This Guide will assist you, the employer, in preparing a written Hazard Communication Program which describes how the standard will be implemented in your workplace.

To use the Guide, follow these steps:

1. Read the Hazard Communication Standard. You may find "Appendix E: Guidelines for Employer Compliance" helpful for interpreting the standard.
2. Follow the model program in order, adding information specific to your worksite. Review the related sections of the standard as you work on each major program section.
3. Use the Checklists to evaluate your program.
4. For clarification or assistance, contact SafetyWorks! at 207-624-6400 or toll-free at 1-877-SAFE-345 (1-877-723-3345).

In order to comply with the standard and provide effective protection against hazardous substances, the written Hazard Communication Program must be tailored to the specific worksite. This is a performance-based standard, which means you have the flexibility to adapt the rule to the needs of your workplace. Be sure to modify the model program to reflect the actual conditions at your worksite.

Please note: The information contained in this publication is not considered a substitute for any provisions of any OSHA standard.

Model Hazard Communication Program

I.Policy statement- 29 CFR 1910.1200(e)

____________________________(company name) has established this Hazard Communication Program in order to comply with 29 CFR 1910.1200, OSHA's Hazard Communication Standard, and to provide a safe and healthy workplace.

All work units are included under this program. The written program will be available for review by any employee during work hours. It is located in _____________________________________________________________________.

_________________________________________ (employee name or position) will review and update the program at least annually and whenever necessary to include new hazardous materials or procedures.

The written program will be made available to employees, their designated representatives, the Assistant Secretary for Labor for OSHA, the director of the National Institute of Occupational Safety and Health (NIOSH), and the Bureau of Labor Standards

Notes to Employers:

• Where employees must travel between workplaces during a workshift, the written program may be kept at the primary workplace facility. The program must be available during all shifts.
• The employer may choose to include a statement of the company's commitment to workplace health and safety.
• The employer may choose to include a statement of the employer's and the employee's responsibilities in relation to this program.

II.Container labeling- 29 CFR 1910.1200(f)

_____________________________________ (employee name or position) will verify that all containers of hazardous substances are properly labeled.

______________________________ (employee name or position) will review the labeling system________________________ (add frequency of review) and update as needed.

______________________________ (employee name or position) will answer questions and provide help on labeling.

Description of labeling system used:

Original containers received for use will be labeled to indicate, at a minimum:

• The identity of the contents. The identity must match the MSDS.
• Appropriate hazard warnings, including routes of entry and target organs if known, and
• The name and address of the manufacturer, importer, or responsible party.

Secondary containers will be labeled with, at a minimum:

• A copy of the original manufacturer's label, or
• Generic label with identity and hazard warnings.

• Labels must be in English. Information may be presented in other languages in addition to English.
• Labels must be legible and prominently displayed. There are no specific requirements for size or color.
• The identity is any name which appears on the label, the MSDS, and the list of chemicals, linking these three sources of information.
• The labeling system may use the labels provided by the supplier, company labels, numerical rating systems, symbols, pictures, or another effective system.

III.List of hazardous chemicals- 29 CFR 1910.1200(e)(1)(i)

_____________________________(employee name or position) is responsible for preparing and updating the list of all chemicals in our workplace that are potentially hazardous.

(List chemicals below or add separate sheet(s).)

• See Hazardous Chemicals List for information on identifying and listing chemicals.

IV. Material safety data sheets (MSDS)--29 CFR 1910.1200(g)

_________________________________ (employee name or position) is responsible for obtaining and maintaining the MSDSs.

_________________________________ (employee name or position) will review incoming MSDSs to make sure they contain all required information, and for changes in health and safety information. He/she will make sure any new information is passed on to the affected employees.

When toxic or hazardous substances are received without the MSDSs, ________________________________ (employee name or position) will send a letter to the supplier requesting the MSDS, with a copy to file.

Employees are not permitted to use any chemicals for which the company does not have the MSDS.

MSDSs will be accessible to all employees during each work shift when they are in their work areas. Copies of MSDSs will be kept in the following location(s):
(list locations)

• Electronic access, microfiche, and other alternative to maintaining paper copies of MSDSs are permitted as long as they do not create barriers to immediate employee access in each workplace. If used, they must be described in the written program.
• Where employees must travel between workplaces during a workshift, the MSDSs may be kept at the primary workplace facility providing employees can immediately obtain the required information in an emergency.
• Where employees report to a temporary work location (such as a construction site), MSDSs must be kept at that location.
• MSDS can be found on the Internet. One site is http://www.hazard.com

V.Employee Information and Training--29 CFR 1910.1200(h)

________________________________ (employee name or position) is responsible for the employee training program.He/she will ensure that all elements specified below are carried out.

_________________________________ (employee name or position) is responsible for assuring that each affected employee will be given information as outlined below for any new chemical prior to that chemical being introduced into the workplace.

Prior to starting work, each new employee of this company will attend a health and safety orientation and will receive information on the following information:

An overview of the requirements contained in the OSHA Hazard Communication Standard, 29 CFR 1910.1200. Chemicals present in their workplace operations. Location and availability of our written hazard communication program. Physical and health effects of the toxic or hazardous substances. Methods and observation techniques used to determine the presence or release of toxic and hazardous substances in the work area. How to use toxic and hazardous substances in the safety possible manner, including safe work practices, personal protective equipment and emergency procedures. Steps the company has taken to lessen or prevent exposure to toxic and hazardous substances. How to read labels and review MSDSs to obtain correct hazard information. Location of MSDSs.

VI. Hazards of non-routine tasks-29 CFR 1910.1200(e)(1)(ii)

Periodically, employees may be required to perform non-routine tasks that involve the use of hazardous chemicals (for instance, cleaning reactor vessels).

_____________________________________(employee name or position) will provide information about hazardous chemicals to which employees may be exposed during non-routine tasks prior to employees starting such tasks.

This information will include:

Specific hazards involved. Protective measures the employee should take. Measures the company has taken to lessen the hazard, including ventilation, respirators, presence of another employee, and emergency procedures. Examples of non-routine hazardous tasks at this company: (For each non-routine hazardous task, list hazardous substances involved and protective measures to take.)

VII. Informing contractors-29CFR 1910.1200(e)(2)

______________________________ (employee name or position)will provide contractors with employees at our worksite the following information:

Toxic and hazardous substances to which the contractor's employees may be exposed while at the worksite. Precautions the employees can take to lessen the possibility of exposure. Location of MSDS (must be accessible at the worksite).

_____________________________________ (employee name or position) will contact each contractor before work is started in our company to gather and disseminate any information concerning chemical hazards that the contractor is bringing into our workplace. He/she is responsible for ensuring that any employees of our company who are exposed to these hazards are properly trained and protected.

Checklists

Once you have drafted your hazard communication program, use the following checklists to review the program, assess its completeness, and make any necessary changes to ensure you are in compliance with the Hazard Communication Standard (HCS).

1. Have we read and do we understand the requirements of the HCS?
2. Have we assigned responsibility for tasks?
3. Have we prepared an inventory of chemicals?
4. Have we ensured containers are labeled?
5. Have we obtained the MSDS for each chemical?
6. Have we prepared a written program?
7. Do we make all MSDSs immediately available to workers?
8. Have we trained workers?
9. Have we established procedures to maintain current program?
10. Have we established procedures to evaluate effectiveness of program?

1. Is the labeling system described?
2. Are all products containing hazardous materials labeled?
3. Are stationary containers of hazardous materials labeled?
4. Are temporary containers used between workshifts or by different employees labeled?
5. Is there an effective method of keeping labels correct and up-to-date?
6. Do labels on original containers include:
   • A chemical name that coincides with the name on the MSDS?

   • The identity of hazards with words in English, pictures or symbols?

   • The name and address of responsible party?
7. Do secondary labels include:
   • A copy of the original label, or

   • A label with the identity and hazard warnings?
8. Is hazard information for stationary process containers readily accessible?
9. Have missing or defaced labels been replaced?
10. Are all incoming containers labeled?
11. Are hazards in pipelines identified?
12. Are labels legible and in English?

1. Does our list of hazardous chemicals include:
   • Raw materials?

   • Products that are cut or otherwise acted upon to release dusts,fumes, or mists?

   • Final products?

   • Cleaning and maintenance chemicals?

   • Laboratory chemicals?
     • (If you dispose of end products, you must comply with Department of Environmental Protection rules.)
2. Is our list updated as new chemicals are introduced?

1. Is a complete MSDS available for every hazardous chemical used?
2. Are MSDSs easily accessible to employees in the work area during each work shift?
3. Do we make MSDSs accessible to our employees at other worksites?
4. Do we have effective procedures for obtaining and updating MSDSs?
5. Do we document our efforts to obtain MSDSs from suppliers?
6. Do we take appropriate action if a shipment of new material is received without the MSDS?
7. Do employees receive MSDS for new materials before using those materials?
8. Are employees informed of changes in MSDSs?

1. Are all employees trained on hazardous chemicals before they use them?
2. Have we informed employees about:
   • The different types of chemicals and the hazards associated with them?

   • Physical and health hazards of the specific chemicals in their work area?

   • How to detect presence of hazardous materials?

   • Proper selection and use of personal protective equipment?

   • Emergency procedures in the event of accidental exposure to hazardous materials, including emergency phone numbers and location of eye wash and safety showers?

   • How to determine hazards by reading a label?

   • The location of MSDS and the procedure for reviewing them and obtaining a copy?

   • How to obtain the correct MSDS for the hazardous substance being used?

   • How the MSDS are kept updated by your company?

   • The significance to the employee of each section of information on the MSDS, how to read the label, and what it means?

   • Hazards associated with non-routine tasks they might have to perform?

   • The measures employees can take to protect themselves from chemical exposure?
3. Do employees know how to detect the presence or release of hazardous chemicals in the workplace?
4. Is training documented?
5. Are employees retrained whenever chemicals or processes change and when they change jobs or departments?
6. Is there a system for evaluating the effectiveness of the training program?

1. Are all non-routine tasks involving the use of or exposure to hazardous materials identified?
2. Are the hazards involved in non-routine tasks described in writing?
3. Are MSDSs available for the hazardous materials involved in these tasks?
4. Are hazardous substances involved with non-routine tasks labeled properly?
5. Do employees receive special training on the performance of non-routine tasks?
6. Are there written standard operating procedures for non-routine tasks?

1. Does our program include how we will inform other employers of the location of MSDS for each hazardous chemical their employees may be exposed to at our worksite?
2. Does our program include how we will inform other employers of the precautions they need to take to protect their employees during routine operations and in foreseeable emergencies
3. Does our program include how we will inform other employers of our labeling system?
4. Do we receive MSDS used by contractors at our worksite?
5. Does our program include how our employees will be trained about hazards introduced by contractors and vendors?

Hazardous Chemicals List

How to Identify Hazardous Chemicals

The manufacturer or importer is responsible for determining whether a chemical is hazardous. As a user of chemicals, the employer may rely on the evaluation received from the supplier through container labels and material safety data sheets.

To prepare a list of the chemicals in your facility that are covered by the standard, write down the name of chemicals or products that have a label indicating a potential hazard (such as, "flammable" or "causes skin irritation"). Do not limit yourself to chemicals in containers. Include substances generated in work operation, such as fumes or dusts, as well as substances in pipes.

Chemicals considered to be hazardous are those:

• regulated by OSHA in 29CFR1910, Subpart Z, Toxic and Hazardous Substances;
• included in the American Conference of Governmental Industrial Hygienists ACGIH) latest edition of Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment;
• found to be suspected or confirmed carcinogens by the National Toxicology Program in the latest edition of the Annual Report on Carcinogens, or by the International Agency for Research on Cancer (IARC) in the latest edition of their IARC monographs.

Once you have a complete list, review it to determine if any of the items are exempt. In paragraphs (b)(5) and (b)(6) of the Hazard Communication Standard, OSHA has listed items that are excluded. Some employers choose to include all chemicals even if they are exempt. In general, if you are uncertain about a particular chemical, it is best to include that chemical in your program.

How to List Chemicals in the Workplace

All hazardous chemical known to be present in your workplace need to be listed using a name found on the MSDS and the label. This list can include common or trade names, Chemical Abstract Service (CAS) Registry names, or other identifiers your employees will recognize. You can make one list for the entire workplace or separate lists by department or work area.

This list is an inventory of everything for which MSDSs must be obtained. The list is part of the written program, and must be made available to employees upon request.

Employee Education and Training Record

Employee__________________________________

Date of Hire__________ Job Title___________________________ Date Assigned_____________

For each subject, include date of training, trainer name, and signature of trainee.

Initial Training:

• Overview of the Standard Chemicals in their workplace
• Location of written program
• Physical and health effects of chemicals in workplace
• How to determine presence of hazardous substances
• How to work safely with hazardous substances
• What company has done to reduce exposure
• How to read labels and MSDS Location of MSDS and written program

Additional Training:

Retraining:

Resources

SafetyWorks! (http://www.state.me.us/labor/blsmain.htm), Maine Department of Labor offers training, information, audio-visual aids and on-site consultation on hazard communication and other workplace health and safety topics. 45 State House Station, Augusta, ME 04333 Tel 624-6400 TTY 1-800-794-1110. E-mail: webmaster.bls@state.me.us

Occupational Safety and Health Administration (OSHA)(http://www.osha.gov) offers information on hazard communication and other workplace health and safety topics. OSHA publication 3084 Chemical Hazard Communication provides an overview of the standard. USDOL/OSHA, 202 Harlow St, Bangor, ME 04401 Tel 941-8177.

Bureau of Remediation and Waste Management (http://www.state.me.us/dep/rwm/homepage.htm) , Maine Department of Environmental Protection regulates the disposal of hazardous materials. 17 State House Station, Augusta, ME 04333-0017 Tel 287-2651.

Insurance agents may provide hazard communication training and assist in developing the written program

Trade Organizations often have information about chemicals found in specific industries and sample hazard communication programs tailored to that industry

The following videotapes related to chemical safety may be borrowed from SafetyWorks!. Call 624-6400 or request on-line

• MSDS: Read it Before You Need It#361
• The OSHA Hazard Communication Standard#363
• Labels and Other Forms of Warning#364
• Health Hazards#365
• Physical Hazards#366
• Right to Know Training#367
• Chemical Hygiene Plan #1#368
• Chemical Hygiene Plan #2#369
• Chemical Hygiene Plan #3#370
• Chemistry Lesson: Working Safely with Hazardous Materials #371
• Chemical Hazards#372