Ames Proceudral
Requirements
Last Revised: 10/24/2008
COMPLIANCE IS MANDATORY
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
24.5.1 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
24.6.1 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)
The Hazard Communication Program was established in order to reduce the chemical-related occupational illnesses and injuries.
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.
Management is responsible for ensuring safe use of hazardous materials at all areas under their control. These responsibilities include (but are not limited to):
Every employee is responsible for workplace safety and must act within the guidelines provided in applicable MSDSs. Employee Hazard Communication responsibilities include:
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:
Ensure that Government Purchase Request for hazardous materials, including requests for open orders and credit cards have Safety, Health and Medical Services Division authorization.
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.
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
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.
- 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).
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.
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.
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:
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.
National Fire Protection Association (NFPA) Material Signal Code
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:
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.