WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM - WHMIS

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1 GOOD SHEPHERD CENTRE HAMILTON POLICY MANUAL DEPARTMENT: OCCUPATIONAL HEALTH AND SAFETY NUMBER: OHS-04 TOPIC: WORKPLACE HAZARDOUS MATERIALS INFORMATION SYSTEM - WHMIS PURPOSE: POLICY: To provide a uniform system for the proper labelling, handling, storage, use and safe disposal of hazardous materials in the work place, to provide ready access to information in the form of current Material Safety Data Sheets (MSDS), and to provide for training and education of all workplace parties related to the WHMIS Program. The Good Shepherd Centres is committed to providing a safe and healthy working environment. It is our belief that a safe workplace enhances the hospitality of the work environment and allows work to be performed in a dignified manner that will enable staff to safely adapt and avail themselves to the needs of our clients. The Workplace Hazardous Materials Information System (WHMIS) program will be implemented according to the requirements of the WHMIS legislation and in a manner that aims to reduce the frequency, severity and costs associated with accidents and illness related to hazardous materials in the work environment. Legislative Context The Federal and Provincial governments passed legislation to implement WHMIS. Federal legislation ensures that the WHMIS framework is applied consistently in all provinces and territories. Provincial legislation provides the operating details that enable WHMIS to be enforced. MATERIAL/EQUIPMENT REQUIRED: Mission and Values of The Good Shepherd Centres Hamilton Occupational Health and Safety Act and WHMIS Regulations WHMIS Binder Records of Training and Completed WHMIS Quizzes Material Safety Data Sheets (MSDS) WHMIS Labels Hazardous Conditions Forms WHMIS/Consumer Products Inventory Record (Appendix A ) WHMIS Approved Products List (Appendix B )

2 1.0 PROCEDURE 1.1 Responsibilities According to WHMIS legislation, the following workplace parties have legislated responsibilities: It is the responsibility of the Supplier to: Determine if the hazardous materials they supply are controlled products Label all controlled products to be sold Provide Material Safety Data Sheets (MSDS) for controlled products. It is the responsibility of the Employer, to ensure compliance in the following areas: Labelling Ensure controlled products are appropriately labelled or identified MSDS Obtain MSDS for controlled products used in the workplace and update it every 3 years Ensure that all WHMIS and MSDS information are easily accessible to the workplace parties and that all required postings are displayed. Provide copies of the MSDS to the Health and Safety Representative upon request. Education/Training To establish an education and training program for workers who may be exposed to hazardous materials in the workplace. To annually review the information and training program in consultation with the Health and Safety Representative and/or Committee. It is the responsibility of the Program/Department Supervisor to: Ensure that all hazardous materials used in the workplace have proper labels Ensure a current hazardous materials inventory and that all MSDS are accessible and up-to-date (within the last three years) Review and provide WHMIS training to new workers upon hire and annually thereafter or as changes in the workplace arise Maintain records of attendance lists for training sessions Ensure personal protective equipment is available, maintained and properly used. It is the responsibility of the Health and Safety Representative/Committee to: Consult with the Good Shepherd management on the content and delivery of training as well as supporting all workplace parties in their compliance to the WHMIS program. Assist the Good Shepherd in the evaluation of the WHMIS program (annually) and as required. Good Shepherd Centres Hamilton WHMIS Policy 2

3 It is the responsibility of the Employee to: Attend and participate in WHMIS training and apply the knowledge. Comply with the WHMIS policy and report to his/her Supervisor any situation violating or potentially violating the WHMIS policy Contact their Supervisor immediately if they do not have the required information for a hazardous material Be aware of the location and contents of the MSDS binder and notify their Supervisor if an MSDS is missing Ensure that labels on hazardous material containers are not removed, altered or defaced (if any of these conditions exist, to notify their Supervisor immediately) Use personal protective equipment as prescribed by the Good Shepherd Inform the supervisor when more supplies of personal protective equipment and storage containers are required Ensure that only Good Shepherd-approved products are used 1.2 Accountability All workplace parties have both specific and general responsibilities in ensuring that the WHMIS program is implemented consistently. Failure to comply with the WHMIS program will result in progressive disciplinary action. Compliance to the WHMIS program will also be a measurable index on each Employee s annual performance appraisals. 1.3 Education/Training on the WHMIS Policy and Program WHMIS training will be delivered to all workplace parties during their orientation and annually or as required if there is a change in their job task with resulting changes in potential for exposure. An Employee s immediate Supervisor (must be knowledgeable in WHMIS training) will be responsible for delivering the job-specific/work-site component of the WHMIS orientation. All Employees of Good Shepherd will attend WHMIS information and training sessions and will demonstrate their knowledge of the program through successful completion of the training course and quiz. The Program/Department Director will ensure that the Employee WHMIS Training Attendance List and Quiz Results are properly maintained in a separate file or binder at the worksite for a period of at least two years in the event that they are required for review by the Health and Safety Representative, Health and Safety Committee, Ministry of Labour Inspector and/or WSIB. Good Shepherd Centres Hamilton WHMIS Policy 3

4 1.4 MSDS Binder Each Program/department Director or designate will maintain the master copy of all program/department specific MSDS in a binder that is accessible to all staff. A copy of each current MSDS shall be sent to the worksite Health and Safety Representative and the Human Resources Department. When new products are purchased or introduced to the department/program for the first time, a copy of the new MSDS sheet shall also be forwarded to the Worksite Health and Safety Representative and the Human Resources Department. The MSDS binder shall contain and be organized in sections as follows: Table of Contents listing the sections of the Binder WHMIS Symbols WHMIS Policy and relevant procedures An alphabetical listing each MSDS that is filed in the binder using the WHMIS Approved Products List (Appendix B ). Each product on this list shall be initialled by the Program/Department Director or management designate to indicate that the product has been approved for introduction and use in the workplace. Material Safety Data Sheets filed in corresponding alphabetical order. A Personal Protective Equipment Inventory and where they are stored (most recent on top) A section that chronicles all communications sent to employees regarding WHMIS i.e. staff meetings, bulleting board postings, etc. A section for completed WHMIS/Consumer Inventory Records A section for annual audit records signed by Management and the worksite Health and Safety Representative 1.5 Communication Requirements The WMIS Program and changes to the WHMIS program will be communicated to all staff by the department/program supervisor by posting the information on the Health and Safety Bulletin Boards located at each worksite and by addressing changes to the program as an agenda item at regular staff meetings. WHMIS posters depicting the symbols and associated risks will be posted on the Health and Safety Boards and in all work areas where there is a potential for exposure to hazardous materials (i.e. kitchen, storage closets, bathrooms, etc). The MSDS will be readily available to all workers. Copies of new or updated MSDS shall be forwarded to the worksite Health and Safety Representative and to the Human Resources Department. Good Shepherd Centres Hamilton WHMIS Policy 4

5 1.6 Purchasing and Acceptance of Chemical Products Each Program/Department Director or designate, shall ensure that only management-approved chemicals can be purchased/accepted into the workplace, stored and used. Only designated staff can purchase chemical products on behalf of the organization New products introduced in the workplace shall not be used by staff who have not been trained on their use Definitions of Controlled and Consumer Products Controlled Product A controlled product is any product that can be included in any of the following six classes: Class A Compressed Gases Class B Flammable and Combustible Material Class C Oxidizing Material Class D Poisonous and Infectious Material Class E Corrosive Material Class F Dangerously Reactive Material Consumer Product A consumer product is one that is packaged in a container that is available for sale to the general public and meets the labelling and other packaging requirements for consumer products under the Hazardous Products Act. Consumer products can be divided into five categories based on the type of hazard (if any) it poses: Category 1 Toxic Products Category 2 Corrosive Products Category 3 Flammable Products Category 4 Quick Skin-Bonding Adhesives Category 5 Pressurized Containers Management will assign the responsibility of purchasing and regularly inventorying chemical products (for the purpose of maintaining stock, ensuring that the MSDS binder is current and complete, etc) to a designated employee (i.e. Executive Assistant). The product inventory and MSDS binder will be audited by the Health and Safety Representative annually in January (see Record Keeping Requirements in 1.3 above) WHMIS Approved Product List (Appendix B ) Management will review the acceptability of products for purchase before they can be introduced and used in the workplace. Management shall maintain an alphabetical listing of products that have been approved for use in the workplace using the WHMIS Approved Products List Form (Appendix B ). This Form shall be completed and updated as needed and shall be kept in the WHMIS Binder. Copies of this completed Form shall Good Shepherd Centres Hamilton WHMIS Policy 5

6 be given to the worksite Health and Safety Representative and to the Human Resources Department. The Human Resources Department shall file this Form and shall maintain it as part of the Corporate MSDS Inventory for review by the Health and Safety Committee and/or review to Ministry of Labour Inspectors if needed In the event that products are available to the Program/Department through private donations, the Director or management designate shall ensure that an MSDS is available for the product and that the product is appropriate and can be safely used in the workplace prior to it being used The Program/Department Director or management designate will ensure that the WHMIS Approved Products List (located in the WHMIS binder) is updated and initialled (Appendix B ) and a revised copy, along with the new MSDS sent to the Health and Safety Representative and the Human Resources Department. 1.7 Storage of Chemical Products Chemical products (controlled and consumer) are to be stored safely and in locations that are approved, accessible and known to all employees Chemical Products in Use Chemical products in use will be stored in the area where they are required. Chemical products of this kind typically include air fresheners (bathrooms), dish detergent (kitchen) and office supplies like toner (for the photocopier and printer) Every effort will be made to keep chemical products in use (located in the areas accessible to the general public) out of the reach of children and other clients at risk due to cognitive impairments All chemical products in use will be securely/tightly closed when not being used All chemical products in use will have supplier labels that are in good condition and legible. Where the original supplier labels are no longer legible, management shall ensure to replace the supplier label with a Workplace label. The Workplace label will be in keeping with WHMIS regulations. While Good Shepherd management is responsible to ensure this is done, it shall be the responsibility of the staff who are aware or, ought to be aware, that the label needs to be replaced to either replace the label or, if the employee is not trained or able to replace the label, to alert management to the need to do so. Good Shepherd Centres Hamilton WHMIS Policy 6

7 1.7.3 Stored Chemical Products (Not In Use) Stored chemical products will be kept primarily in two locations: Storage Cupboard used primarily for household items Office Supplies Storage Room used primarily for office supplies Unopened chemical products will be stored separately from food items and other household and office items, on a separate shelf All unopened chemical products will have supplier labels that are in good condition and legible. Where the original supplier labels are no longer legible, management shall ensure that the supplier label is replaced with a Workplace label. The Workplace label will be in keeping with WHMIS regulations. While Good Shepherd management is responsible to ensure this is done, it shall be the responsibility of the staff who are aware, or ought to be aware, that the label needs to be replaced to either replace the label or, if the employee is not trained or able to replace the label, to alert management to the need to do so. 1.8 Workplace (Employer) Labelling System Consistent with WHMIS regulations: A workplace label is a label that the employer produces for use in the employer s workplace only and that contains the following information: Product identifier (i.e. product name) Safe handling procedures Reference to the MSDS Workplace labels are to be used in the following situations: When decanting a controlled product from its original container into another container; When the Supplier or Workplace label is no longer legible; When a bulk shipment of a controlled product is received and a Supplier Label is not included on each product/item; When a controlled or consumer product is donated to the department/program without a supplier label. Good Shepherd Centres Hamilton WHMIS Policy 7

8 1.8.3 When a Workplace label is required, Management will ensure that the appropriate Workplace label is attached to the product All employees must alert Management immediately to Supplier and Workplace labels that are not legible, destroyed or missing Where the workplace label cannot be immediately affixed to the product, management or its delegate will remove the product from use until the workplace label can be affixed. 1.9 Annual Audit/Review of the WHMIS Program Department/Program Management will undertake an annual audit/inspection of the WHMIS program in January of each year to ensure its currency and staff compliance. Management will involve the Health and Safety Representative in this annual inspection. The worksite Health and Safety Representative will audit the inventory of all consumer and WHMIS products using the WHMIS/Consumer Product Inventory Record (attached as Appendix A ). The inventory will be submitted to the Supervisor for review and the Supervisor will take any action needed to maintain the accuracy and completeness of the records In addition to the above, management and the Health and Safety Representative will audit the following elements of the WHMIS program on an annual basis using the WHMIS Program Review Report Form (Appendix C ): WMHIS Policies and Procedures Review Department/Program management will undertake a review of the application of the WHMIS policies and procedures to ensure their currency and compliance in the workplace. Material Safety Data Sheets All controlled products have an MSDS stored in the WHMIS binder All MSDS are updated every 3 years Required WHMIS Postings Required postings are in good condition and displayed where controlled and consumer products are stored. Bulletin Boards contain information about the WHMIS Program and WHMIS Symbols Good Shepherd Centres Hamilton WHMIS Policy 8

9 Employee WHMIS Training All employees have received their initial WHMIS training and annual reviews thereafter and the required record keeping requirements have been met o All Quiz Results are filed in a separate file in alphabetical order o All WHMIS training Attendance Lists are filed in a separate file o Training records are accessible and are readily available if needed for Committee inspections or external government inspections. WHMIS Binder Complies with the WHMIS policies and procedures Contains a Table of Contents listing the sections of the Binder Contains a copy of the WHMIS Symbols Contains the WHMIS Policy and relevant procedures Contains an alphabetical listing each MSDS that is filed in the binder using the WHMIS Approved Products List (Appendix B ). Each product on this list shall be initialled by the Program/Department Director or management designate to indicate that the product has been approved for introduction and use in the workplace. Contains the Material Safety Data Sheets for all controlled products in corresponding alphabetical order Contains a Personal Protective Equipment Inventory and where they are stored (most recent on top) Contains a section that chronicles all communications sent to employees regarding WHMIS i.e. staff meetings, bulleting board postings, etc. Contains a section for completed WHMIS/Consumer Inventory Records Contains a section for annual audit records Labelling Controlled products are appropriately labelled with the Supplier or Workplace labels. Personal Protective Equipment Personal Protective Equipment is available to employees The Personal Protective Equipment Inventory is up-to-date and sufficient supplies are stored Good Shepherd Centres Hamilton WHMIS Policy 9

10 Near Misses, Incidents and Accidents All Near Misses, Incidents and Accidents involving any aspect of the WHMIS program will be audited for trends, patterns, issues and lessons learned (reference Hazardous Conditions Forms on file) Management and the Health and Safety Representative will conduct their review together and will document all outcomes on the WHMIS Program Review Report Form (Appendix C ). The original report is given to the Department Director for review. Once reviewed, the original Report Form is filed in the appropriate section of the WHMIS Binder and a copy sent to the Human Resources Department and Executive Director s Office (or the appropriate Assistant Executive Director) The outcomes of the annual WHMIS Program Review will be shared with all employees through the Department/Program Staff Meeting process Personal Protective Equipment Management is responsible for ensuring that all required Personal Protective Equipment (PPE) as identified through the MSDS is available and accessible to employees who work with the chemicals. Management is responsible for orienting employees at the start of their employment and annually thereafter to the following: When to use PPE What PPE to use How to use PPE Management will document in the employee file when employees have received direction/training in the use of PPE required by Good Shepherd Management (via a designated employee) is responsible for ensuring that PPE are in stock and replaced as required Employees are responsible for using PPE as directed and for advising management when additional PPE is required. Further, employees are responsible to alert management to situations where PPE procedures are not being followed Monthly, the designated employee responsible for PPE inventory, will check the PPE inventory and order/purchase additional supplies as required PPE will be stored in an appropriate Supply Cabinet/cupboard. Good Shepherd Centres Hamilton WHMIS Policy 10

11 PPE typically used at The Good Shepherd Centres includes: Nitrile gloves when using bleach, cleaning up spills and messes and using toner Chemical resistant eyewear when decanting chemical products like bleach Any other PPE that is identified by the Department/Program Management as being necessary to handle certain chemical products In order to understand when and how often PPE products are used and to assist the designated employee responsible for PPE inventory with keeping the appropriate amount of PPE on hand, employees will immediately notify management through the designated individual responsible for the inventory when supplies are running out so that he/she can place an order Each program/department manager shall establish an inventory monitoring and ordering system for the department/program to ensure that supplies of PPE do not deplete before being replenishes. Such system should make note of usage of PPE vs. # of times PPE would be expected to be used during a designated period of time. This system will be communicated to staff. 2.0 DOCUMENTATION 2.1 MSDS in the WHMIS Binder and copies to the worksite Health and Safety Representative and a copy to the Human Resources Department to maintain the organizational WHMIS Inventory 2.2 Training Records will be maintained by the program/department management 2.3 Copies of the WHMIS / Consumer Products Inventory Record are filed in the WHMIS Binder and a copy to the Health and Safety Committee via the Human Resources Department 2.4 The completed WHMIS APPROVED PRODUCTS LIST filed in WHMIS Binder and copy to the Health and Safety Committee via the Human Resources Department 2.5 The original Annual Department/Program WHMIS Program Review Form filed in the WHMIS Binder with a copy to the Health and Safety Committee via the Human Resources Department and a copy to Executive Director via the appropriate Assistant Executive Director 3.0 REFERENCE SOURCES 3.1 Ontario Safety Association for Community and Health Care 3.2 Occupational Health and Safety Act and WHMIS Regulations Good Shepherd Centres Hamilton WHMIS Policy 11

12 APPROVED BY: Executive Director EFFECTIVE DATE: September 14, 2006 IMPLEMENATION DATE: November 1, 2006 REVIEW/REVISION DATE: SUPERCEDES: New Good Shepherd Centres Hamilton WHMIS Policy 12

13 Appendix A WHMIS / Consumer Products Inventory Record (To be completed by the Site Health and Safety Representative in January of each year) Department/Program Location: Product Name WHMIS Product [ ] Consumer Product [ ] Comments MSDS Date Signature of H&S Representative: Supervisor Signature: Date: Date: (Copies to Supervisor and Human Resources) Good Shepherd Centres Hamilton WHMIS Policy 13

14 Appendix B WHMIS APPROVED PRODUCTS LIST (Completed by the Department/Program Director/Supervisor and up-dated as necessary) Department/Program Location: Date: Product Name WHMIS Product [ ] Consumer Product [ ] Intended Use of Product Mgmt Initials and Approval For Use (Copies to Health and Safety Representative and Human Resources Department)

15 Appendix C Annual Department/Program WHMIS Program Review Form (To be completed by the Worksite Health and Safety Representative and worksite management representative) Items Reviewed Yes No Comments/Action Needed Action Planned WMHIS Policies and Procedures: WHMIS policies and procedures are current and complied to in the workplace. WHMIS Binder Complies with the WHMIS policies and procedures Contains a Table of Contents listing the sections of the Binder Contains a copy of the WHMIS Symbols Contains WHMIS Policy and relevant procedures Contains alphabetical and initialled listing of MSDS approved for the workplace. Contains the MSDS for all controlled products in corresponding alphabetical order Contains a Personal Protective Equipment Inventory and storage locations Contains chronology of communications to employees re WHMIS i.e. staff meetings, etc. Contains section for completed WHMIS/Consumer Inventory Records Material Safety Data Sheets There is an MSDS for each controlled products in the WHMIS binder All MSDS are current i.e. less than 3 yrs old Labelling Controlled products are appropriately labelled with the Supplier or Workplace labels. Good Shepherd Centres Hamilton WHMIS Policy 15

16 Items Reviewed Yes No Comments/Action Needed Action Planned Employee WHMIS Training All employees have received their initial WHMIS training and annual reviews and record keeping requirements have been met All Quiz Results are filed separately in alphabetical order All WHMIS training Attendance Lists are filed separately Training records are accessible and readily available if needed for Committee inspections or external government inspections. Required WHMIS Postings Required postings in good condition and displayed where controlled and consumer products are stored. Bulletin Boards contain information about the WHMIS Program and WHMIS Symbols Personal Protective Equipment Personal Protective Equipment is available to employees The Personal Protective Equipment Inventory is up-to-date and sufficient supplies are stored Near Misses, Incidents and Accidents All Near Misses, Incidents and Accidents involving aspects of WHMIS program have been audited for trends, patterns, issues and lessons learned (reference Hazardous Conditions Forms and Incident Reports) H&S Rep Signature: Date: Supervisor Signature: Date: Director Signature: Date: Management to forward copies to Human Resources Department and to Executive Director via the appropriate Assistant Executive Director Original in Department/Program WHMIS Binder Good Shepherd Centres Hamilton WHMIS Policy 16

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