Procedure 21 – Hazardous Materials Communication (HazCom)

1.0 PURPOSE
The purpose of the Nitro Construction Services Hazardous Material Communication Program is to establish methods for the organization and communication of information on hazardous and potentially hazardous materials workers could be exposed to in the workplace. The requirements of this procedure are intended to be consistent with the provisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS).

2.0 RESPONSIBILITIES
The site manager/superintendent shall have responsibility for the jobsite implementation of the program.

3.0 REFERENCES
29 CFR 1910.1200

4.0 DEFINITIONS
4.1 Classification – to identify the relevant data regarding the hazards of a chemical; review those data to ascertain the hazards associated with the chemical, and decide whether the chemical will be classified as hazardous according to the definition of a hazardous chemical in this section. In addition, classification for health and physical hazards includes the determination of the degree of hazard, where appropriate, by comparing the data with the criteria for health and physical hazards.
4.2 Common name – any designation or identification such as code name, code number, trade name, brand name or generic name used to identify a chemical other than by its chemical name
4.3 Employee – a worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. Workers such as office workers or bank tellers who encounter hazardous chemicals only in non-routine, isolated instances are not covered.
4.4 Employer – a person engaged in a business where chemicals are either used, distributed, or are produced for use or distribution, including a contractor or subcontractor.
4.5 Hazard category – the division of criteria within each hazard class, e.g., oral acute toxicity and flammable liquids include four hazard categories. These categories compare hazard severity within a hazard class and should not be taken as a comparison of hazard categories more generally.
4.6 Hazardous Chemical – Any chemical that presents physical or health hazards, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.
4.7 Hazard class – the nature of the physical or health hazards, e.g., flammable solid, carcinogen, oral acute toxicity. For each chemical, the chemical manufacturer or importer shall determine the hazard classes, and, where appropriate, the category of each class that applies to the chemical being classified.
4.8 Hazard statement – a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard.
4.9 Label – an appropriate group of written, printed, or graphic information elements concerning a hazardous chemical that is affixed to, printed on, or attached to the immediate container of a hazardous chemical, or to the outside packaging.
4.9 Pictogram – a composition that may include a symbol plus other graphic elements, such as a border, background pattern, or color, that is intended to convey specific information about the hazards of a chemical. Eight pictograms are designated under this standard for application to a hazard category.
4.10 Safety Data Sheet (SDS) – Written or printed material concerning a hazardous chemical which is prepared by manufacturers in accordance with paragraph (g) of the OSHA Hazardous Communication Standard.
4.11 Signal word – a word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used in this section are “danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is used for the less severe.
4.12 Use – to package, handle, react, emit, extract, generate as a byproduct, or transfer.

5.0 PROGRAM REQUIREMENTS
5.1 Labels and Other Forms of Warning
5.2.1 Nitro Construction Services shall ensure that all incoming containers of hazardous chemicals in the work area are properly labeled. If the labels do not have the following information, the manufacturer or distributor must be contacted:
5.2.1.1 Product Identifier.
5.2.1.2 Signal Word.
5.2.1.3 Hazard Statement(s).
5.2.1.4 Pictogram(s).
5.2.1.5 Precautionary statement(s); and
5.2.1.6 Name, address, and telephone number of the chemical manufacturer, importer, or other responsible parties.
5.2.2 Chemicals transferred from a labeled container to portable containers that is intended for immediate use by the employee making the transfer do not require separate labels. If the container is to be used by any persons other than the person who has made the transfer, labeling is required.
5.2.3 Existing labels shall not be removed or defaced from incoming containers of hazardous chemicals.
5.2.4 Labels or other forms of warning shall be legible, in English, and prominently displayed on the container, or readily available in the work area.

5.3 Safety Data Sheets
5.3.1 Chemical manufacturers and importers shall obtain or develop a safety data sheet for each hazardous chemical they produce or import and ensure that distributors and employers are provided an appropriate safety data sheet with their initial shipment, and with the first shipment after a safety data sheet is updated.
5.3.2 Nitro Construction Services, Inc shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s).
5.3.3 Where employees must travel between workplaces during a work shift, the safety data sheets may be kept at the primary workplace facility

5.4 Employee Information and Training
Nitro Construction Services, Inc shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.
5.3.1 All new employees will receive initial training on the Hazard Communication Standard, as part of their general safety orientation, and the safe use of those chemicals.
5.3.2 This training shall include but will not be limited to the following:
5.3.2.1 The specific requirements of the program.
5.3.2.2 Any operations in their work area where hazardous chemicals are present.
5.3.2.3 The location and availability of the written Hazard Communication Program, including the required list(s) of hazardous chemicals, and material safety data sheets required by this section.
5.3.2.4 Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);
5.3.2.5 The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.
5.3.2.6 The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; and,
5.3.2.7 The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information.
5.3.3 Whenever a new hazardous chemical is introduced, additional training will be provided. Initial information should be reviewed on a regular basis. Supervisors and foremen should have additional training to monitor the job area and answer employee questions more effectively.

5.4 Non-Routine Tasks
When personnel is required to perform hazardous non-routine tasks (cleaning tanks, entering confined spaces, etc.), a special training session will be conducted to inform them regarding the hazardous materials to which they might be exposed and the proper precautions to take to reduce or avoid exposure.

5.5 Multi-Employer Sites
The on-site Project Superintendent or on-site Safety Rep will provide sub-contractors or other contractors working in the same general area with access to all the Safety Data Sheets (SDS) for each hazardous chemical they may be exposed to while working and provide data concerning the labeling system utilized. The protective measures required during normal working or emergency conditions will be reviewed. The employer shall make this written Hazard Communication Program available to all employees.

6.0 PROGRAM COMMUNICATION FOR NON-ENGLISH-SPEAKING EMPLOYEES
6.1 While OSHA requires that a written Hazard Communication Program, all MSDS’s, and container labels be written in English, Nitro Construction Services will communicate the Hazard Communication Program in the language of non-English speakers.

7.0 LIST OF HAZARDOUS CHEMICALS AND SDS FILE
7.1 The Site Manager / Superintendent shall maintain a hazardous chemicals list.
7.2 The hazardous chemicals list shall include all hazardous and potentially hazardous chemicals to which personnel could be exposed.
7.3 The hazardous chemicals list should be reviewed regularly (i.e., annually).

8.0 “RIGHT TO KNOW” OVERVIEW

The OSHA Hazard Communication Regulations 29 CFR 1910.1200 require that all employers provide their employees and contractors with information on the Hazard Communication Regulation, the company’s program, and the rights of employees under the law.

The purpose of this overview is to provide that information to you and to advise you of where you may obtain additional information.

1. The primary requirement, under the law, is the implementation of a plan to protect employees from the dangers associated with the presence and use of hazardous materials found in the workplace. Copies of this plan, “Hazard Materials Communication Program”, are available from your superintendent or may be obtained by calling the Safety Department and requesting a copy.

2. Per the requirements of the plan, a list of all hazardous materials at this site has been compiled by your superintendent. This list will be updated periodically, as required per the terms of the plan.

3. The regulation requires that a “Safety Data Sheet” be maintained on file for each hazardous material which might be found in the workplace and that each employee is trained in the proper use of that material if his duties will bring him into contact with same.

Each employee will be trained in the proper use and handling of the materials with which they are likely to come into contact. If you would like copies of the Safety Data Sheet or if you have not had training, it is your responsibility to notify your immediate supervisor of this fact and to receive the required information and training prior to using the material.

4. It is your right under the law:

A. To receive all information regarding hazardous material to which you may be exposed.

B. For your physician to receive information regarding hazardous material to which you may be exposed.

C. To be protected against discharge or other discrimination due to your exercise of rights under the regulation.

It is the policy of the management of Nitro Construction Services to provide you with any/ all information and training that may require you to perform your duties without jeopardizing your health.

Thank you for your assistance and cooperation in the implementation of this program.