Download Hazard Communication Program - The School District of Palm

Hazard Communication Program
The purpose of this program is to inform interested persons, including employees,
that our organization is complying with the OSHA Hazard Communication
Standard, Title 29 Code of Federal Regulations 1910.1200, by compiling hazardous
chemicals lists, using safety data sheets (SDS’s) and ensuring that containers are
labeled or provide other forms of warning and training our employees.
This program applies to all work related operation of the School District of Palm
Beach County (SDPBC) where employees may be exposed to hazardous chemicals
under normal working conditions or during an emergency situation. Under this
program, our employees will be informed about the content in the Hazard
Communication Standard, the hazards of chemicals with which they work, safe
handling procedures, and measures to take to protect themselves from these
chemicals, among other training elements.
The School District’s Environmental & Conservation Services (ECS) has overall
responsibility for the program, including reviewing and updating the program, as
necessary. Copies of this written program may be obtained online at
palmbeachschools.org/ecs. Moreover, all employees, or their designated
representative, may obtain further information about the written program and
the Hazard Communication Standard, from the District’s Environmental
&Conservation Services (ECS) Department.
Finally, if after review of this program, you find that improvements can be made
please contact ECS. All suggestions are encouraged because the District is
committed to the success and continual improvement of our written Hazard
Communication Program. We strive for clear understanding, safe behavior, and
involvement in the program from every level of the organization.
List of Hazardous Chemicals
The “chemical inventory” is a list of hazardous chemicals known to be present in
our workplaces throughout the District. Anyone who may come in contact with
District approved hazardous chemicals needs to know what those chemicals are,
the associated hazards, how to protect themselves and what to do in the event of
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an exposure. This is why it’s so important that hazardous chemicals are properly
identified, whether they are found in a container or generated in work operations
(for example, chemical solutions for class experiments). The hazardous chemicals
listed in the chemical inventories can cover a variety of physical forms including
liquids, solids, gases, vapors, fumes, and mists. Sometimes hazardous chemicals
can be identified by investigating the purchase order paperwork. Identification of
other chemicals may require visual survey of the workplace with proper written
documentation. Each applicable school or facility is responsible for generating
and updating the hazardous chemical inventory as necessary.
A chemical inventory is available electronically for each school center or ancillary
facility via MSDS online which can be accessed via the District’s portal.
MSDSonline is the District’s contracted Data Management System. The chemical
inventory serves as a list of every hazardous chemical for which an SDS must be
maintained for that school or facility.
Safety Data Sheets (SDSs)
SDSs are fact sheets for chemicals that pose a physical or health hazard in the
workplace. These sheets provide our employees with specific information on the
chemicals in their work areas.
Each department within each school or ancillary facility is responsible for
developing and updating their chemical inventory. The chemical inventory
consists of at a minimum:
 The specific name of the chemical.
 The strength, percentage and molarity where applicable.
 The manufacturer of each chemical (please be aware that you may have
more than 1 manufacturer of the same chemical).
 The location and room number where each chemical is stored.
The inventories will then be submitted to ECS who will then place each electronic
SDS copy into the appropriate “eBinder” for the specific location which will then
be accessible to all employees.
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It should be noted that OSHA allows SDS’s to be kept in any form as long as the
information is provided to each hazardous chemical and is readily assessable
during each work shift to employees when they are in their work area(s).
Therefore, we have taken advantage of this flexible OSHA provision for
alternatives to SDS’s in the workplace and have made all SDS’s available through
MSDS On-Line via the Districts Portal.
Labels and Other Forms of Warning
Hazardous chemical containers in the workplace must be clearly labeled, tagged,
or marked in accordance with the Hazard Communication Standard, either with:
 The product identifier, signal word, hazard statement(s), pictograms (s),
and precautionary statements(s); or
 The product identifier and words, pictures symbols, or combination
thereof, which provide at least “general’ information regarding the hazards
of the chemicals, and which, in conjunction with the other information
immediately available to employees under the Hazard Communication
Program, will provide employees with the “specific” information regarding
the physical and health hazards of the hazardous chemical
The name and address of the manufacturer, importer, or other responsible party
may also be found on the label, tag, or marking because shipped containers of
hazardous chemical must contain this information. Hazards not otherwise
classified, if any, do not have to be addressed on a container but must be
addressed on the SDS.
Because the product identifier is found on the label, the SDS, and the chemical
inventory, the product identifier links these three sources of information, which
facilitates cross-referencing. The product identifier used by the supplier may be a
common or trade name, a chemical name, or a number. Employees should be
aware that label information can be verified by referring to the corresponding
SDS.
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Each school or ancillary facility is responsible for ensuring that all hazard
chemicals in containers at the workplace have proper labels or other forms of
warnings that are legible, in English (although other languages may also be
included), and displayed clearly on the container or readably available in the work
area throughout each work shift, as required. The designated individuals at each
school or ancillary facility are responsible for updating the labels, as necessary,
and also ensuring that newly purchased chemicals are checked for proper labels
when containers are received.
While not required for in-house labeling, the name and address for the
manufacturer, importer, or other responsible party may also be found on the
label, tag, or marking because shipped containers of hazardous chemicals must
bear this information. Hazards not otherwise classified, if any, do not have to be
addressed on a container but must be addressed on the SDS.
Secondary Containers
If employees transfer chemicals from a labeled container to a portable, secondary
container that is intended only for their IMMEDIATE use (complete amount will
be consumed and not stored), no labels, tags, or markings are required on the
portable container. Otherwise portable containers must be labeled, tagged, or
marked in accordance with our in-house labeling system for workplace
containers.
All containers should be examined before and after each use to review and
update label information to ensure that if labels have fallen off or become
unreadable that they are immediately replaced.
Training
Everyone who works with or is potentially “exposed “ to hazardous chemical on
the job will receive initial training on the Hazard Communication Standard via
Train U and trained in the safe use of those hazardous chemicals before starting
work (which includes reviewing the SDS prior to chemical use). “Exposure” means
that “an employee is subjected in the course of employment to a chemical that
has an associated physical or health hazard, and includes potential (e.g. accidental
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or possible) exposure.” Whenever a new chemical hazard is introduced or an old
hazard changes, additional training shall be provided. Effective information and
training is a critical part of the Hazard Communication Program. We train our
employees to read and understand the information on labels and SDSs, determine
how the information can be obtained and used in their own work areas and
understand the risks of exposure to the chemicals in their work areas, as well as
ways to protect themselves. Our goal is to: ensure that employees know when
they may be exposed to hazardous chemicals, have the skills to read and use
labels and SDSs, and understand how to appropriately follow the protective
measures we have established. We urge our employees to ask questions for
greater comprehension.
Training Content
The training program emphasizes these elements:
 Summary of the Hazard Communication Standard
 What hazardous chemicals are present in operations in employee work
areas.
 Chemical and physical properties of hazardous chemicals (e.g., flash point,
reactivity, etc.) and how to detect the presence or release of these
chemicals.
 Physical hazards of chemicals (e.g., potential for fire, explosions, etc.).
 Health hazards, including signs and symptoms of overexposure, associated
with exposure to chemicals and any medical condition known to be
aggravated by exposure to them.
 Any simple asphyxiation, combustible dust, and pyrophoric hazards, as well
as hazards not otherwise classified, of chemicals in work areas.
 Any step the company has taken to reduce or prevent exposure to
hazardous chemicals, such as engineering controls.
 Procedures to protect against hazards and exposure (e.g., work practices or
methods to assure proper use and handling of chemicals and any required
personal protective equipment and its proper use and maintenance
 Procedures for reporting and responding to chemical emergencies.
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 How to read and use both the workplace labeling system and labels
received on shipped containers.
 The order of information found on SDS’s and how to read the information
and what it means.
 How to access SDS’s and the written Hazard Communication Program.
The procedure to train new employees at the time of their initial assignment is to
refer them to the Train U training module. Employees need to be trained
(reviewing the SDS is an acceptable means) when a Training documentation is
maintained by the Train U computer application.
Training documentation is maintained by the Train U computer application.
Hazards of Non-routine Tasks
Periodically, employees are required to perform non-routine tasks that involve
hazardous chemicals. When employees will be required to perform hazardous nonroutine tasks, such as painting or cleaning that have the potential to expose
employees to hazardous chemicals, we inform them of these hazards by providing
a copy of the SDS.
Additional Information
As stated earlier, all employees, or their designated representatives, may obtain
further information on this written program and the Hazard Communication
Standard from the School District’s Risk Management & Safety Department and/or
ECS.
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