Hazard Communication Guide for Printing Operations - Version 2.0

SAMPLE WRITTEN PROGRAM

Disclaimer

Prepared by the Printing Industries of America Environmental, Health, and Safety Affairs Department

This is a sample written program provided only as a guide to assist in complying with 29 CFR 1910.1200, OSHA's Hazard Communications Standard. It is not intended to supersede the requirements detailed in the standards. You need to review the standard for particular requirements which are applicable to your specific situation. Employers will need to delete or add information relevant to your particular facility and operation in order to develop an effective, comprehensive hazard communication plan.

Although every effort has been made to provide accurate information within this program, the authors, organizations, and individuals that assisted in its development make no representation or warranty, express or implied, as to the completeness, correctness, or utility of the information and related materials.

The printer should not rely exclusively on this program to address specific questions that apply to a particular set of facts or circumstances. Business practices and operations can vary significantly. Suggested practices in this program and related materials should only be considered to be potential options for achieving improved performance and should not be considered to be the only means to reduce or eliminate exposures to hazardous chemicals. Your particular facility may have unique or additional concerns based upon processes, practices, and materials.

It is assumed and intended that users of this material will exercise appropriate personal judgment and responsibility when utilizing or applying potential hazard abatement procedures and practices. The authors will not be held responsible for any misuse or incorrect use of the suggested procedures or practices depicted.

Name of Company__________________________________________

Date Prepared ____________________

PURPOSE

The purpose of this Written Hazard Communication program is to ensure that:

1. Hazardous substances present in the work place are properly identified and labeled.

2. Employees have access to information on the hazards of these substances.

3. Employees are provided with information and training on how to prevent injuries or illnesses due to exposure to these substances.

4. A responsible person is assigned and identified responsibility for overseeing and maintaining the program.

Note: This program will be available to all employees for review and a copy will be located in NAME OF LOCATION

This standard applies to all work operations within NAME OF COMPANY where an employee is exposed to hazardous substances under normal work conditions or during any foreseeable emergency situation.

The program is updated as new information or interpretations of regulations and supplier information becomes available. This Hazard Communication Program remains uniform throughout all departments in order to maintain the effectiveness of the information provided and to keep the employee instruction consistent within this program.

In order to comply with the Hazard Communication Standard, NAME OF COMPANY has taken the following steps:

1. Developed a written program explaining how NAME OF COMPANY meets the requirements of the Hazard Communication Standard.

2. Compiled an inventory list of all hazardous chemicals.

3. Maintained and updated Safety Data Sheets (SDS) for each of the hazardous chemicals.

4. Ensured all incoming and in-plant containers are properly labeled.

5. Provided employee instruction and training according to the guidelines of the standard. All employees of NAME OF COMPANY are provided safety orientation training which includes initial information on Hazard Communication. Employees whose job duties involve working with any hazardous chemicals receive more detailed instruction at the time of their initial assignment and whenever a new chemical hazard is introduced into their work area.

RESPONSIBILITY FOR COMPLIANCE

NAME OF DESIGNATED PERSON/POSITION will be responsible for seeing that all aspects of our program are carried out according to the regulatory requirements.

The administrative responsibilities of this individual/position include:

1. Identification of the employees to be included in the Hazard Communication Program.

2. Development and maintenance of a hazardous substance master inventory.

3. Coordination and supervision of employee training.

4. Coordination and supervision of the facility's container labeling program.

5. Coordination and supervision of required recordkeeping.

6. Monitoring and maintaining of the overall program.

Employees are responsible for following all safe work practices and using proper precautions required by the guidelines in this program.

HAZARD DETERMINATION

We rely upon the manufacturers’ evaluations of the various hazards of the chemicals they supply to us and will therefore accept the information as provided on the Safety Data Sheets (SDS).

Each SDS will be reviewed when received to see that it contains the required information and has no blank spaces. If any information is missing from the SDS, or if questions arise, the supplier will be contacted. NAME OF DESIGNATED PERSON/POSITION will ensure that information concerning the hazards is transmitted to the appropriate supervisor, will send a copy of the SDS to the appropriate department supervisor, and will retain the original in a master SDS book.

Every attempt will be made by the company to provide engineering controls, administrative controls, or personal protective equipment to eliminate or reduce any hazard to our employees.

HAZARDOUS CHEMICAL INVENTORY

NAME OF DESIGNATED PERSON/POSITION is responsible for compiling, maintaining, and updating, as necessary, a master list of hazardous chemicals used or produced in the facility and placing a copy of the inventory list within the applicable SDS binder. The inventory list will include the product name, common identity, or trade name of the product that is referenced on the appropriate safety data sheet.

NAME OF DESIGNATED PERSON/POSITION will review this list of chemicals at least annually.

SAFETY DATA SHEETS

Safety Data Sheets (SDS) will be available to the employees on all hazardous substances to which there is potential or actual exposure. NAME OF DESIGNATED PERSON/POSITION is responsible for ensuring that an SDS is available on all incoming products. If the SDS is not available, or is incomplete, a request will be made to the supplier for the missing SDS or information.

A single collection of SDSs is maintained for all departments, stored within SDS binders, and indexed by department and general chemical category. NAME OF DESIGNATED PERSON/POSITION is responsible for compiling and updating the master SDS file. This file will be kept at NAME OF LOCATION.

Copies of SDSs will be kept in the following areas:

Department Location

Employees will have access to these SDSs during all work shifts. Copies will be made available upon request to NAME OF DESIGNATED PERSON/POSITION.

All SDSs will be kept for a period of at least 30 years after the use of the substance has been discontinued.

LABELS

All containers in the workplace are to be labeled in order to provide information about the product and an immediate visual warning about the hazards of the chemical in the container. NAME OF DESIGNATED PERSON/POSITION and department supervisors are responsible for ensuring that all containers in the plant are labeled.

Each department supervisor ensures that all hazardous chemical containers used within their applicable department work area are properly labeled. Labels provided on all original manufacturer containers will be maintained and not removed unless immediately re-labeled with an appropriate in-plant label.

Each label on an orginal manufacturer container must contain the following information:

1. Identity of the substance2. Signal word3. Hazard statement4. Pictogram(s)5. Precautionary statement3. Name and address of the manufacturer

Each department supervisor will periodically review all hazardous chemical containers to ensure that the chemical containers are correctly labeled and that labels are not removed from any container or defaced in any manner. Each department supervisor is also responsible for updating and replacing labels as necessary. Any hazardous chemical container label that is found to be non-legible, or any

hazardous chemical container found without a label, including original manufacturer containers, will be properly labeled immediately.

Since chemical manufacturers are required to label their shipped containers, any original manufacturer labels will be used as the primary means of labeling. If chemicals covered under this program are transferred from the original shipped container to another container, those secondary containers will be labeled with an in-plant secondary label. The secondary or in-plant labeling system will consist of using a label similar to the label supplied by the vendor or PROVIDE DESCRIPTION OF ALTERNATIVE PLAN. This will assist employees in easily identifying the product involved with less chance of error. When the container is empty, it may be used for other materials provided it is properly cleaned and relabeled for the other chemical.

Unlabled portable containers, such as pails and buckets, will be used by the employee filling it and emptied at the end of each shift. If the secondary containers are used by more than one employee and/or its contents are not emptied at the end of the shift, the department supervisor is responsible for labeling the container with either a copy of the original label or an in-plant secondary label which communicates the appropriate hazard warnings.

NON-ROUTINE TASKS

Incidental chemical releases by either a spilled or ruptured hazardous waste container, which does not have the potential for becoming an emergency, are covered under this program in conjunction with the emergency/evacuation program.

Any uncontrollable spill or release of a hazardous substance, those which pose a safety and health hazard, and those which exceed the scope of the hazard communication program, requires a complete facility evacuation and notification of emergency services summoned by dialing 9-1-1.

FIRST RESPONDER AT AWARENESS LEVEL

Applicable employees who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response by notifying the proper authorities of a release are considered First Responders at the Awareness Level and must be competent in the following areas:

1. Roles of a First Responder at the Awareness Level

2. Ability to recognize the presence of hazardous materials in an emergency

3. Ability to identify the hazardous substance

4. Appropriate Personal Protective Equipment (PPE) (if necessary)

5. Means for notifying authorities

6. Knowledge on how to secure the applicable area

First Responders at the Awareness Level will take no further action beyond notifying the authorities of the release.

INCIDENTAL SPILL RESPONSE PROCEDURES

Keep appropriate spill-containment material on hand for emergencies. Contact NAME OF DESIGNATED PERSON/POSITION to determine which materials are suitable in a particular department.

Determine if the spill is a simple incidental spill or a major spill. All major spills require the need for outside help.

The following steps shall be followed for incidental spills:

1. Alert employees in the immediate area that a spill has occurred

2. Evaluate the toxicity, flammability, and other hazardous properties of the chemical as well as the size and location of the spill to determine whether evacuation or additional assistance is necessary. Large spills and toxic spills are beyond the scope of this procedure.

3. Initially contain any hazardous liquid spills by using pigs, spill absorbent or other absorbent materials. If releases occur within a room, contain the release also by keeping doors closed if it does not pose a hazard and using absorbent materials near the door thresholds.

4. Cordon off the spill area to prevent further exposure or contamination of employees.

5. Notify management that a spill or release occurred.

6. Identify the hazardous substance, if possible, and consult the applicable SDS for other precautions.

7. Obtain applicable cleaning supplies/equipment and the appropriate PPE, if needed.

8. Wear the appropriate PPE such as gloves, goggles, apron, shoe covers, or respirator. The PPE selection will be based on the hazardous material present.

9. Absorb liquid spills using paper towels, spill pigs, vermiculite, or sand. Place the spill pigs over the spill to draw in the free liquid. Sprinkle vermiculite or sand over the surface of the free liquid.

10. Place the used absorbent materials and waste in plastic bags for proper disposal along with contaminated disposable gear, such as gloves.

If the spill exceeds the scope of the employees experience, training, or willingness to respond, the workers must notify their supervisior, NAME OF RESPONSIBLE PERSON/POSITION, and any other personell as required by NAME OF COMPANY’S emergency response plan.

EMPLOYEE TRAINING

All employees at NAME OF COMPANY are given initial orientation training on each general element of the Hazard Communication Program. Employees whose job duties require working with and handling hazardous chemicals are provided with additional training on the specific hazards. Applicable employee training will occur at the time of their initial employment, prior to being exposed to hazards, and whenever a new physical or health hazard is introduced.

Training topics shall include:

1. Scope of the Hazard Communication Standard

2. The details of our hazard communication program and the location and availability of the written program

3. Hazardous properties of all chemicals present and worked with

4. Safe handling procedures and measures to take in order to protect themselves

5. How to read and identify manufacturer and in-plant labels for hazardous substance containers

6. How to locate and read Safety Data Sheets (SDS)

7. The physical, health, simple asphyxiation, and combustible dust hazards, as well as hazards not otherwise classified, of chemicals present in the work area

8. Means to detect releases of hazardous substances and emergency response procedures for hazardous chemical spills.

9. Work practices that may result in exposure

10. How to prevent or reduce exposure to hazardous substances

11. Appropriate personal protective equipment, where it is located, and how to use it

NAME OF DESIGNATED PERSON/POSITION is responsible for scheduling and conducting the safety orientation training, including Hazard Communication training prior to starting work at NAME OF COMPANY and ensuring that all applicable employees receive updated safety training as necessary or whenever processes, materials, and situations are updated, changed, or modified.

Initial orientation of Hazard Communication training is mandatory for all employees.

Applicable department supervisors shall give employees additional information/training whenever a new hazard which causes health effects unlike those covered in the training session is brought into the employee work area.

Refresher training will be conducted when a new hazard or new product is introduced into the work area in order to identify the hazards of the new product’s hazard or the effects of a new hazard not previously identified and trained on. Refresher training sessions are provided as necessary or when changes occur which may affect those employees who work with hazardous chemicals. Attendance to refresher training is mandatory.

VISITORS, COMMUNITY MEMBERS, AND OUTSIDE CONRACTORS

Visitors It is the responsibility of the host employee to review with the visitors the hazards that they may be exposed to as a result of the visit. All visitors have the right to examine SDSs during normal NAME OF COMPANY business hours and may by issued copies of SDSs after signing for them, if requested.

Community MembersNAME OF DESIGNATED PERSON/POSITION is responsible for responding to requests from members of the community on hazardous substances used in the facility.

Outside ContractorsContractors who work at NAME OF COMPANY should be informed of any chemical hazards associated with NAME OF COMPANY operations in the area where they will be working. Prior to the start of any job involving contractors, NAME OF DESIGNATED PERSON/POSITION should brief the contractor on the hazards related to the areas in which he or she will be working and provide the following information:

1. Precautionary measures that need to be taken to protect workers during normal operating conditions and in forseeable emergencies

2. The labeling system used in this facility3. Onsite access to SDSs for each hazardous chemical the contractors may be exposed to while

working

The contractor and his or her employees may examine applicable SDSs during regular working hours and may be issued copies of any SDS after signing for them. It should be noted that NAME OF COMPANY is not required to give a copy of an SDS to a contractor unless he or she specifically requests one. NAME OF COMPANY’S obligation is to make SDSs available to the contractor.

The contractor must supply an SDS for any products containing hazardous chemicals that is introduced to the facility. Any new hazard information presented by the product is communicated immediately to any potentially exposed NAME OF COMPANY employee.

Any leftover hazardous substances brought to NAME OF COMPANY by the contractor are to be removed by the contractor.

ENFORCEMENT POLICIES

Whenever it is discovered or reported that an employee is not following safety and health rules, NAME OF COMPANY will take all applicable disciplinary action as required under our current disciplinary policy.