Trinity Operating Procedures - TOPs

TOP-HAZCM: Hazardous Communication Program

Rev: 12/06/2017

Scope: This procedure covers the Trinity Forge Written Hazardous Communication Program which was prepared for use by the Trinity Forge organization to explain how this organization meets the requirements of the federal Occupational Safety and Health Administration's (OSHA) hazard communication standard (29 CFR 1910, 1200). It spells out how this company will inventory chemicals in use, obtain and use safety data sheets, maintain labels on chemical substances, and train employees and contract workers about the hazard of chemicals they are likely to encounter on the job. A "hazardous chemical" under OSHA's requirements is essentially any chemical that poses physical or health hazards. Employees, their designated representatives, and government officials must be provided copies of this program upon request. In addition to the program, other information required as part of our hazardous communication efforts is available to workers upon request. Asking to see this information is an employee's right. No one will be penalized in any way for asking to review it. Using this information is a part of our shared commitment to a safe, healthy workplace.

Procedure:

GENERAL RESPONSIBILITY

The purpose of this Written Hazardous communication Program is to explain how Trinity Forge meets the requirements of federal, state, and local rules on informing employees about the possible hazards of chemicals in the workplace. In this organization, the HR Manager is designated the "Environmental Coordinator" with overall responsibility for the program. This person is able to answer questions and provide additional information if needed.

NON-ROUTINE TASKS

Any time an employee or subcontractor is working in an unfamiliar area it is the responsibility of the manager, supervisor or leadman of that area to inform them of the hazards of chemicals they are likely to encounter on the job and what to do if they do encounter them. This is also applicable to any other potential safety or dangerous situations.

HAZARDOUS CHEMICALS

No new hazardous chemical substances may be purchased or brought into this facility unless the Environmental Coordinator is informed in advance.

SAFETY DATA SHEETS (SDS)

As part of this organization's compliance with the hazard communication standard, the Environmental Coordinator maintains a library of Safety Data Sheets (SDS) for chemicals used in this facility. The SDS consists of a fully completed OSHA Form 174 or equivalent. The SDSs are kept in the foreman's office and online in a database, They are readily available to all employees during all work shifts.

NEW SDSs

Supervisors must forward each new SDS that is received to the Environmental Coordinator. After evaluating the SDS, the Environmental Coordinator will assure new chemicals are added to the Master Chemical List. The original SDS will be stored in the Environmental Coordinator's files and a copy of it will be filed with other SDSs in the Foreman's office. The new SDS will also be scanned and the new SDS must be received prior to purchase of any potentially hazardous chemical from a supplier. It is the policy of Trinity Forge to stop purchasing hazardous chemical products from any supplier that does not provide an appropriate MSDS in a timely fashion.

ACQUIRING SDSs

Anyone purchasing products with hazardous ingredients is responsible for obtaining SDSs from suppliers and forwarding them to the Environmental Coordinator for evaluation immediately. An SDS must be on file for all products purchased with hazardous ingredients. This can be done by simply specifying on all orders for hazardous products to vendors, "PLEASE SEND MSDS". The Environmental Coordinator will contact suppliers for missing SDSs. The Environmental Coordinator will check SDS files for accuracy and maintain a master list of SDSs. All new chemical purchases must be cleared through the Environmental Coordinator. The least hazardous substance will be purchased whenever possible.

CONTROL OF SDSs

The original version of each new SDS must be forwarded immediately to the Environmental Coordinator The Environmental Coordinator will, on an annual basis, review SDSs for any that are more than three years old. Anyone who feels an SDS has been handled improperly should report his/her concerns to the VP-Manufacturing for resolution.

LABELS, LABELING AND WARNING

The Environmental Coordinator will ensure that all hazardous chemicals used in the facility are properly labeled. This person also will verify that the identifying information and other data on the label correspond with the information on the SDS for that hazardous chemical. Damaged labels or labels lacking needed information should be reported to the Environmental Coordinator immediately. This person will also approve all labels prepared for in-house use before they are used and check on a regular basis that all containers are labeled and up to date.

Labels on incoming containers of hazardous chemicals may not be removed or defaced unless a new label or markings with the required warnings are immediately attached to the container. However, containers into which an employee transfers a hazardous chemical for his or her own immediate use do not require labeling.

Labels, tags or markings on containers will list at least:

1. The identity of the hazardous chemical(s) as listed on the SDS.
2. Appropriate hazard warnings to help employees protect themselves from the hazards of the substance.
3. Labels provided by chemical manufacturers, distributors and importers must also list the name and address of the manufacturer, importer or other person responsible for the chemical and from whom more information about the chemical can be obtained.
4. Missing labels, tags, and markings must be reported to the Environmental Coordinator so the containers can be re-labeled with as much of the information from items 1 through 3 as possible. If necessary, as determined by the Environmental Coordinator, the container may have to be disposed of per TOP-WASTE.

TRAINING

Every employee who works with or may be exposed to hazardous chemicals will be trained on safe use of those substances and about the hazard communication standard. The initial training will be completed as soon as possible. All training will be completed under the direction of the Environmental Coordinator. Additional training will be provided whenever a new hazard is introduced into the work area. Line supervisors will conduct supplementary training on a daily basis as a way of reinforcing the importance of handling hazardous chemicals properly. In most cases, the immediate supervisor will take part in formal training using materials provided by the Environmental Coordinator. This person also will monitor and maintain records of employee training and will advise upper management of additional training needs. Details of training are available in the Trinity Forge Training Modules.

ASBESTOS MANAGEMENT PLAN

Some of the Trinity Forge's buildings were constructed while asbestos was still commonly used in building materials. Although the government reports no concern with asbestos as such, if disturbed asbestos can present a cancer risk. We thus have a written Asbestos Management Plan that has been approved as an extension to the Trinity Operating Procedures and is subject to the audit and compliance as TOPs. The Asbestos Program Manager (John Fairbanks, ext 6637) is responsible for ensuring full compliance with the Asbestos Management Plan. No work may be done to disturb any materials even suspected of containing asbestos without the approval of the Asbestos Program Manager or other trained person he may designate to act in his behalf. Of particular concern would be any maintenance work involving floors, ceilings, walls, or insulation. Even drilling a hole through drywall must be approved by the Asbestos Program Manager.

Revision history: