XIV. HAZARD COMMUNICATION
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14. HAZARD COMMUNICATION PROGRAM
PURPOSE
This document defines the program which has been developed to comply with Federal and/or State
regulations which require that employees be made aware of the potential hazards associated with
materials in the workplace.
DEFINITIONS
1. Hazardous Chemical -- means any chemical which is a physical hazard or a health hazard.
2. Health Hazard -- means a chemical for which there is statistically significant evidence that acute
or chronic effects may occur in exposed employees.
3. Physical Hazard -- means a chemical for which there is scientifically valid evidence that it is a
combustible liquid, a compressed gas, explosive or flammable material.
GENERAL
This program has been developed to provide employees with information concerning hazardous materials
to which they may be exposed at their work location, the protective measures to be taken, the safe work
habits necessary to eliminate or minimize the risks of unhealthful exposure, and to provide the information
required to facilitate medical treatment in the event of unsafe levels of exposure.
The primary elements of the program are:
1. Identification and maintenance of a listing of all hazardous substances in use in the plant or job
site, as applicable.
2. Obtaining from supplies, subcontractors (or other parties, when applicable,) a Material Safety
Data Sheet (MSDS) for each hazardous substance in use and to maintain the MSDSs readily
accessible to all employees (as well as client or subcontractor representatives if applicable).
3. Ensuring that all containers of hazardous substances are properly labeled.
4. Communicating to employees the contents of this program as well as MSDS information for the
specific hazardous substances to which they may be exposed.
IDENTIFICATION OF HAZARDOUS SUBSTANCES
1. It shall be the responsibility of the Plant Manager or job site Project Manager, as applicable, to
identify the hazardous substances in use in the plant or job site and prepare a perpetually
maintained listing of the substances. This list shall be checked against Reference 2, paragraph 2,
or other source recognized by OSHA to determine that the substances are classified as
hazardous.
2. At the request of the Project Manager, subcontractors shall be required to provide a listing of all
hazardous materials under the subcontractor's control.
3. The hazardous material list shall be maintained current by the following actions:
a. Purchasing personnel shall request an MSDS for every chemical which is requisitioned.
b. When it is determined that a new hazardous material is to be used in the plant or at the job
site, the new substance will be added to the list.
c. The Project Manager shall require that subcontractor's management supply information when
a new hazardous substance is brought on the job.
d. As hazardous substances are permanently depleted or removed from the job site, the Plant
Manager/Project Manager shall remove those items from the active listing. Examples: If a
particular subcontractor is the only one using a substance that is on the listing and that
subcontractor's work has been completed and the substance removed, it will be deleted from
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the listing. Likewise, if a chemical is used in the plant or a job site for a particular phase of the
work (e.g., cleaning solvent) for high voltage terminations and the substance is no longer
needed, it shall be disposed of and the item removed from the active listing.
When acting as a subcontractor or work on a job site under the control of a General Contractor or
Construction Manager, the Project Manager shall request MSDS's from the General Contractor or
Construction Manager to arrange for employees to have access to other contractor's MSDS files, as
applicable, and to take part in the hazard training provided by the individual contractors.
MATERIAL SAFETY DATA SHEETS
1. Chemical manufacturers are required to provide MSDS's to users of the chemicals. A sample
MSDS is shown as Exhibit 11A for familiarization and training purposes.
2. For each hazardous substance shown on the listing prepared as described above, the
Purchasing Agent, Plant Manager/Project Manager, as applicable, shall coordinate to obtain an
MSDS to be used for information and training of personnel and for reference information for
subcontractors when applicable.
a. MSDS's for hazardous substances purchased by personnel will be requested from the vendor
or other source from which purchased.
b. MSDS's for hazardous substances brought to the job site by subcontractors will be requested
from the subcontractor.
c. In certain situations, where there is no fixed job site, such as in servicing operations, MSDS's
may be retained in a central location, providing that the information is readily available by
telephone, computer terminal, etc., in the event of an emergency.
LABELING CONTAINERS OF HAZARDOUS SUBSTANCES
1. The Plant Manager/Project Manager, as applicable, shall ensure that containers of hazardous
substances in the plant or job site are labeled with the identity of the substance and with
appropriate words English language, picture or symbols to convey a warning of the health and
physical hazards of the substance. Labeling must conform to the following criteria:
a. The identity appearing on the label must match the identity shown on the corresponding
MSDS. (Refer to MSDS Section 1, upper left on 11-5.)
b. The identity on the label must also match the identity shown on the hazardous substance
listing.
2. The subcontractor who introduces a hazardous substance to a job site, or a supplier of a
purchased substance, should provide the labels.
3. Labeling is not required for small portable containers into which hazardous chemicals are
transferred from a labeled container and which are intended only for the immediate use by the
employee who transfers the substance. However, the Plant Manager/Project Manager must
closely monitor work activities to assure that portable containers are not left unattended or
handled in such a manner as to create an undue hazard.
EMPLOYEE INFORMATION AND TRAINING
1. The contents of this program shall be conveyed to affected employees. Employees shall be made
aware of any operations in their work area where hazardous chemicals are present; where the
hazardous chemicals listing is maintained and the procedure for obtaining MSDS information.
2. Training of employees may be by classroom or group methods. However, based on work
schedules, job peculiarities, etc., the training requirements can be met if each employee reads
the contents of this program and is given an opportunity to present questions and receive
answers concerning the program. New employees should receive orientation and training on the
program as soon as they report to work.
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3. Employee training shall include:
a. Methods and observations which may be used to detect the presence or release of
hazardous chemicals.
b. The physical and health hazards of chemicals in the work area.
c. The measures employees can take to protect themselves from these hazards including any
plant or job site procedures or work practices.
d. Details of the hazard communication program including an explanation of labeling, how to
read MSDS's and how the employee can obtain and use hazard information. The Plant
Manager/Project Manager, as applicable, shall assign personnel to conduct training of
employees. Personnel performing training functions shall maintain accurate records of all
personnel training including dates of training, subjects covered and personnel attending.
SAMPLE FORMS:
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14A. SAMPLE MSDS
MATERIAL SAFETY DATA SHEET
MANUFACTURER'S NAME:
EMERGENCY TELEPHONE NO:
SUREGUARD, INC.
800-535-5053
2350 114th STREET
GRAND PRAIRIE, TEXAS 75050
INFORMATION TELEPHONE NO:
214-647-9049
DATE OF PREPARATION: 2/23/90
SECTION I -- PRODUCT IDENTIFICATION
PRODUCT NUMBER: C500
PRODUCT NAME: CANTEX #99 CLEAR
PRODUCT CLASS: CONDUIT SOLVENT CEMENT
HEALTH 3
HAZARD RATING SCALE
FIRE 3
0=MINIMAL 3=SERIOUS
REACTIVITY 1
1=SLIGHT 4=SEVERE
PROTECTION C
2=MODERATE
SECTION II -- HAZARDOUS INGREDIENTS
occupational Vap. Press
exposure limits @20C
INGREDIENT CAS NUMBER WT.% TLV/TWA
ACGIH MM Hg
ppm
METHYL ETHYL KETONE 78-93-3 43 200
75.0
TETRAHYDROFURAN 109-99-9 40 200
160.0
CYCLOHEXANONE 108-94-1 7 25
(SKIN) 5.0
FLAMMABLE
IRRITANT
OTHER INGREDIENTS
PVC COPOLYMER 90023-22-9 10
not applicable n/a
SECTION III -- PHYSICAL/CHEMICAL CHARACTERISTICS
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BOILING POINT: 151-325F
VAPOR DENSITY (AIR=1): HEAVIER THAN AIR
WEIGHT / GALLON: 7.39 POUNDS / GALLON
EVAPORATION RATE: SLOWER THAN ETHER
% VOLATILE VOLUME: 93.86
APPEARANCE AND ODOR: CLEAR, COLORLESS LIQUID; SWEET, ACETONE-LIKE ODOR
SECTION IV -- FIRE AND EXPLOSION HAZARD DATA
WARNING! FLAMMABLE LIQUID.
FLAMMABILITY CLASSIFICATION: FLAMMABLE LIQUID ?1B
FLASH POINT: 6F TCC THF LEL: 1.3 FOR
SOLVENTS
EXTINGUISHING MEDIA: USE DRY CHEMICAL, CO2, OR ALCOHOL FOAM.
DO NOT USE WATER TO FIGHT FIRE!
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SPECIAL FIRE FIGHTING PROCEDURES: EVACUATE AFFECTED AREA, STAY UP WIND AND
AVOID SMOKE AND FUMES. FIRE FIGHTERS SHOULD WEAR SELF CONTAINED BREATHING
APPARATUS AND FULL PROTECTIVE CLOTHING. USE WATER SPRAY TO COOL NEARBY
CONTAINS AND STRUCTURES EXPOSED TO FIRE.
UNUSUAL FIRE AND EXPLOSION HAZARDS: EXTREMELY FLAMMABLE; THF IS AN OSHA CLASS
1B FLAMMABLE LIIQUID. EXTINGUISH ALL NEARBY SOURCES OF IGNITION. VAPORS MAY
TRAVEL BY AIR CURRENTS TO DISTANT IGNITION SOURCE. THF CAN FORM HEAT SENSITIVE
PEROXIDE WHICH MAY EXPLODE ON CONCENTRATION BY DISTILLATION. FIVE PERCENT THF
IN WATER IS FLAMMABLE. DO NOT DISTILL IF TEST SHOWS MORE THAN 0.05% THF PEROXIDE
IS PRESENT. THF SHOULD NEVER BE DISTILLED TO DRYNESS, TO AVOID A POSSIBLE
EXPLOSION.
SECTION V -- HEALTH HAZARD DATA
FIRST AID MEASURES
INHALATION: REMOVE TO FRESH AIR. GIVE ARTIFICIAL RESPIRATION IF NOT BREATHING .
GET IMMEDIATE MEDICAL ATTENTION.
EYE CONTACT: IMMEDIATELY FLUSH EYES WITH LOTS OF RUNNING WATER FOR 15 MINUTES,
LIFTING THE UPPER AND LOWER EYELIDS OCCASIONALLY. GET IMMEDIATE MEDICAL
ATTENTION.
SKIN CONTACT: IMMEDIATELY WASH SKIN WITH LOTS OF SOAP AND WATER. REMOVE
CONTAMINATED CLOTHING AND SHOES; WASH BEFORE REUSE. GET MEDICAL ATTENTION IF
IRRITATION PERSISTS AFTER WASHING.
INGESTION: DO NOT INDUCE VOMITING. GET IMMEDIATE MEDICAL ATTENTION. IF VOMITING
OCCURS SPONTANEOUSLY, KEEP VICTIM'S HEAD BELOW HIS HIPS TO PREVENT HIS
BREATHING THE VOMITUS INTO HIS LUNGS.
NOTE TO PHYSICIAN: ASPIRATED METHLY ETHYL KETONE MAY CAUSE SEVERE LUNG
DAMAGE AND PRESENT A SIGNIFICANT HAZARD. STOMACH CONTENTS SHOULD BE
EVACUATED QUICKLY IN A MANNER WHICH AVOIDS ASPIRATION. OTHERWISE, TREATMENT IS
DIRECTED AT THE CONTROL OF SYMPTOMS AND CLINICAL CONDITION. THERE IS NO
SPECIFIC ANTIDOTE FOR MEK.
HEALTH HAZARD INFORMATION
PRIMARY ROUTES OF EXPOSURE: SKIN OR EYE CONTACT, INHALATION
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OTHER DATA: LABORATORY RATS EXPOSED BY INHALATION TO OVER 1000 PPM MEK FOR
MOST OF THEIR PREGNANCY PERIOD EXHIBITED MINOR EMBRYOTIC/FETOTOXIC EFFECTS.
THIS CONCENTRATION OF MEK IS OVER 5 TIMES THE OSHA PEL MEK MAY POTENTIATE THE
TOXIC EFFECTS OF N-HEXANE, METHYL BUTYL KETONE, AND CARBON TETRACHLORIDE.
SECTION VI -- HAZARDOUS REACTIVITY
STABILITY: THF CAN FORM POTENTIALLY EXPLOSIVE PEROXIDES UPON LONG STANDING IN
AIR.
POLYMERIZATION: OF THF CAN OCCUR IN THE PRESENCE OF CATIONIC INITIATORS SUCH AS
SELECTED LEWIS ACIDS OR STRONG PROTON ACIDS.
CONDITIONS TO AVOID: HEAT SPARKS, AND OPEN FLAMES.
MATERIALS TO AVOID: ACIDS, OXIDIZING MATERIALS, ALKALIS, CHLORINATED COMPOUNDS,
COPPER OR COPPER ALLOYS.
HAZARDOUS DECOMPOSITION PRODUCTS: MAY LIBERATE CARBON MONOXIDE, CARBON
DIOXIDE, AND UNIDENTIFIED ORGANIC COMPOUNDS IN BLACK SMOKE. MEK IN CONTACT
WITH COPPER MAY FORM ACETYLENE GAS.
SECTION VII -- SPILL, LEAK, AND DISPOSAL PROCEDURES
ACTION TO TAKE FOR SPILLS OR LEAKS: WEAR PROTECTIVE EQUIPMENT INCLUDING RUBBER
BOOTS, RUBBER GLOVES, RUBBER APRON, AND A SELF-CONTAINED BREATHING APPARATUS
IN THE PRESSURE DEMAND MODE OR A SUPPLIED-AIR RESPIRATOR. IF THE SPILL OR LEAK IS
SMALL, A FULL FACEPIECE AIR-PURIFYING CARTRIDGE RESPIRATOR EQUIPPED FOR ORGANIC
VAPORS MAY BE SATISFACTORY. IN ANY EVENT, ALWAYS WEAR EYE PROTECTION.
EXTINGUISH ALL IGNITION SOURCES AND ENSURE THAT ALL HANDLING EQUIPMENT IS
ELECTRICALLY GROUNDED. FOR SMALL SPILLS OR DRIPS, MOP OR WIPE UP AND DISPOSE OF
IN DOT-APPROVED WASTE CONTAINERS. FOR LARGE SPILLS, CONTAIN BY DIKING WITH SOIL
OR APPROVED WASTE CONTAINERS; OR ABSORB WITH NON-COMBUSTIBLE SORBENT
MATERIAL. PLACE RESIDUE IN DOT-APPROVED WASTE CONTAINERS. KEEP OUT OF SEWERS,
STORM DRAINS, SURFACE WATERS, AND SOIL. COMPLY WITH ALL APPLICABLE GOVERNMENT
REGULATIONS ON SPILL REPORTING, AND HANDLING AND DISPOSAL OF WASTE.
NOTE: EMPTY CONTAINERS CAN HAVE RESIDUES, GASES AND MISTS AND ARE SUBJECT TO
PROPER WASTE DISPOSAL.
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SECTION X -- OTHER REGULATORY INFORMATION
THIS PRODUCT CONTAINS THE FOLLOWING TOXIC CHEMICAL SUBJECT TO THE REPORTING
REQUIREMENTS OF SECTION 313 OF TITLE III OF THE SUPERFUND AMENDMENTS AND
REAUTHORIZATION ACT OF 1986 AND 40 CFR PART 372:
NAME CAS
NO. %WT
METHYL ETHYL KETONE 78-93-3
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NOTE
EXCLUSION OF WARRANTIES POLICY
SUREGUARD INCORPORATED
SELLER MAKES NO WARRANTY, EXPRESS OR IMPLIED, CONCERNING THE PRODUCT OR THE
MERCHANTABILITY OR FITNESS THEREOF FOR ANY PURPOSE OR CONCERNING THE
ACCURACY OF ANY INFORMATION PROVIDED BY SUREGUARD INCORPORATED, except that the
product shall conform to contracted specifications, and that the product does not infringe any valid United
States patent. The information provided herein was believed by Sureguard to be accurate at the time of
preparation or prepared from sources believed to be reliable, but it is the responsibility of the user to
investigate and understand other pertinent sources of information, to comply with all laws and procedures
applicable to the safe handling, use, and disposal of waste associated with the products, and to
determine the SUITABILITY OF THE PRODUCT FOR ITS INTENDED USE. Buyer's exclusive remedy
shall be for damages and no claim of any kind, whether as to produce delivered or for non-delivery of
product, and whether based on contract, breach of warranty, negligence or otherwise shall be greater in
amount than the purchase price of the quantity of product in respect of which damages are claimed. In
no event shall Seller be liable for incidental or consequential damages, whether Buyer's claim is based on
contract, breach of warranty, negligence or otherwise.
PREPARED BY JIM LITCHFIELD
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14B. HAZARDOUS SUBSTANCES LIST
PROJECT
LOCATION
HAZARDOUS SUBSTANCE MANUFACTURER(S) APPLICABILITY MSDS
Trade/Generic
Name(s) Hazardous Components Name(s)/Emergency Used On This Available Available At Date Added
Synonyms (Ingredients) Phone Numbers Project On Site Home Office To List
Yes No Yes No Yes No
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14C. SAMPLE PURCHASE ORDER STATEMENTS
"If any materials on this order have been identified as "hazardous substances" in 29 CFR Part
1910 Subpart Z or State Government, suppliers shall provide a Material Safety Data Sheet
(MSDS) for the hazardous substances as required by 29 CFR Part 1910:1200."
If order is for a material which is known to be a hazardous substance, the purchase order
should contain the following statement:
"Item(s) of this purchase order is a known hazardous substance. Please
provide a Material Safety Data Sheet (MSDS) as required by OSHA 29 CFR Part 1910:1200."
Subcontracts should include the following statement:
"Prior to the start of your jobsite work, submit a Material Safety Data Sheet (MSDS) for each
substance you or your subcontractors intend to use on the jobsite which is classified as a
hazardous substance by Federal or State agencies. Submit the MSDS's to the Project
Manager."
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14D. MSDS SUPPLIER FOLLOW-UP REQUEST LETTER
Date:
Addressee:
Dear
On ( date of first letter ), we requested a MSDS for the following substance(s):
(List substance(s) by chemical name, common name and trade name)
To date, we have not received the above referenced MSDS(s). In order to comply with the
Hazard Communication Standard, 20 CFR Part 1910:1200, we need to be in receipt of the
MSDS(s) by the
( 25 days from the date of the original letter ).
Your cooperation in this matter is greatly needed and appreciated. Please send the MSDS(s)
to:
(Name of Hazard Communication Compliance Manager)
(Address)
Sincerely,
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14E. MSDS DIRECTORS NOTICE OF NO RESPONSE
Date:
The Director of Industrial Relations or
OSHA Regional Director
Address in Applicable State
Dear Director:
We have made two requests to ( name of supplier ), our chemical supplier, requesting
(a) MSDS(s) for the following substance(s):
(List substance by chemical, common, and trade name)
Our request was made in an attempt to comply with a request from our employee. To date we
have received no response. In order to be in compliance with Federal Regulation 29 CFR Part
1910:1200, enclosed are copies of the two requests.
Your assistance in this matter is greatly appreciated.
Sincerely,
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14F. MSDS REQUEST--SAMPLE GENERAL
CONTRACTOR/CONSTRUCTION MANAGER
Date:
Addressee:
Reference: 29 CFR Part 1910:1200 and Subpart Z
Dear
Our company hereby requests that Material Safety Data Sheets (MSDS's) for hazardous
materials used on the jobsite by other contractors be furnished to our site
Project Manager, . If such action cannot be accomplished with 15 days
after receipt of this request, please arrange for affected employees to have access to MSDS
information in the individual contractor's files and to attend hazardous materials training
conducted by the other site contractors.
Your cooperation in helping us to comply with Federal and State regulations concerning
employee hazard communication will be greatly appreciated.
Sincerely,
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