SAMPLE HAZARD COMMUNICATION TRAINING PROGRAM

Prepared by

7373 N. Lincoln Avenue Lincolnwood, IL www.issa.com June 30, 2006

INTRODUCTION Training is an integral part of any hazard communication program. Under the OSHA Hazard Communication Standard (29 CFR 1910.1200), all employers are required to inform and train their employees at the time of their initial assignment to a work area where hazardous chemicals are present, and wherever a new hazard is introduced into the work area. The general topics that must be addressed in an employee information and training program is the same for all employers. However, the actual information presented must be based on the specific circumstances present at each particular workplace. Therefore, while employers are encouraged to use this sample program to train their employees, it is important that it be supplemented with workplace specific information such as the location and availability of MSDSs and a companys written hazard communication program. The OSHA Hazard Communication Standard requires that the following topics be covered in an employee information and training program: The provisions of the Hazard Communication Standard Any operations in employees work areas where hazardous chemicals are present The location and availability of the companys written hazard communication program, including the required list(s) of hazardous chemicals and MSDSs required by the Hazard Communication Standard Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area The physical and health hazards of the chemical in the works area The measures employees can take to protect themselves from these hazards, including information on work practices, emergency procedures and personal protective equipment required by the employer The details of the employers written hazard communication program, including an explanation of the labeling system used by the employer, MSDSs, and how employees can obtain and use the appropriate hazard information on the labels and in the MSDSs.

(Special Note to Distributors Who Only Handle Chemicals in Sealed Containers Which Are Not Opened Under Normal Conditions of Use: Such distributors must ensure that their employees are provided with information and training (except for the information regarding the written hazcom program) to the extent necessary to protect them in the event of a spill or leak of a hazardous chemical from a sealed container.) The sections below illustrate how a typical training program might be designed. Employers can develop an effective employee training program that meets the objectives of the OSHA Hazard Communication Standard by following the sample program below along with workplace specific information regarding hazardous products, labels, MSDSs and other pertinent information.

SAMPLE HAZARD COMMUNICATION PROGRAM I OVERVIEW OF EMPLOYEE TRAINING PROGRAM

Our company is committed to providing a safe and healthy workplace for all of our employers. As part of that commitment, our company complies fully with the OSHA Hazard Communication Standard. The Hazard Communication Standard is based on a simple concept that employees have both a need and a right to know the hazards of the chemical products they are exposed to when working. More importantly the standard ensures that employees are provided with the information necessary to avoid harm from occurring such as how to properly use products, what personal protective equipment is called for, what to do in the event of an accidental exposure, etc. Information and training is a critical part of our hazard communication program. Information regarding hazards and protective measures are provided on labels and MSDSs. However, through effective information and training, employees learn to read and understand such information, determine how it can be obtained and used in our workplace, and understand the risks of exposure to chemical products as well as ways to protect themselves. II HAZARD COMMUNICATION

A. Purpose. The purpose of the Hazard Communication Standard is to ensure that the hazards of all chemicals produced or imported are evaluated, and that information concerning their hazards are communicated to employers and employees. Manufacturers of chemical products and importers must assess, and provide information about, the hazards of chemicals that they produce or import. Distributors of hazardous materials are required to pass on the information to their customers. B. Employer Requirements. Employers must provide information to their employees about the hazardous chemicals to which they may be exposed. As part of this education process, they must: Identify and list hazardous chemicals in the workplace; Obtain MSDSs and labels for each hazardous chemical; Develop and implement a site-specific, written hazard communication program including labels, MSDSs and employee training; and Communicate hazard information to their employees through labels, MSDSs and formal training programs.

C. Employee Responsibilities. Employees also have responsibilities under the OSHA Hazard Communication Standard to ensure their own safety and that of their coworkers.

Employees should become familiar with the nature of the hazards associated with the chemical products with which they work or are otherwise exposed, as well as how to handle them safely. In general, employees should: Be familiar with the location and availability of material safety data sheets (MSDSs) and the written hazard communication program; Use chemical products in a manner that is consistent with the information set forth on the label and MSDS, including but not limited to directions for use, hazard warnings and precautionary measures; Follow appropriate work practices when working with hazardous chemical products such as the use of personal protective equipment and ventilation; Comply with OSHA regulations and company safety and health policies; and Report hazardous conditions to your supervisor.

Remember, safety is everyones responsibility! III PHYSICAL & HEALTH HAZARDS IN THE WORKPLACE

A number of hazardous chemical products are present in the workplace, all of which generally fall into one or more of the following categories. Corrosives/Irritants Flammables/Combustibles Oxidizers Toxins/Poisons Carcinogens, Mutagens and Teratogens

Many hazardous chemical products fall into more than one hazard category. For example, a solvent based cleaner may be a toxin, corrosive and flammable. Your workplace contains many types of hazardous chemical products, which fall into one of the hazard categories listed above. The majority of the chemical cleaning products in your workplace falls into one or all of the first three categories. A. Corrosives and Irritants. 1. Corrosives. Products classified as corrosive can cause visible destruction of, or irreversible damage to, living tissue by chemical action at the site of contact. Corrosives are often found in the form of concentrated acids and bases. Examples of corrosive products include: Ovens and Grill Cleaners Acid Toilet Bowl Cleaners Alkaline Drain Cleaners

Contact with corrosive substances can have immediate and damaging effect. Corrosive products can severely burn skin or eyes on contact. If accidentally swallowed, a corrosive can cause internal burns and otherwise cause damage to body organs. Many corrosive products also can react violently if mixed with other products. The following is an overview of the different ways you can be exposed to corrosives and what the affect would be: Skin Contact Corrosives can badly burn and blister the skin. Eye Contact Corrosives can burn the eyes and could result in scars or permanent blindness. Inhalation Breathing in the vapors of a corrosive product can burn the inner lining of the nose, throat, windpipe and lungs. In serious cases, this results in a buildup of fluids in the lungs that can be fatal. Ingestion Swallowing corrosives burns the sensitive lining of the mouth, throat, esophagus and stomach.

2. Irritants. Irritants are chemical products that cause a reversible inflammatory effect on living tissue (i.e., skin, eye) by chemical action at the site of contact. Examples of products classified as irritants include: Industrial Cleaners & Degreasers Sanitizers General Purpose Cleaners

3. First Aid. In the case of exposure to skin, remove contaminated clothing, rinse skin immediately with plenty of water for 15-20 minutes. If in the eyes, hold eye open and rinse slowly and gently with water for 15-20 minutes. Remove contact lenses, if present, after the first 5 minutes, then continue rinsing. In either event, call a poison control center or doctor for treatment advice. Check the products MSDS and label for specific first-aid information. B. Flammables & Combustibles. Products that are classified as flammable or combustible are substances that can catch fire and burn. The following are examples of flammable and combustible materials: Flammable liquids: acetone, gasoline, solvent based products Combustible Liquids: mineral oil Flammable Gases: propane Aerosols: certain aerosol products may contain propellants that cause them to be flammable 1. Physical Hazards. The vapors of flammable and combustible materials can ignite easily, burn rapidly and may explode, and/or produce toxic vapors. Flammables have a flash point at or below 100 F, while combustibles have a flash point between 100 and 200 F. Flash point is the temperature at which the vapors will ignite.
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2. Health Hazards. Exposure to the vapors of flammable and combustible materials may produce adverse health effects. Acute Effects: headaches, dizziness, nausea. Chronic Effects: general damage to lungs, liver and kidneys. Do not use near open flame or other source of ignition. Keep container closed when not in use. Store in a cool, dry place space. Store separately from oxidizers. Check MSDS for product specific information.

3. Precautionary Measures.

C. Oxidizers. Materials classified as oxidizers are substances that enhance the burning of other materials through the release of oxygen. Oxidizers are generally very reactive. Contact with flammable or combustible materials is likely to result in fire. Oxidizers may react with other products to form noxious fumes. An example of an oxidizer is sodium hypochlorite also known as bleach. 1. Physical Hazards Fire Explosion 2. Health Hazards Acute Effects: Inflammation/destruction of tissue; severe irritation of the upper respiratory tract; irritation of nose and eyes. Chronic Effects: Damage to the nervous system; potential fertility disorders. 3. Precautionary Measures Store separately from flammables and combustibles. Do not mix with other products and materials (i.e., do not mix bleach with products containing ammonia). Keep containers closed when not in use. Check MSDS for product specific information. D. Toxins/Poisons. Toxins are chemical products that are extremely poisonous. All chemicals are poisonous to some degree, but a toxin can cause serious health effects even in small doses. Typical examples of products that may be considered toxic include: Hydrofluoric based aluminum cleaners/brighteners Sulfuric acid based drain cleaners Ethylene glycol based cleaners

The word POISON and the skull and crossbones symbol generally appears on the label of products that are highly toxic. 1. Health Hazards. The acute and chronic effect of toxins varies widely based upon the chemicals present and the route of entry. Refer to MSDSs and labels for specific hazards. 2. Safe Handling & Storage. Refer to the MSDS and labels for specific precautionary measures. In general, restrict access to areas where toxins are in use and stored. Be sure to keep containers tightly sealed when not in use. E. Carcinogens. While relatively rare, carcinogens may be present in some of the products present in the workplace. The MSDS and label generally will identify whether or not the product contains such a substance as well as the precautionary measures and appropriate work practices to be followed. IV ROUTES OF EXPOSURE

In general, exposure to chemical products occurs through skin absorption (i.e., absorbed into the skin), inhalation (i.e., breathing in vapors), or ingestion (i.e., eating or swallowing the substance). A. Skin Most susceptible to liquids, oils or pastes. Think of the skin as a two way street. In the summer sweat comes out in one direction. Year round, toxic materials can enter your body in the opposite direction. Eyes are considered part of your skin and are a primary route of entry. Keep your skin protected from hazardous materials with clothing, personal protective equipment and common sense.

B. Inhalation Lungs have no natural barrier One of the fastest routes of entry Most susceptible to gases and vapors Protect your lungs. Use common sense, ventilation, and if necessary the appropriate type of respirator.

C. Ingestion Contaminated food Hand to mouth contact Facial Splash Avoid having food or drink in areas where hazardous products are used or stored Thoroughly wash hands before eating

PERSONAL PROTECTIVE EQUIPMENT

Personal protective equipment (PPE) may be necessary to protect employees from the hazards of certain cleaning products. PPE is designed to reduce employee exposure to hazards when other means of reducing exposure are not feasible. When working with chemical cleaning products, the potential hazards generally relate to skin and eye exposures through splashing or other direct contact, and inhalation of vapors and particulates. Therefore it is important to consult the label and MSDS to determine what, if any, appropriate PPE is necessary to provide you with an effective barrier to potential chemical hazards. The following are some examples: Eye Protection: Safety glasses, goggles, face shields Body Protection: Gloves, aprons, outer clothing (long sleeves, etc.) Respiratory Protection: Masks, respirators, self-contained breathing apparatus

In addition, OSHA requires that PPE: VI Provide adequate protection against the hazard; Be reasonably comfortable; Fit snugly without interfering with movement or vision; Be durable; Be capable of being disinfected; and Be kept clean and in good repair. OSHA LABELING REQUIREMENTS

A. OSHA Labeling Requirements. Under the OSHA Hazard Communication Standard suppliers must ensure that the labels of hazardous cleaning products contain at a minimum the following information: Name or identity of the product (same name as used on the MSDS); Appropriate hazard warnings Name and address of the manufacturer, distributor or other responsible party.

B. Additional Information. Labels provided on products often contain information in addition to that described above such as: Directions for use Storage instructions First aid Recommended PPE

Remember that the label is intended to only provide an immediate visual warning. The MSDS should be reviewed for more detailed info.

B. Portable Containers. Portable containers, such as spray bottles, into which hazardous products are transferred, should be labeled with the name of the product and appropriate hazard warnings. C. Employee Responsibilities. In reference to product labels, employees should be sure to: VII Read labels before using product Do not deface or remove the label Ask your supervisor if you are unsure of anything MATERIAL SAFETY DATA SHEETS

Material Safety Data Sheets (MSDSs) are intended to be the primary source of information relating to hazardous chemical products. In general, MSDSs set forth at a minimum the following information: Identity of the chemical product as used on the label Name, address and telephone number of Manufacturer, Distributor, Importer or other responsible party who can provide additional information about the chemical product and emergency procedures if necessary Hazardous components of the product Physical/chemical properties of the product Whether the product is flammable/combustible, and if so, how the fire should be put out What products or substances the hazardous product should not come into contact with Health hazards that may occur as a result of inappropriate exposure to the product Steps to be taken in the event of a spill or leak Precautions to be taken in handling and storing Appropriate personal protective equipment

We maintain MSDSs for every hazardous chemical product so that they are readily accessible to all of our employees who may be exposed to hazardous chemical products. Our MSDSs are located ____________________________________________________ ________________________________________________________________________ ________________________________________________________________________ and can be accessed by ____________________________________________________ ________________________________________________________________________ ________________________________________________________________________ An MSDS for a particular product can be referenced by the product name used on the label.

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WRITTEN HAZARD COMMUNICATION PROGRAM

Our company has developed and implemented a Written Hazard Communication Program which describes how we comply with the labeling, MSDS, and employee information and training provisions of the OSHA Hazard Communication Standard, and which also includes: A list of the hazardous chemical products present in the workplace The methods we use to inform our employees of the hazards of non-routine tasks and the hazards associated with chemicals contained in unlabeled pipes in their work areas. The methods we will use to provide other employers with access to MSDSs and whose employees we may expose to hazardous chemicals; explanation of the labeling system; and any precautionary measures needed to protect their employees.

The following is an overview of our Written Hazard Communication Program:________ _______________________________________________________________________ _______________________________________________________________________ _______________________________________________________________________ Our Written Hazard Communication Program is located __________________________ ________________________________________________________________________ and can be readily accessed by making a request to ______________________________ ________________________________________________________________________ ________________________________________________________________________

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STORAGE AND HANDLING / SPILLS AND LEAKS

Always consult the MSDS and/or label for specific instructions regarding storage and handling and spills and leaks. The following suggestions, however, are generally applicable to most hazardous materials. A. Storage and Handling Keep containers closed when not in use; Check containers periodically for leaks; Store incompatible materials away from each other (i.e., bleach and ammonia); Storage and work areas should be well ventilated; When storing hazardous materials stay within the environmental limits specified on the product label or MSDS; Temperature Humidity Ventilation Approved flammable material storage areas/cabinets

When handling hazardous materials, use appropriate personal protective equipment; 9

Check with your supervisor about eliminating old chemical products that are not used; and Always check the MSDS and/or label for special instructions.

B. Spills and Leaks Clear the area; If spilled materials are flammable or combustible, remove sources of ignition or heat. Use no tools or devices that create sparks, heat or flames; Stop the spill from spreading; Keep the spill from flowing into drainage or sewer systems; For liquid spills, use absorbent solid to soak and contain the spill; Sweep up used absorbent and dispose of properly. Some chemical product spills may have to be handled and disposed of as hazardous waste; Use appropriate personal protective equipment; Consult appropriate MSDS for instructions on disposal, PPE and general handling precautions; and Inform supervisors of the spill or leak.

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