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Ames Proceudral
Requirements

Last Revised: 10/24/2008

COMPLIANCE IS MANDATORY


Chapter 24 - Chemical Hazard Communication Plan

Table of Contents

24.1 Overview
24.2 References
24.3 Definitions
24.4 Responsibilities

24.4.1 Occupational Safety & Health and Medical Services Division
24.4.2 Supervisors
24.4.3 Employees
24.4.4 Contracting OfficerÕs Technical Representative (COTR)
24.4.5 Acquisition Division/SEMA Agreement Routing
24.4.6 Shipping and Receiving Personnel

24.5 Hazard Communication Plan

24.5.1 Material Safety Data Sheet (MSDS)
24.5.2 Labeling

24.5.2.1 General Requirements
24.5.2.2 Chemical Labels

24.5.3 Information Management

24.5.3.1 Documents
24.5.3.2 Trade Secrets
24.5.3.3 Communication in Multi-Employer Workplace

24.5.4 Purchasing/Sema Agreements
24.5.5 Training

25.5.5.1 Updating Training
25.5.5.2 Training Documentation

24.6 Appendices

24.6.1 Appendix A: Performance Checklist for Communication Program
24.6.2 Appendix B: Substances Regulated by a Specific OSHA Standard
24.6.3 Appendix C: Chemical Labels Requirements (National Fire Protection Association (NFPA) Material Signal Code
24.6.4 Appendix D: SEMA Agreement (sample)


24.1 Overview

The Hazard Communication Program was established in order to reduce the chemical-related occupational illnesses and injuries.

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24.2 References

  1. NHS/IH-1845.3A, NASA Health Standard on Hazard Communication
  2. 29 CFR 1910.1200, OSHA Hazard Communication Standard
  3. 29 CFR 1960, Basic Program Elements for Federal Occupational Safety and Health Programs
  4. NPR 8710.2, NASA Safety and Health Program
  5. ANSI Z400.1-1993, Material Safety Data Sheets - Preparation
  6. 58 FR 41981, Executive Order 12856, August 3, 1993, Occupational Safety and Health Programs for Federal Employees

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24.4 Definitions

Appendices A and B of the Hazard Communication Standard (29 CFR 1910.1200, OSHA HAZCOM Standard) provide further guidance in defining the scope of health hazards and determining whether or not a chemical is to be considered hazardous for purposes of this standard.

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24.4 Responsibilities

24.4.1 Occupational Safety, Health and Medical Services Division

  1. Provide Hazard Communication training to civil service employees.
  2. Establish SEMA Agreements for new chemical purchasers. SEMA Agreements are established for a 3-year period and should be renewed accordingly.
  3. Provide oversight of chemical purchases on Bank Cards, and special approval on SAP purchases over $2500.

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24.4.2 Supervisors

Management is responsible for ensuring safe use of hazardous materials at all areas under their control. These responsibilities include (but are not limited to):

  1. Ensure that MSDSs (as hard copies or electronic files) are available for all hazardous chemicals in the work area, stored or in use, during all shifts.
  2. Ensure that hazardous chemical containers are properly labeled.
  3. Ensure that employees receive on-the-job training before working on any hazard chemical assignment.
  4. Ensure that training is provided when a new chemical is introduced into the workplace or when there is a substantial change in chemical usage or work practices.
  5. Ensure that any hazardous materials shipped from an ARC facility are packaged and documented by an authorized Transportation Officer.
  6. Ensure that outside employees or contractors who in order to comply with OSHA requirements for multi-employer worksites
  7. Ensure that acquisitions of hazardous materials are subject to all applicable Safety & Health Division requirements, including SEMA Agreements and training.
  8. Ensure that hazard determinations are completed and MSDSs are prepared. If you develop an new chemical, a new MSDS must be written to correlate that chemical in accordance with the criteria contained in 29CFR 1910.1200.

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24.4.3 Employees

Every employee is responsible for workplace safety and must act within the guidelines provided in applicable MSDSs. Employee Hazard Communication responsibilities include:

  1. Attend Hazard Communication training before working with hazardous material.
  2. Read/understand the MSDS for each hazardous material that you will handle or may be exposed to at work.
  3. Establish SEMA Agreement with the Safety and Health Division before purchasing chemicals.
  4. Use the least hazardous material appropriate for the job.
  5. For large inventories, use the Central Chemical Storage Facility. Purge unwanted chemicals by using the Ames Chemical Exchange (ACE) program.
  6. Use PPE when required.
  7. Follow all site procedures for acquisition, labeling, storage, and handling of hazardous materials.
  8. In the event of personnel exposure to a hazardous material, provide applicable MSDSs along with other relevant information to emergency personnel and medical care providers.

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24.4.4 Contracting OfficerÕs Technical Representative (COTR)

The COTR evaluates contractor performance and compliance with all contract requirements. Most Ames contracts specify compliance with OSHA standards and the Ames Health and Safety Procedural Requirements as contract requirements. The COTR communicates with the responsible government managers and the Safety, Health and Medical Services Divsion, as appropriate, regarding compliance issues. Tasks that the COTR may perform to ensure Hazard Communication compliance include:

  1. Ensure that contractor employees know ARC Hazard Communication policies and comply with this program while working on site.
  2. Ensure that contractor purchases of hazardous materials are reviewed for compliance with applicable regulations and ARC policy and requirements as specified in this chapter.
  3. Review and evaluate contractor Hazard Communication policies, written hazard communication program, and performance, using the Chemical Hazard Communication Performance Checklist (See Appendix A).

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24.4.5 Acquisition Division/SEMA Agreement Routing

Ensure that Government Purchase Request for hazardous materials, including requests for open orders and credit cards have Safety, Health and Medical Services Division authorization.

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24.4.6 Shipping and Receiving Personnel

  1. Ensure that received containers of hazardous materials are properly labeled.
  2. Ensure that MSDSs accompany all incoming hazardous chemicals as required on the purchase request.
  3. Ensure that the lab-generated materials shipped from ARC are accompanied by appropriate MSDSs.

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24.5 Hazard Communication Plan

The Hazard Communication Plan describes how ARC provides MSDSs, labels and other warnings, employee information and training, and lists of hazardous chemicals present in the workplace to government and contractor employees. This information is provided in English and in other languages as needed.

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24.5.1 Material Safety Data Sheet (MSDS)

The manufacturerÕs current MSDS is obtained by the user before acquisition of any hazardous material and is maintained in a location accessible within 10 minutes to worksites where the material is stored or used. MSDSs may be obtained by contacting the vendor directly, or through the Code Q website/ChemWatch. If an online service is used, the MSDS obtained must exactly match the product name and manufacturer of the item to be purchased.

24.5.1.1 Users should always verify that they have the current MSDS for the product or chemical in question

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24.5.2 Labeling

Each workplace container of hazardous material is labeled, tagged, and marked to identify the material and to provide appropriate warnings.

24.5.2.1 General Requirements

The following rules and guidelines apply to all chemical containers.

  1. At a minimum, the label should identify the chemical(s), and the hazard warnings (including target organ effects). The chemical (s) identity provided on the label must be the same as or cross-referenced to the same identifier on the MSDS and inventory. The user shall label all containers to which chemicals may be transferred from the primary container, prior to transfer.
  2. Incoming containers received with defaced or missing labels should be rejected unless the contents are definitely known and the container is immediately labeled with the appropriate information.
  3. Labels shall not be removed or defaced, and must remain intact.
  4. Labels must be legible, in English (another language may be used in addition to English when appropriate), and prominently displayed on the exterior of the container.
  5. Preprinted and manufacturers' labels must be revised within three months of receipt of significant new information and before the material is reintroduced into the worksite.
  6. The Safety, Health and Medical Services Division strongly recommends that labels also contain the following supplemental information:

- Name of owner or responsible person.
- Date dispensed or mixed.
- Expiration date.

24.5.2.2 Chemical Labels

Labels for many pure chemicals can be printed from the Code Q website using ChemWatch II . Biohazard and Target Organ labels are also available. A current list and set of instructions is available from the Safety, Health and Medical Services Division. Blank NFPA system labels are also available from Ames Stores Stock (AIB).

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24.5.3 Information Management

24.5.3.1 Documents

Copies of this Hazard Communication Plan and relevant standards are maintained in the Safety, Health and Medical Services Division, and are accessible to employees, contractors, health care providers, and emergency responders. The Division is available to provide additional information, reference materials, and consultation.

MSDSs are available via web-links (ChemWatch) from the Code Q website.

The Building Emergency Action Plan (BEAP), which contains chemical inventories for each building, is compiled and updated annually. The BEAP is provided to NASA management (Division, Branch, or Office Chief) resident in each building, as well as to local emergency responders and agencies as needed.

24.5.3.2 Trade Secrets

In an emergency, where a treating physician or nurse determines that the specific chemical identity of a hazardous chemical is necessary for emergency or first aid treatment, the manufacturer shall be contacted immediately at the emergency information number provided on the MSDS. The manufacturer or importer is required by law to disclose the specific chemical identity of a trade secret chemical, regardless of the existence of a written statement of need of a confidentiality agreement.

In a nonemergency situation, the employee, physician, or other persons with a need to know a manufacturerÕs trade secret information may request that information in writing. However, the employee should consult first with the Office of the Patent Counsel (DL). Information acquired for an employeeÕs medical record must be labeled ÒTrade Secret.Ó

24.5.3.3 Communication in Multi-employer Workplace

Identification of major facility hazardous operations, and chemical inventories, is available to contractor employees through the COTRs.

Hazardous chemicals to be acquired or used by onsite contractors are identified to contracting officers, government managers, and/or COTRs in proposals and/or safety plan. MSDSs for proposed hazardous materials are provided to the Safety & Health Division with the Safety & Health Plan, if possible, and in all cases prior to onsite use of hazardous materials. An explanation of any labeling system must be provided along with the chemical inventory list. Storage and use areas should be labeled to identify the hazard, with standard NFPA labels. Sample NFPA Labels can be found in Appendix C.

When necessary in order to prevent exposure to others, operations with hazardous chemicals shall be performed in a designated, labeled controlled access area.

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24.5.4 Purchasing/SEMA Agreements

If you purchase hazardous materials using the P-Card system, you must establish a Safety, Environmental and Mission Assurance (SEMA) Agreement with Code Q. SEMA Agreements spell out the requirements for chemical users and must be renewed every three years, or when any new chemical is being ordered. Sample SEMA Agreement can be found in Appendix D.

Material Code 68 ÒChemical and Chemical ProductsÓ should be used when creating your Order Log. Use chemical desciptors in the text fields so your Approving Official will know you have purchased a chemical. If you are purchasing for someone else, you are still the responsible party.

Refer to QE any new or significantly changed use of air pollutants, including gases and volatile solvents. Refer to QH any new use of hazardous materials or a familiar material in a new process.

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24.5.5 Training

OSHA requires Hazard Communication training for employees who use or are potentially exposed to hazardous chemicals on a routine basis or in a foreseeable emergency. At ARC, the diversity and distribution of operations with hazardous materials necessitates all employees to attend general Hazard Communication Training. Employees who handle hazardous materials also receive task-specific training by their supervisors.

See Appendix E for specific training requirements

A copy of this document is provided for each employee at the time of training.

24.2.1.1 Udating Training

Update training is provided by Supervisors whenever:

  1. New chemica hazard is introduced to the workplace.
  2. New or updated information is received relative to materials used in the workplace 9example: new MSDSs).
  3. Chemical use or work practices are changed.

24.2.1.2 Training Documentation

The Safety, Health and Medical Services Division maintains records of training provided by Occupational Safety, Health and Medical Services Division. Supervisors may obtain attendance rosters and verifications from Occupational Safety, Health and Medical Services Division. Managers maintain records of supervisor-provided task specific training. Records of site and task-specific training shall include the date and time (duration), name of trainer, and outline or summary of topics presented.

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24.6 Appendices

24.6.1 Appendix A: Performance Checklist for Hazard Communication Program

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24.6.2 Appendix B: Substances Regulated by a Specific OSHA Standard


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24.6.3 Appendix C: Exceptions to Chemical Labels Requirements

National Fire Protection Association (NFPA) Material Signal Code

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24.9.4 Appendix D: SEMA Agreement

BANKCARD PURCHASE AUTHORIZATION

AGREEMENT FOR SAFETY RESTRICTED ITEMS

I intend to purchase potentially hazardous chemicals or materials by BankCard for use in the _____(lab, shop, area) in N-____, Room ___. I understand that I must help ensure workplace safety and environmental compliance. I agree to fulfill the following:

  1. (Training) Complete annual HazCom training, initial PPE training and other safety training identified herewith, by supervisor or Safety Division. Maintain familiarity and ensure compliance with applicable regulations and ARC policies for hazardous materials.*
  2. (MSDS) Review MSDS and suitability of conditions and precautions prior to purchase. Try to identify an alternative less hazardous material or application to meet your needs.
  3. (Coordinating) Request industrial hygiene review prior to acquisition of a new hazardous material or use in new process. Inform management of the inventory list of hazardous chemicals.***
  4. (Inventory) Enter any new chemical purchase into the chemical inventory.
  5. (Recycle) Utilize Ames Chemical Exchange (ACE) and Central Chemical Storage Facility (CCSF) chemicals and facilities to the maximum extent possible.
  6. (Logistics) Make arrangements and post instructions for delivery of chemicals in my absence.
  7. (Clean Air) Refer each new or significantly changed use of any air pollutant, including toxic gases and volatile solvents to Environmental Division for environmental compliance review prior to purchase.**
  8. (Exceptions) The purchase of radioactive materials, controlled drugs, chlorofluorocarbons, explosives or pyrotechnic devices is not authorized by this agreement.
Authorized user purchaser:


______________________________    ______________       _______________       
Printed Name                      Signature            Date

Organization    ___________
Mail Stop       ___________
Phone           ___________


Safety Division review by:        Effective for three years from date below:

___________________________       ______________________       ____________ 
Printed Name                      Signature                    Date


cc: ______________, M/S_____ (approving official)

BANKCARD PURCHASE AUTHORIZATION
AND AGREEMENT FOR SAFETY RESTRICTED ITEM
INFORMATION

* Training includes, but is not limited to:

Building Emergency Action Plan
Hazard Communication
Chemical Safety for First Responders
Decontamination Procedures
Hazardous Waste/Environmental Essentials
Personal Protective Equipment
Spill Control and Containment Strategy
Storm Water Pollution Prevention

For course descriptions. registration, and contact information, access Training folder at http://dq.arc.nasa.gov or call Tami Williams at x4-2056.

** For information on the following hazardous materials requirements, call the listed contact:

Santa Clara County Hazardous Materials Storage
(Linda Vrabel x4-0924)

Air Pollutants, including solvent cleaning
(Kobin Lee x4-1523, Dana Bolles x4-3145)

Toxic Gas
(Dan Winningham x4-2613)

Hazardous Waste
(Dan Winningham x4-2613)

Industrial Waste Water Discharge
(Dan Petroff x4-5850)

*** Hazardous Materials definitions

Materials identified on the MSDS or ARC Chemical Inventory as hazardous for transport according to U.S. Department of Transportation (DOT) criteria and/or the OSHA Hazard Communication Standard.

See Ames Health and Safety Manual APR 1700.1 and Ames Environmental Management Handbook APR 8800.3 for more information. (Access at http://dq.arc.nasa.gov/)

The manner of use is frequently the determining factor. If planned use of the material can cause exposure to a target organ or general safety, an MSDS is required and stated precautions must be taken. For example, solder becomes a potential exposure hazard when heated.

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