Policy 2-8 RESCINDED BY ADMIN POLICY 3-24
Prior to the adoption of 2-8 on 07/26/2005, Policy 2-8 read as follows.
DISTRIBUTION: All Departments
SUBJECT: Chemical Hazard Communication Program
PURPOSE: To identify and properly label hazardous substances used or otherwise
present in
the workplace of City employees, to provide information to and educate employees on the
chemicals that they are or may be exposed to while on the job, and to record and make available
to employees a summary of the exposure they have had to specific hazardous substances in
the
workplace.
BACKGROUND: City employees are exposed to a variety of hazardous
substances in the
workplace. To minimize the adverse health affects of these chemicals, employee education
and
prescribed protective procedures and equipment are required. In 1985 the Oklahoma
Hazard
Communication Standard was enacted as law under the
authority of Title 40 O.S. and is
enforced by the Oklahoma Department of Labor (ODOL). ODOL basically adopted the OSHA
Hazard Communication Standard applying to private industry, extended it to cover public
employees, and added provisions recognizing the unique requirements for firefighters and other
public safety employees.
DEFINITIONS: Terms used in this policy are defined as follows:
1. CAS Number - The unique identification number assigned by the
Chemical Abstract
Service to chemicals.
2. Chemical Name - The scientific designation of a substance in
accordance with the
nomenclature system developed by the International Union of Pure and Applied Chemistry or
the Chemical Abstract Service or an alternate name found in the NIOSH Registry of Toxic
Effects of Chemical Substances or a prescription generic drug.
3. Common Name - Any designation or identification used to identify a
substance other than
its chemical name.
4. Container - Any barrel, bottle, box, can, cylinder, drum, pipe
or piping system, storage
tank, reaction vessel, or the like that contains a hazardous material.
5. Distributor - A business, other than a chemical manufacturer or importer,
which supplies
hazardous substances to the employer.
6. Employee Exposure Report - A report that must be generated on the appropriate
form
when an employee's contact with a known hazardous substance has occurred or has been
discovered to have occurred by any method of entry and which may result or does result in injury
to the employee.
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Page 2
7. Employee Potential Exposure Report - A report that must be generated on the
appropriate
form when an employee may have been exposed to a known hazardous substance which may
result in the employee sustaining an injury from contact with the known hazardous substance.
8. Hazardous Substance - Any substance which is a physical hazard or a
health hazard.
9. Health Hazard - Any chemical, biological substance or agent which is
listed in the U.S.
Occupational Safety and Health Administrations list of Toxic and Hazardous Substances, 29
CFR Part 1910, Subpart "Z" and any other substance including but not limited to chemicals
which are carcinogens, toxic agents, reproductive toxins, irritants, corrosives, sensitizers,
toxins
affecting liver function, and agents which damage the lungs, skin, eyes or mucous membranes,
and any substance for which a Material Safety Data Sheet has been provided by the
manufacturer, as a hazardous material, or such substances deemed by the Oklahoma Department
of Labor Commissioner, based on documented scientific evidence, that poses a threat to the
health of an employee.
10. Material Safety Data Sheet ( MSDS) - A document provided by the manufacturer,
importer, or distributor of a chemical product which identifies and describes the characteristics
and hazards of the product and its ingredients, instructions on how to handle and use the product
safely, and instructions on what to do in case of emergency such as leak or spill of the product or
over-exposure to the product by employees.
11. Physical Hazard - A chemical which is a compressed gas, explosive,
flammable, an
organic peroxide, and oxidizer, pyrogoric, unstable or water-reactive, and which is contained
in
OSHA's list of Hazardous Materials and any substance for which a Material Safety Data Sheet
has been provided by the manufacturer as a hazardous material, or such substances deemed by
the Oklahoma Department of Labor Commissioner, based on documented scientific evidence that
poses a threat to the safety of an employee.
12. Proprietor - The owner, manager, or other person or organization
which has control over
any location where hazardous substances are present, and which is subject to the jurisdiction of
employers subject to the provisions of these rules.
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Page 3
13. Specific Hazard - A hazard of a chemical substance not adequately
described in degrees of
health hazards, flammability, or reactivity. It may describe important factors to be considered
in
a fire emergency; such as, the chemical's reactivity with water, whether or not the chemical is
radioactive, proper fire extinguishing agents, protective equipment required, or whether the
chemical is an oxidizer, corrosive, acid, alkali, etc. In the NFPA 704 Placarding system, the
specific hazard is indicated by a symbol in the white diamond.
14. Workplace - Any location away from home, permanent or temporary, where
any employee
performs any work related activity in the course of his/her employment.
PROCEDURES: A. Substances to Which This Policy
Applies:
Substances which are or contain hazardous chemicals as indicated in their Material Safety Data
Sheets fall under the provisions of this program. Material Safety Data Sheets will be obtained
for all products used or present in the workplace that list a warning or hazard alert on their labels.
B. Exclusions:
This policy does not apply to foods, drugs, cosmetics, or tobacco products intended for personal
consumption by employees while in the workplace. Additionally, this policy does not apply to
any consumer products and food stuffs packaged for distribution to, and intended for use by, the
general public unless these consumer products are purchased by the employer for the required
use of the employee.
C. Employees
to which this Policy Applies:
All employees who are exposed to the types of chemicals as referenced in paragraph "A" are
covered by the provisions of this policy.
RESPONSIBILITIES
AND PROCEDURES:
A. Program Coordinator: The Safety and Risk Officer will function
as the City's Hazard
Communications Program Coordinator. Should a full time Hazardous Materials
Officer be
appointed in the future, the person assuming this position will be designated as the program
coordinator.
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B. HAZCOM Coordinators: This policy establishes the function of
Hazard Communications
(HAZCOM) Coordinator which will be assumed as an additional duty for employees in various,
defined workplaces. The HAZCOM Coordinator must be knowledgeable of the chemicals and
job tasks performed in the work unit he represents. Department heads shall appoint HAZCOM
Coordinators for their assigned department/divisions as appropriate.
1. HAZCOM Coordinators, as a minimum, will be designated for work units as follows:
a. Fire, Police, Planning, Engineering and Finance Departments.
b. Field Utilities, Street (including Electronic Maintenance),
Solid Waste, Wastewater
Treatment, Water Treatment, Equipment Maintenance, Buildings
and Grounds, Museum,
Lakes and Land, and Sports and Aquatics (Leisure Services)
Divisions.
2. Responsibilities:
a. Assist in HAZCOM training of employees as necessary. Maintain records
of employee
HAZCOM training.
b. Perform initial and annual physical inventory of all chemical substances in
the work place to
insure all hazardous substances are included in the HAZCOM Program.
c. Maintain the Chemical Information List for the division or department. Append
supplemental lists to the CIL as new chemicals are added. Re-alphabetize the list annually to
include chemicals listed in the addenda.
d. Insure that Material Safety Data Sheets for all chemical substances used or
present in the
workplace are on file and accessible to the employees. At least once every twelve months,
review MSDS file and certify all required MSDS's are on file. Coordinate with the Hazardous
Materials Officer or the Safety and Risk Officer in procuring any needed MSDS's.
C. Chemical Information Lists:
1. Chemical Information Lists (CIL's) are lists of chemicals used or present
in the workplace.
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2. Two master lists (CIL's) of all chemical substances present in any City of
Lawton workplace
will be maintained and updated annually by the Safety and Risk Officer. One CIL will list the
chemical substances by the common names of the substances; the other will list them by trade
name. Both must be cross-referenced to the applicable Material Safety Data Sheets. Both
lists
must be in alphabetical order.
3. Two CIL's of chemicals present will be prepared and maintained in each workplace. These
lists will be filed in the binder with the Material Safety Data Sheets for all chemicals used or
present in the workplace. One CIL will list substance by common name; the other will list them
by trade name. Each will be alphabetized, and will be updated annually.
D. Material Safety Data Sheets:
1. No hazardous substance or agent will be used by City employees prior to receipt
and review
of a Material Safety Data Sheet (MSDS) for the substance or agent.
2. Purchasing Division Buyers will specify that MSDS's must precede or accompany
all
hazardous substance shipments received by the City. Such shipments will not be
accepted
unless this requirement is met. Manufacturers and distributors are required by law to provide
MSDS's to purchasers of their products.
3. For Central Stores items requiring MSDS's, copies of the MSDS's will be available
in the
warehouse.
4. A master file with copies of MSDS's for all chemical substances present in
the City of
Lawton workplaces will be maintained by the Safety and Risk Officer. Each MSDS will be
assigned a unique identifying number which will be referenced in the master CIL's. MSDS's will
be filed in loose leaf binders in numerical order by category (i.e. fuels and oils, solvents, paints
and coatings, etc.).
5. Each workplace will have available copies of MSDS's for all chemicals present
in the
workplace. These will be maintained in clearly marked, loose leaf binders.
a. Binders will be readily available for review by any and all employees in
the workplace.
b. Employee training will include instructions on the location and use of the
MSDS file
(binder).
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c. No less than once every twelve months, the HAZCOM Coordinator for the
workplace will re-inventory chemicals in the workplace and check the MSDS file
to insure
that MSDS's are available for all chemicals on hand. A written record of the inventory and
MSDS review will be maintained in the MSDS file (binder).
d. The HAZCOM Coordinator will inform the Safety and Risk Officer of any needed
MSDS's.
The HAZCOM Coordinator will take action to procure the MSDS's if the MSDS's are not
available in the master file.
E. Education and Training of Employees:
1. All employees will receive chemical hazard communication training within 30
days of hire
and on an annual basis throughout their tenure. This training will include the nature of the
hazards of the specific chemicals with which they may be required to work; the precautions,
procedures, and equipment that must be used to safely work with the chemical; and emergency
and fir-aid procedures to use in case of spill or over-exposure. Prior to receiving this training,
employees should be allowed to handle hazardous chemicals only under close, direct supervision
of trained personnel.
2. Courses of instruction will be modified accordingly whenever job procedures
involving
hazardous substances change or whenever different or additional hazardous substances
are
introduced into the work place. This information will be provided by Superintendents or
Department Directors to the HAZCOM Coordinator. Public safety employees will rely on
proprietors to provide this information.
3. Training Responsibilities:
a. Hazard Communication (HAZCOM) training courses for Fire Department personnel
will be
conducted by the Hazardous Materials Officer.
b. HAZCOM training for Police personnel will be provided through the Police training
section.
The initial training will be provided through the Police Academy. The annual training will be
provided during in-service training.
c. HAZCOM training for all general employees will be conducted as follows:
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(1) The Department/Division Hazard Communications (HAZCOM) Coordinator (See
paragraph E) or appropriately training supervisor will conduct HAZCOM training for new
employees within 30 days of their hire dates. The coordinator or supervisor will complete a
checklist of the items covered during the training; each item will be initialed by the trainer and
the trainee.
(2) The HAZCOM coordinator or appropriately trained supervisor will train all
affected
employees on revised procedures and precautions necessitated by the introduction of a different
chemical substance into the work environment.
(3) The HAZCOM coordinator and the Hazardous Materials Officer or Safety and
risk Officer
will jointly conduct annual HAZCOM training. The Hazardous Materials Officer or the Safety
and Risk Officer will provide general HAZCOM program training. The HAZCOM Coordinator
will instruct on the specific handling and storage procedures for the particular chemicals used in
the workplace of the employees being trained.
d. The Hazardous Materials Officer will provide HAZCOM training to the trainers
in the
various departments/division.
4. Training Documentation: All HAZCOM training must be documented and recorded.
a. For each course conducted, the following information must be recorded by the
person
conducting the course:
(1) Date and time of training.
(2) Length of the course.
(3) Instructor's name.
(4) Synopsis of the material covered.
(5) Names of all employees who attended.
b. This information will be provided in a report to the Safety and Risk Officer
who will record
and file the information.
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c. HAZCOM Coordinators will also file a copy of HAZCOM training records. In
addition,
each employee trained will sign a statement indicating that he/she has been trained and
understood the content of the training course. These statements will be filed and retained by the
HAZCOM Coordinator.
d. Written tests should be administered and filed to indicate employee understanding
of course
content.
F. Employee Exposure and Potential Exposure Reports.
Written reports are required whenever an employee is exposed or may have been exposed to
hazardous concentrations of a chemical substance. This exposure may be contact by inhalation,
ingestion, or on the skin. Of concern are contacts with chemicals that may cause either acute
or
chronic health problems for the employees.
1. Employee exposure reports are required when an employee is exposed to concentrations
of a
hazardous chemical known to be above the permissible exposure levels specified in the MSDS
for the chemical, or the employee ingests or comes into skin contact with the chemical contrary
to MSDS recommendations, or the employee claims a chronic or acute health affect from the
exposure (i.e. irritation, dizziness, rash, breathing difficulty, etc.). For each exposure of
each
employee, a separate form (See Exhibit #1) will be completed. The completed form will be
forwarded to the Safety and Risk Officer within 72 hours after the exposure. After recording the
exposure, the Safety and Risk Officer will forward the report to the Personnel Department for
filing in the employee's personnel file.
2. Employee Potential Exposure reports are required when the employee may
have been
exposed to concentrations of hazardous chemicals above permissible levels or it is suspected the
employee may suffer some ill affect from the exposure at a later date. Each such exposure
will
be recorded on a separate form (see Exhibit #2) for each employee so exposed. The completed
form will be forwarded to the Safety and Risk Officer within two weeks of the potential
exposure. After recording the potential exposure, the report will be forwarded to the Personnel
Department for filing.
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Page 9
3. When supervisory personnel become aware an employee has received a hazardous
or
potentially hazardous exposure to any substance or agent covered by this policy, the supervisor
will immediately inform the employee and arrange for any necessary medical care.
4. An Employee Exposure Summary will be maintained on each employee indicating
the
chemicals (hazardous substances) to which the employee has been exposed throughout the period
of employment. These summaries will be maintained by the Safety and Risk Officer based on
reports of exposure from the affected departments. Once an affected employee terminates
employment with the City of Lawton, the exposure summary for the employee will be forwarded
to the Personnel Department. It will be placed in the individual's personnel files and will be
retained for at least 40 years.
G. Written Safe Handling Procedures.
Each Division will prepare written safe operating procedures for job tasks involving use or
storage of hazardous substances. A separate safe operating procedure is not required for each
item listed the workplace CIL. If the safe handling procedures are the same for two or more
chemical substances, then the chemicals may be grouped together and covered by one safe
operating procedure. These procedures must be consistent with the MSDS provisions for the
substance. A copy of each operating procedure will be provided to the HAZCOM Coordinator
for use in training Division personnel. When these procedures are modified (to include use of
different chemicals) updated standard safe operating procedures will be prepared and copies
provided to the HAZCOM Coordinator. Copies of the Procedures should be filed in the
workplace MSDS binder or otherwise be made readily accessible to employees performing
the
tasks.
H. Labeling.
1. All containers will be labeled as to content and the hazards of the substances
contained
therein. If the labels on containers of hazardous substances do not contain the CAS number and
chemical name of the substance, the using Division must re-label the containers to include this
information. Also, Divisions must insure that labels are protected to maintain readability.
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Page 10
2. Labels are not required for portable containers into which hazardous substances
are
transferred from labeled containers if they are intended only for the immediate use of the
employee. This exemption does not apply to portable containers used to store gasoline and other
fuel.
3. Should a labeled container be re-used to contain a substance other than that
indicated on the
label, the label must be removed or obliterated and replaced with the appropriate
label. This
includes containers re-used for waste (used oil, trash, etc.). Containers are to be re-used only
if
MSDS or label for the chemical substance previously contained therein does not warn against re-use of
the container.
4. Labels are not required for portable containers into which hazardous substances
are
transferred from labeled containers if they are intended only for the immediate use of the
employee. This exemption does not apply to portable containers used to store gasoline and other
fuel.
I. Placarding.
1. Divisions which store "significant amounts" of hazardous chemicals
are required to post
signs (placards) to identify storage locations.
2. For the purpose of this policy, "significant amount" is defined
as follows:
a. An amount of hazardous chemical which is classified according to the U.S.
Department of
Transportation as:
(1) A Class A or Class B explosive.
(2) A Class A or Class B poison.
(3) A flammable solid with a "Dangerous when Wet warning, or
(4) A yellow III label, Radioactive material.
b. The aggregate of the amount of hazardous chemicals store, placed, or used
at the workplace
is greater than or equal to fifty-five (55) gallons of liquid, five hundred (500) pounds of non-liquid,
or eight hundred (800) cubic feet of compressed gas where the numerical rating of the
hazardous chemical based on NFPA 704-1985 system results in:
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(1) Health rating greater than or equal to 2, or
(2) Flammability rating greater or equal to 2, or
(3) Reactivity rating greater than or equal to 1.
3. The National Fire Protection Association provides a simple system of readily
recognizable
and easily understood marking which will give at a glance a general idea of
the inherent
hazards of any material and the order of severity of these hazards as they relate to fire prevention,
exposure, and control: The NFPA 704 Placarding System. This system
will be used in
marking storage areas where hazard chemicals are stored.
4. Placards will be mounted at the entrance, on door or gate, to all storage
areas where
significant amounts of hazardous chemicals are stored or in the location(s) specified by the fire
Department.
5. The placards will be diamond shaped at least 7 and 1/2 inches on each side. The placards
will be in NFPA Standard 704 format, color and number coded to identify the health,
flammability, reactivity, and specific hazards of the chemical.
6. Division superintendents will coordinate with the Fire Department Hazardous
Materials
Officer to determine if placarding is required for a particular storage area and to determine
hazard codes to be used on any required placarding.
J. Employee Right of Access to Records:
Employees or designated employee representatives have right of access to Exposure Reports or
Exposure summaries maintained on them and to Material Safety Data Sheets for the hazardous
substances covered by this policy. Requests for exposure reports or summaries must be made to
the Safety and Risk Officer who will provide copies of the documents within 15 days of receipt
of the request. MSDS's and Chemical Inventory Lists (CIL's) must be available at the workplace
for review by the employees prior to working with the chemicals.
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K. Fire Safety:
In accordance with state law, each proprietor within the service area of the Lawton Fire
Department is required to provide the names and locations of any significant amounts of
hazardous substances stored, placed, or used in the proprietor's facility. Further, proprietors
are
required to properly label containers and provide warning signs at location where such
substances are maintained. Actual procedures for the receipt, maintenance, and use of the
required information from proprietors and for assuring proprietor compliance will be established
by the Fire Department.
REFERENCES: Title 40, Sections 401-424, Oklahoma Statutes and 29 CFR Part
1910.
EFFECTIVE DATE: This policy becomes effective on March 12, 1990 and will
remain in
effect until rescinded.
_______________________________
ROBERT M. HOPKINS
CITY MANAGER