Appendix G
Hazard Communication Program
WAC 296-800-170
Hazardous Chemical Communication Program
ESD 101 is committed to the prevention of exposures that result in injury and/or
illness, and to comply with all applicable state health and safety rules. To make
sure that all affected employees know about information concerning the dangers
of all hazardous chemicals used by ESD 101 the following hazardous information
program has been established.
All work units will participate in the hazard communication program. This written
program will be available in our written Accident Prevention Program for review
by any interested employee.
Container Labeling
The Safety Program Manager is responsible for container labeling procedures,
reviewing, and updating. The procedures for proper labeling of all containers and
reviewing and updating label warnings are as follows:

Ensure that all chemicals received are properly labeled and contain an
MSDS.

Ensure that all chemicals transferred from one container to another are
properly labeled.
It is the policy of ESD 101 that no container will be released for use until the
above procedures are followed.
Material Safety Data Sheets (MSDS)
The Safety Program Manager is responsible for establishing and monitoring the
employer's MSDS program. This person will make sure procedures are
developed to obtain the necessary MSDSs and will review incoming MSDSs for
new or significant health and safety information. This person will see that any
new information is passed on to affected employees.
The procedures to obtain MSDSs and review incoming MSDSs for new or
significant health and safety information are as follows:
Copies of MSDSs for all hazardous chemicals in use will be kept in the Safety
Program Manager’s office.
MSDSs will be available to all employees during each work shift. If an MSDS is
not available or a new chemical in use does not have an MSDS, immediately
contact the Safety Program Manager.
Revised, January 2005
Hazard Communication Program
Employee Information and Training
The Safety Program Manager is responsible for the employer/employee training
program.
The procedures for how employees will be informed and trained will be
established by the Safety Program Manager.
The Safety Program Manager will make sure that before starting work, each new
employee of ESD 101 will attend a health and safety orientation that includes
information and training on the following:

An overview of the requirements contained in the Hazard Communication
Standard.

Hazardous chemicals present at his or her work places.

Physical and health risks of the hazardous chemical.

The symptoms of overexposure.

How to determine the presence or release of hazardous chemicals in his
or her work area.

How to reduce or prevent exposure to hazardous chemicals through use
of control procedures, work practices, and personal protective equipment.

Steps the employer has taken to reduce or prevent exposure to hazardous
chemicals.

Procedures to follow if employees are overexposed to hazardous
chemicals.

How to read labels and review MSDSs to obtain hazard information.

Location of the MSDS file and written hazard communication program.
Before introducing a new chemical hazard into any section of ESD 101, each
employee in that section will be given information and training as outlined above
for the new chemical.
Hazardous non-routine tasks
Examples of non-routine tasks include:

confined space entry,

tank cleaning, and

painting reactor vessels.
No non-routine tasks will be performed by employees of ESD 101 without
specific permission, training and personal protective equipment. Normally nonroutine tasks will be assigned to a contractor.
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Hazard Communication Program
Multi-employer work places
It is the responsibility of ESD 101 to provide employers of any other employees
at the work site with the following information:

Copies of MSDSs (or make them available at a central location) for any
hazardous chemicals that the other employers’ employee may be exposed
to while working.

Inform other employers of any precautionary measures that need to be
taken to protect employees during normal operating conditions or in
foreseeable emergencies.

Provide other employers with an explanation of the labeling system that is
used at the work site.
It is also the responsibility of ESD 101 to identify and obtain MSDSs for the
chemicals the contractor is bringing into the work place.
List of hazardous chemicals
Information on each chemical may be obtained by reviewing the chemical
inventory and MSDSs located at the Safety Program Manager’s office.
OSHA clarifies “consumer product” exemption of Hazard Communication
Standard.
In July of 2004, OSHA issued a Letter of Interpretation to address a situation
regarding the Hazard Communication’s consumer product exemption. OSHA
notes that their Letters of Interpretation apply only to the specific circumstances
described, but the information provided can make employers think about similar
situations in their facilities. The Letter includes the following:
“The consumer products exemption applies when a product is defined a
“consumer product” by the Consumer Safety Act (15 U.S.C. 2051 et seq.), and
“the employer can show that it is used in the workplace for the purpose intended
by the chemical manufacturer or importer of the product and its use results in a
duration and frequency of exposure which is not greater than the range of
exposures that could reasonably be experienced by consumers when used for
the purpose intended” (29 CFR 1910.1200(b)(6)(ix)). The term “consumer
product” mean any article, or component part thereof, produced or distributed (i)
for sale to a consumer for use in or around a permanent or temporary household
or residence, a school, in recreation, or otherwise, or (ii) for the personal use,
consumption, or enjoyment of a consumer in or around a permanent or
temporary household or residence, a school, in recreation, or otherwise… (15
U.S.C. 2052).”
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Hazard Communication Program
Question: ESD 101 only uses and stores small quantities of office chemicals
such as white-out, adhesive, copier chemicals and cleaning agents. Are these
covered by the Hazard Communication Standard (HCS)?
Response: OSHA considers office chemicals such as white out, cleaning
chemicals, and copier chemicals to be exempt under the provisions of the rule,
as consumer products. Consumer products, which are hazardous chemicals as
defined by the HCS, fall under the provisions of the standard only when they are
used with greater frequency or duration than a normal consumer, or for uses not
intended by the manufacturer. For instance, OSHA has previously stated that
intermittent or occasional use of a copying machine does not result in coverage
under the rule. However, if an employee were hired to service the machine (such
as for a copier repair position), then the HCS would be applicable.
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Hazard Communication Program
ESD 101
Hazard Communication Checklist
1.
Have we prepared a list of all the hazardous chemicals in ESD 101?
2.
Are we prepared to update our hazardous chemical list?
3.
Have we obtained or developed a material safety data sheet (MSDS)
for each hazardous chemical we use?
4.
Have we developed a system to ensure that all incoming hazardous
chemicals are checked for proper labels and material safety data
sheets?
5.
Do we have procedures to ensure proper labeling or warning signs
for containers that hold hazardous chemicals?
6.
Are our employees aware of the specific information and training
requirements of the WISHA Hazard Communication Standard?
7.
Are our employees familiar with the different types of chemicals and
the hazards associated with them?
8.
Have our employees been informed of the hazards associated with
performing non-routine tasks?
9.
Do our employees understand how to detect the presence or release
of hazardous chemicals in ESD 101 buildings?
10. Are employees trained about proper work practices and personal
protective equipment in relation to the hazardous chemicals in their
work areas?
11. Does our training program provide information on appropriate first
aid, emergency procedures and the likely symptoms of
overexposure?
12. Does our training program include an explanation of labels and
warnings that are used in each work area?
13. Does the training describe where to obtain material safety data
sheets (MSDS) and how employees may use them?
14. Have we worked out a system to ensure that new employees are
trained before beginning work?
15. Have we developed a system to identify new hazardous chemicals
before they are introduced into a work area?
16. Do we have a system for informing employees when we learn of new
hazards associated with a chemical we use?
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Hazard Communication Program
NIOSH Hazard Communication Checklist
1.
Has a written hazard communication program been developed,
implemented, and maintained at your worksite?
2.
Has a list of known hazardous chemicals at your facility been prepared?
3.
Have methods been developed to inform employees of the hazards of
non-routine tasks?
Note: Such tasks may include emergency response or equipment repair.
4.
Are methods developed for communicating hazards to outside contractors
or vendors who may be exposed to hazardous chemicals at your
worksite?
Labels
5.
Are all containers of hazardous chemicals in the workplace labeled,
tagged, or marked with the following information?
 The identity of the hazardous chemical(s)
 The appropriate warnings
 The name and address of the chemical manufacturer, importer, or
other responsible party.
Note: Labels must be affixed to all containers of hazardous chemicals
when they are shipped by a manufacturer or supplier. If the container is
received without a hazard warning label, you must make a good faith effort
to obtain the missing information from the manufacturer or supplier. The
following hazardous chemicals are exempt from this labeling requirement,
although subject to other labeling requirements: pesticides, foods, food
additives, color additives, drugs, cosmetics, medical devices, alcoholic
beverages, consumer products, hazardous waste, tobacco products, and
wood products.
6.
Is removal or defacing of labels on incoming containers of hazardous
chemicals prohibited?
7.
Are labels or other forms of warnings legible, in English, and prominently
displayed?
Material Safety Data Sheets
8.
Are material safety data sheets on hand for each hazardous chemical
used and identified on the hazardous chemical?
9.
If a hazardous chemical has no material safety data sheet, are attempts
made to obtain one from the chemical manufacturer or importer as soon
as possible?
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Hazard Communication Program
10.
Are material safety data sheets for the hazardous chemicals kept in the
facility and made readily accessible to employees?
Information and Training
11.
Is information and training on hazardous chemicals in the worksite
provided on initial assignment and whenever new physical hazards or
health hazards are introduced into the work area?
12.
Does the information provided include the requirements of this standard,
as well as the following?
13.

The operations at the worksite where hazardous chemicals are present

The location and availability of the written hazard communication
program, including the list of hazardous chemicals and material safety
data sheets
Does the training provided include information about the following?

Methods and observations that may be used to detect the presence or
release of a hazardous chemicals in the work area (such as monitoring
conducted by the employer, continuous monitoring devices, visual
appearance or odor of hazardous chemicals when being released, etc)

The physical hazards and health hazards of the chemicals in the work
area.

The measures employees can take to protect themselves from these
hazards, including procedures the employer has implemented to
protect employees from exposures to hazardous chemicals
(appropriate work practices, emergency procedures, and personal
protective equipment).

The details of the hazard communication program developed by the
employer, including explanations of the labeling system, material
safety data sheets, and how employees can obtain and use the
appropriate hazard information.
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