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CITY OF EL CENTRO HAZARD COMMUNICATION PROGRAM

I. PURPOSE To establish a procedure for the effective communication of hazards within the workplace in accordance with standards set forth by Cal/OSHA and Fed/OSHA. II. SCOPE The City of El Centro (City) hereby adopts this Hazard Communication (HAZCOM) Program to enhance employee health and safety. The HAZCOM Program is designed to ensure that employees in all job classifications, students, volunteers and contract personnel are made aware of, and specifically trained in, the hazards associated with any chemical or substance they may be exposed to while working on City leased or owned facilities, property, City equipment, structure or right-of-way. This program is applicable to all employees who handle, label, store, use, or have the potential to come in contact with chemical products or hazardous substances. The City intends to provide information about chemical hazards and other hazardous substances, and the control of hazards via this comprehensive HAZCOM Program, which includes container labeling, Material Safety Data Sheets (MSDS) and training. III. RESPONSIBILITY The Risk Manager is the responsible person for coordinating the program. Supervisors are responsible for HAZCOM program compliance in workplaces under their supervision and ensuring that the training requirements of this program are met. Each affected employee is responsible for reading, understanding, and complying with this program. Any questioned responsibilities will be addressed by the Program Coordinator. Any employee requiring or requesting a product that has not yet been previously used must have that product approved by his/her supervisor. IV. DEFINITIONS The terms chemical, substance and product are used interchangeably.

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V. PROGRAM The City’s HAZCOM Program consists of the following components: 1. 2. 3. 4. 5. 1.

Hazardous substance/product inventory Material Safety Data Sheets Labeling Employee training Contractor notification HAZARDOUS SUBSTANCE INVENTORY

Each Division shall list on the “Inventory List” (Exhibit “A”) the following information: HAZARDOUS SUBSTANCE, the PRODUCT IDENTIFICATION NUMBER (if available), and whether an MSDS is present.

EXAMPLE: INVENTORY LIST HAZARDOUS SUBSTANCE

PRODUCT ID #

WD 40 Berryman Brake Cleaner Ammonia Acetone

MSDS Y/N Y Y Y Y

Supervisors are responsible to make certain that all known hazardous substances present in the work area are listed. Specific information on each noted hazardous substance can be obtained by reviewing the Material Safety Data Sheets. Evaluation of Hazardous Chemicals/Substance OSHA’s Hazard Communication Standard requires that the employer identify substances present in the workplace that are hazardous and provide material safety data sheets for those substances. According to Cal/OSHA a hazardous substance is any substance that presents a physical or health hazard. A substance presents a physical hazard if it is flammable, combustible, compressed gas, explosive, an organic peroxide, or oxidizer, is unstable or reactive, or water reactive. A substance is a health hazard if at least one study of the substance shows that when persons are exposed to it, acute or chronic health effects may occur.

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Substances that cause cancer or damage to various body organs (such as the liver or the lungs) or systems (such as the nervous or reproductive systems), or are corrosive, or cause sensitization, are considered hazardous. Substances that cause a mild skin irritation (contact dermatitis) are considered hazardous as well. Cal/OSHA’s definition of a hazardous substance is very broad, so the determination of hazardous substances should not be limited to those substances that have “skull and crossbones” markings. The evaluation may include common items such as diesel fuel, lubricating oil, copy machine toner, window cleaner, drain cleaner, solder, mineral spirits, solvents, gasoline, and paint. Other identified substances may usually include those that are emitted into the air, such as welding fumes or carbon monoxide from vehicles. The most practical way of determining if a material is hazardous is to ask the following questions. If the answer to any of the questions is yes, the chemical or substance should be treated as hazardous.       

Does the product label have the words “Caution,” “Warning,” or “Danger”? Is the material labeled as a flammable, combustible, or ignitable? Will the material burn your eyes or skin? Does the label warn against breathing the fumes directly? Will ingestion of the material cause problems? When mixed with another material, could a reaction occur that might be problematic? Does the manufacturer or distributor have a material safety data sheet on the material?

The inventory of hazardous substances may be compiled for the entire Divison or for individual work areas. The inventory should list the substance name, Product ID Number and whether and MSDS is present. This Inventory List is part of the HAZCOM Program and must be available to the employees at all times. 2. MATERIAL SAFETY DATA SHEETS A MSDS must be maintained for each of the hazardous substances or chemicals listed on the Inventory List. A MSDS can be ordered from the manufacturer or distributor or the Risk Manager will provide assistance. The MSDS must be readily accessible to employees. The manufacturer or distributor of the substance, chemical or product should provide the MSDS, which provides critical information about the hazards of the substance or chemical and proper procedures to be followed in case of an emergency. Under the OSHA Hazard Communication Standard, a MSDS must contain at least the following information, in English, about the substance or chemical:   

Trade name (product identity, same as used on the label) The chemical and common name Physical and chemical characteristics of the hazardous substance (such as vapor pressure, flash points, and solubility, etc.)

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The physical hazards of the chemical or substance (such as the potential for fire, explosion, or reactivity) The acute (short tem) and chronic (long term) health hazards of the chemical or substance, including symptoms of exposure The primary routes of entry (into the body) The OSHA exposure limit (permissible Exposure Limit or PEL), the American Conference of Government Industrial Hygienists Threshold Limit Value (TLV), and/or any other exposure limits Information on whether the chemical or substance is listed in the National Toxicology Program Annual Report on Carcinogens or has been found to be a potential carcinogen in the International Agency for Research on Cancer (IARC) Monographs or by OSHA Precautions for safe handling use and storage, such as spill clean-up procedures and applicable hygienic practices Any applicable measures that can be used to control exposure – this would include personal protective equipment or engineering or work practice controls Emergency and spill clean-up procedures First aid procedures The date the MSDS was prepared The name, address, and telephone number of the substance or chemical manufacturer, importer, employer, other responsible party preparing or distributing the MSDS

There may be additional information on the sheets that the substance manufacturer or originator of the data sheet has chosen to include. Check the Material Safety Data Sheet The MSDS should be checked to see that it contains all the required information. The following is a quick checklist that can be used to review a MSDS.

MSDS CHECKLIST   

Are there any blanks on the data sheet?” If a given category does not apply, it should be marked to indicate this some way: “No Relevant Information” or “N/A.” Is there a revision date listed to determine check if the MSDS on file has been updated? Is there health hazard information on the MSDS? This will be the most valuable information for an employee working with or around the substance or chemical. Make sure that the information discusses symptoms of exposure, routes of entry, and emergency first aid procedures.

If a new product is received without an MSDS, DO NOT USE THE PRODUCT. It is the responsibility of the Supervisor to request a MSDS for the particular product using the MSDS Request Form (Exhibit “B”). Without a MSDS, health hazards or the need for personal protective equipment cannot be determined. If, after reasonable amount of time, a response to the request is not received, a second letter requesting either a MSDS or disclaimer that the material is not hazardous must be sent/faxed. 4

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NOTE: Copies of the request form should be made and placed in the workplace MSDS file. These copies will document that an attempt was made to determine the hazards of the product. If after the second request, no response is received, return the product and seek a replacement vendor. In cases where Divisions receive repetitive shipments of the same product from the supplies, the MSDS may already be on file. Check the revision date and the date of the MSDS, if they are the same, discard the copy. If more recent, replace the existing MSDS and send a copy to the Program Coordinator. This is to identify those situations where a “new” hazard associated with an existing product has been identified, or a new ingredient has been included in a currently used product. If an MSDS is incomplete or inaccurate, contact the manufacturer and request a corrected copy of the data sheet. DO NOT MAKE ANY CHANGES OR ADD MISSING INFORMATION TO THE MSDS. Anyone revising a MSDS assumes the responsibility for the accuracy of the data. Keep records of any requests made to manufacturers for corrected data sheets. Manufacturers are required to update the MSDS within three months of learning that new hazard data is available which affects the MSDS information. MSDSs must be readily available in the work are to review during each work shift. A work area is defined as a room or a specific workplace. MSDSs that are kept in a Supervisors office, which is sometimes locked, are not considered readily accessible. The supervisor must review incoming data sheets for new and significant health/safety information. The supervisor must inform employees of any new information by tailgate sessions, safety meetings or formal instruction. It is the supervisor’s responsibility to make certain that all substances and chemicals are listed on the Inventory List and that each chemical, substance or product listed has an up-to-date MSDS and in the MSDS file in that work place. MSDS Reference Explanation See Exhibit “C.” “RIGHT-TO-KNOW” Poster A “Right-to-Know” poster must be displayed at each location where products are considered to be hazardous by Cal/OSHA are used. The following appropriate places for posters to be displayed:   

Bulletin boards in main operations and employee break areas Shop bulletin boards Maintenance areas

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3. LABELING Hazardous chemicals and substances in the workplace are required by Cal/OSHA to be labeled, tagged, or marked to warn employees about their potential danger. The purpose of the labels and other forms of marking on the container of hazardous substances are to provide the employee with an immediate warning of the potential hazard. The label also serves as a reminder that a MSDS is available for the substance. No hazardous substance should be used until:   

Containers are clearly labeled as to the contents Appropriate hazard warnings are noted The name and address of the manufacturer are listed

What Should Hazard Communication Labels Look Like? There is no standard for marking and labeling. Any label that clearly conveys the required information, in English, is acceptable to Cal/OSHA. Generally, containers of hazardous substances are shipped with acceptable labels or markings. It is not necessary to relabel containers of hazardous chemicals if the existing labels contain the required information. Cal/OSHA permits alternate methods of notifying employees of hazardous chemicals, other than a label, as long as the required information is provided. In these instances, signs, placards, process sheets, or batch tickets may be used. For example, in a vehicle repair area, it is acceptable to post signs warning regarding the presence and hazards of carbon monoxide. Labeling Situations There are situations that may require that a container be relabeled. 

If substances are transferred from their original containers to other containers, labeling of the new container will be necessary in most instances. This situation frequently occurs in many facilities when supplies are ordered in bulk and then distributed in smaller containers throughout the facility. Most of the time, these smaller, more portable containers will need a label.

EXCEPTION: A portable container (spray bottle) that does not have to be labeled is when the transferred substance will be used only by the employee who transferred it and only during his or her work shift. In this situation, the employee doing the transferring would have access to the warning and label information on the original container, so the portable container would not need a label. If, however, some of the substance will be left for used the next day or will be used by other employees either on the day of the transfer or during future work shifts, then the container will need a label.

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Labeling may also be necessary if the substances were purchased long ago, before there was a labeling requirement. The manufacturer of the substance should be contacted for the necessary labeling information. If the label has fallen off, is corroded, or is otherwise torn or damaged, it should be replaced. Storage tanks, process vessels, and similar containers, which are filled on-site, are required to be labeled in some manner. Signs or placards may be suitable label alternatives. A hazardous substance that is emitted into the air from some work procedure or process is required to have a label or other suitable marking. This would be the case in a welding area, around loading docks, or in an area where materials are being cut. If a hazardous substance is shipped to your facility without a label, the best option is to refuse the shipment; otherwise a label must be prepared.

Labeling is the responsibility of the supervisors. All secondary containers must be labeled. Exceptions may be approved by supervisors. The supervisor in each area must ensure that all secondary containers are labeled with either an extra copy of the original manufacturer’s label or with generic labels which have a block for the identity of the substance. Secondary containers are to be used only by person transferring the product and for that day’s use. Excess product must be returned to the original container at the end of the work shift or the container must be properly labeled with the contents and the appropriate hazard warnings. Personnel trained and certified to ship hazardous materials and wastes are responsible for labeling containers that are prepared for shipment. What Should Be On the Label? Cal/OSHA requires that the manufacturer of the substance include three pieces of information on the label or marking of each hazardous chemical:   

The identity of the hazardous substance The appropriate hazard warning; and The name and address of the manufacturer

The identity of the substance can be either the chemical or common name of the substance, so long as the name on the label corresponds with the name on the MSDS and on the Inventory List. The hazard warning could be words, pictures or symbols indicating the hazards of the substance. 4. TRAINING Providing employees with information and training is an essential aspect of the Hazard Communication Program.

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What is Required? The HAZCOM Standard requires employers to provide employees with both information and training on the hazardous substances in the workplace. Hazard communication information and training must be provided when an employee is initially assigned to a job and whenever a new hazard is introduced in the work area. The intent of this requirement is to ensure that employees have information regarding a hazardous substance prior to exposure to the substance. The following information must be provided to employees:    

The requirements of the HAZCOM Standard (including employee rights under the Standard) Information regarding workplace areas where hazardous substances are present; The location of MSDS, the list of hazardous substances and chemicals in the workplace And The location of the City’s HAZCOM Program

Hazard Communication training must also cover certain specific issues, including:   

How can the employee detect the presence or release of a hazardous substance in the employee’s work area? What are the physical and health hazards of the materials in the work area and what measures can be taken to protect the employees from the hazards (such as work practices, personal protective equipment, and emergency procedures)? The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the MSDS and how labels and MSDS’s can be obtained and used to protect the employee.

Who Must Be Trained? All covered employees must be trained. OSHA’s definition of a “covered employee” is any employee who may be exposed to hazardous substances under normal operating conditions or in emergencies. There may be instances where an employee who appears to be a “non-covered employee” is in fact covered. For example, if a clerk’s job requires walking through a area every day, and thus being potentially exposed while performing assigned duties, then training would be necessary. Determining who must be trained in the workplace can sometimes be a sticky issue. It is better to be cautious and train workers who may occasionally have an exposure. Training Tips The training requirements under the HAZCOM Standard are “performance-oriented,” that is, categories of information to be covered with employees are listed without specifying how training is to be accomplished. Since there are no guidelines for how training must be done, the City has chosen the following training options and techniques:

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Training should be specific to the workplace. While it is acceptable to provide workers with general information regarding the hazards and potential hazards of substances in the work areas, specific training should be given for the substances to which workers are exposed. o Cal/OSHA has cited companies for hazard communication violations when training has been conducted, but the training did not cover the hazards of the substances to which employees are exposed. Training should cover items listed on the Inventory List that has been compiled for the work area.

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Group chemicals/substances by hazard category, if possible. It is not always necessary to cover each chemical or substance specifically. For example, there may be many types of paints used in the workplace that all have the same types of hazards. Several different solvents may be used, all with the same handling precautions. In these situations, it may be better to break chemicals down into groups and discuss the hazards and precautions of the group as a whole. This can save time and eliminate unnecessary repetition during training.

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Training should allow for information exchange. Giving an employee a Material Safety Data Sheet to read does not satisfy the intent of the standard with regard to training. The training is to be a forum for explaining to employees not only the hazards of the substance in their work area, but also how to use the information generated in the HAZCOM Program. This can be accomplished in many ways (audiovisuals, classroom instruction, interactive video), and should include an opportunity for employees to ask questions to ensure that they understand the information presented to them.

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It is important employees comprehend the information provided to them. When Cal/OSHA makes an inspection, employees may be randomly interviewed regarding their training. The inspector will likely be asking general questions, such as the location of the MSDS’s, chemical-specific knowledge, and understanding of labels. While employees are not expected to recall everything covered in a HAZCOM training session, the inspector will use the interview to determine whether the appropriate training was conducted and whether the employee has some understanding of the information provided.

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Evaluate employee knowledge. If an employee has not received training or is not adequately trained, Cal/OSHA will hold the employer responsible. According to OSHA’s compliance directive, the “employer, therefore, has a responsibility to evaluate an employee’s level of knowledge with regard to the training and information requirements of the standard.” This can be done through a test or by asking the employee to demonstrate knowledge in some other way.

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Document the training. Cal/OSHA has no requirement in the regulation for documenting the HAZCOM training. However, the City requires all training sessions and the subject matter is documented and acknowledged by employee signatures.

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Retrain as necessary. The standard does not require retraining at specific intervals; however, employees must be trained at the time of their initial assignment and whenever a new hazard is introduced in the work area. Much of the necessary retraining can be handled through brief, periodic safety meetings.

Employee Information and Training Supervisors must conduct health and safety orientation for new employees to discuss the following:         

Requirements contained in the HAZCOM Program, including their rights to know information Hazardous substances that are present in the work area Location and availability of the written HAZCOM Program Physical and health effects of the hazardous substances Methods and observation techniques used to determine the presence or release of hazardous substances in the work area How to lessen or prevent exposure to these hazardous substances through usage of the engineering controls, work practices, and/or the use of personal protective equipment Steps the City has taken to lessen or prevent exposure to these substances Emergency and first aid procedures to follow if employees are exposed to hazardous substances How to read and review MSDS to obtain hazard information

NOTE: It is critically important that all employees understand the training. Any questions should be directed to the Risk Manager. All personnel who are or may be exposed to hazardous and/or toxic chemicals or substances while performing duties in their work area must receive training on these hazards at the time of their initial assignment and whenever a new hazard is introduced into their work area and annually thereafter. Persons who have not received this training will not be allowed to work in areas where hazardous chemicals or substances exist. Supervisors are responsible to be aware of the above training items as they are related to the work area and to provide the appropriate training. 5. CONTRACTOR NOTIFICATION It is important that the City’s outside contractors also have a safe work environment. It is the responsibility of the Department where the work is being performed to provide contractors with the following information:   

Hazardous substances to which they may be exposed while on the jobsite Precautions employees may take to lessen the possibility of exposure Copies of the City of El Centro’s HAZCOM Program along with a copy of the

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The location of the MSDS files Information and all locations for any hazardous substances to which they may be exposed while working on the job site

Contractors are required to review this information with their employees prior to the start of work at any City location or facility. Contractors of the City are required to provide information on any hazardous chemical or substance they will use at any City facility, job site or multi-employer work site where City employees may be present. Copies of the MSDSs should be provided to the City’s Supervisor where the work is being performed. Supervisors should conduct the appropriate training for City employees as soon as the MSDS information is available or as soon as the hazardous substance is known or suspected.

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Exhibit “C”

Material Safety Data Sheet (MSDS) Sample

Guide to Understanding MSDS’s

This attachment provides information for understanding and interpreting the MSDS. A typical MSDS for Methyl Ethyl Ketone is shown and then analyzed by section to aid in understanding the terms and contents.

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Exhibit “B”

MATERIAL SAFETY DATA SHEET (MSDS) SAMPLE REQUEST LETTER

Date:

Chemical Company or Distributor: Re: Material Safety Data Sheet Request Form MSDSs are needed for compliance with the State of California Hazard Communication Regulation, Title 8, Section 5194. In order to meet these regulations and policies, we request a completed MSDS for the following product(s): Product Name

We also request any additional information, supplemental MSDSs, or any relevant data your company or supplier currently has, or may acquire in the future, concerning the safety and health aspects of the product(s). Please remit this information to the following address:

If this product does not require an MSDS, please notify us in writing. Sincerely,

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