacturers change their formulas occasionally, any old SDS's for chemicals which are no longer used should be removed from the active file (to prevent confusion and clutter) and kept in an archive file.
The Hazard Communication Standard requires that the information on the SDS is presented using consistent headings in a specified sequence. The format of the 16-section SDS should include the following sections:
Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision
Threshold Limit Values (TLVs) on the SDS will provide employers and employees with useful information to help them assess the hazards presented by their workplaces. Understand that TLV's are recommendations. In addition to TLVs, OSHA permissible exposure limits (PELs), and any other exposure limit used or recommended by the chemical manufacturer, importer, or employer preparing the safety data sheet are also required. PEL's are enforceable by law.
If a chemical is listed as a carcinogen by either the International Agency for Research on Cancer (IARC) or National Toxicology Program (NTP), it must be noted on the SDS.
The Hazard Communication Standard requires that Department Directors maintain copies (these can be electronic copies) of safety data sheets for each hazardous chemical used in the workplace for at least 30 years.
Department Directors ensure that hazardous chemicals in their department are properly labeled and updated, as necessary. Labels should at least show the chemical identity, appropriate hazard warnings, and the name of the manufacturer or other responsible party.
Labels will contain the following elements:
- Pictogram: a symbol plus other graphic elements, such as a border, background pattern, or color intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e. a red diamond).
- Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for less severe hazards.
- Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
- Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical.
There are nine pictograms to convey the health, physical, and environmental hazards:
- Health Hazard
- Exclamation Mark
- Gas Cylinder
- Exploding Bomb
- Flame over Circle
- Skull and Crossbones
|HCS Pictograms and Hazards|
|Health Hazard||Flame||Exclamation Mark|
|Gas Cylinder||Corrosion||Exploding Bomb|
|Flame Over Circle||Environment|
|Skull and Crossbones|
Employers who become newly aware of any significant information regarding the hazards of a chemical shall revise the labels for the chemical within six months of becoming aware of the new information, and shall ensure that labels on containers of hazardous chemicals shipped after that time contain the new information.
If a diluted material or a chemical is transferred to a container that will remain therein more than a day, or be handled by employees other than the one who made the transfer, it must be properly labeled. If the container will only be used by the person who filled it and is not more than a day's supply of material, it is not required to be labeled with all of the standard information.
While there is nothing in the standard that requires pipes to be labeled,label pipes to prevent confusion. Many piping systems have brief labels, such as 'hot water' and directional flow arrows. It is useful to label pipes in areas where there are several diverse materials flowing through the pipes.
Periodically, employees are required to perform hazardous non-routine tasks (e.g., cleaning tanks, entering confined spaces, etc.). Prior to starting work on such projects, each affected employee is trained by his/her supervisor about hazardous chemicals to which they may be exposed while performing the task, and proper precautions to take in order to reduce exposure. (If employees are entering confined spaces, they are required to do it according to the OSHA confined space entry system, if it is a permit-required confined space. See 29 CFR 1910.146 permit-required confined spaces.)
Everyone who works with or is potentially exposed to hazardous chemicals receives initial training on the Hazardous Communication Standard and the safe use of those chemicals. The Department Director is responsible to ensure that each employee is adequately trained annually on the chemicals in his/her area. Department Directors may request assistance from the Risk Management Division to arrange training and/or provide training resources such as videos and training guides.
Training on the 4 elements of the Hierarchy of Controls is extremely useful. These elements have to do with recognizing the hazard and teaching the steps to take to mitigate the hazard:
Hierarchy of Controls
Eliminate the Hazard: If possible, get rid of the hazard. Example: substitute a less hazardous chemical for a more hazardous one.
Engineering Controls: If step #1 was not possible, put engineering controls in place to prevent employees from exposure to the hazard. Example: Machine guarding is a classic example. The hazard (moving part) is still there but a barrier has been put between it and the person, protecting the person.
Administrative Controls: If step #1 didn't work and step #2 is not feasible, use administrative controls to limit exposure to the hazard. Example: Rotating shifts of employees into and out of hot areas to prevent heat illness. Traffic laws are great examples of this step.
Personal Protective Equipment (PPE): This is the last choice because the hazard has not been eliminated or controlled. If the PPE fails, the employee is exposed to the hazard. If the employee is not properly trained and willing to wear the PPE correctly, they are exposed to the hazard. The other three steps should be tried before putting anyone in PPE. PPE should be re-evaluated periodically to determine if technology is newly available to eliminate the hazard or engineer it out. Many hazards where PPE was the answer in the past have been eliminated or guarded with advent of useful technology. The PPE itself may also become more effective as technology improves. Improvements in technology should be considered by the Department Director, taking into account the costs and benefits, and implemented where reasonable.
Whenever a new chemical is introduced or the nature of a hazard changes, additional training will be provided. Periodic departmental safety meetings should be held as needed under the direction of the Department Director to reinforce previous training.
The training should emphasize these items:
- Where potentially hazardous materials are used.
- Physical and health hazards employees may come in contact with.
- Precautions to avoid unnecessary exposure.
- Instruction about personal protective equipment.
- Review of SDSs and labels to be sure they are readable and comprehendible.
- Procedures to follow in case of a spill or leak.
The Department Director advises 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, the safe handling procedures to be used, and the location of SDSs. Each contractor bringing chemicals on-site must provide the Department Director with the appropriate hazard information on these substances, including labels used and precautions to take.
Failure to follow the terms of this policy and properly utilize the Hazard Communication Program will be treated as a violation of City policy. Disciplinary action may result, which could include but is not limited to verbal or written reprimand, suspension, and/or termination.
Employees may obtain further information on this program from the Risk Management Division.
Minor Edit, 1/6/2004
Amended, 12/4/2012, Previous Policy 4108
Amended, 3/31/2014, Previous Policy 4108