The Hazard Communication Standard 29 CFR Part 1910.1200

North Colonie Central School District Updated: April2015

Prepared with the Assistance of: The Health-Safety-Risk Management Service

Capital Region BOCES School Support Services

Suite 102, 900 Watervliet-Shaker Road, Albany, NY 12205

Hazard Communication Program Introduction & District Contacts The intent of this program is to disclose to employees the potential exposure to toxic substances. There may be a potential danger to the health of employees throughout the school district if

'----- significant exposure to toxic substances is encountered during the course and scope of employment. The result of this exposure may be immediate (acute) or may not be realized for many years or generations (chronic). It is considered the duty of the Superintendent, or their designees, to give each employee notice of his/her exposure to toxic substances that pose known and suspected health hazards and may cause serious illness or physical harm to the employee.

Employees are frequently in the best position to be aware of the symptoms of toxicity, if they are first made aware of the nature of the toxic substances they are working with. Employees have an inherent right to know about the known and suspected health hazards that may result from working with toxic substances so they may make more knowledgeable and reasoned decisions with respect to any personal risks of their employment and the need for corrective action. Therefore, the intention of this Hazard Communication Program is to ensure that employees be given information concerning the nature of the toxic substances with which they work and full information concerning the known and suspected health hazards of such toxic substances.

• The Overseers and Contact Persons for Hazard Communication Questions and Information,

•

• Hazard Communication training is scheduled through: • Assistant Director of Facility/Health & Safety

• Training provided by: • Assistant Director of Facility/Health & Safety andjor • Health/Safety/Risk Management Service, Capital Region BOCES

• Training records are maintained collectively by: • Human Resources Department, Goodrich Building • Assistant Director of Facilities/Health & Safety, Maintenance Shop

of the

The written Hazard Communication Program, Chemical Inventories and Safety Data Sheets in the locations:

*Safety Data Sheets (SDS) also include Material Safety Data Sheets (MSDS).

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Statement of Intent

This Hazard Communication Program is written to inform the employees that the hazards of all chemicals andjor chemical products present, entering and used throughout the school district have been evaluated and that information concerning the hazards has been transmitted to employees who may be exposed to such chemicals. This program is written to fulfill the requirements of the Occupational Safety and Health Administration, CFR 1910.1200 and to fulfill the requirements of the New York State Official Compilations of Codes, Part 820 of Title 12, commonly known as, the Right To Know Law. A copy of this written program is maintained in each work site as required.

Objectives To accomplish the goals of this program, the following actions are necessary: 1. Complete a written Hazard Communication Program, represented by this document 2. Take an inventory of all harmful and toxic chemical products in the school district, noting

locations and departments of product storage and use. 3. Request and collect Safety Data Sheets for all chemical products used on-site. These Safety

Data Sheets must be made available to all employees. 4. Establish procedures and persons responsible for overseeing labeling procedures, which are

required to be implemented under the Hazard Communication Standard. 5. Offer a training program for employee awareness and information. 6. Post notice to employees regarding their rights under the law. 7. Notify local fire department, or other emergency response groups and the community

regarding hazardous materials located in the workplace. 8. Notify contractors who work in the school of disclosure requirements for products they may

bring into the building. 9. Keep Hazard Communication Records on file for a period of 40 years from the date of

occurrence, including attendance sheets from employee training sessions. 10. Train new employees prior to working with chemical products in their job.

Globally Harmonized System (GHS)

Globally Harmonized System Overview: On March 20, 2012 the United States Occupational Health and Safety Administration (OSHA) revised the Hazard Communication Standard (HCS) to formally adopt the Globally Harmonized System (GHS). Your "Right to Know" has become your "Right to Understand" with the Hazard Communication Standard's 2012 adoption of the Globally Harmonized System (GHS) of classification and labeling of chemicals.

According to Occupational Safety and Health Administration (OSHA), the new GHS system will benefit workers by reducing confusion about chemical hazards in the workplace, facilitating safety training and improving understanding of hazards.

The GHS system will require manufacturers to label and create "safety data sheets" (SDS), formerly called material safety data sheets (MSDS), that are meant to be easier to read and understand. This system is already in use in many countries, so the revision to the federal OSHA Hazard Communication Standard will align with the GHS system that is being used internationally.

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OSHA is requiring that employees be trained on the new label elements (e.g., pictograms and signal words) and SDS format before the end of 2013. During this transition period, both styles of data sheets (MSDS or SDS), and both styles oflabels and pictograms may be used.

Major Changes to the Hazard Communication Standard

• Hazard classification: Chemical manufacturers and importers are required to determine the hazards of the chemicals they produce or import. Hazard classification under the new, updated standard provides specific criteria to address health and physical hazards as well as classification of chemical mixtures.

• Labels: Chemical manufacturers and importers must provide a label that includes a signal word, pictogram, hazard statement, and precautionary statement for each hazard class and category.

• Safety Data Sheets: The new format requires 16 specific sections, ensuring consistency in presentation of important protection information.

• Information and training: To facilitate understanding of the new system, the new standard requires that workers be trained by December 1, 2013 on the new label elements and safety data sheet format, in addition to the current training requirements.

• Other Deadlines: By June 1, 2015, chemical manufacturers, importers, distributors, and employers must comply with all modified provisions of the final rule; December 1, 2015, is the deadline for distributors to ship containers labeled by the manufacturer's old system. By June 1, 2016, employers must update alternative workplace labeling and hazard communication programs as necessary, and provide additional worker training for the physical and health hazards.

Updated Definitions Ahazardous chemical is any chemical which is classified as a physical hazard or a health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise classified.

A health hazard is a chemical which is classified as posing one of the following hazardous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or aspiration hazard.

Aphysical hazard is a chemical that is classified as posing one of the following hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits flammable gas.

Apictogram is 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.

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Safety Data Sheets

~ This school district has obtained the necessary Safety Data Sheets related to chemicals and chemical products used throughout the school district. Access to Safety Data Sheets is available through online access using MSDSonline as well as your district's binder(s).

Using the Internet to Locate Safety Data Sheets: This service is free to school districts who participate in the Capital Region BOCES, Health/Safety/Risk Management Service. Just follow steps 1-7 below.

Powered By

.,+;,, MSDSonline" 1. Go to website http:/lwww.msdsonline.com. to complete the "Customer Login" box using our

username and password as follows: • Username = capitalregion • Password = safety

Customer Login

! Usemam, ~ Passwon

17 Remember Username Log I~ I

2. Click on the "Log In" button; 3. Click on the "MSDS Search" or "Safety Center" tabs located on the top left of the screen; 4. Search for MSDSs by typing in either the "Product'' name or "Manufacturer" name as shown

in the box below:

Product I Manufacturer i

5. Click on "Search" button; 6. Scroll down to find your MSDS/SDS; 7. Under the "View" column, click on the PDF to read and/or print out the SDS.

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http:http:/lwww.msdsonline.com

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Safety Data Sheet Section Headings

These safety data sheet sections are required to be listed in the following, specific order: ·..~ 1. Identification

2. Hazard( s) Identification 3. Composition/information on ingredients 4. First-aid measures 5. Fire-fighting measures 6. Accidental release measures 7. Handling and storage 8. Exposure controls/personal protection 9. Physical and chemical 10. Stability and reactivity 11. Toxicological information 12. Ecological information 13. Disposal considerations 14. Transport information 15. Regulatory information 16. Other information, including date of preparation or last revision

Sample Safety Data Sheet:

SAFETY DATA SHEET

1. PRODUCT IDENTIFICATION

Hydrog-1'>-xlc:le~.t.-~

J.ly~~ ~.-\ciu~ SdWQn~;r(I..

Each SDS is kept on file for as long as the material is used within the school district. When a product is no longer used in the school district, or a more recent edition replaces an SDS, the former SDS is removed from the binder and placed in an "Out of Date" file. The date when the use of the material is discontinued will be marked on the SDS.

Safety Data Sheet Request Procedure

All purchase orders sent to vendors by district personnel should contain wording similar in nature to the following statement:

Safety Data Sheets must be sent to the same person and address whose name appears on the purchase order under "Ship Materials To" for all chemicals and for chemical products containing toxic substances, as required by Federal Labor Law (29CFR 19100). An order will not be processed for payment until the required Safety Data Sheet has been received.

At minimum, the purchase order should be stamped: "Safety Data Sheet Required". Safety Data Sheets should be periodically updated by requesting a new copy from the manufacturer.

When SDS's are not received from the manufacturer or supplier the following steps shall be taken:

1. Send a letterI email to the supplier requesting a copy of the appropriate SDS. Keep a copy of this letter/email on file.

2. Send a follow-up second letter/email if the SDS is not received within 30 days of the request.

3. lfSDS's are not received within 10 days of the second request, a complaint will be filed with the New York State Department of Labor. A copy of the complaint will be sentto the supplier of the toxic substance.

GHS Label Information

Some GHS label elements have been standardized (identical with no variation) and are directly related to the hazard level. Other label elements are harmonized with common definitions and/or principles. The standardized label elements included in the GHS are:

• Symbols (hazard pictograms): Convey health, physical and environmental hazard

information, assigned to a GHS hazard class and category.

• Signal Words: "Danger" or "Warning" are used to emphasize hazards and indicate the

relative level of severity of the hazard, assigned to a GHS hazard class and category.

• Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard.

The symbols, signal words, and hazard statements have all been standardized and assigned to specific hazard categories and classes, as appropriate. Other GHS label elements include:

• Precautionary Statements and Pictograms: Measures to minimize or prevent adverse effects.

• Product Identifier (ingredient disclosure): Name or number used for a hazardous product on a label or in the SDS.

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• Supplier identification: The name, address and telephone number should be provided on the hlcl .

• Supplemental information: non-harmonized information.

Labels are meant to provide essential information about the hazards of using a chemical product The label is not intended to be either the sole or most complete source of information regarding the nature or identity of hazardous chemicals in the workplace. Although the SDS is the main source of information regarding the hazards of a material, the most visible form of warning are labels, warning signs and placards. As of June 1, 2015, all labels will be required to have pictograms, a signal word (i.e., Danger; Warning), hazard and precautionary statements, the product identifier, and supplier identification.

There are two types of container labels: • Labels on Shipped Containers: Shipped Container labels must contain the product

identifier, signal word, hazard statement(s), pictogram(s), precautionary statement(s), name, address, and telephone number of the chemical manufacturer, importer, or other responsible party.

• Workplace Labels: Workplace Labels must contain the Shipped Container Label or the product identifier and words, pictures, symbols, or combination of those, which provide general information regarding the hazards of the chemicals.

Sample Shipped Container Label: .&_ ToxiFlam (Contains: XYZ) Aw ~Danger! Toxic If Swallowed, Flammable Liquid and Vapor

D\01 col cal. drink or usc toba-c-~;-o wbco u;:in.; dlis prodoct. '\\'a.;h bamds dtorough]y after handling. Keep oolai11C'r ri.ghdy dosed. Kc:-tp a>.'·

Workplace labels ensure proper identification of all hazardous products, and therefore aid in protecting school employees who may come in contact with containers of hazardous chemicals. All instructional and non-instructional departments should be supplied with standard procedures and materials to properly implement this labeling system.

Hazard warning considerations for labels are:

1 Ph . lH dWSICa azar s: li_xplosives Flammable Gases Flammable Aerosols Oxidizing Gases Gases Under Pressure

Flammable Liquids

Flammable Solids Self-Reactive Substances

Pyrophoric Liquids Pyrophoric Solids Self-Heating Substances

Substances which, in contact with water, emit flammable gases

Oxidizing Liquids Oxidizing Solids Organic Peroxides Corrosive to Metals

2 Health Hazards· Acute Toxicity Skin

Corrosion/Irritation Serious Eye Damage/Eye Irritation

Respiratory or Skin Sensitization

Germ Cell Mutagenicity

Carcinogenicity Reproductive Toxicology

Target Organ Systemic Toxicity - Single Exposure

Target Organ Systemic Toxicity -Repeated Exposure

Aspiration Toxicity

3 Environmental Hazards· Hazardous to the Aquatic Environment

Acute aquatic toxicity

Chronic aquatic toxicity

Bioaccumulation potential

Rapid degradability

4. Simple Asphyxiant

5. Combustible Dust

6. Pyrophoric Gas

7. Hazard Not Otherwise Classified

The above information will be derived from the Safety Data Sheet provided by the manufacturer, supplier or importer. If the Safety Data Sheet provides insufficient information, other qualified sources can be contacted for this information, such as the manufacturer, fire department and your school district's BOCES Health/Safety/Risk Management Service.

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GHS PictogramjHazard Identification Chart

Health Hazard

~ • Carcinogen • r ...1utagenicity • Reproductive Toxiciry • Respirator"Y SensitizeI"'

• Tal"'getOrgan Toxicity • Aspiration Toxicity

H:CS Pictograms and Hazards

Flame

~ • Flammables • Pyi"'phorics • Self-Heating • Emits Flammable Gas

• Self Reactives . 0 rganic Pei"''xid-es

Exclamation !'lark

• Irritant (skin and eye) • Skin Sensitizer

• Acute T oxici"tV • r·rarcotic Effects • Respiratory Tract Irritant

'• Hazardous toOzone Layer (lion-Nandato"Y)

I

Gas Cylinder

0 • Gases Under Pressure

Corrosion

~. • Skin Cor-rosion/Burns • EyeDamage • Corrosive to Metals

Exploding Bomb

0 • Explosives • Seclf-Reactives • Organic Peroxides

Flame over Circle

~ • Ox.idizel"S

Environment (rlon-Nandatory)

~ • Aquatic Toxicity

Skull and Crossbones

Employee Rights

The General Duty Clause of the Federal Occupational Health & Safety Act (Public Law 91-596, Section 5(a)(1), states:

Each employer shall furnish each ofhis employees' employment in a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

The overall intent of "Right-to-Know" legislation is to provide employees with information about the known and suspected health hazards that may result from working with toxic substances. The employees have an inherent right to this information so they may make more knowledgeable and reasoned decisions with respect to any personal risks of their employment and the need for corrective action.

Employees have the right to: 1. Have access to information, including the HAZCOM written plan, inventory and SDS file. 2. Make photocopies of that information to keep on hand in their department. 3. Be informed of the hazardous products used in their jobs by reviewing the inventory. 4. Be informed of the potentially hazardous ingredients found in those products (see SDS). 5. Be informed of the hazards associated with overexposure to those ingredients (including

health hazards, fire hazards, etc.). 6. Be informed of the specific proper procedures for handling those products containing

potentially harmful ingredients. 7. Be provided with protective gear, ventilation and proper equipment when needed. 8. Refuse to work with a toxic substance if they have not been provided with any of the above

information upon request. In the event the employer does not possess an SDS for a specific substance for which a good faith effort has been made to secure an SDS, the employee and the employer must agree on safe handling procedures or replace the product with a safer alternative.

9. File a complaint, as a last resort, with the Department of Labor if the above conditions have not been met. The employee should first try to solve the problem with the school district before filing a complaint.

10. Be protected from discrimination as a result of their use of any of these rights under the HAZCOM Standard.

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Poster

Each school building in the school district will post a sign in the workplace. The sign will alert all employees of their rights under the law, and will inform them of the name and location of the Compliance Officer for the school.

U HAVE A RIGHT TO KNO I..

Your employer must inform you of the health effects and hazards of toxic substances at your worksite.

Learn all

you can

about toxic

substances

on your job.

For more

Information.

contact:

THE RIGHT TO KNOW LAW WORKS FOR YOU. NEW YORK STATE DEPARTMENT OF HEALTH

Note: Although a poster is not specifically mentioned in the OSHA Hazard Communication Standard, the Federal Occupational Safety & Health Act of 1970 (29 CFR 1903.2) requires that each employer post a notice furnished by the Department of Labor informing employees of the protections and obligations provided for under the Act.

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Product I: Manufacturer i: undefined: ECf: ICSCr: undefined_2: My Product Warning Causes Skin and Eye irritation Suspected of causing cancer by inhalation Contains XYZ: Gases Under Pressure: Flammable Liquids: Flammable Solids: Self Reactive Substances: Pyrophoric Liquids: Pyrophoric Solids: SelfHeating Substances: Corrosive to Metals: Acute Toxicity: Skin CorrosionIrritation: Gerni Cell Mutagenicity: Carcinogenicity: Reproductive Toxicology: Aspiration Toxicity: