hazard communication - Oklahoma State University

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HAZARD COMMUNICATION
Train-the-Trainer
RIGHT-TO-KNOW PROGRAM
Train-the-Trainer
October 2011
OSU Environmental Health & Safety Dept.
Oklahoma Hazard Communication Standard
Enacted: April 11, 1986
Scope:
The Oklahoma standard applies to all public employers who use hazardous substances,
to any person who imports and sells a hazardous substance to any public employer in
the state, and to manufacturers who produce or distribute hazardous substances in the
state.
State Agency:
Oklahoma Department of Labor
4001 North Lincoln Boulevard
Oklahoma City, Oklahoma 73015
(405) 528-1500
Authority:
Title 40 O.S. Sections 407 et seq
Oklahoma Dept. of Labor, effective July 1, 2009, adopted the Federal Hazard
Communication Standard in 29 CFR 1910.1200, with the exception that training is
required annually.
To Whom Does This Program Apply?
 Cities
 Counties
 Public Authorities
 Public Schools
 Universities
 All State and Local Government Employers
Five Stages of Hazcom Program
1. Material Safety Data Sheets (MSDS)
2. Labeling & Marking System
3. Employee Training Sessions
4. Written Plan
5. Chemical Inventory (Online)
COMPONENT ONE
Material Safety Data Sheets
Material Safety Data Sheets
Purpose:
• Prepared by Chemical Manufacturers or Importers to describe
characteristics of product and provide information concerning
potential hazards.
• Must be readily available for employee review at all times the
employee is in the work place.
What Information is on an MSDS?
• Company Information
• Hazardous Ingredients
• Physical Data
• Fire and Explosion Hazard Data
• Health Hazard Data
• Reactivity Data
• Spill or Leak Procedures
• Special Protection Information
• Special Precautions
02/24/99
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Review MSDS for Completeness
 It is the responsibility of the end user to
determine that an MSDS is complete and has
useable information.
 Some manufacturers have a tendency to gloss
over hazards and certain facts.
COMPONENT TWO
Labeling & Marking System
Labeling & Marking System
• Manufacturer's Responsibility
Name and Address
Identity of Hazardous Components
Appropriate Hazard Warnings
• User's Responsibility
Identity of Hazardous Components
Appropriate Hazard Warnings
CAS# -- Chemical Abstract Service Number
Assure that Manufacturer's label is not defaced or removed
OSU’s HMLS
(Hazardous Materials Labeling System)
 Code-Oriented
 Easy to Learn
 Complements the Manufacturer’s Labeling
"*" next to the Health number means that the substance has chronic
health effects.
Label
Chemical:
Isopropyl Alcohol
Cas# 67-63-0
Health
Flammability
Instability
Personal Protection
Oklahoma State Hazard Communication
HEALTH
4
3
2
1
0
FLAMMABILITY
INSTABILITY
Deadly
Very Flammable
May detonate
Extreme
Danger
Flammable under
most conditions
Explosive
Dangerous
May ignite—use
caution
Unstable
Slight
Hazard
Must be preheated to ignite
Normally
stable
No Hazard Will not burn
Stable
OSU’s Personal Protection Symbols
Problem Solving Session
Signs & Placards
All buildings on Oklahoma State University property will be
placarded in compliance with the law.
Each building that contains over the TPQ (threshold planning
quantity) of a hazardous substance will bear the appropriately
numbered, diamond-shaped placard approved by the National
Fire Protection Association (NFPA).
ISOPROPYL ALCOHOL
HAZARD COMMUNICATION
WORKSHOP ANSWERS
• MEK
1*30
(Depends)
• TOLUENE
2*30
(Depends)
Not Regulated
(Depends)
2*01
(Depends)
• WOW
• Aluminum
COMPONENT THREE
Employee Training Program
Employee Training Program
REQUIRED:
• Within 30 Days of Initial Assignment
• Whenever New Hazards Are Introduced
• Annual Review Is Required
Training & Information Requirements
Employees must be informed of:
•
Requirements of Regulations
•
Any Operations in Their Area Where Hazardous
Chemicals Are Used
•
Location and Availability of MSDS and Plan
Training must cover:
•
Method to Detect Presence of Release
•
Physical and Health Hazards
•
Measures for Personal Protection
•
Details of Written Hazard Communication Plan
Proposed Training Program Format
Follows the Five Program Stages
1.
Material Safety Data Sheets
2.
Marking and Labeling System
3.
Employee Training
4.
Written Plan
5.
Chemical Inventory
Proposed Training Program Format
Describe Policies and Procedures
 Hazard Detection
 Spill Response
 Use of Protective Equipment
  Open Book Test
Conducting the Training
• It will take a minimum of 30 to 45 minutes to
conduct the basic Hazard Communication
Training.
• If there are any specific hazardous substances or
situations to be trained on, the session will take
longer to complete, depending on the type and
number of hazardous substances.
EXAMPLE:
Office Employees with no
specific hazardous
substances.
30 - 45 minutes per
session
Paint Shop Employees
with 4 specific substances
to be trained on (paints,
solvents, etc.)
1 to 1½ hours,
depending on their
training needs
Choosing Specific Substances for Training
Train on any substance having an OSU HMLS rating of...
HEALTH:
FLAMMABILITY:
REACTIVITY:
3 or above
3 or above
2 or above
If none of the above, choose 4 or 5 of the worst substances that you do
have and use them in the training.
Training (Comments)
• Training isn't handing out MSDS/s and asking them to read.
• Training should be accompanied by a simple test with signature,
and filed for documentation.
• Training probably occurs in two phases:
1. General chemical safety, spill response, labeling
procedure, etc. Perhaps film or tape.
2. Specific work place. Specific labels, MSDS/s,
emergency plans, etc.
Training (Comments)
• Phase 2 (specific) trainers should be trained and provided
guidelines.
• If decentralized, periodic audits will help.
• Annual retraining or when new hazard is introduced.
• Trainers should not criticize program.
• Training packages are available:
* computer self-paced instruction
* films
* video tapes
• There is no substitute for workplace-specific training.
Sample Test for Hazard Communication
1. MSDS means:
2. What does this emblem mean and where can you
expect to see it?
3. This training session is your required Hazard
Communication training (true or false).
4. Where are the MSDS’s kept for your department?
5. If you have a question about the safe use of a
chemical, always consult your: _________.
•
Signature & Date
Emergency Information Signage
COMPONENT FOUR
OSU’s Written Program
OSU’s Written Program
Our written program is Oklahoma State University Policy
and Procedure #3-0535 ---
“Hazard Communication Program”
COMPONENT FIVE
Chemical Inventory
Chemical Inventory
 Kept online at ehs.okstate.edu
 Virtually paperless
 Updated at least annually
 Updated when adding any new product
 Signs, Placards, Labeling
 Identify chemical hazards
Chemical Safety Assistant
(online inventory program)
Chemical Safety Assistant
(online inventory program)
Inventory reports can be printed or saved as a
PDF file.
Methods of Instruction
Conducting a Training Session
INTRODUCTION
NOTE:
Make use of the training manual and contents in the
packet when conducting the training session.
1.
Have Trainees sign attendance sheet.
2.
Introduce Right-To-Know and who it covers.
3.
Briefly explain the intent of RTK legislation.
4.
Introduce the five components of an RTK program.
5.
Inform trainees that a test will be given at the end of the
session.
REMEMBER

Make sure that the training session addresses the materials and
situations encountered in your department.
Component One 
MATERIAL SAFETY DATA SHEETS (MSDS)
 Explain the purpose of an MSDS.
 Explain what information is on an MSDS
(use a material common in your department).
Identify:
Any health hazards (acute or chronic effects)
Exposure Limits
First Aid Procedures
Material's Physical Characteristics
Fire and Explosion Hazards
Material's Reactivity
Personal Protection Requirements
Special Precautions
Manufacturer's Name
Emergency Phone Numbers
Component One 
MSDS (continued)
 Inform the trainees of the location of the MSDS/s and
CIL/s that apply to them and that they are readily
available to the employees.
OSU ADDITIONAL INFORMATION
 Explain the meaning of, and method of filling out, the
Employee Exposure Report.
POINTS TO STRESS
 Make sure everybody understands what an MSDS is
and how to read one.
Component Two 
LABELING

Explain the OSU (HMLS) system for labeling hazardous materials and
where it is used.

Show an example label and explain.

Allow the trainees to read a label for an example material common in
your department.
HAZARDOUS MATERIAL SIGNAGE

Explain the OSU Uniform Laboratory Hazard Signs (ULHS) for work
area hazardous materials and where it is used.

Explain that EHS will put placards on campus buildings.
Component Two 
POINTS TO STRESS

Make sure trainees understand how to interpret the HMIS labeling
scheme, and where they can expect to encounter it.
 Make sure trainees understand how to interpret the NFPA labeling
scheme, and where they can expect to encounter it
NOTE:
Make use of the material provided with this manual when
conducting training.
Component Three 
TRAINING


Explain when Right-To-Know training is required.
Explain what this training must consist of.
POINTS TO STRESS

This training session is their required RTK training
Component Four 
WRITTEN PROGRAM

Explain OSU's Hazard Communication Policy
(Policy & Procedures Letter 3-0535).

Use and refer to OSU’s Hazard Communication Brochure, which is
summary of the Policy.

The brochure is available on the EHS website at
http://ehs.okstate.edu/hazcom/brochure.pdf .
POINTS TO STRESS

The plan is available to employees on request, and where that plan is
located.
Component Five 
CHEMICAL INVENTORY

Explain why a Chemical Inventory is required, citing what laws and
regulations (federal and state), and how often it should be updated.

Explain how it is used by emergency response personnel.

Explain how campus hazard signage is determined and
what its function is.

Explain when an MSDS is required.

Explain how access to the Online Inventory is obtained.
POINTS TO STRESS

Make sure everyone knows that the Chemical Inventory must be updated
annually and any time a new substance is brought into the
department.
Specific Department Hazards 

Cover any hazards or situations unique to your department.

Choose 4 or 5 of the worst materials encountered in your
department. Train employees on how to recognize and deal with
emergency situations concerning these specific materials.

If there are any special Personal Protection Equipment
requirements, then the employees should be trained on how to
use the equipment.

Explain procedures for dealing with spills and emergency
situations.
OSU-Specific Guidelines 
O
Contingency Checklist
Important to identify contact personnel as well as an evacuation route
O
Employee Exposure Report
Responsibility of employee’s supervisor to fill out this report. It will be
kept on file for 40 years from date of exposure.
O
Labels
Available from EHS at no charge to departments. Please call 4-7241 to
place an order for labels and how to obtain needed forms.
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