Guilford County Schools HAZARD COMMUNICATION PLAN Policy In accordance with the regulations established by the United States Department of Labor pursuant to the Occupational Safety and Health Act and the North Carolina Safety and Health Administration Hazard Communication Standard, 1910.1200, Guilford County Schools shall have in effect a Hazard Communication Plan. The plan is designed to provide for the safe purchasing, storage, use and disposal of chemicals that will protect all school employees. At auxiliary sites, the Director or Site Manager will be the Hazard Communication Coordinator. At the school sites, the principal shall be the supervisor for purposes of this plan and have overall responsibility for the duties of the Hazard Communication Coordinator. At all locations, the Hazard Communication Coordinator may delegate those responsibilities by making the assignment and attaching an appendix to this plan stating the name of the person and the responsibilities delegated. Employees must know how to safely handle and use hazardous chemicals, compounds, or substances to which they are exposed to in the workplace. Guilford County Schools provides information on hazardous chemicals in the workplace and employees will be trained in the potential hazards of those workplace chemicals to which they may be exposed. A copy of this written program will be kept in the Hazard Communication Coordinators office and in all work areas not in the immediate vicinity of that office. Additionally, a copy of this written program, Material Safety Data Sheets (MSDS) or other information pertinent to their safety may be obtained by any employee by requesting a copy from their supervisor. All Guilford County School System employees will be trained in the Hazard Communication program prior to starting work, when changing jobs that may involve hazards for which they have not been trained, and when new hazards are introduced into their work area. 1
HAZARD COMMUNICATION This section describes the specifics of Guilford County Schools' Hazard Communication Plan. Purpose The purpose of the Guilford County School System's Hazard Communication Plan is to inform employees of the nature of physical and chemical workplace hazards and to provide training in interpreting labels and MSDSs in order to enable employees to safely handle the hazardous chemicals with which they work. The Hazard Communication plan will ensure that: 1. All employees are aware of our Hazard Communication Plan and that it is available to all employees. 2. All hazardous chemicals used in the work place are labeled and a list of chemicals is maintained. 3. Employees receive information and training so they are informed of the requirements of the program and are trained in the hazards of their work. 4. All persons given non-routine work assignments are informed of the potential hazards covered by this program. 5. Contractors, subcontractors, and their employees are informed of potentially hazardous materials used at Guilford County Schools work sites. 6. Guilford County Schools and our employees are informed of any hazardous materials brought onto our work site by another contractor or subcontractor. The Guilford County Schools program shall be applicable to all employees and shall include the following program areas: 1. Program Coordination and Responsibilities 2. Written Programs 3. Chemical Inventories (Appendix A to this program) 4. Acquisition and Distribution of Material Safety Data Sheets MSDS) 5. Hazard Determination 6. Container Labeling and Other Forms of Warning 7. Employee Education and Training 8. Non routine Work Procedures 9. Hazard Communication for Contractors 10. Obtaining Confidential Information 11. Program Evaluation 2
Application The Guilford County School System Hazard Communication Plan applies to "known" and "suspected" occupational safety and health hazards of chemicals as identified by: MSDSs provided by chemical manufacturers and distributors Safety and health standards, codes, and regulations Environmental monitoring Chemical inventories prepared by the school or department I. PROGRAM COORDINATION AND RESPONSIBILITIES The following accountabilities are not all-inclusive but are designed to give guidance in program implementation. A. Program Administrator for Safety and Health (Maintenance Department) Ensure all employees are aware of and committed to the Hazard Communication Plan. Maintain an inventory of all chemical based products used in all facilities and all corresponding MSDSs. Coordinate activities such as revising the written program, training, periodic inspections, etc. Periodically audit the Program's progress. Ensure that instructors are provided to conduct training in all locations. Ensure employee training is conducted and properly documented. Provide consultation in the areas of labeling, storage requirements, emergency procedures and specialized training. Periodically inspect engineering controls and use of personal protective equipment. Enforce applicable safety and health rules. Conduct audits of all the facilities. B. Principal/Facility Manager Ensure all employees are aware of and committed to the Hazard Communication Plan. Appoint a Hazard Communication Coordinator. (If applicable) Ensure employee training is conducted and properly documented. Periodically audit the Program's progress. Identify all chemical-based products being used in work area. Determine the jobs that may require specialized follow-up training. Ensure up-to-date records are maintained on the training of all employees required to handle hazardous chemicals. 3
Ensure that all new employees (permanent, temporary, contract, etc.) receive hazard communication training prior to beginning their assignment and that training is documented. Notify the Hazard Communication Coordinator of any operating changes affecting materials being used. Serve as first contact for an employee wanting any hazard communication information. C. Hazard Communication Coordinator Maintain an inventory of all chemical based products used at the facility and all corresponding MSDSs. Coordinate activities such as supplemental written program, training, periodic inspections, etc. Periodically review work areas for compliance with school system policy. Coordinate with and inform contractors of hazards within the facility. Implement labeling requirements. Coordinate supplemental programs. Provide consultation in the areas of labeling, storage requirements, emergency procedures and specialized training. Provide feedback on labeling deficiencies to supervision. Provide copies of all new MSDSs to the safety office. Ensure containers are properly labeled and that hazardous chemicals are stored in designated areas. Periodically inspect engineering controls and use of personal protective equipment. Make routine work area surveys to ensure safe practices are followed. Enforce applicable safety and health rules. Conduct audits of the facility. D. Employees Obey established safety rules. Use personal protective equipment as required by school system procedure. Immediately inform supervisor of: -Any symptoms of overexposure related to hazardous chemicals -Missing labels on containers -Malfunctioning safety equipment. Use approved labels on the containers (do not remove or deface labels). Use only approved containers for hazardous chemicals. Know their role in emergency procedures. E. Supply and Purchasing Ensure person authorizing purchase for all purchase items obtains MSDSs Ensure that the following (or similar) statement is on all purchase requisitions and purchase order forms: 4
All chemicals purchased require a material safety data sheet (MSDS) and must have a purchase order number. Materials requiring an MSDS cannot be received unless the MSDS has been provided to the person originating the order. Procedure for initiating a purchase order Each school/department will be issued a rubber stamp from the (Sample shown) that requires the signer of each Purchase Requisition to verify that the Material Safety Data Sheets are available for any materials that they are ordering. Materials Safety Data Sheet Available N/A MSDS Index Number This information will be stamped on each Purchase Requisition prior to processing the requisition to the Purchasing Department. The Purchasing Department will return ANY Purchase Requisition that is not stamped and filled out by the requester. For those schools/departments using the automated purchasing system a statement must be included to indicate whether or not a MSDS is on file along with the MSDS Index Number prior to the Purchasing Department accepting the requisition. If a MSDS is required and available, the appropriate MSDS Index Number must be filled in (See MSDS Indexing discussed below.) Providing the MSDS Index number indicates to the Purchasing Department that this chemical/material has been ordered before and that the MSDS is not only available in the school/department, but also in the school system Master Listing of MSDSs. If a new chemical is being purchased, the user must obtain a copy of the MSDS from the supplier and provide it to the Program Administrator for Safety and Health. The Program Administrator for Safety and Health will verify the all required safety precautions are taken and that the material can be used safely. Upon this verification, the Program Administrator for Safety and Health will provide an MSDS Index Number to the user. The MSDS Index Number can then be placed on the Purchase Order for processing. If the MSDS Index Number is not provided, the Purchasing Department will return the Purchase Requisition to the requester. Materials requiring an MSDS are not to be accepted from delivery or used unless a valid MSDS has been provided. The MSDS Index will be updated annually by the Maintenance Department and will be available to all departments/schools through the Internet (See Auxiliary Service Manual). The MSDS website will be updated prior to April 15th of each year. It is the responsibility of the signer/authorizing individual of the requisition to ensure that the appropriate information is provided and that required MSDS's are on hand prior to receiving the materials. If chemicals are received without an MSDS, they will be returned to the supplier. Individuals requesting the use of a new chemical/material must secure a copy of the MSDS from the supplier/manufacturer before purchasing the item. If the requester of the new material has difficulty obtaining the MSDS, contact the Program Administrator for Safety and Health in the Maintenance Department at 370-2395 for assistance. 5
MSDS INDEXING: To simplify the tracking of MSDS sheets and to ensure that MSDS sheets are available, the Program Administrator for Safety and Health will compile the index and provide a copy for the Principals/Facility Managers. This listing will be updated annually and provided to the schools/departments prior to April 15th of each year. II. WRITTEN PROGRAM This document will serve as the Guilford County School System's written Hazard Communication Program as required by the OSHA regulation. This written program explains how the standard will be implemented. All employees will keep a copy of this written program on file in the Hazard Communication Coordinators office and in all work areas not in the immediate vicinity of that office so as to be available for review. III. CHEMICAL INVENTORIES/HAZARDOUS SUBSTANCES LISTS Each Guilford County School and service unit will maintain a listing of all chemicals known to be present in the workplace. A list will be available upon request for employee review. The manager responsible for the facility will maintain a current list of all chemicals provided Guilford County Schools at that location. The current list will be maintained in appendix A for that site and a consolidated list maintained in the safety office. Contractors and subcontractors are required to provide a list to any Guilford County School System facility of all potentially hazardous chemicals they bring onto the job site. Access to this information will be provided to any subcontractor or their appointed responsible representative who works on, or has responsibility for that location. IV. MATERIAL SAFETY DATA SHEETS (MSDSs) Material Safety Data Sheets are written or printed material concerning a hazardous substance. MSDSs are prepared and distributed with the products by the manufacturers and/or distributors. MSDSs will contain the special precautions and controls necessary for handling hazardous chemicals. The Hazard Communication Coordinator will maintain a central MSDS file for all hazardous chemicals used. The MSDS will be readily accessible to personnel on all shifts. Employees may review their MSDSs by contacting their immediate supervisor or by submitting a written request for the desired information. A copy of the MSDS is required in the area where the chemical/material is being used; a copy is also required in the main office at the school or department, and a copy must be maintained in the school system's MSDS Master Listing retained by the Program Administrator for Safety and Health in the Maintenance Department. 6
When a new chemical or MSDS is received, the receiver will place a copy in the notebook(s) maintained for that location and forward a copy to the Program Administrator for Safety and Health for the MSDS Master Listing. Chemical manufacturers or vendors will be contacted if additional information is necessary or if an MSDS has not been supplied with an initial shipment. The chemical or substance in question will not be placed in use until an MSDS has been obtained or the required information has been provided for each hazardous chemical. V. HAZARD DETERMINATION Determination of which materials are classified as "hazardous" based on the following categories [refer to OSHA 1910.1200(c) Definitions for a description of these categories]: A. Physical Hazards Combustible Liquid Flammable Solid Flammable Aerosol Flammable Gas Compressed Gas Explosive Water Reactive Pyrophoric Oxidizer Organic Peroxide Unstable (Reactive) B. Health Hazards Toxic Carcinogens Reproductive Toxin Irritants Corrosives Sensitizers Hepatotoxins Nephrotoxins Neurotoxins Agents that damage lungs, skin, eyes, or mucous membranes Guilford County Schools will conduct environmental monitoring surveys and review job profiles to assist in obtaining information on potential risks and exposures. Information will be developed describing chemicals and protective equipment that an employee is required to use. 7
VI. LABELS AND OTHER FORMS OF WARNING Potentially hazardous chemicals will be stored in their original, properly labeled container. Manufacturer's labels will not be defaced or removed. The labels must list the contents of the container and any appropriate hazard warnings. Containers that have not been labeled or from which the manufacturer's label has been removed will be properly labeled. No unmarked containers of any size will be left unlabeled. Labels are designed to provide information to employees concerning the hazards of various chemicals. It is important that no hazardous chemical is placed in an improperly labeled container. Labels will be left intact on manufacturers' containers used to store or dispense chemicals. Observation or other detection of a defaced label must be reported to supervision so that appropriate labels can be reapplied immediately. As a minimum, each label must contain the following: Identification of the material in the container. Appropriate hazard warnings, such as fire, health, and reactivity. Name and address of the manufacturer, importer, distributor, or other responsible party. In rare cases, Guilford County Schools will use signs, placards, process sheets, batch tickets, operating procedures or similar accessible written materials instead of affixing labels to individual containers. General policy is, however, that each individual container must be labeled. The Program Administrator must approve any exceptions to this policy for Health and Safety. All stationary containers, including mixing vessels or tanks, will be labeled, placarded, tagged or marked to show the above information. If the mixing vessel serves a multiple use, then a formula sheet may be used to identify the contents. The formula sheet will be maintained in the work area and identified with the container to which it applies. Where multiple use containers are present, MSDSs for hazardous chemicals listed on the formula sheet must be maintained in the work area. The procurement and installation of labels, signs, tags or other markings for hazardous materials will be the supervisor's accountability. He/she may choose qualified employees to oversee replacement labels, tags, etc. Additional labels may be obtained through the supply room to replace defaced or missing labels. VII. EMPLOYEE INFORMATION, EDUCATION, AND TRAINING The intent of the Guilford County School System Hazard Communication Program is to inform, educate and train employees of chemical and physical hazards within their workplace. Technical terms should be properly explained along with Management's action to protect the employees. Training and information shall be provided to the employee at the time of his/her initial job assignment and under the conditions described in the "Retraining" Section. 8
Guilford County Schools will use a combination of audiovisual tapes, written instructions, and verbal instructions to inform employees of the requirements of this program. The following sections of this written program describe the specific information to be given to the employee: A. "Initial" Training The purpose of this phase of training is to inform all new Guilford County School System employees that the Hazard Communication standard exists and to explain how the components of the program will be implemented within their workplace. Training of new employees will be conducted prior to their assignment to areas where hazardous chemicals are used. Initial training will provide the following training and information: A restatement of the Guilford County School System's overall policy on occupational safety and health, A brief synopsis of the history behind and intent of the OSHA regulation, Location and availability of the written programs, How to obtain an MSDS, Location, availability and/or explanation of: 1. Written programs 2. Hazardous Substances List 3. Material Safety Data Sheets 4. Labeling systems Emphasis on the employees' responsibility in following this program. Documentation of employee attendance will be made. The Hazard Communication Program Coordinator will keep attendance records. Management and administrative personnel will have additional training enforcement and recordkeeping responsibilities. B. "Specific" Training Specific training relating to individual employee jobs or groups having common jobs involving the same hazardous materials will be conducted. Training covering each hazardous substance will include: Identity and characteristics of the hazard/chemicals with which the employee works and a description of the jobs/operations in their work area where the hazardous substance is present. Physical and health hazards (both acute and chronic) due to exposure to the substance. Methods and observations that may be used by the employee to detect the release or presence of the hazardous substance in the work area. 9
Measures employees can take to protect themselves from the identified hazards, including proper use of engineering controls, personal protective equipment and proper handling procedures. Emergency procedures and first aid measures. Review of labels and MSDSs concerning the identified hazardous substance. C. Retraining Guilford County Schools will conduct retraining sessions. The principal/facility manager or designated representative will provide additional employee training concerning workplace hazards when: New hazardous chemicals are introduced into the workplace. Process or equipment changes are made which could cause new or increased employee exposures. Procedures and work practices are introduced or changed which could cause changes in the employees' exposure. Employees are transferred from one work area to another where different hazards are present. Employee shows evidence that prior training has been forgotten or unsure. VIII. Chemical Waste Disposal Employees are apprised of chemicals that need to be purged from their chemical inventory and the procedures concerning the collection and containment of waste chemicals. Waste chemicals should be boxed and stored by compatible families, and labeled as To be Discarded and stored in a secure and safe place. A Work Order Request should be submitted to Guilford County Schools Maintenance Department requesting disposal. The Work Order Request must be accompanied by a faxed form to the Maintenance Department at 370-2398 as an addendum to the Work Order Request which will include the name of the chemical to be disposed of, the quantity of the chemical to be disposed of and the specific location of the chemical at the site to be disposed of and the name of a contact person at the site who is knowledgeable of the requested chemical disposal. Form is located in Appendix C. IX. NON ROUTINE WORK Guilford County School employees performing work that occurs rarely or tasks required for the first time is classified as non routine work. Non routine work will be treated as routine work for purposes of hazard communication. The supervisor of an employee performing a non-routine task is responsible for adequately training the employee concerning the potential hazards associated with the non-routine task. 10
X. HAZARD COMMUNICATION FOR CONTRACTORS Contractors shall be informed of all hazardous chemicals to which their employees are potentially exposed while performing work at a Guilford County School System location. A list of hazardous chemicals and the appropriate hazard information as well as any recommendations for special protection will be reviewed with the contractor before the contractor comes on site. Material Safety Data Sheets for the area in which the contractor is working will be available for review by the contractor through the respective Hazard Communications Coordinator. Review of any MSDS will be documented in the same manner as when reviewed by any Guilford County School System employee. The contractor will submit a list of hazardous chemicals that will be brought on site to the controlling manager. All hazardous chemicals must be approved before they can be brought onto Guilford County School System property. MSDSs for all hazardous chemicals brought onto Guilford County School System property must be kept on site by the contractor for review by facility management and Guilford County School System employees who may be exposed to the chemical. XI. PROCUREMENT OF CONFIDENTIAL INFORMATION Situations may arise when manufacturers of chemical products will claim certain hazardrelated information as "confidential." If an employee has a bona fide "need to know" confidential information, the Guilford County School System has legal procedures to provide that information. All such inquiries, whether emergency or non-emergency, will be directed to the office of the Safety Manager. XII. PROGRAM EVALUATION The principal/facility manager or Hazard Communication Coordinator will conduct periodic inspections/surveys of phases of the program. (labeling, documentation, record keeping, employee knowledge of work site hazards, use of personal protective equipment.) Deficiencies will be noted and the corrective measures will be taken. The central safety office will conduct the same on a system wide basis. 11
APPENDIX A Chemical Inventory List 12
APPENDIX B The Hazard Communication coordinator for ------------------------- is-------------------. 13
APPENDIX C GCS Chemical Disposal Form School: Contact Person: Date Requested: Date Removed: Removed By Signature: Verification of Removal Signature: Chemical Name Quantity Location 14