The Hazard Communication Standard 29 CFR Part 1910.1200 Greenwich Central School District Updated July 2016 Prepared with the Assistance of: The Health-Safety-Risk Management Service Capital Region BOCES School Support Services Suite 102, 900 Watervliet-Shaker Road, Albany, NY 12205
Hazard Communication Program Introduction & District Contacts The intent of this program is to disclose to employees the potential exposure to toxic substances. There may be a potential danger to the health of employees throughout the school district if significant exposure to toxic substances is encountered during the course and scope of employment. The result of this exposure may be immediate (acute) or may not be realized for many years or generations (chronic). It is considered the duty of the Superintendent, or their designees, to give each employee notice of his/her exposure to toxic substances that pose known and suspected health hazards and may cause serious illness or physical harm to the employee. Employees are frequently in the best position to be aware of the symptoms of toxicity, if they are first made aware of the nature of the toxic substances they are working with. Employees have an inherent right to know about the known and suspected health hazards that may result from working with toxic substances so they may make more knowledgeable and reasoned decisions with respect to any personal risks of their employment and the need for corrective action. Therefore, the intention of this Hazard Communication Program is to ensure that employees be given information concerning the nature of the toxic substances with which they work and full information concerning the known and suspected health hazards of such toxic substances. The Overseer(s) and Contact Person(s) for Hazard Communication Questions and Information is: Troy Tyler, Business Administrator Ron Nicholson, Director of Facilities The written Hazard Communication Program, Chemical Inventories and Safety Data Sheets (SDS)* are available in the following location(s): Buildings and Grounds Office located in the Middle Grade Building 10 Gray Avenue Greenwich, NY 12834 Main Offices of Primary School, Middle Grade and High School Science Prep Rooms in the High School Bus Garage Main Office Person(s) responsible for overseeing implementation of the labeling program is: Ron Nicholson, Director of Facilities, 692-9542 ext. 6403 Hazard Communication training is scheduled through: Troy Tyler, Business Administrator, 692-9542 ext.6803 Training provided by: Health/Safety/Risk Management Service, Capital Region BOCES Phone: (518) 464-5119/5115 Fax: (518) 464-5110 District contact person(s) for overseeing online training is: o Troy Tyler, Business Administrator, 692-9542 ext.6803 *Safety Data Sheets (SDS) also include Safety Data Sheets (SDS). 2
Statement of Intent This Hazard Communication Program is written to inform the employees that the hazards of all chemicals and/or chemical products present, entering and used throughout the school district have been evaluated and that information concerning the hazards has been transmitted to employees who may be exposed to such chemicals. This program is written to fulfill the requirements of the Occupational Safety and Health Administration, CFR 1910.1200 and to fulfill the requirements of the New York State Official Compilations of Codes, Part 820 of Title 12, commonly known as, the Right To Know Law. A copy of this written program is maintained in each work site as required. Objectives To accomplish the goals of this program, the following actions are necessary: 1. Complete a written Hazard Communication Program, represented by this document. 2. Take an inventory of all harmful and toxic chemical products in the school district, noting locations and departments of product storage and use. 3. Request and collect Safety Data Sheets for all chemical products used on-site. These Safety Data Sheets must be made available to all employees. 4. Establish procedures and persons responsible for overseeing labeling procedures, which are required to be implemented under the Hazard Communication Standard. 5. Offer a training program for employee awareness and information. 6. Post notice to employees regarding their rights under the law. 7. Notify local fire department, or other emergency response groups and the community regarding hazardous materials located in the workplace. 8. Notify contractors who work in the school of disclosure requirements for products they may bring into the building. 9. Keep Hazard Communication Records on file for a period of 40 years from the date of occurrence, including attendance sheets from employee training sessions. 10. Train new employees prior to working with chemical products in their job. Globally Harmonized System (GHS) Globally Harmonized System Overview: On March 20, 2012 the United States Occupational Health and Safety Administration (OSHA) revised the Hazard Communication Standard (HCS) to formally adopt the Globally Harmonized System (GHS). Your Right to Know has become your Right to Understand with the Hazard Communication Standard s 2012 adoption of the Globally Harmonized System (GHS) of classification and labeling of chemicals. 3
According to Occupational Safety and Health Administration (OSHA), the new GHS system benefits workers by reducing confusion about chemical hazards in the workplace, facilitating safety training and improving understanding of hazards. The GHS system requires manufacturers to label and create safety data sheets (SDS), formerly called material safety data sheets (MSDS), that are meant to be easier to read and understand. This system is already in use in many countries, so the revision to the federal OSHA Hazard Communication Standard aligns with the GHS system that is being used internationally. OSHA is requiring that employees be trained on the new label elements (e.g., pictograms and signal words) and SDS format before the end of 2013. During this transition period, both styles of data sheets (MSDS or SDS), and both styles of labels and pictograms may be used. Major Changes to the Hazard Communication Standard Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures. Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category. Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information. Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements. Other Deadlines: By June 1, 2015, chemical manufacturers, importers, distributors, and employers must comply with all modified provisions of the final rule; December 1, 2015, is the deadline for distributors to ship containers labeled by the manufacturer s old system. By June 1, 2016, employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional worker training for the physical and health hazards. Updated Definitions A hazardous chemical is 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. A health hazard is 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 (single or repeated exposure); or aspiration hazard. A physical hazard is 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. A pictogram is 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 designated under this standard for application to a hazard category. 4
Safety Data Sheets This school district has obtained the necessary Safety Data Sheets related to chemicals and chemical products used throughout the school district. Access to Safety Data Sheets is available through online access using MSDSonline as well as your district s binder(s). Using the Internet to Locate Safety Data Sheets: This service is free to school districts who participate in the Capital Region BOCES, Health/Safety/Risk Management Service. Just follow steps 1-7 below. 1. Go to website http://www.msdsonline.com, to complete the Customer Login box using our username and password as follows: Username = capitalregion Password = safety Customer Login Usernam Passwor Remember Username Log In 2. Click on the Log In button; 3. Click on the MSDS Search or Safety Center tabs located on the top left of the screen; 4. Search for MSDSs by typing in either the Product name or Manufacturer name as shown in the box below: Product Manufacturer Search 5. Click on "Search" button; 6. Scroll down to find your MSDS/SDS; 7. Under the View column, click on the PDF to read and/or print out the SDS. NOTE: If you need help locating a Safety Data Sheet, contact your BOCES Safety Coordinator at 464-5119/5115. 5
Safety Data Sheet Section Headings These safety data sheet sections are required to be listed in the following, specific order: 1. Identification 2. Hazard(s) Identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls/personal protection 9. Physical and chemical 10. Stability and reactivity 11. Toxicological information 12. Ecological information 13. Disposal considerations 14. Transport information 15. Regulatory information 16. Other information, including date of preparation or last revision Sample Safety Data Sheet: 6
Each SDS is kept on file for as long as the material is used within the school district. When a product is no longer used in the school district, or a more recent edition replaces an SDS, the former SDS is removed from the binder and placed in an "Out of Date" file. The date when the use of the material is discontinued is marked on the SDS. Safety Data Sheet Request Procedure All purchase orders sent to vendors by district personnel contain wording similar in nature to the following statement: Safety Data Sheets must be sent to the same person and address whose name appears on the purchase order under "Ship Materials To" for all chemicals and for chemical products containing toxic substances, as required by Federal Labor Law (29CFR 19100). An order will not be processed for payment until the required Safety Data Sheet has been received. At minimum, the purchase order is stamped: Safety Data Sheet Required. Safety Data Sheets are periodically updated by requesting a new copy from the manufacturer. When SDS s are not received from the manufacturer or supplier the following steps shall be taken: 1. Send a letter/email to the supplier requesting a copy of the appropriate SDS. Keep a copy of this letter/email on file. 2. Send a follow-up second letter/email if the SDS is not received within 30 days of the request. 3. If SDS s are not received within 10 days of the second request, a complaint is filed with the New York State Department of Labor. A copy of the complaint is sent to the supplier of the toxic substance. GHS Label Information Some GHS label elements have been standardized (identical with no variation) and are directly related to the hazard level. Other label elements are harmonized with common definitions and/or principles. The standardized label elements included in the GHS are: Symbols (hazard pictograms): Convey health, physical and environmental hazard information, assigned to a GHS hazard class and category. Signal Words: "Danger" or "Warning" are used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category. Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard. The symbols, signal words, and hazard statements have all been standardized and assigned to specific hazard categories and classes, as appropriate. Other GHS label elements include: Precautionary Statements and Pictograms: Measures to minimize or prevent adverse effects. Product Identifier (ingredient disclosure): Name or number used for a hazardous product on a label or in the SDS. 7
Supplier identification: The name, address and telephone number are provided on the label. Supplemental information: non-harmonized information. Labels are meant to provide essential information about the hazards of using a chemical product. The label is not intended to be either the sole or most complete source of information regarding the nature or identity of hazardous chemicals in the workplace. Although the SDS is the main source of information regarding the hazards of a material, the most visible form of warning are labels, warning signs and placards. As of June 1, 2015, all labels are required to have pictograms, a signal word (i.e., Danger; Warning), hazard and precautionary statements, the product identifier, and supplier identification. There are two types of container labels: Labels on Shipped Containers: Shipped Container labels must contain the product identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), name, address, and telephone number of the chemical manufacturer, importer, or other responsible party. Workplace Labels: Workplace Labels must contain the Shipped Container Label or the product identifier and words, pictures, symbols, or combination of those, which provide general information regarding the hazards of the chemicals. Sample Shipped Container Label: Sample Workplace Label: My Product Warning! Causes Skin and Eye irritation Suspected of causing cancer by inhalation Contains: XYZ 8
Workplace labels ensure proper identification of all hazardous products, and therefore aid in protecting school employees who may come in contact with containers of hazardous chemicals. All instructional and non-instructional departments are supplied with standard procedures and materials to properly implement this labeling system. Hazard warning considerations for labels are: 1. Physical Hazards: Explosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases Under Flammable Flammable Solids Self-Reactive Substances Pressure Liquids Pyrophoric Liquids Pyrophoric Solids Self-Heating Substances Substances which, in contact with water, emit flammable gases Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals 2. Health Hazards: Acute Toxicity Carcinogenicity Skin Corrosion/Irritation Reproductive Toxicology Serious Eye Damage/Eye Irritation Target Organ Systemic Toxicity - Single Exposure Respiratory or Skin Sensitization Target Organ Systemic Toxicity - Repeated Exposure Germ Cell Mutagenicity Aspiration Toxicity 3. Environmental Hazards: Hazardous to the Acute aquatic Aquatic toxicity Environment Chronic aquatic toxicity Bioaccumulation potential Rapid degradability 4. Simple Asphyxiant 5. Combustible Dust 6. Pyrophoric Gas 7. Hazard Not Otherwise Classified The above information is derived from the Safety Data Sheet provided by the manufacturer, supplier or importer. If the Safety Data Sheet provides insufficient information, other qualified sources can be contacted for this information, such as the manufacturer, fire department and your school district's BOCES Health/Safety/Risk Management Service. 9
GHS Pictogram/Hazard Identification Chart 10
Employee Rights The General Duty Clause of the Federal Occupational Health & Safety Act (Public Law 91-596, Section 5(a)(1), states: Each employer shall furnish each of his employees employment in a place of employment, which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees. The overall intent of "Right-to-Know" legislation is to provide employees with information about the known and suspected health hazards that may result from working with toxic substances. The employees have an inherent right to this information so they may make more knowledgeable and reasoned decisions with respect to any personal risks of their employment and the need for corrective action. Employees have the right to: 1. Have access to information, including the HAZCOM written plan, inventory and SDS file. 2. Make photocopies of that information to keep on hand in their department. 3. Be informed of the hazardous products used in their jobs by reviewing the inventory. 4. Be informed of the potentially hazardous ingredients found in those products (see SDS). 5. Be informed of the hazards associated with overexposure to those ingredients (including health hazards, fire hazards, etc.). 6. Be informed of the specific proper procedures for handling those products containing potentially harmful ingredients. 7. Be provided with protective gear, ventilation and proper equipment when needed. 8. Refuse to work with a toxic substance if they have not been provided with any of the above information upon request. In the event the employer does not possess an SDS for a specific substance for which a good faith effort has been made to secure an SDS, the employee and the employer must agree on safe handling procedures or replace the product with a safer alternative. 9. File a complaint, as a last resort, with the Department of Labor if the above conditions have not been met. The employee should first try to solve the problem with the school district before filing a complaint. 10. Be protected from discrimination as a result of their use of any of these rights under the HAZCOM Standard. 11
Poster Each school building in the school district posts a sign in the workplace. The sign alerts all employees of their rights under the law, and informs them of the name and location of the Compliance Officer for the school. To find a Material Safety Data Sheet (MSDS), use the Internet website: http://www.msdsonline.com. The Customer Login user name is capitalregion and the password is safety. For a specific inventory list, click on MSDS Search tab, click on Locations and type in your district s name in the Search for Location box. Insert name here Insert location & phone number here Note: Although a poster is not specifically mentioned in the OSHA Hazard Communication Standard, the Federal Occupational Safety & Health Act of 1970 (29 CFR 1903.2) requires that each employer post a notice furnished by the Department of Labor informing employees of the protections and obligations provided for under the Act. 12
Trade Secrets New York State, as well as the Federal Standard, provides protection for trade secrets in varying degrees. However, when a treating physician or health care professional determines that a medical emergency exists employers, manufacturers and importers must disclose any necessary trade secret information. The company involved may require a health care professional who requests the information to sign a confidentiality agreement. If non-emergency situations exist, occupational health professionals may request trade secret information and the company involved must provide the information if the request is in writing, explaining the need for the information and how the trade secret information is protected from further disclosure. If the trade secret information is withheld on a SDS, all other information must be provided on the substance's properties and effects. The SDS should indicate the category of information being withheld. Non-Routine Tasks When an employee is asked to perform a non-routine task (i.e. a task not ordinarily undertaken by a person with that particular job title and/or involving a chemical product no on that employee's department's section of the chemical inventory), that employee: 1) has the right to be informed of the hazards and proper work practices regarding the chemical products being used; 2) has the right to be supplied with any protective gear necessary to use that chemical product safely; and 3) is provided with safety data sheets on chemical products before they begin work. Outside Contractors If this school district hires an outside contractor to perform work in the school district, there are certain requirements: 1) the contractor must supply copies of safety data sheets for any chemical products that they may bring into school facilities before work begins; 2) the school district must inform the contractor of any dangerous chemicals or conditions that they may encounter in the area of the school where they do work. For example, if they are going to be welding near a storage cabinet containing flammable chemicals, they are informed that those chemicals are there. If necessary, those chemicals would be moved away or changes in the contractor's work procedures would be made; and 3) employees are informed of any chemicals that are used or applied in their work areas before they are used, or before employees are asked to return to those work areas. Training Requirements Employee training takes place before employees are assigned or transferred to work where they may be routinely exposed to a toxic substance and at least annually thereafter. Additional training also takes place whenever there is new or altered information on hazards involved with toxic substances store, used or produced at their workplace. The training is done at the worksite and at a time that is convenient to the employees. Training must be done during work hours, or employees must be paid to attend at other times. 13
Attendance Sheets (for any training method) are distributed requesting employee's name, last 4 digits of social security number and signature. These attendance sheets are kept on file for a period of 40 years. Training (live sessions, online, video and/or DVD) cover the following topics: 1. Introduction 2. Hazard Communication Standard 2012 and GHS 3. The Hazard Communication Standard & NYS Right-To-Know Law 4. Employee and Employer Rights and Responsibilities 5. The "Basics" of Hazardous Chemicals and Toxicology, including Health Effects and Detection of Hazards 6. The Product Inventory & Safety Data Sheet 7. Container Labeling Requirements 8. Safe Handling and Emergency Procedures 9. Universal Precautions 10. District-specific Information and Resources Hazard Communication Standard Video Tape or DVD: Instructional/Administrative Staff Tape or DVD: The video tape or DVD are suitable and acceptable for HAZCOM training of instructional and administrative employees, provided a knowledgeable person be available to introduce the topic, provide an opportunity for questions and answers, and inform the staff of the location of the HAZCOM Plan and inventory. The HAZCOM Plan reflects the procedures followed for training using the videotape or DVD. New Employee Tape or DVD: The videotape or DVD are suitable and acceptable for HAZCOM training of any new employee in the district. This presentation is adequate training for the new employee until that employee has the opportunity to attend a workshop for their employee group (such as custodial, instructional groups, etc.). Video/DVD Presentation Agenda 1. Brief introduction of the Hazard Communication Videotape/DVD Presentation. Pass out employee booklets, attendance sheets and other materials. 2. Viewing of the Hazard Communication Videotape/DVD. 3. Opportunity for employees to ask questions and voice concerns. 4. Specific information on the location and availability of the HAZCOM plan, product inventory and safety data sheets. 5. Specific information on persons responsible in the HAZCOM Plan. 6. Opportunity for employees to review the product inventory and safety data sheets. 14
Hazard Communication Standard Online Training The district offers an electronic training option to supplement their for HAZCOM/Right-To- Know/Universal Precautions training program. The online instructions, with district-specific information can be accessed by Greenwich employees only through the district s intranet Staff Resources page. A training booklet is online at: http://capregboces.org/risk/pdfs/hazcom_univprec09.pdf The district contact is responsible to: - Track which employees need this training. - Inform these employees about the training option and send them the web link. - Track which employees have completed the training and passed the test by opening the district s designated Hazcom email. Compare the completed list with the employee roster to account for attendance. - Provide district specific information to employees, which is available through the website for easy reference. - Determine if any employees need additional training on chemical products that they use in their workplace. Also determine which staff need additional training for Bloodborne Pathogens, Lockout/Tag-out or Asbestos Awareness, which are topics not covered in this specific online course. 15