by David Blustein

The most cited violation for an OSHA inspection is a Hazard Communication Standard that does not meet all the regulations for a written program. A good written program is the start to having effective hazard communications in place. To avoid the fines, informal hearings, formal contests, citations, violations, abatement periods, penalties and progress report, one's company should have a complete Hazard Communication program implemented to inform workers of the potential chemical hazards to which they may be exposed.

The following template can be used to make your company's Written Hazard Communication Program. Fill in the information as it applies to your company and you have a "basic" program. Be aware of what you are including, as well as excluding. And don't forget to review each and every point with a knowledgeable expert.
________(1)__________is the name of your company.
________(2)__________is the name of the Hazard Communication Coordinator
(An important note is that if you are using other effective means than those described in this sample written program, specify those means in your written program.)

HAZARD COMMUNICATION OF_________ (1)_________
The purpose of the Hazard Communication Program is to ensure that _____(1)_____is in compliance with the Occupational Safety and Health Administration (OSHA) Hazard Communication Standard 29 CFR 1910.1200. The objective is that each employee at the worksite will be apprised of the contents and intent of this Written Hazard Communication Program, the hazardous properties of the chemicals that they work with, and measures to take to protect themselves from any of the hazards that these chemicals may have.

The program has been established for the entire facility. _______(2)_______ is the overall coordinator of the program. If there are process changes using different chemicals, those changes will be incorporated immediately in the Hazard Communication Program. The written program is available from ______ (2)______. All employees will be notified of this program and the Material Safety Data Sheets (MSDSs).

I. Hazard Determination
The hazard determination and evaluation, in most cases, were done by the supplier of the chemical. Additional information used to evaluate the chemicals was done using accepted references.

II. Chemical Inventory
Material Hazardous Ingredient Hazard
______ _________________ ______
______ _________________ ______
etc.

III. Material Safety Data Sheets (MSDSs)
______(2)______will maintain a Material Safety Data Sheet library on every substance on the Chemical Inventory List. The MSDS will contain information on the following:
1. Manufacturer's name and address.
2. Hazardous ingredients
3. Physical/Chemical properties and characteristics
4. Chemical identity
5. Fire/Explosion hazards
6. Reactivity data
7. Acute and chronic health effects
8. Relevant exposure limits
9. Information about potential carcinogenicity
10. Recommended personal protective equipment
11. Precautions for safe handling and use
12. Emergency and first aid information
13. Control measures
14. Preparer and an emergency phone number
The Material Safety Data sheets will be readily available to all employees.

______(2)______is responsible for acquiring and updating the Material Safety Data Sheets. They will also review each MSDS for accuracy and completeness and correspond with the supplier if additional research is necessary. All new procurements for the company must be cleared by ______(2)______. Whenever possible the least hazardous substance will be procured.

MSDSs that meet the requirements of the Hazard Communication Program must be fully completed and received at the facility either prior to, or at the time of receipt of the first shipment of any potentially hazardous chemical.

IV. Container Labeling
______(1)______will require that all hazardous chemicals in the facility are properly labeled. Labels should list at least the chemical identity, appropriate hazard warnings and the name and address of the manufacturer or supplier. The corresponding Material Safety Data Sheet will be checked for consistency with the information on the label of the material container. When a substance is transferred from the original container to another container and if it is not for the immediate (same shift) use of the person performing the transfer, the secondary container will be labeled with the identity of the substance and the hazards it presents, if practical. Vats, dip tanks and bulk storage vessels with hazardous chemicals will be identified with appropriate signs or placards specifying the substance present and the nature of the hazards present.

______(2)______will perform an internal audit on a monthly basis to ensure that all containers in the facility are labeled and that the labels are current and up to date.

V. Training
Each employee who works with or is potentially exposed to hazardous chemicals will receive initial training on the Hazard Communication Program and the safe use of those hazardous chemicals. Additional training will be provided for employees whenever a new hazard is introduced into their work areas. The training will emphasize these elements:
1. A summary of the standard and this written program
2. Hazardous chemical properties including visual appearance, odor and methods that can be used to detect the presence or release of hazardous chemicals.
3. Physical and health hazards associated with potential exposure to workplace chemicals
4. Procedures to protect against hazards, for example, personal protective equipment, work practices, and emergency procedures
5. Hazardous chemical spill and leak procedures
6. Where MSDSs are located, how to understand their content, and how employees may obtain and use appropriate hazard information
7. An explanation of the labeling system.
______(2)______will monitor and maintain records of employee training and advise supervisors when training is scheduled.

VI. Outside Contractors
If outside contractors are working in the plant, for example, an electrician repairing the control panel, ______(2)_____will ensure that they are given the following information:
1. Hazardous chemicals to which they may be exposed while on the job site
2. Measures the employees may take to lessen the possibility of exposure
3. MSDSs for materials worked around

VII. Non-Routine Tasks
When employees will be doing non-routine tasks they will be instructed as to the hazards of the materials with which they will be working, the precautions they should take, and what the company has provided for them in the way of protection. Supervisory personnel,under the direction of ______ (2)______, will instruct employees in the hazards associated with non-routine tasks before they are assigned to perform such tasks.
An example of a non-routine task would be if a former sander who has been promoted to another activity has to fill in for a sander, if that sander is sick or on vacation, the person filling in will be instructed on the hazards of the job.

IX. Additional Information
The preceding template is similar to those left by OSHA compliance officers when there is need for an acceptable written Communication Program. Further information on this written program and applicable Material Safety Data Sheets is available from Great Tracers at 708/255-0436.