HAZARD COMMUNICATION PROGRAM
(Right-to-Know)
for
Van Buren/Cass District Health Department
Background
This written hazard communication program not only meets OSHA requirements, but also ensures that all
Van Buren/Cass District Health Department employees are effectively informed concerning potential and
existing chemical hazards. Hazard Communication is one important aspect of Van Buren/Cass District
Health Department Occupational Safety and Health Program, which includes:
 Management commitment and active support
 Engineering controls for safety and health hazards
 Enforcement of safety rules and programs
 Recognition, Evaluation, and control of occupational safety and health hazards
 Medical Surveillance
 Assigned safety and health responsibility and accountability
Purpose
The purpose of this Hazard Communication Program is to inform our employees of all potential or
existing chemical hazards.
Approach
The method used to inform employees include:
 Container labeling and other forms of warning
 Material Safety Data Sheets (MSDS’s)
 Employee education and training.
In order to comply with the MIOSHA Hazard Communication Standard (29 CFR 1910, 1200), Van
Buren/Cass District Health Department has established the following written hazard communication
program.
1)
Hazard Determination
Van Buren/Cass District Health Department will rely on the Material Safety Data Sheets from
material suppliers to meet hazard determination requirements.
2)
Labeling
A. All labels on chemicals shall be checked for: name of chemical, hazard warning, and
special instructions on handling before using.
B. Maintenance shall be responsible for seeing that the piping systems are painted at
access points and every 10 feet where the piping is 8 feet or closer to employee
contact. Piping shall be painted as follows:
Oxygen
Green
Acetylene
Orange
Natural Gas
Blue
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C. Whenever a chemical is placed into a container that is different than the original
container, the director of that specific department or his/her assistant will be
responsible for properly labeling and storing these containers (See attached sample
of labels).
D. Portable containers of hazardous chemicals do not have to be labeled if they contain
chemicals transferred from labeled containers, which are intended for the immediate
use of the employee who performs the transfer.
E. All labels on incoming containers should not be defaced in any way.
3)
Material Safety Data Sheets (MSDS)
MSDS’s are prepared and distributed by manufacturers and distributors of hazardous materials.
All chemical manufacturer and distributors must obtain or develop a MSDS for each hazardous
material they produce or import. A hazardous material is one that is either a physical hazard (ie,
flammable, oxidizer, etc) or a health hazard (ie, causes acute or chronic health effects).
A. The Administrative Assistant maintains the master MSDS file for all hazardous
materials used or handled in the company workplace and will be responsible for the
distribution of these MSDS to other sites as necessary.
B. It will be Custodial and/or individual department staff’s responsibility to see to it
that the Administrative Assistant at the health department receives copies of all
MSDS on chemicals they receive and are housed at a health department site. Follow
the MSDS policy and procedures (located in the front cover of the Hazard
Communication (Right to Know) Manual.
C. MSDSs will be on hand for all chemicals that are considered:
Hazardous,
Over the counter chemicals (when used for a purpose other than what they are
intended for) and
Drugs when not in solid form.
D. Each satellite office will have a binder with MSDS for chemicals housed at that
particular site and will be located at the front desk.
E. MSDS’s are in English, are in various formats but all must contain the following
information (see attached sample of a MSDS):
* Identity of Chemical (name on label)
* Manufacturer’s Name, address and phone number
* Hazardous Ingredients/Identity Information
* Physical and Chemical Characteristics
* Fire and Explosion Hazard Data
* Reactivity Data
* Health Hazard Data
* Precautions for Safe Handling and Use
* Control Measures
F. The master MSDS book is available for review to all employees during normal
working hours. It can be located at the front desk in Hartford. Copies are available
upon request.
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G. Departments placing their own order(s) will be responsible for requesting a copy of a
MSDS for all hazardous chemicals. These copies will be forwarded the
Administrative Assistant’s office for compiling.
H. The Administrative Assistant must be informed if a hazardous chemical is received
without a MSDS. It will be the responsibility of the Administrative Assistant to
obtain a copy of the MSDS either by calling or writing to the company. If a letter is
written, a copy will be kept on file in the Administrative Assistant’s office.
I.
A list of common MSDS terms is located in the front of each MSDS book located at
each site for easy reference.
J. A Hazard rating index and Hazardous material identification guide is located in the
front of each MSDS book located at each site for easy reference.
K. The MIOSHA Right-to-Know poster (see attached sample) will be updated as
necessary whenever a new or revised chemical has been introduced into the facility.
New or revised MSDS’s will be posted at each office within 5 days of receipt of a
new chemical.
L. The Administrative Assistant will forward copies of MSDS to front desk personal at
satellite offices as needed with instructions to place in their respective MSDS book
and posting on the Right-to-Know poster.
M. All MSDS’s must be retained while the hazardous material is in use or stored on the
property plus 30 years. All MSDS’s that have been either replaced by a more
updated version, or no longer in use must be kept in a “dead” file and turned into the
Administrative Assistant on a yearly basis. A folder to keep track of those MSDS
that are considered “dead” will be located in the back of each Right-to-Know, MSDS
binder.
4)
Inventory
Each respective department where chemicals are stored will conduct an inventory annually by
using the inventory form (see attached). These forms will be used to update their respective
MSDS book. A copy will be given to the Administrative Assistant to compile in the master
MSDS book.
5)
Employee Information and Training
A.
The Administrative Assistant shall coordinate and maintain records of training and
retraining conducted on all employees as necessary.
B.
Each employee who receives training for Right To Know will be requested to sign a
roster indicating their attendance and/or an acknowledgement form. A quiz may also be
given, these documents will be kept in the employer's training file to be used as
documentation that they received training.
C.
Whenever a new chemical is first introduced into a department, that respective Director
has the responsibility to inform the employees within his/her department on proper use,
handling, etc. Both the Director and/or employee will sign a statement indicating that
their Department head informed them on how to use the chemical and what to do if there
is a spill within their department (see attached form).
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D.
6)
The supervisor of an employee performing a non-routine task, such as cleaning process
equipment, is responsible for properly training the employee concerning the potential
hazards associated with the task. The employee also shares in this responsibility by
making sure that his/her immediate supervisor knows that the non-routine task will be
performed.
Informing Contractors
It is the responsibility of the Maintenance to provide contractors and their employees with
information on hazardous materials to which they may be exposed while on the job site.
Maintenance may also request the Administrative Assistant to provide copies of MSDS to
contractors and their employees.
7)
Spills and/or Leaks
Spills kits are located under the sink in each lab of all facilities.
Procedures to follow in the event of a chemical spill:
OSHA recommendations:
1.
Report all spills immediately (regardless of size) to a supervisor and/or our emergency
management supervisor; pull the MSDS for that particular chemical and report the
following:
*
What is leaking/spilled
*
Where the leak/spill is
*
The size of the spill/leak
*
The rate of the flow
If the spill is small, simply follow the procedures below. If the spill is large, contact your supervisor
and/or emergency management supervisor. They will inform you whether or not it is safe to clean up or
whether employees should evacuate the area and leave the clean up to specially trained and equipped
response teams. If necessary, the supervisor and/or emergency management supervisor will notify state,
federal and local authorities as well as local fire and police departments and other spill containment
specialists who might be needed.
2.
Contain the spill. This is a specialized task. Only employees and/or spill specialists who
are specially trained and equipped should be allowed to respond to any major spill.
Employees can respond to very minor and/or small chemical spills. The sooner
containment starts the better. Successful containment involves several steps:
*
Stop the source of the leak (close valves, pumps, etc.)
*
Cover drains or other possible escape routes
*
Patch holes with patch kits, valve pluggers, etc.
*
Contain the spill by the best method possible, such as:
a) Building a dike to keep the spilled liquid from getting into any water
source.
b) Repairing the container or putting it into another container that
doesn’t leak.
c) Channeling the spill to a place where it won’t spread
d) Placing an empty container under the leak
e) Rotating or shifting the container’s position to stop the leak.
DO NOT PLACE A LEAKING CONTAINER IN THE SINK!
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3.
Cleanup personnel (spill containment specialist) must follow required decontamination
procedures. Therefore, have the MSDS of the chemical leaking available to share with
the cleanup personnel. The MSDS will have what procedures and/or tasks that need to
be followed as well as what PPE (Personal Protective Equipment) should be worn to
avoid any spreading of possible hazardous chemicals into clean areas of the facility.
All equipment and tools used (PPE, etc.) during the cleanup effort should be appropriately
decontaminated and/or disposed of in an EPA approved container. Anyone believed to have been
exposed to the toxic chemical, as a result of the spill, may be required to seek further medical assistance
from a local medical facility. Follow Workers Compensation procedures if this should be required.
Employee responsibilities during a chemical spill include:

1.
Read and follow the OSHA recommendations above.
2.
If a small spill, retrieve the spill kit (these are located under the sink in all lab areas) of
all sites.
3.
Put on the appropriate personal protective equipment: (face protection, gown and heavyduty gloves). Refer to MSDS for appropriate PPE. PPE will be kept with the spill kit.
4.
Pour absorbent material on the spill, using enough that the spill becomes manageable in a
solid form. A special spill kit, or powdered sulfur, must be used to clean up mercury. (If
a mercury spill, refer to Mercury Spill Procedures.)
5.
Using the broom and scoop in the chemical spill kit, sweep up the spill and dispose
according to MSDS direction, or if a biohazardous spill, dispose in a red bag.
6.
Clean the area with soap and water.
7.
If the spill is potentially biohazardous, spray the area with a hospital grade disinfectant
using the spray-wipe-spray technique.
The Spill Kit should contain the following items: Absorbent material, personal protective
equipment (face shield, gown, and heavy-duty gloves), small broom (of washable material) and
dust pan, bags for disposal, paper towels for cleaning and disinfectant.
NOTE: Never reuse a disposable item from the spill kit. These must all be disposed of and replaced by
contacting the Administrative Assistant. The broom and dust pan must be disinfected before being
replaced in the spill kit.
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