Title: Hazard Communication. Site Function: Ecology, Health and Safety Procedure No.: WYN Page: 1 of 15

Transcription

1 Procedure No.: WYN Page: 1 of 15 Preparer: Owner: Approver: EHS Specialist EHS Specialist EHS Hub Manager Revision History Revision Date Revision Number 03/ / / Details of Change Added Revision History. Reformatted standard to be consistent with P&PO. Added Immediate Use definition. Revised MSDS section requirements. Added MSDS Search Page link in Added new training requirements and removed annual training frequency requirement in Training section. Added new Unit Program Requirements section. Removed App A & B. Site standard references removed from Section 6. Hyperlinks removed from referenced internet documents. Added oxygen deficient atmosphere in bulk container labeling requirements in Complete revision of all WYN sections for new GHS requirements.

2 Procedure No.: WYN Page: 2 of PURPOSE To ensure that the chemicals used and produced at the Wyandotte Site are properly classified for hazards and that information is communicated to employees and contractors working at this location. This standard, in conjunction with the Unit programs, is designed to comply with MIOSHA s Employee Right-to-Know Rule /Part DEFINITIONS 2.1. BASF REPRESENTATIVE A BASF employee who has the responsibility and accountability to ensure that all Contractor work is performed safely and in accordance with BASF requirements from project s commencement until its completion BULK CONTAINER Tank truck, rail car, or similar vehicle in which Hazardous Chemicals are loaded with no intermediate form of containment. Bulk Containers exclude Containers defined below CHEMICAL Any substance or mixture of substances CONTAINER Any bag, barrel, bottle, box, can, cylinder, drum, vessel, vial, storage tank, or the like that contains a Hazardous Chemical. For purposes of this standard, pipes or piping systems, engines, fuel tanks, or other operating systems in a vehicle, are not considered to be containers CONTRACTOR A company which will be bringing Contractor(s) or Contractor Employee(s) on to the Wyandotte Site. As used in this procedure, Contractor also means Subcontractor EMPLOYEE A worker who may be exposed to a Hazardous Chemical under normal operating conditions or in foreseeable emergencies. Workers such as administrative personnel who encounter Hazardous Chemicals only in nonroutine, isolated instances are not covered. Also covers BASF, Contracted, Contingent Staff, Leased or Temporary Employees.

3 Procedure No.: WYN Page: 3 of FORESEEABLE EMERGENCY Any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a Hazardous Chemical into the Workplace HAZARDOUS CHEMICAL Any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified HAZARD STATEMENT A statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard HEALTH HAZARD A chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity; or aspiration hazard IMMEDIATE USE This means that a Hazardous Chemical must be under the control of and used only by the person who transfers it. This use must only be within the work shift in which it is transferred INTERMEDIATE Hazardous Chemicals formed in a discrete step in the manufacturing process of making the final product. For example, chemical E is created in two steps, A + B = C and C + D = E, therefore the creation of C is a discrete stopping point would be considered an intermediate. In the case where A+B makes C which continues to react with B to form D, for the purposes of this procedure, no intermediate is formed in a discrete step in the process PHYSICAL HAZARD A chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.

4 Procedure No.: WYN Page: 4 of 15 Hazardous Temperatures and Pressures: Pipe lines are deemed hazardous when the following parameters are exceeded: 1) Cryogenics 2) Temperatures above 120 deg. F 3) Pressure above 70 PSIG PICTOGRAM A composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are mandatory for use under this standard for application to a hazard category PRECAUTIONARY STATEMENT A phrase that describes recommended measures that should be taken to minimize or prevent adverse effects resulting from exposure to a Hazardous Chemical or improper storage or handling PROCESS PIPING Process piping that is a conduit, ¾ outside diameter and greater, for the transportation of gases, liquids, solids, or fine particulate dust. The word line or pipe has the same meaning for the purpose of this procedure PRODUCT IDENTIFIER The name or number used for a Hazardous Chemical on a label or in the SDS. It provides a unique means by which the user can identify the chemical. The product identifier used shall permit cross-references to be made among the list of Hazardous Chemicals required in the written hazard communication program, the label and the SDS R&D LABORATORY A facility where the "laboratory use of Hazardous Chemicals" occurs. It is a workplace where relatively small quantities of Hazardous Chemicals are used on a non-production basis. This definition does not include process quality control laboratories or other production laboratories SAFETY DATA SHEET (SDS) A written document concerning a Hazardous Chemical that is prepared in accordance with OSHA s Hazard Communication Standard (g). This may also be known as Material Safety Data Sheet (MSDS) SHIPPED CONTAINER LABEL A label applied to Containers of Hazardous Chemicals leaving the workplace.

5 Procedure No.: WYN Page: 5 of SIGNAL WORD A word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in this section are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for the less severe STATIONARY PROCESS CONTAINER A container that is not mobile, in which a process takes place, or a stationary container which contains a liquid (other than water) used for dipping and coating SDS MANAGEMENT SYSTEM The current vendor for storing and managing raw materials, finished products and ancillary materials is the 3E Company (or 3E Online). They can be contacted via a 24/7/365 live support line at WORKPLACE An establishment, job site, laboratory, or project, at one geographical location containing one or more rooms or defined spaces where Hazardous Substances are produced or used, and where workers are present WORKPLACE LABEL A label applied to Containers of Hazardous Chemicals that will not leave the Workplace. 3. SCOPE 3.1. This standard applies to Employees at the Wyandotte Site where they may be exposed to Hazardous Chemicals under normal working conditions or in a Foreseeable Emergency 3.2. The application of this standard to R&D Laboratories is limited to the following: Ensure that labels on received shipped containers of Hazardous Chemicals are not removed or defaced. Ensure that any containers of Hazardous Chemicals shipped off site or to non R&D units are labeled in accordance with Section and that a SDS be provided, as necessary. Maintain SDSs for those chemicals received in the SDS Management System in accordance with Section 4.2 of this standard. Ensure that laboratory employees are provided information and training in accordance with Section 4.3 of this standard.

6 Procedure No.: WYN Page: 6 of 15 Compliance with Chapter Six of the CARES Chemical Hygiene Plan. In addition to these requirements, the R&D laboratories must also comply with MIOSHA s Part 431 Hazardous Work in Laboratory Standard and Part 430 Employee Right To Know Law. 4. PROCEDURE 4.1 LABELING OF HAZARDOUS CHEMICALS SHIPPED CONTAINER LABELS Each container of a Hazardous Chemical leaving the Wyandotte Site shall be labeled with the following:. Product identifier; Signal word; Hazard statement(s); Pictogram(s); Precautionary statement(s); and, Name, address, and telephone number of the chemical manufacturer, importer, or other responsible party All Shipped Container Labels must be generated through the Global Label Management system (GLM) via the Epson printers using Brandywine label stock. The GLM is the standard for ondemand Shipped Container Labels on site Hazardous waste and universal waste containers as defined by Environmental Protection Agency s (EPA) Resource Conservation and Recovery Act (RCRA) are not subject to Hazard Communication. They must be labeled according to Federal and other State requirements Waste, which doesn t meet the definition of Hazardous Waste as defined by RCRA, but is a Hazardous Chemical, must have labels that meet Section requirements Any OSHA chemical-specific labeling requirements (i.e. contaminated equipment, PPE or clothing with asbestos, lead, formaldehyde, etc.) must be met as applicable and shall only use approved labels as specified in the Corporate EHS procedure Communication of Chemical Hazards (BC ).

7 Procedure No.: WYN Page: 7 of All outgoing containers must meet applicable Department of Transportation (DOT) labeling requirements per 49 CFR All Bulk Containers where oxygen deficient atmospheres are present shall be labeled or tagged as follows: Labels/tags must be securely fastened at the time the nitrogen or other inert gas is introduced into the bulk container. Labels/tags must be readily visible (i.e., no other action required to view) at or near the point of entry. Labels/tags and securing devices must be constructed of materials able to withstand applicable environmental conditions. Only site-approved tags can be used. These are kept stocked at or can be ordered through the Stores Warehouse RECEIVED SHIPPED CONTAINER LABELS If the manufacturer's existing label isn t legible, has been defaced in any way or doesn t contain, at least, the Product Identifier and appropriate hazard information then it shall be replaced immediately with a BASF internal workplace label that meets the requirements in WORKPLACE LABELS When a GHS Classification is available for a Hazardous Chemical, a workplace label shall be created using 3E Online or contain equivalent information from the BASF Label in 3E for all production and site service units. (Note: R&D is exempt from using GHS labeling in the workplace). The BASF Label will include the following elements: Product Identifier Signal Word Pictogram(s) where a red border is not required A statement indicating the SDS contains more information And, as the label size and available space allows: Hazard Statement(s) Precautionary Statement(s)

8 Procedure No.: WYN Page: 8 of 15 NFPA Ratings If a GHS classification is not available for a Hazardous Chemical then, at a minimum, the following workplace label requirements apply: Product identifier; Words, pictures, symbols; Or combination thereof, which provide at least general information regarding the hazards of the chemicals For stationary process containers which have a specific identification (i.e. vessel number), labeling may include alternative measures such as signs, placards, process sheets, batch tickets, operating procedures, and other such written materials. The alternative method must identify the applicable containers and convey the information required in The written materials shall be readily accessible to workers in their work area throughout each work shift Workplace labels must be legible and in English. Additional label information in other languages may be added as needed for employee comprehension Secondary containers that are intended for "immediate use (i.e. grab samples) are exempted from these labeling requirements Containers held as QC or retain samples shall be labeled as required in In situations where the containers are too small to apply an individual label, the sample carrier, rack or area may be labeled, in lieu of, a container label PROCESS PIPE LABELING All pipes containing Hazardous Chemicals shall be identified by a label, sign, placard, written operating instructions, process sheet, batch ticket, or a substance identification system that conveys the same information from section or (See Attachment 1 in Related Documents Section 6. for guidance on pipe labels.)

9 Procedure No.: WYN Page: 9 of Color-coding, where specific colors are designated for a specific service, may be used as a secondary means of identification. Pipe systems will be painted in accordance with the Color Code Standard (WYN ). 4.2 SAFETY DATA SHEETS (SDS) All Hazardous Chemicals must have an SDS prior to being brought on site. Chemicals that are applicable are as follows: Raw materials Intermediates Finished products Ancillary materials including non-hazardous wastes If a chemical is received without the corresponding SDS, the receiving unit s SDS coordinator or other responsible person will contact the shipper or manufacturer and obtain the proper SDS All SDSs must be kept and maintained in the SDS Management System (3E Online) for all production, R&D and site service units When multiple suppliers provide the same chemical, each supplier s SDS shall be maintained An SDS must be provided with the initial shipment of a Hazardous Chemical, and with the first shipment after an SDS is updated. The SDS can be provided with the shipped containers or sent prior to the time of the shipment For products ordered through SAP that are shipped off site, the system ensures SDSs are distributed with the initial shipment and with the first shipment after the SDS is modified For R&D samples leaving the site, the responsible unit personnel preparing the shipment shall ensure that a GHS compliant SDS is provided prior to or during initial shipment For nonhazardous wastes, a BASF Waste Determination Sheet is provided to the Waste Contractor prior to any shipments. This profile contains an attachment for the latest SDS revision for that waste.

10 Procedure No.: WYN Page: 10 of SDSs must be maintained so they are readily accessible during the work shift to all employees in their workplaces. Copies in alternate languages (i.e. Spanish, French, etc.) may be provided if workers can t understand English In the event of an emergency, SDSs can be accessed 24/7/365 through a live support line for SDS requests at (800) EMPLOYEE INFORMATION AND TRAINING All employees shall be provided with pertinent information and training on the Hazardous Chemicals in their work area Information and training shall be provided prior to any exposure with a Hazardous Chemical at the time of initial assignment. Initial training shall include at least the following as out lined in Table 1: Table 1: Hazard Communication Topics by Method of Training Topic Corporate EHS Courses (i.e. Success Factors) Unit- Specific Training (i.e. Safety Meeting, etc.) The requirements of the OSHA Hazard Covered - Communication standard ( ). Operations in the workplace where - Covered Hazardous Chemicals are present. The location and availability of this program including the inventory list and SDSs. - Covered Methods used to detect the presence of a Hazardous Chemical in the work area including monitoring conducted by the employer, visual appearance or odor of released chemicals. Physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards of the chemicals in the workplace. Protective measures the employee can take to lessen exposure including ventilation, PPE, work practices and emergency procedures. An explanation of the labeling system, SDSs, and how to retrieve SDSs. Covered Covered for Unit Specific Methods Covered Covered for Unit Specific Chemicals - Covered Covered -

11 Procedure No.: WYN Page: 11 of At a minimum, all applicable employees shall be assigned Corporate EHS modules Hazard Communication and 3E Online General User Training in Success Factors and complete these upon initial assignment prior to handling any Hazardous Chemicals For those employees in units with Hazardous Chemicals, unit-specific training shall also be completed, in addition, to the Corporate EHS modules, and this may be conducted through a safety meeting or other appropriate venue Each unit shall create a training powerpoint using the appropriate site approved Hazard Communication training template and add additional unit specific information, as applicable; or use equivalent training material which contains the required information to meet the unit specific hazard communication training requirement. (See Related Documents Section 6.) Unit specific hazard communication refresher training shall be completed, at least, every three years or sooner, if deficiencies are noted Units subject to chemical specific standards (i.e. acrylonitrile, ethylene oxide, etc.) shall cover those chemical hazards and applicable processes during unit training that meets the mandatory frequency requirement (i.e. annually) The course contents, participant s name and date of the training must be documented for all unit training Each unit is responsible for coordinating employee training and maintaining all records of the training conducted in Success Factors Whenever a new chemical hazard is introduced, appropriate additional training shall be provided such as reviewing SDS, procedures, PPE, etc For special or non-routine situations, such as spill clean-up, emergency response, or waste handling, additional training may also be required. 4.4 LIST OF HAZARDOUS CHEMICALS PRESENT IN THE WORKPLACE The Wyandotte Site maintains a current chemical inventory of all Hazardous Chemicals present in the workplace. This inventory is maintained in the SDS management system (3E Online).

12 Procedure No.: WYN Page: 12 of To access inventory report for a given location, go to Report Center Tab in 3E Online. Select your desired unit under Location window on the left of screen. Select the Inventory Summary report and hit the Run Report button. This will produce a chemical list of all raw materials, finished goods and ancillary chemicals associated with that unit which can be downloaded into an excel file. See example below All manufacturing and site service units must review their inventories annually and update them as necessary (i.e. adding missing SDSs, removing no longer used chemicals, etc.). Note: R&D units are exempted from the annual inventory requirement. 4.5 METHODS OF INFORMING EMPLOYEES OF THE HAZARDS FROM NON- ROUTINE TASKS Prior to starting non-routine work, employees shall be given information about the hazards involved with these activities. Procedures, work

13 Procedure No.: WYN Page: 13 of 15 instructions and /or JSAs shall be maintained which address proper and safe handling of hazardous substances under non-routine situations. Such methods can include, but are not limited to, the following: Safe/ Hot Work Permitting Line Breaking Procedure Confined Space Entry Permitting Personal and Respiratory Protective Equipment Procedures Site Integrated Contingency Plan Unit SOPs, JSAs, Work Instructions and Emergency Response Procedures 4.6 METHODS OF INFORMING CONTRACTORS OF THE HAZARDOUS CHEMICALS IN THE WORKPLACE Contractor employees will be given an EHS orientation that includes the required elements specified in the Corporate Contractor EHS Management (BC ) and the Wyandotte Contractor EHS Management (WYN ) standards along with the following: Methods to provide Contractors access to SDSs for each Hazardous Chemical their employee s may be exposed to while working. Methods to inform Contractors of the Workplace Labeling system As required by the Safe Work Permit (WYN ) standard, Contractors will be issued a safe work permit which will identify hazards and communicate protective measures needed based on the specific Hazardous Chemical(s) involved and the nature of the work The Contractor is responsible for informing their BASF Representative of any chemicals they will bring on site and must provide an SDS prior to being brought on site, or at a minimum, must provide immediate access to each SDS upon request. 4.7 UNIT PROGRAM REQUIREMENTS Each unit with Hazardous Chemicals in the workplace shall comply with the following unit-specific program elements: Display the MIOSHA Right To Know (RTK) Posters SDS(s) For This Workplace Are Located At and New or Revised SDS in a conspicuous or central location (See Related Documents Section 6).

14 Procedure No.: WYN Page: 14 of 15 Within 5 working days of their receipt, post a notice of the existence of a new or revised SDS for, at least, 10 working days on the appropriate poster. Assign (a) unit coordinator(s) who will coordinate the following: 1. Unit SDS Management Receiving new/ revised SDSs prior to new raw materials or products entering the unit. Obtaining new/ revised SDSs if not received with initial shipment, as necessary. (Note: If an SDS cannot be obtained, a log of attempts, method of contact, date and letter to file need to be maintained). Associating and maintaining unit SDS inventory in 3E Online. Note: Production and site service units must complete and verify inventory of SDSs annually. R&D is exempted from inventory requirement. Update unit MIOSHA RTK posters as necessary. Provide and maintain unit specific training on Hazard Communication for BASF, contracted and contractor employees. 5 RESPONSIBILITIES 5.1 EHS SPECIALIST Responsible for drafting, maintenance and interpretation of this procedure. Provides compliance verification with procedure requirements. 5.2 EMPLOYEE/ CONTRACTOR Responsible for following all the applicable requirements set forth in this procedure. 5.3 MANAGEMENT Designate a Unit SDS Coordinator for unit program management. Responsible for the administration and implementation of all Hazard Communication requirements. 5.4 UNIT COORDINATOR Responsible for managing and maintaining unit SDSs, unit chemical inventory, MIOSHA Right To Know posters and other unit program elements.

15 Procedure No.: WYN Page: 15 of 15 6 RELATED DOCUMENTS 6.1 ATTACHMENT 1- WYANDOTTE SITE PIPE LABELING Pipe Labeling Attachment ATTACHMENT 2- UNIT TRAINING TEMPLATES Unit HazComm Template CARES Haz Comm Template 6.3 OSHA 29 CFR HAZARD COMMUNICATION 6.4 EPA 40 CFR PARTS 262, 273 & 279- RCRA 6.5 BASF CORPORATION BC COMMUNICATION OF CHEMICAL HAZARDS 6.6 DOT 49 CFR HAZARDOUS MATERIALS TABLE 6.7 MIOSHA PART 430 EMPLOYEE RIGHT-TO-KNOW STANDARD 6.8 MIOSHA PART 431 HAZARDOUS WORK IN LABORATORY STANDARD 6.9 CARES CHEMICAL HYGIENE PLAN 6.10 BASF CORPORATION BC CONTRACTOR EHS MANAGEMENT 6.11 WYANDOTTE SITE WYN CONTRACTOR EHS MANAGMENT 6.12 WYANDOTTE SITE WYN SAFE WORK PERMIT 6.13 MIOSHA RTK SDS POSTERS MIOSHA SDS Location MIOSHA SDS New or Revised