Hazard Communication “Right-to-Know” Program

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Hazard Communication “Right-to-Know” Program
XYZ Animal Hospital – Hazard Communication “Right-to-Know” Program
Approved By:
Position:
Date: 7/16/08
Date:
PURPOSE
The purpose of this program is to protect XYZ Animal Hospital employees from the hazards
associated with the use of hazardous chemicals associated with our operations.
SCOPE
This program applies to all XYZ Animal Hospital employees, vendors, contractors, and
subcontractors.
RESPONSIBILITY
Practice Manager
 Oversee the overall implementation of this Hazard Communication “Right to Know”
Program.
Program Administrator (Enter Position of Program Administrator)
 Identify hazardous chemicals used at XYZ Animal Hospital
 Review and approve the use of new chemicals used at XYZ Animal Hospital
 Maintain current and obsolete Material Safety Data Sheets (MSDS) for the chemicals
used at XYZ Animal Hospital
 Conduct employee training on the provisions of this program
 Provide proper labeling for the chemicals used at XYZ Animal Hospital
Supervisors and Employees
 Comply with all aspects of this program.
DEFINITIONS
Article: A manufactured item other than a fluid or particle: (i) Which is formed to a specific
shape or design during manufacture; (ii) Which has end use function(s) dependant in whole or
in part upon its shape or design during end use; and (iii) Which under normal conditions of use
does not release more than very small quantities, e.g., minute trace amounts of a hazardous
chemical and does not pose a physical or health risk to employees.
Acute: Health effects that show up a short length of time after exposure.
Contractor: A non-company employee being paid to perform work in our facility.
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CONFIDENTIAL AND PROPRIETARY – © 2008 XYZ Animal Hospital
Hazardous Chemical: A chemical that has the capability of producing adverse effects on the
health and safety of humans.
Health Hazard: A chemical which is: carcinogenic, toxic, corrosive, a reproductive hazard, an
irritant, a sensitizer, or can damage body systems.
Material Safety Data Sheet (MSDS): A written document prepared by the chemical
manufacturer, supplier, or distributor that details the contents, hazards, proper use directives,
and emergency response protocol for a hazardous chemical.
Physical Hazard: A chemical which is: a combustible liquid, a compressed gas, explosive,
flammable, organic peroxide, oxidizer, pyrophoric, unstable, or water reactive.
Vendor: A non-company employee being paid to perform a service in our facility.
PROGRAM APPLICATION
This program will be applicable to all chemicals that exhibit or could exhibit health hazards or
physical hazards under conditions of normal operation or during emergencies. The following
materials are exempt from the OSHA requirements of inclusion for this program:
 Consumer products when used in the workplace in a duration and frequency that is not
greater than that experienced by a regular consumer
 Articles (see Definition)
 Food
MATERIAL ORDERING & HAZARD DETERMINATION
Any employee wishing to introduce a new chemical into the facility must obtain a material
safety data sheet (MSDS) and submit the MSDS to the Program Administrator prior to ordering
the chemical. The Program Administrator will evaluate all new or replacement chemicals to
determine if the chemical presents health or physical hazards for our employees or to our
facility. If the Program Administrator determines that the new chemical can not be handled
safely, the chemical will not be ordered.
Information on new chemicals, or new information on currently used chemicals, will be
communicated to affected employees by the Program Administrator. Every effort will be made
to select chemicals that are not hazardous or that present the minimum degree of hazard
commensurate with necessary chemical capability.
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CONFIDENTIAL AND PROPRIETARY – © 2008 XYZ Animal Hospital
HAZARDOUS CHEMICAL INVENTORY & MSDS
A list of hazardous chemicals currently used at our facilities will be maintained by the Program
Administrator (see Appendix A for the Hazardous Chemical Inventory). As new chemicals are
purchased the necessary information will be added to the Inventory.
MSDS will be obtained and maintained for all hazardous chemicals used at XYZ Animal
Hospital Facilities. MSDS will be available to all employees on all shifts.
The Hazardous Chemical Inventory and MSDS files will be maintained in the following
location(s): (Enter Locations of MSDS below)
MSDS Locations
Chemicals no longer used at our facilities will be removed from the Inventory. MSDS for these
chemicals will be retained on site for 30 years.
CHEMICAL LABELING
All containers containing hazardous chemicals will be labeled with the following information:
 Identity of the hazardous chemical
 Appropriate hazard warnings alerting employees of the health and physical hazards
presented by the chemical.
All incoming containers containing hazardous chemicals will be inspected by the receiving
personnel. Containers that are not properly labeled will be labeled by receiving personnel.
Containers received with contents not listed on the hazardous chemical inventory will be
refused or will be placed in quarantine and the Program Administrator notified immediately.
The Program Administrator will approve all labels used within our practice. Each departmental
supervisor is responsible to assure that all hazardous chemical containers, including containers
that are refillable from bulk containers, are labeled properly and that the label is visible during
use.
Labels will not be removed or covered over until a container is empty.
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CONFIDENTIAL AND PROPRIETARY – © 2008 XYZ Animal Hospital
TRAINING
Training will be provided at the following times:
 At time of initial assignment
 Whenever a new hazardous chemical is introduced, or when the hazard information
regarding a currently used chemical changes
 When the program elements change
 Whenever the Program Administrator or other management members determine through
observation that retraining is needed
Training will consist of:
 An overview this program
 Review of operations where hazardous chemicals are present
 Location of the written hazard communication program, Hazardous Chemical Inventory,
and MSDS files
 Methods and observations used to detect the presence or release of hazardous chemicals
 Physical and health hazards of chemicals in the work area
 Measures that employees are required to take to protect themselves from hazards
including: procedures, work practices, emergency procedures and personal protective
equipment requirements.
 Explanation of the labeling system and how to read an MSDS so that this information
can be used appropriately by all personnel
SAFE CHEMICAL HANDLING
Employees handling/using chemicals will take the following precautions:
 Read, understand and follow label, MSDS and work instructions
 Check to be sure labels are in place and legible
 Never mix chemicals unless instructed
 Store and handle chemicals properly
 Wear all required personal protective equipment
 Wash hands after use
NON-ROUTINE TASKS
Whenever a non-routine job involving work with hazardous chemicals is required, special
training will be provided for all affected employees prior to the job. The training will include:
 Hazardous chemicals to be used in the non-routine task
 Protective measure required to perform the work safely
 Emergency procedures
 An opportunity to ask questions or ask for additional information
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CONFIDENTIAL AND PROPRIETARY – © 2008 XYZ Animal Hospital
CONTRACTORS
Contractors who will bring hazardous chemicals into our facility shall do the following:
 Provide the Program Administrator with a chemical inventory list and an MSDS for
each hazardous chemical that will be used in our facility
 Maintain a copy of the MSDS for each approved chemical on site
 Will not bring chemicals into our facility unless approved by the Program Administrator
 Will comply with all provisions of the Hazard Communication Standard that are
applicable to their company
XYZ Animal Hospital reserves the right to refuse the use of chemicals based upon our
evaluation. We also reserve the right to terminate the use of chemicals at any time based upon
variable conditions within our facility.
Contractors will be provided the following information whenever their work location could
bring them into contact with our hazardous chemicals.
 Hazardous chemicals that they may be exposed to while performing the specified work
and how to obtain a copy of appropriate MSDS
 Necessary job precautions to work safely within the proximity of the chemicals
involved.
PROGRAM EVALUATION
The Hazard Communication “Right to Know” Program will be reviewed annually by the
Program Administrator. The revisions at the time of review will be recorded and noted on the
next revised version of the policy.
APPENDICES
Appendix A – Hazardous Chemical Inventory
Revision Date
Description of Revision
Approved By:
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CONFIDENTIAL AND PROPRIETARY – © 2008 XYZ Animal Hospital
Appendix A
Hazardous Chemical Inventory
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CONFIDENTIAL AND PROPRIETARY – © 2008 XYZ Animal Hospital
Hazardous Chemical Inventory
Chemical
Program Administrator:
Last review:
Common Name
MSDS #
______________________________________
______________________________________
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CONFIDENTIAL AND PROPRIETARY – © 2008 XYZ Animal Hospital
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