In 1983, the Occupational Safety and Health Administration (OSHA) issued a rule called, Hazard Communication. The rule initially applied to all employers in the manufacturing sector, but was expanded in 1987 to include employers in the non-manufacturing sector. (Refer to CFR 29.1910 for a current copy of the regulation). These rules were created to protect employees against thehazards posed by chemical exposure.
The purpose of this program is to assist all USG Corporation facilities in complying with both federal (OSHA) and state regulations on Hazard Communication. A model program is provided, along with a variety of reference materials to assist you in this effort. However, it is imperative that your specific facility program is regularly reviewed to insure thatchanges in the operation, formulation and chemical knowledge are considered.
HAZARD COMMUNICATION PROGRAM
Following is a list of requirements for the OSHA Hazard Communication Program along with a brief explanation of each:
A formal notice to employees of existence and compliance with the OSHA Hazard Communication Program along with adesignated compliance coordinator (name, title). The training coordinator at the (name) plant is (name, title). (Attachment I)
(Note: in selecting the Hazard Communication Coordinator, careful consideration should be given to knowledge of purchased materials, chemical formulations, knowledge of and longevity with the plant and the ability to handle the overall responsibilities of the program.)List of Hazardous Chemicals
A list of all hazardous chemicals to which employees may be exposed. Suggestions of chemicals that the (name) plant may need to include on this list are included as Attachment II-B.
(Note: this list needs to include the manufacturer name and product name and/or number and UPC code (if available). A copy of this list should be forwarded to 3E Company at4920 Carroll Canyon Road, San Diego, Ca. 92121. This list should be received by 3E no later than February 1, each year so that they are prepared to handle any employee request.)
List of Solvents
Solvents are included in the plant’s list of all hazardous chemicals to which employees may be exposed. Past epidemiological studies have shown that solvents have the ability to produce bothacute and chronic neurotoxic effects. Employee training plays an important part in assuring that all employees are aware of the dangers that solvents possess. Sample lists of highly toxic and potentially toxic solvents that employees may be exposed to are included as Attachment IIC & IID.
In addition, certain solvents are particularly dangerous and extremely toxic therefore USG prohibits theiruse without special approval from the Safety Department. These closely maintained solvents are listed in Attachment II-C.
Material Safety Data Sheets (MSDS)
MSDSs are written by the manufacturer and are used to outline the precautions and controls necessary for handling chemicals. OSHA Standard 1910.1200 (g),(vii),(8) allows for MSDSs to be filed off site as long as there are no immediatebarriers to employee access. The (name) plant follows the policy that the only way a MSDS may be changed is through the manufacturer. No plant has the authority to change or rewrite a MSDS. If the manufacturer rewrites the MSDS, 3E Company will receive the revised copy and place it on file. A MSDS contains twelve (12) sections; from those sections, an employee may learn the proper proceduresfor handling the product as well as the measures needed to protect themselves against the chemical. An employee may receive a MSDS by calling toll-free, 1 (800) 451-8346. The MSDS may be received at the (name) plant at the fax machine located in (location) at (fax number). Located around the (name) plant are posters and right to know stations that inform employees how to request MSDSs and...