5.5 Hazard Communication

5.5.1 Overview

A hazard communication program is required for all Church employees who work with hazardous chemicals. These guidelines are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS).

The general requirements of the hazard communication program include the following:

• A written hazard communication program (see Written Hazard Communication Program in chapter 7) that:

  • Provides a list of hazardous chemicals (see Chemical Inventory List in chapter 7)

  • Designates people responsible for labeling chemicals, maintaining safety data sheets (SDSs), and training

  • Describes the labeling system

  • Provides the location of SDSs and procedures for getting and updating SDSs

  • Provides a format and elements of the training program

  • Provides procedures to train new employees

• Labels (see sample label and pictograms at the end of this section) and other forms of warning that should:

  • Be placed on portable and process containers

  • Identify contents and have appropriate hazard warnings

  • Cross reference with SDSs and the Chemical Inventory List

• SDSs that should:

  • Be available for each chemical used

  • Be current (manufacturers must provide an SDS with the first shipment of a chemical and also update the SDSs if the information changes)

  • Be readily accessible to employees in their work area during their work shift

• Information or training for employees about:

  • Hazardous chemicals in the employee’s work area (a) when an employee is initially assigned and (b) when new chemicals are introduced

  • The standard requirements for hazard communication

  • Locations of hazards

  • Location of written program, SDSs, and the Chemical Inventory List

  • Ways to determine hazards (warning properties) and specific hazards of chemicals (health effects)

  • Labeling

  • Precautions

5.5.2 Hazard Communication Program

The purpose of the hazard communication program is to ensure that:

• An evaluation is made of the hazards of all chemicals produced or imported by chemical manufacturers or importers.

• Information is transmitted to appropriate employees.

5.5.3 Documentation

A complete written hazard communication program should be maintained.

5.5.4 Responsibilities

The Church, as an employer, should develop and implement a hazard communication program at each work location. The program should facilitate the following actions:

1. Identifying hazardous chemicals

2. Labeling chemical containers with warning labels

3. Providing access to SDSs

4. Providing information and training for employees

5. Providing a written hazard communication program for each work location

The following is more information about the five basic parts of the program and a list of tasks for each part.

1. Identifying Hazardous Chemicals

The chemical manufacturer or importer is responsible for determining if a chemical is hazardous. As a user, you may rely on the evaluation from these suppliers through labels on containers and SDSs.

Managers and supervisors should complete the Chemical Inventory List (see chapter 7) and do the following:

• Conduct an on-site chemical inventory by writing down the names of all hazardous chemicals. Hazardous chemical means any chemical that is classified as a physical hazard or a health hazard, a simple asphyxiant, a combustible dust, a pyrophoric gas, or a hazard not otherwise classified. List all hazardous chemicals using the identifying name that appears on the appropriate SDS and label for the chemical. Compile the list for the entire workplace or for individual work areas in various sections of the facility.

  The list will be part of the written program and should be made available to employees on request. It will also serve as an inventory to ensure all required SDSs are obtained.

• Review your completed list to determine if any of the items are exempted. The following items are exempt from the hazard communication standard:

  • Hazardous wastes

  • Wood or wood products

  • Manufactured articles or products that do not release hazardous chemicals under normal use

  • Foods, drugs, or cosmetics for employees’ personal use

  • Any consumer product or hazardous substance that is used in the workplace in the same manner as it is normally used by consumers. Exposure to chemicals that results from using the item must not be greater than normal consumer experience

You may include all chemicals on your Chemical Inventory List, even if they are exempted. If there is any question regarding a particular chemical, it is best to include that chemical on the list.

2. Labeling Chemical Containers with Warning Labels

• Label all hazardous materials in the workplace with the six required GHS elements, including (1) product identifier, (2) signal word, (3) hazard statements, (4) pictograms, (5) precautionary statements, and (6) name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

  • A sample hazard communication program label that identifies the required label elements is shown at the end of this section.

  • Examples of pictograms are shown at the end of this section. The pictograms on labels are intended to alert users to the chemical hazards they may be exposed to. Each pictogram consists of a symbol on a white background framed within a red border and represents a distinct hazard. The pictogram on the label is determined by the chemical hazard classification.

• Make sure that labels are in the primary language understood by the employees. If employees speak other languages, the information may also be presented in those languages.

• Check all incoming shipments of hazardous chemicals to be sure they are labeled.

• Do not remove or deface existing labels on incoming containers of hazardous chemicals unless the container is labeled immediately with the required information.

• Ensure that each portable container into which hazardous chemicals are transferred is labeled with one of the following:

  • A GHS-compliant pre-label from the chemical manufacturer or distributor.

  • A secondary label copied from the shipped container.

  • Other secondary labels with GHS-compliant information.

• Ensure that each container of hazardous chemicals, such as a stationary process container or tank, is labeled with one of the following:

  • A secondary label copied from the shipped container.

  • Other secondary labels with GHS-compliant information.

  • A product identifier and words, pictures, symbols, or a combination that provides information regarding the physical and health hazards of the chemical. Train employees on understanding the alternative workplace labeling system.

3. Providing Access to SDSs

Safety data sheets display written or printed information concerning a hazardous chemical prepared by the manufacturer. They should be provided by the chemical supplier when the product is shipped or delivered for the first time or when the SDS is changed.

• Compile SDSs currently in use as part of the written hazard communication program (see “Provide a Written Hazard Communication Program for Each Work Location” in this section). SDSs for products no longer in use should be retained by the organization for 30 years in a separate file for historical SDSs.

• Provide electronic access to SDSs if desired. Computers for accessing electronic SDSs should be readily accessible. Train employees how to access electronic SDSs. Provide an adequate back-up so workers can access SDSs during emergencies. Ensure that workers can get hard copies of SDSs if they want them.

• For all hazardous chemicals, maintain SDS files in readily accessible areas. SDSs should be in the primary language understood by employees (copies may be maintained in other languages). They should contain the following 16 sections:

  • Section 1: Identification

  • Section 2: Hazard identification

  • Section 3: Composition of and information on ingredients

  • Section 4: First-aid measures

  • Section 5: Firefighting measures

  • Section 6: Accidental-release measures

  • Section 7: Handling and storage

  • Section 8: Exposure controls and personal protection

  • Section 9: Physical and chemical properties

  • Section 10: Stability and reactivity

  • Section 11: Toxicological information

  • Section 12: Ecological information

  • Section 13: Disposal considerations

  • Section 14: Transport information

  • Section 15: Regulatory information

  • Section 16: Other information, including date of preparation or last revision

• Index SDSs by names that employees or others will recognize. This could be by type of product, trade name, or chemical name, whichever employees are familiar with and can easily recognize. Inform each employee that the information is available, and tell them where it can be found. This location should be readily accessible at all times during working hours and should be on the premises where the employees work.

• Give each location a full set of SDSs for the chemicals listed on the Chemical Inventory List.

• If you have not received a particular SDS or if it is missing, request it in writing from the supplier who provided the chemical.

• Keep a copy on file of letters requesting missing SDSs. The letters should be available for review by local regulators. If the chemical supplier cannot provide SDSs, do not purchase chemicals from them.

• In case of injury, provide the physician with the information on the SDS so the physician can determine proper treatment. In order to provide the physician with this information quickly, others who might not necessarily be directly involved in using the products should also know the location of the information.

• Inform people who answer telephone calls in each location where the information is located so they can supply this information if it is requested by a poison control center, hospital, doctor, or others in an emergency.

4. Providing Information and Training for Employees

Train employees on the hazardous chemicals in their work area. Employees should learn about:

• Provisions of the hazard communication program.

• Operations in employee work areas where hazardous chemicals are present.

• Location and availability of the written hazard communication program, including the required lists of hazardous chemicals and SDSs.

• Physical and health hazards of the chemicals in the work area.

• Measures employees can take to protect themselves from these hazards, including information on work practices, emergency procedures, and personal protective equipment.

• Work procedures that ensure protection when cleaning hazardous chemical spills and leaks.

• Details of the written hazard communication program, including an explanation of the labels received on shipped containers, the workplace labeling system, and SDSs. Employees should also receive training on the order of information on the labels and on how they can obtain and use the appropriate hazard information on the labels and in the SDSs.

Managers, supervisors, or other qualified persons may be assigned as instructors. Instructors should:

• Cover the above items during the general training employees receive when they are initially assigned. The depth of training should be relative to the frequency of chemical use and the severity of chemical hazards to which employees are exposed.

• Instruct employees concerning information in each section of each SDS.

• Conduct training during the employees’ regular working hours.

• Give special attention to each product. The primary message should be how to safely use the chemical. Train employees about (a) how the product will affect personal health in any way through its use or misuse and (b) the dangers of improperly mixing chemical products.

• Provide employees additional training concerning workplace hazards when:

  • Chemicals with new hazards are introduced into the workplace.

  • Changes to processes or equipment are made that could cause new or increased exposures.

  • Procedures and work practices that could cause new or increased exposures are introduced or changed.

  • Employees are transferred from one work area to another where different hazards may be present.

• Follow up and evaluate the training program periodically to make sure employees know how to apply the training and handle chemicals they use. Provide training periodically (annually) to employees who work frequently with chemicals and may be at high risk.

• Training should be provided in the language that employees understand.

Documenting Training Sessions. Include a record of employee training in each employee’s training file and in the written hazard communication program. Use the Safety Training Meeting Record (see chapter 7).

• Keep a log showing the date of the training, who attended, what chemicals were covered, and the name of the instructor. This log should also include the signature of the employees who attended as proof that they were there, that they were trained, and that they understood what was taught.

Hazardous Nonroutine Tasks. The supervisor of an employee performing a hazardous nonroutine task should train that employee concerning the task. Training should include procedures pertaining to the task. The employee should inform the supervisor when a nonroutine task will be performed.

Some nonroutine tasks require special permits before work begins or require that some special procedures be followed. Employees should follow these procedures to ensure their own safety.

Contractors. When contracted employees or their supervisors first enter the premises, advise them of safety regulations.

Contractor employees are expected to take appropriate measures to protect themselves from any hazards present. They should be informed of hazards they may be exposed to and of the availability of SDSs. The contractors should, in turn, notify you of hazards they may expose your employees to and provide SDSs for hazardous materials they introduce.

5. Provide a Written Hazard Communication Program for Each Work Location

Managers and supervisors should see that a written hazard communication program is prepared for each location. Make a copy of and complete the Written Hazard Communication Program form (see chapter 7). Put the form in a clearly labeled hazard communication program file or binder, and make it available to all employees and contractors. Keep a copy of the information at each work location. The information should be divided into sections and include the following:

Section 1—Emergency Contacts

• List of emergency telephone numbers, including the toll-free, 24-hour, local poison control number (see Emergency Telephone Numbers form in chapter 7)

Section 2—Requirements and Methods

(See Written Hazard Communication Program form in chapter 7.)

• Description of how the requirements for SDSs will be met

• Description of how the requirements for employee information and training will be met

• Methods for informing employees of the hazards of routine and nonroutine tasks and the hazards associated with chemicals in unlabeled pipes in their work areas

• Methods for informing contractors of the hazardous chemicals their employees may be exposed to while performing their work and suggestions for appropriate precautions

• Methods for contractors to provide SDSs for all hazardous materials they may bring into your workplace and procedures to inform your employees concerning this information

Section 3—Chemical Inventory List and SDS Materials

• Chemical Inventory List (see chapter 7) of hazardous chemicals known to be present in the workplace

• SDSs for the chemicals at the location, or information on electronic access to SDSs

Section 4—Training Materials

• Training records for the employees who work at the location

Section 5—Other Materials

• Other pertinent information as necessary