UNION PUBLIC SCHOOLS HAZARD COMMUNICATION PLAN

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1 UNION PUBLIC SCHOOLS HAZARD COMMUNICATION PLAN UNION PUBLIC SCHOOLS INDEPENDENT SCHOOL DISTRICT NO. 9 TULSA COUNTY, OKLAHOMA Union Public Schools Page 1

2 TABLE OF CONTENTS I. POLICY STATEMENT A. General Statement B. Purpose C. Existence of Chemicals D. Affected Employees II. LOCATION AND UP-DATE OF PLAN A. Location of Plan B. Location of Plan at each Site C. Review and Up-date of Plan III. MATERIAL SAFETY DATA SHEETS (MSDS) A. Location of Material Safety Data Sheets B. All MSDSs shall be legible C. Maintenance of MSDS Files D. Introduction of New Chemicals into the Workplace IV. CHEMICAL INVENTORY A. Location of Chemical Inventory List (CIL) B. Obtaining MSDSs for Existing Chemicals C. Location of Master Chemical Inventory List V. LABELING A. Label Information B. Secondary Containers C. Removal of Labels D. Special Labeling E. Storage and Building Labeling VI. TRAINING A. Frequency of Training B. Training Objective C. Contents of Training D. Records Inspection Union Public Schools Page 2

3 VII. RECORD KEEPING A. Location of Training Records B. Contents of Training Record C. Exposure Records D. Requesting Safety and Hazard Information VIII. RIGHT TO REFUSE WORK IX. NON-ROUTINE TASKS X. CONTRACTOR AND SUB-CONTRACTOR INFORMATION A. Contractor's Notification of Hazardous Chemicals B. District's Notification of Contractor's Hazardous Chemicals C. Substitute or Temporary Employees XI. DISCIPLINARY ACTIONS GLOSSARY OF COMMON WORDS AND TERMINOLOGY Union Public Schools Page 3

4 I. POLICY STATEMENT A. General Statement UNION PUBLIC SCHOOLS HAZARD COMMUNICATION PROGRAM Union Public Schools, Independent School District I-9 of Tulsa County, a political subdivision of the State of Oklahoma, recognizes the responsibility it has to provide a safe and healthy working environment for its employees. In an effort to provide as safe and healthy a working environment as possible and provide protection to its employees, the district hereby establishes the following Hazardous Materials Communication Program. B. Purpose The purpose of this program is to communicate the procedures, rules, and guidelines for the handling of all hazardous chemicals and substances that may be present in the workplace. C. Existence of Chemicals Although the District is not in the chemical business, it does purchase and use a variety of chemicals and substances that, if not handled properly, could be hazardous to district employees. D. Affected Employees All work sites and departments of the district are included as a part of this plan. A safe working environment can only be maintained when all employees of the district take the responsibility of developing safe work habits and following all safety plans including, but not limited to this plan. II. LOCATION AND UP-DATE OF THE PLAN A. Location of Plan A copy of this plan will be located at each school site, the Education Service Center, Distribution Center, Food Service Department, Operations Department, and Transportation- Mechanic's Office. The master copy of the plan will be located at the Education Service Center and maintained by the Safety Coordinator. B. Location of the Plan Copies of the plan shall be located in the administrative office at each school site. C. Review and Up-date of Plan Union Public Schools Page 4

5 The plan will be reviewed by the Safety Coordinator and/or the Safety Committee annually on or before June 30 th of each fiscal year or when changes to plan are warranted to require modification of the workpractices and procedures. III. MATERIAL SAFETY DATA SHEETS (MSDS) A. Location of Material Safety Data Sheets Material Safety Data Sheets, herein referred to as MSDSs, for every chemical or hazardous substance located at each school site will be maintained at the location where the chemical is present. A file containing all MSDSs for the chemicals located at each school site shall be kept in the administration office of that site. The principal at each site will be responsible to see that this file is kept up-to-date. A file containing all MSDSs of hazardous materials and chemicals located in the Distribution Center, Transportation, Food Service and Operations areas will be kept in each department. It shall be maintained by the respective Departmental Director s designees. A district-wide master file of all MSDSs will be maintained in the Support Services Offices at the Education Service Center. A copy of MSDSs for all corrosive and hazardous chemicals used in science labs must be kept in the labs; however, a copy of all such MSDSs must also be maintained in the school's master file. B. All MSDSs shall be legible and written in the English language. If the manufacturer of the chemical offers the MSDS in other languages, the District may also maintain MSDSs in other languages. C. Maintenance of MSDS Files It will be the responsibility of the principal to designate an employee to maintain an up-to-date MSDS file for their site. The directors of the Food Service, Transportation, and Operations Departments shall designate an appropriate employee to maintain and keep current MSDS files for their respective areas. The ultimate responsibility for the file remains with the principals and directors. The district-wide MSDS file shall be kept in the Support Services Offices at the Education Service Center by an employee designated by the Director of Operations or it will be the the designated safety coordinator s responsibility to maintain the file. D. Introduction of New Chemicals into the Workplace All new chemicals entering the workplace shall not arrive on the premises unless an MSDS has been delivered to its destination prior to arrival of the chemical. If a chemical is being delivered through the Distribution Center, all MSDSs shall be on file in the Distribution Center prior to the arrival of the chemical. Union Public Schools Page 5

6 Chemicals must not be picked up or delivered unless a copy of the MSDS is on file at the workplace where the chemical is to be delivered: i.e., Distribution Center or school site. Chemicals delivered to a site prior to receipt of MSDS should be rejected and returned to supplier. The Director of Purchasing or his designee will request an MSDS from the supplier and forward the MSDS to the Union Public Schools Distribution Center and site where the chemical is to be delivered. The original MSDS copy must be sent to the Support Services Office and added to district-wide master file. Employees ordering chemicals should plan ahead for delivery of chemicals to ensure that an MSDS is on file before the chemical arrives. The Distribution Center Foreman will keep a copy of the MSDS for each new chemical delivered and stored in the Distribution Center. A log containing the date of arrival and presence of an MSDS of each new chemical will be maintained and kept in the Distribution Center by the foreman or his/her designee. The Safety Coordinator(s) may at his/her discretion inspect any/all facilities at any time to determine if chemicals have been introduced into the workplace without required documentation. IV. CHEMICAL INVENTORY A. Location of Chemical Inventory List (CIL) A chemical inventory list (CIL) of all chemicals located at each school site, the Operations facility and the Education Service Center will be located with the MSDS file. The CIL must be up-dated monthly by the same employee responsible for maintaining the MSDS files, with a copy of the CIL forwarded to the Support Services Offices. CILs can be up dated utilizing electronic mail, if available. If no new chemicals were introduced to the workplace/site during the one (1) month period, an up-dated CIL is not required to be submitted to Support Services. B. Obtaining MSDSs for Existing Chemicals If a chemical, located on the property, is discovered with no corresponding MSDS on file, the employee responsible for maintaining the MSDS files shall contact the supplier or manufacturer of the chemical and obtain an MSDS within thirty (30) days. If no MSDS is provided by the supplier/manufacturer within the specified time, the chemical shall be removed from the property and disposed of properly. A follow up letter should be sent to the manufacturer/supplier notifying them of their failure to provide the MSDS. All letters notifying the manufacturer of their failure to provide MSDS should also be copied to OSHA. C. Location of Master Chemical Inventory List Union Public Schools Page 6

7 V. LABELING A central file containing all chemical inventories from all Union Public Schools sites will be maintained at the Union Public Schools Education Service Center in the Support Services Offices. The Safety Coordinator or his/her designee will be responsible for maintaining the list. A. Label Information All containers must be labeled by the manufacturer with the following information legibly written in English: Name of the chemical names and CAS numbers; an appropriate hazard warning; name and address of the manufacturer. It will be each department head's responsibility to ensure that all containers with hazardous substances/chemicals including secondary containers are properly labeled. B. Secondary Containers All secondary containers must be labeled, preferably with a label provided by the manufacturer or with a generic label with appropriate identity and hazard warning information listed, as indicated. Secondary containers, containing chemicals for immediate use (during one work shift), are not required to be labeled; however, the chemical must be placed back into the original container at the end of the employee's shift and the secondary container cleaned appropriately. C. Removal of Labels Employees shall not remove or deface existing labels on incoming containers of hazardous chemicals. Labels that become illegible should be replaced. If a label is removed, it must be replaced immediately. D. Special Labeling Pipelines containing hazardous substances shall be labeled at valve or at valve locations at the point where the substance enters the workplace pipeline system and at normally operated valves, outlets, vents, drains, and sample connectors as required by local and state code. F. Storage and Building Labeling The Union PublicSchools Operations Department will provide the Tulsa Fire Department and Broken Arrow Fire Department with information as required by local fire codes. Union Public Schools Page 7

8 Placards and signs will be posted outside of storage areas and buildings in accordance with local fire code or copies of any waivers granted by fire departments will be kept on file in the Safety Coordinator's Office. VI. TRAINING A. Frequency of Training The Director and/or Principal of each of the Union Public Schools sites and/or departments, e.g. transportation, will be responsible for providing training on hazardous chemicals to employees assigned to their work area within thirty (30) days of initial assignment or re-assignment and annually thereafter. The Director and/or Principal of each site and/or department will be responsible for notifying and providing training to employees within his/her responsibility whenever the employee may be routinely exposed to additional hazardous substances or when changes in work practices increase risk for potential exposure. B. Training Objective Training will be provided to equip Union Public Schools employees with the information and skills necessary for recognizing existing hazardous chemicals, knowing the location of chemicals in their work area, and knowing the means to protect themselves from the existing hazards. C. Contents of Training Information and training on hazardous chemicals/substances will include, but may not be limited to: Operations in an employee's work area where hazardous chemicals are present; Location and availability of written hazard communication program, chemical list, and MSDS at each site; Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area; Physical and health hazards of the chemicals in the work area; Employees "Right to Know Law; Measures employees can take to protect themselves from hazards; Labels and labeling system used by employer; and Location and availability of records. Union Public Schools Page 8

9 D. Records Inspection Safety Coordinator(s) or their designee(s) may inspect training records and/or question any employee regarding hazard communication training at any time. VII. RECORD KEEPING A. Location of Training Records Training records will be maintained in the Safety Coordinators Office at the Union Multipurpose Activities Center (UMAC) and at each school site in the central administration office. Records for support employees will be maintained in the Safety Coordinators Office at the UMAC as well as the employee's respective departmental central office, where the employee reports; i.e., Operations, Transportation, and Food Service. Anytime an employee is transferred to another site or department, training on the hazards at the new location should be conducted. Original training records should remain at the employee's original assigned site or department. A new record of training shall be made and kept at the new location upon completion of the training session. B. Contents of Training Record All training shall be documented using the SafeSchools online training and compliance management system specifically designed for Union Public School employees. Training records shall contain the following information: The name of each employee; The employee's I.D. number; The date training was conducted; and/or completed online. The name of the safety course; A copy of a post-training quiz for each employee listed on the training record sheet. C. Exposure Records A copy of all chemical exposure reports will be maintained in a file at the Education Service Center for forty (40) years. Employees experiencing a chemical exposure may request a copy of their exposure records upon termination of employment. The request must be in writing. D. Requesting Safety and Hazard Information Union Public Schools Page 9

10 Upon request, any Union Public Schools employee will be allowed to see a copy of safety or hazard communication information within a reasonable time, place and manner, but no later than one (1) calendar day after the request has been made. The request should be made to the department head. Upon receipt of a written request, any employee will be given a copy of safety or hazard communication information within fifteen (15) days. The employee s "right to access" is limited to records on substances to which that employee may reasonably expect to be exposed to during normal working hours. VIII. RIGHT TO REFUSE WORK Any Union Public Schools employee, who after having requested to see a copy of hazard information, which that employee may reasonably be expected to be exposed to during normal working hours or after having requested a copy of the information in writing, is not provided the information by the time specified in section (8.01, D), has the right to refuse to work with hazardous chemicals/substances or in a location where the specific substance is being used until such a time information is provided. No punitive action shall be taken against the employee for refusing to work with hazardous chemicals or substances, based on the conditions specified in this paragraph. IX. NON-ROUTINE TASKS Periodically, employees might be required to perform hazardous non-routine tasks, such as spills or clean-up, repairs, and construction activities. Prior to starting work on such projects, the employees will be given information by their immediate supervisor on hazardous chemicals to which they may be exposed. The information will include: Specific chemical hazards Protective/safety measures the employee can take. Measures the company has taken to lessen the hazards including ventilation, respiration, and safety aids. Union Public Schools Page 10

11 X. CONTRACTOR AND SUB-CONTRACTOR INFORMATION A. Contractor's Notification of Hazardous Chemicals Union Public Schools project managers, who are responsible for overseeing any project involving the services of an outside contractor, shall contact the Director of Operations or designated safety coordinator to assess and provide to the contractor with the following information: Hazardous chemicals which contractors and/or sub-contractors or their employees may be exposed to while on the job site; and Precautions the employer may take to lessen the possibility of exposure. B. District's Notification of Contractor's Hazardous Chemicals Union Public Schools project managers will be responsible for notifying each contractor before any chemicals or hazardous substances enter the workplace to gather and disseminate any information concerning those chemical hazards that the contractor is bringing into the district's workplace. All hazardous chemicals/materials information must be forwarded to the Operations Department prior to the introduction of the chemicals or hazardous substance into the workplace. It shall be the responsibility of contracting companies to train their own employees in hazardous materials. C. Substitute or Temporary Employees Training and hazardous substance information should be provided within ten (10) days of initial assignment. XI. DISCIPLINARY ACTIONS Union Public Schools employees not following the procedures outlined in this plan or using chemicals improperly against the manufacturer's recommendations may be subject to disciplinary action including and up to, but not limited to, suspension, demotion, and/or termination in accordance with Union Public Schools Board Policy and Human Resources procedures and protocol for disciplinary action. Union Public Schools Page 11

12 APPENDEX A Glossary of Common Words and Terminology CAS Means the unique identification number assigned by the Chemical Abstract Service to chemicals. Chemical Any element, chemical compound or mixture of elements and/or compounds. Chemical Manufacturer An employer with a workplace where chemical(s) are produced for use or distribution. Chemical Name The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry (IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name that will clearly identify the chemical for the purpose of conducting a hazard evaluation. Container Refers to any bag, barrel, bottle, box, can cylinder, drum, reaction vessel, storage tank, or the like that contains a hazardous chemical. Pipes or piping systems and engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers. Contractor Any outside company or individual hired to perform work or services for the district. Day Refers to a working business day. Department Head Refers to the employee designated to oversee an academic department, and/or a departmental manager, director or principal. District Refers to the local school district, Union Public Schools. Union Public Schools Project Manager Individual responsible for soliciting bids, recommending, or overseeing any contractual construction or other type projects that require the work or services of non-district employees on district property. Education Service Center Refers to Education Service Center located at 8506 E 61 st Street, Tulsa, Oklahoma. Employee Refers to a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered. Union Public Schools Page 12

13 Employer Refers to a person engaged in a business where chemicals are either used, distributed, or are produced for use in distribution, including a contractor or subcontractor. Exposure or Exposed Means that an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorption, etc.) and includes potential (e.g. accidental or possible) exposure. Hazardous Chemical Refers to any chemical which is a physical hazard or a health hazard. Hazard Warning Refers to any words, pictures, symbols, or combination thereof appearing on a label or other appropriate form of warning which convey the hazard(s) of the chemical(s) in the container(s). Identity Refers to any chemical or common name which is indicated on the material safety data sheet (MSDS) for the chemical. The identity used shall permit cross-references to be made among the required list of hazardous chemicals, the label and the MSDS. Immediate Use Means that the hazardous chemical will be under the control of and used only by the person who transfers it from a labeled container and only within the work shift in which it is transferred. Label Refers to any written, printed, or graphic material, displayed on or affixed to containers of hazardous chemicals. Location Refers to the school site or building Material Safety Data Sheet (MSDS) Refers to written or printed material concerning a hazardous chemical. Use To package, handle, react, or transfer. Workplace Refers to an establishment, job site, or project, at one geographical location containing one or more work areas. Union Public Schools Page 13