Hazard Communication Program
Purpose and Objective
Cherokee Brick is committed to providing a safe and healthy workplace for its employees. The objective of this program is to ensure that all hazardous materials in the workplace are evaluated prior to use and that protective mitigations are in place. This program is also to ensure that the information about these materials is effectively communicated to employees.
This program applies to all company operations.
Definitions
Chemical: Any substance or mixture of substances.
Chemical Manufacturer: An employer with a workplace in which chemical(s) are produced for use or distribution.
Chemical Name: The scientific designation of a chemical in accordance with the nomenclature system developed by the International Union of Pure and Applied Chemistry or a name that will clearly identify the chemical for the purpose of conducting a hazard classification.
Container: Any bag, barrel, bottle, box can, cylinder, drum, or other object which was created to contain a hazardous chemical.
Distributor: A business other than a chemical manufacturer or importer which supplies hazardous chemicals to employers.
Exposure: An employee who is subjected in the course of employment to a chemical which is a physical or health hazard.
Hazard Category: The division of criteria within each hazard class which compares hazard severity within a class.
Hazard Class: The nature of the physical or health hazards, e.g., flammable, carcinogen, or acute toxicity.
Hazard Statement: A statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical.
Hazardous Chemical: Any chemical which is classified as a physical or health hazard, such as a simple asphyxiant, combustible dust, pyrophoric gas, or a hazard not otherwise classified.
Health Hazard: 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 irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific tarter organ toxicity (single or repeated exposure); or aspiration hazard.
Immediate Use: The hazardous chemical will be under the control of and used by only the person who transfers it from a labeled container and only within the work shift in which it is transferred.
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.
Non-Routine Tasks: Tasks which do not occur on a frequent basis or are not identified as a normal employee task.
Pictogram: A composition that may include a symbol plus other graphic elements as required by the Globally Harmonized System (GHS).
Precautionary Statement: A phrase that describes the recommended procedure that should be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical or improper storage or handling.
Product Identifier: The name or number used for a hazardous chemical on a label or in the SDS.
Safety Data Sheet (SDS): Written or printed material concerning a hazardous chemical that is prepared in accordance with OSHA requirements.
Responsibilities
Management
Management is responsible for implementing, supporting, and enforcing this program.
Supervisors are responsible for leading program implementation and ensuring the hazard communication practices in this program are utilized. In addition, supervisors are responsible for:
- Maintaining safety data sheets (SDSs) including any new chemicals needed onsite
- Notifying contractors of the hazardous chemicals used in their work area and making SDSs available to them
- Ensuring contractors provide information on hazardous substances used
Employees
Employees are responsible for following the rules of this program and taking the required precautions when working with hazardous materials.
Contractors and vendors are responsible for:
- Providing SDSs prior to bringing substances onsite
- Informing the contract manager of any hazardous chemicals used during work onsite
Hazard Chemical Identification
In order to correctly identify hazardous chemicals which are in use onsite, all chemicals will be reviewed prior to purchase or use onsite. This will include a review of the Safety Data Sheet (SDS) provided by the manufacturer. During the review, potential hazards will be identified and mitigations implemented to ensure employees are protected. Any chemical that is accepted onsite will also have the corresponding SDS cataloged to allow access to chemical information for employees.
It is necessary to maintain an inventory of those chemicals and the information that pertains to them. This information will be readily accessible by all employees. The information will include the SDS provided by the manufacturer which provides detailed information about the physical, health, and other hazards of each chemical. These will be stored by product identifier or more simply by the product name to ensure ease of access to the information.
Labeling Hazardous Chemicals
The labeling system will follow the requirements of OSHA as well as the United Nations Globally Harmonized System (GHS) to comply with updated standards.
All hazardous chemical containers allowed onsite must include the manufacturer’s original label with the following:
- A product identifier
- Signal word
- Hazard statement
- Pictogram
- Precautionary statement
- The name, address, and phone number of the manufacturer or other responsible party
If containers arrive onsite that are not properly labeled or identified, that substance will not be released for use. Labeling information will be available to employees in English. Considerations will be made for other languages if such employees are present in the workforce.
When substances are transferred from their original manufacturer-provided containers to small quantity containers, there are several requirements. First, the container, known as a small quantity container, should only be for immediate use meaning that the product is used during a typical shift by one individual and disposed of thereafter. Second, the small quantity container must be labeled with the contents such as stating the product name or identifier. The following procedures should be used for small quantity labeling:
- Printing labels from the chemical manufacturer’s website or other means of labeling.
- A description of the procedures for labeling of secondary containers.
- A description of the procedures for reviewing and updating label warnings and how often that task must be conducted.
- The name, title, or department of who will be responsible for updating labels.
Safety Data Sheet (SDS) Inventory
In order to keep an accurate inventory of the chemicals in use onsite, all SDSs must be collected and cataloged. These SDS sheets will be made easily available to all employees during their normal work shifts.
Cherokee Brick uses MSDSonline for SDS Inventory. Our SDS computers are in the:
- Greenroom
- Mixing Plant breakroom
- Plant 3 breakroom
- Annex
- Mine
Directions on how to look up safety data sheets (SDS) are located at each computer.
Specialized/Non-Routine Tasks
Personnel may occasionally be required to perform non-routine tasks requiring the use of hazardous chemicals. Prior to any employee conducting specialized or non-routine tasks that involve new or increased chemical hazards, they will be informed about the hazards and instructed on mitigating any potential exposures.
Site Visitors or Contractors
The company will notify site visitors who have the potential to be exposed to hazardous chemicals about the hazards and the mitigations to protect themselves. This notification should include the identity of the chemicals, how to access SDSs, and an explanation of the chemical labeling system. That should also include any applicable safety work practices such as procedures and PPE required to protect from chemical exposures. When employees of a contracted company could potentially be exposed to chemicals used or stored onsite, the contractor will be granted access to:
- Copies of relevant SDSs
- Information on precautionary measures needed to protect employees
- An explanation of the chemical labeling system used on site
Contractors working on site are required to bring copies of SDSs for all hazardous material they will be bringing onsite for the duration of their work scope. These will be approved using the same methods as those brought onsite for employees. Each subcontractor should also provide SDSs for the jobs which they will conduct onsite for approval prior to work.
Emergency Response
The company will develop emergency procedures specific to operations. All affected employees must be aware of these procedures. The program will include:
- Evacuation protocol for fires, chemical spill, and other foreseeable situations
- First aid
- Safe shut down of equipment during evacuations
- Locations of emergency equipment
Any employees who discover or who are involved with hazardous chemical emergencies are responsible for taking appropriate action to protect themselves and others. Notifications of the appropriate authorities or emergency contacts must be made as soon as possible after the employee is safe.
Training Employees on the Hazards of Chemicals
Training will be provided for all employees who may potentially be exposed to hazardous chemicals during their job duties. This training will be conducted initially at the beginning of employment and periodically thereafter when new hazardous chemicals are introduced. This training will include:
- The basics of the OSHA Hazard Communication Standard
- Specific hazardous chemicals that are present in the workplace
- Physical and health hazards of those chemicals
- Any areas where hazardous chemicals are anticipated to be used
- The correct way to access the written Hazard Communication Program
- Instruction on the information in the SDS sheets and assistance in aiding employee understanding of information
- What are pictograms?
- What are signal words and how are they used?
- What are hazard statements?
- What are precautionary statements?
- Sampling methods or other methods of protection that may be used for these chemicals
- Steps or mitigations to reduce chemical exposures
- Instructions on how employees can protect themselves
- Emergency procedures following a chemical exposure
Recordkeeping
The SDS archive will be retained for the use of the product.
