Hazard Determination

Prior to use, all chemicals used will be evaluated in regard to physical and health hazards. The Production will rely upon supplier – provided SDS for the hazard determination. The provided SDS will be reviewed for completeness by the Safety Program Director with the assistance of the Production Safety Consultant, if needed. The Production Safety Consultant may also make appropriate recommendations or develop a Special Work Practice / Procedure in regard to the safe use of chemicals by employees.

Safety Data Sheets (SDS)

A SDS is to be obtained and filed in an SDS binder before a chemical is used by any employee. The SDS will be filed alphabetically by its common trade name. The department manager or supervisor is the only person permitted to add or remove SDSs from the department’s binder. In the event a SDS is not received with a chemical or the SDS is not complete, the department manager or supervisor shall request a SDS from the supplier. The SDS binder shall be readily accessible to all employees. Employees need not obtain their supervisor’s permission to review the SDS.

SDS Hotline

A SDS Hotline service is available to all departments and employees of the Production. The telephone number of this service is: (888) 362­7416.  When contacting this service, employees should provide the operator with the name, product number, UPC Code (if available), and manufacturer of the material in question. In addition, the employee should provide the operator with a valid return fax number. The SDS will then be promptly faxed to the employee. There is no charge to the employee or to the Production for the use of the SDS Hotline service.

Chemical List

A listing of hazardous chemicals shall be maintained by the department manager or supervisor for all hazardous chemicals utilized by his or her department. The list shall be reviewed for accuracy on a quarterly basis. Each employee shall receive a copy of the current chemical list during training. A copy of the current list shall be filed in the department’s SDS binder. When a chemical is deleted from the list, the department manager or supervisor shall draw a line through the deleted chemical and date and initial the line. When a new chemical hazard is added, the department manager or supervisor will add the chemical to the list and mark the chemical with an asterisk (*). Old chemical lists and Hazard Communication Program Update memos shall be maintained by the Safety Program Director to meet the exposure record requirements of Cal/OSHA and Federal OSHA.

Labeling

When the Production receives containers of a hazardous substance, the supplier’s original containers should have a label providing the following information:

• Product Identifier
• Hazard statement(s)
• Signal Word
• Pictogram
• Precautionary statement(s)
• Name, address and phone number of the chemical manufacturer, distributor, importer, or other responsible party

If any of this information is missing, it is the responsibility of the department manager or supervisor to apply an additional label indicating the missing information. Manufacturer’s labels will NOT be removed, defaced, or covered. Chemicals in containers must not be used until the required information is affixed to the container. The exceptions to this requirement are:

1. Portable containers do not require labels when chemicals are transferred from labeled containers for immediate use, provided the chemical will be used by the employee who performs the transfer and will be used during the employee’s shift.
2. Smaller containers do not require labels when they are removed from a labeled box or labeled rack, provided they will be used immediately by the employee who removed the containers and the material will be used during the employee’s shift.
3. If chemicals in an unlabeled container have not been completely used at the end of the employee’s shift, the chemical must be returned to a labeled container, box or rack.  Employees must be able to identify the health, fire, and reactivity hazards of the container contents by reading the label.

Contractors

Contractors working for the Production in areas where hazardous chemicals are used will be informed of the hazards within the area. The department manager or supervisor will provide a contractor representative with copies of the current chemical list and training hand­out material. Each of the contractor’s employees working in the area should receive a copy of the two documents. Questions relating to the hazardous chemicals shall be addressed to the Safety Program Director. Contractors will be required to provide a list of the hazardous chemicals or copies of the SDS they will use to the department manager or supervisor. Employees will be informed of the hazards of the chemicals used by any contractors working in their area. The department manager or supervisor shall review the provided list and SDS to ensure chemicals which are prohibited are not included.

Employee Information and Training

Employees must be trained regarding the Production’s Hazard Communication Program. This includes the following: Information and training on hazardous substance(s) must be provided at the time of initial assignment and when a new hazardous substance is introduced into the workplace. Prior to starting work, employees are required to attend a health & safety orientation set up by the department manager or supervisor for information and training on the following:

1. An overview of the requirements contained in the Hazard Communication Regulation, including their rights under the Regulation.
2. Inform employees of any operations in their work area where hazardous substances are present.
3. Locations and availability of the written Hazard Communication Program.
4. Physical and health effects of the hazardous substances.
5. Methods and observation techniques used to determine the presence or release of hazardous substances in the work area.
6. How to lessen or prevent exposure to these hazardous substances through the use of engineering controls, work practices, and/or the use of personal protective equipment.
7. Steps that the Production has taken to lessen or prevent exposure to these substances.
8. Emergency and first aid procedures to follow if employees are exposed to hazardous substance(s).
9. Location and availability of SDS Sheets, including the order of information. How to read labels and review SDS to obtain appropriate hazard information.
10. Review of the Globally Harmonized System of Classification and Labelling of Chemicals.  Written documentation regarding employee training must be maintained for a minimum of three years.

It is critically important that all of the Production’s employees understand this training. If an employee has any additional questions, the department manager or supervisor should be contacted. When new hazardous substances are introduced, the department manager or supervisor should review the above items as they relate to the new substances in the department’s work area.

See the Hazard Communication Training Materials and documentation form for more information.