Written programs: Hazardous

Compliance with the written program can be verified during the walkaround by personal observation and employee interviews. If respirators are required to be worn in the workplace or respirators other than dust masks are worn by voluntary users, a written program is required. An overexposure is not required to cite. Discrepancies between the written program and implemented work practices at the worksite should be cited. Use of a elastomeric or supplied-air respirator, even when voluntary on the part of the employee, will require the employer to include all elements in a written program that will make sure that there is proper use of these respirators so that they do not create a hazard. 

Managing chemical reactivity hazards is not a one-time project, review, or audit. It is also not a written program document to put on the shelf and ignore. Managing chemical reactivity hazards is an ongoing effort to protect employees, contractors, customers, the public, environment, and property against the potential consequences of chemical reactivity incidents. 

No written program to identify and evaluate hazardous practices and/or conditions... 

A written program developed and implemented by an employer designating proceedures, equipment, personal protective equipment, and work practices that are capable of protecting employees from the health hazards presented by hazardous chemicals usid in that particular workplace. 

The Hazard Commimication Standard reqirires each facility to conduct a hazard assessment for each chenucal in the workplace, maintain an inventory of chemicals in the workplace, retain MSDSs for each chemical in the workplace, properly label each chemical according to a uniform labeling policy, train each employee to understand the MSDSs, product labels, and Hazard Communication Standard, and develop a written program that explains how the Hazard Communication Standard is to be implemented at the facility. 

Employers must establish a written, comprehensive hazard conununication program that includes provisions for container labeling, material safety data sheets, and an employee training program. The program must include a list of the hazardous chemicals in each work area, the means the anployer uses to inform employees... 

One of the biggest differences between the RMP and PSM standards is that EPA requires that a formal, written program be prepared, and which is then placed in the public domain. OSHA does not require this. EPA needs a written plan because the RMP is very concerned with making sure that members of the public are fuUy informed as to what hazards are in their community, and what to do if there is an accident, and how the various emergency agencies can work together. 

For employers using hazardous chemicals, the most important aspect of the written program in terms of MSDSs is to ensure that someone is responsible for obtaining and maintaining the MSDSs for every hazardous chemical in the workplace. The list of hazardous chemicals required to be maintained as part of the written program will serve as an inventory. As new chemicals are purchased, the list should be updated. Many companies have found it convenient to include on their purchase orders the name and address of the person designated in their company to receive MSDS. 

The written program must define how the employees are to be informed of the requirements of the standard. This will include details of (1) how the employees are to be informed about the contents of the standard (2) the contents of the written plan (3) how they are to meet the labeling requirements (4) how they are to learn of the methods available to them to warn them of exposures (5) how to obtain and interpret a MSDS for a given chemical (6) the hazards associated with the chemicals to which they are exposed (7) how they are to be trained in procedures which will eliminate or reduce these chemical hazards and (8) how they are to react in an emergency. 

Usually you will receive or be told where to get a copy of the written program during hazard communication training. You may always ask your supervisor for a copy. 

The Hazard Communication Standard mandates that your employer must comply with five regulatory requirements chemical inventory, safety data sheets, labeling, employee training, and a written program. 

Where records of employee exposure to toxic substances and harmful physical agents have been required, they are also examined for compliance with the recordkeeping requirements. The officer may also ask to look at required inspection and training records and written programs, as well as the PPE hazard assessment. 

The HCS requires that employers who use hazardous chemicals have a written program that explains how they will comply with the requirements of the standard. 

The written program must also contain a copy of the hazardous chemical inventory. 

J. J. KELLER S CONSTRUCTION TOOLBOX TALKS Hazard Communication — Written Program... 

Hazard Communication — What Is GHS Hazard Communication — GHS Overview Hazard Communication — Container Labels Hazard Communication — Container Labels Alternate Hazard Communication — Outer Container Labels Hazard Communication — GHS Pictograms Hazard Communication—Health Hazards Hazard Communication—Safety Data Sheets Hazard Communication — Safety Data Sheets Alternate Hazard Communication—Other Hazards Hazard Communication—Physical Hazards Hazard Communication— Written Program Occupational Health — Carcinogens Occupational Health — Diesel Exhaust Occupational Health — Silicosis Safety Health Program Management — Employee Exposure and Medical Records... 

A written program should include critical elements such as management leadership and employee involvement, worksite analysis, hazard prevention and control, and safety and health training. Sub-elements of a basic safety and health program should also be part of the written program. 

Organizations requiring contracted services in locations of their facility where hazardous materials are used or stored must inform those contracted employees of all hazards present. This must be part of the written program. This program should include methods and procedures the employer will use to provide all contractors with MSDSs, information on labeling and other forms of warning, and... 

The location and availability of the written program, including lists of hazardous chemicals and MSDSs... 

If an employer decides employees will not enter permit spaces, he posts an appropriate danger sign and prevents employees from entering the spaces. If he decides employees will enter permit spaces, he must develop and implement a written program. There is a major exception to this. If the employer can demonstrate the only hazard is atmospheric and is alleviated through continuous forced air ventilation, all procedures do not have to be followed. 

Sampling Strategy The written program must address sampling protocols and methods implemented to accurately assess employees exposure to health hazards. Sampling should be conducted when ... 

A fundamental principle of the chemical hazard communication (HAZCOM) program is that informed people are less likely to be injured by chemicals and chemical processes than uninformed people. According to the standard, all of the chemical inventories and processes within a chemical plant or refinery must be evaluated for potential hazards and risks. Where a risk is found, essential information and training are required for all people affected. A chemical HAZCOM program is composed of two essential parts the written program (which addresses chemical manufacturers) and employee training (Figure 3-3). 

Employers are responsible for the development of a written hazard communication program, a hazardous chemical inventory list, and associated material safety data sheets. This written program should be designed so that it is given to the new employee upon initial assignment. The materials should be site specific, readily accessible by plant personnel, and include an evergreen feature that will keep it up to date. Employers are also required to provide training to employees... 

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