SECTION 4

SECTION 4

HAZARDOUS CHEMICALS COMMUNICATIONS PROGRAM

1. Purpose

To establish a written program to inform employees about the hazardous chemicals to which they are exposed by means of this procedure, the use of labels, and other forms of warnings, MSDS, information and training.

2. Responsibility

The SMC safety coordinator is responsible for the implementation and compliance to this procedure. The site superintendent or his designee shall be responsible for the administration and maintenance of this program.

3. Definitions

Material Safety Data Sheet (MSDS): Written or printed material concerning a hazardous chemical or product with the manufacturer's location, warnings, hazards, and precautions listed.

Label: Any written or printed material displayed on containers of hazardous products.

Article: A manufactured item whose form is shaped during design or manufacturing and does not release a hazardous chemical or fragment under normal use.

Container: Any bag, barrel, box, can, drum, etc. that contains a hazardous substance.

Immediate Use: A hazardous chemical that is under the control and use of one person, who transferred the item from its labeled container and only within one (1) work shift.

Health Hazard: A chemical for which there is at least one (1) study done with scientific principles that acute or chronic health problems that may occur to exposed employees. These are items such as carcinogens, irritants, toxins which damage the skin, eyes, lungs, mucous membranes.

TLV (Threshold Limit Value): The concentration of a chemical/particulate in the air that can be breathed for five consecutive eight hour days without effects.

TWA (Time Weighted Average): Exposure to a hazardous material in any eight (8) hour work shift in any 40 hour week.

PEL (Permissible Exposure Limit): The average exposure in eight (8) hours. You can work safely in higher concentrations providing your average exposure is not higher than the PEL, i.e. a chemical has a PEL of 10 PPM. Work could be as follows:

4 hrs at 5 PPM, 2 hrs at 10 PPM, 2 hrs at 15 PPM, and still be within the limit (4 hrs x 5 PPM) + (2 hrs x 10 PPM) + (2 hrs x 15 PPM) = 70 PPM ÷ 8 hrs = 8.75 PPM.

Ceiling: Exposure for a set number of minutes in an eight (8) hour day.

Max Peak: The maximum exposure (PPM) allowed in a specified time for eight (8) hours, i.e., a chemical has a ceiling of 25 PPM for 10 minutes and a Max peak of 50 PPM. You can enter an atmosphere with a concentration of between 25 and 50 PPM without a respirator providing you are not exposed for more than 10 minutes in eight (8) hours.

4. Material Safety Data Sheets (MSDS)

MSDS's are required for every hazardous chemical or product on the job site except those items which the average consumer can buy, but only in quantities you would have at home, and if they are not altered. If they state "For Industrial Use", an MSDS is required.

The purchasing agent shall request two (2) copies of the MSDS when he/she purchases any hazardous chemical or article. The request for the MSDS shall be on the material requisition. (Examples of hazardous products are petroleum, paint, mortar, concrete, compressed gases. Hazardous articles are wood, steel, welding rods, insulation.)

One copy of the MSDS shall be sent with the product to the job site, the other to the safety coordinator.

Upon receiving the MSDS, the safety coordinator shall stamp it with the date received, log it on the MSDS Log Sheet (see Attachment 1), and file it in the MSDS file.

Upon receiving the product and MSDS on the jobsite, the superintendent shall check the MSDS against the label on the container to ensure both are in agreement.

After his review, he shall stamp it with the date received, log it on the MSDS Log Sheet, and file it in the MSDS file.

When products are received without the MSDS, the superintendent shall immediately notify the purchasing agent. He shall also initiate the letter requesting the MSDS and forward it to the purchasing agent. A copy of this letter shall be filed in the MSDS file.

If, after seven (7) days, the MSDS has not been received, a second request shall be made as outlined above, using the second request letter. A copy of this letter shall also be given to the safety coordinator.

For those items bought in quantities at a retail outlet, a request for the MSDS shall be made at the time of purchase. Logging and filing of the data sheet shall be as per item 4 in this section.

If the MSDS cannot be obtained through the retailer, the retailer should supply the Superintendent with the name, address, and phone number of the manufacturer.

The superintendent shall then contact the manufacturer by phone requesting the MSDS, followed by a written request for the MSDS as outlined in item 7 in this section.

This letter shall be filed in the MSDS file.

If after seven (7) days, the MSDS has not been received, a second request shall be made as outlined in item 7 in this section.

(Note: New MSDS's are required only when a product's chemical makeup has been changed or the product is supplied by a different manufacturer.)

The safety coordinator shall prepare and submit a list of those hazardous chemicals/articles covered in the Hazards Communications Program to the agencies listed below on an annual basis as follows:

1. A list of all hazardous chemicals/gases/flammable liquids normally stored in quantities in excess of 500 pounds or 55 gallons to the local fire chief.

All MSDS sheets of pertinent information (chemical name, manufacturer, phone number, where it was used) must be retained for 30 years. The historical MSDS shall be kept in a fire proof storage system. Access to these documents shall be limited.

5. Labels

All containers of hazardous chemicals shall be marked with its contents, physical and health hazards. This shall be done either by the manufacturer or by the superintendent. The physical and health hazards are listed on the MSDS.

When hazardous chemicals are transferred from the primary storage container (original) to a secondary container, i.e. paint from a paint can to a pail, the secondary container shall be labeled per SMC's labeling system, if the product is used by more than one employee or if it remains in the secondary container for more than one shift.

If the product is for immediate use, labeling is not required.

Marking shall be done as follows.

1. Per the MSDS, the superintendent shall select the appropriate colored tag based on the health hazard:

Green Low Health Risk

Yellow Moderate Health Risk

Red High Health Risk

2. Once the tag has been selected, he shall then write the name of the hazardous material on the top line, the MSDS number and the flammability of the material as indicated below.

0 Non Flammable

1 Flammable

2 Extremely Flammable

It is the responsibility of the employee to obtain the required label and the superintendent's responsibility to see that this is done.

A copy of SMC's labeling system shall be posted with the right to know and other safety related posters.

6. Pipe Labeling

Prior to beginning any work, the superintendent or his designee shall review the piping system with the owner to determine isolation points, outage requirements and cleaning of the system. This shall be done as early as possible to permit scheduling of the outage.

The Material Safety Data Sheets (MSDS) shall be reviewed for the particular product expected to be encountered to determine the related hazards. He shall inform those employees responsible for the work of the hazards and precautions needed.

Face shields, goggles and gloves are required as a minimum when opening any line. Additional protection may be required per the MSDS.

The superintendent or his designee shall implement the “Lockout, Tagout” procedure at the time specified by the owner. He shall then complete the appropriate permits.

Where hot work is required or when hazardous materials ma y be encountered, after the “Lockout, Tagout” procedure has been implemented, slip blinds shall be installed in the first flange joint on either side of the area to be entered or modified. In the absence of flanges, expandable rings shall be used.

At all entry points, including those for slip blind installations, the ground shall be protected to prevent soil contamination or control the spillage within the building.

Unbolting of Flanges

Always work above or behind the flange joint where possible.

Loosen the bolt the furthest away from you and the bottom studs before the top as follows: the furthest away - 3 full turns, the lower bolts - 2 full turns and break the seal away from you. This will minimize the chance of injury.

If the line is found to have pressure, retighten the bolts closest to you and proceed to tighten the joint. Then contact the superintendent or foreman.

When entering a welded system where the pressure or drainage cannot be verified, a pilot or inspection hole shall be drilled at the entry point. This hole shall be no larger than 1/4”.

When drilling the inspection hole, the drill bit shall be cooled with water.

If the line is found to be under pressure, the area shall be cleared and the owner and superintendent notified.

Where practical, all initial cutting shall be done with port-a-bands.

7. Employee Training

Employees shall be trained immediately after completing the signing up phase. He/she shall be trained for all hazardous substances on the job site that he/she could come into contact with during the course of their job or in an emergency. Training shall be as outlined in this section.

The superintendent or his designee shall train each employee on all the hazardous materials on the job site. These shall be recorded on the training sheet along with the time, date, and location of where the training has taken place.

The superintendent or his designee shall explain how to read the MSDS. Explain each section:

1. Identification: Chemical name, as it is on the label. Manufacturer's name, address, emergency phone number, signature of preparer.

2. Hazardous Ingredients/Identity Information: Contains the specific chemical formula, exposure limit (maximum amount of chemical a person can be exposed to without harm), threshold limit (amount that can be breathed for five (5) consecutive eight (8) hour work days, without harmful effects).

3. Physical Characteristics: Boiling point, vapor pressure (measurement of liquids tendency to evaporate), vapor density (weight compared to air), solubility in water (if it can be mixed in water without separation), color and odor, specific gravity (ratio of material weight to equal volume of water), melting point, evaporation rate (temperature at which it evaporates).

4. Fire/Explosion Hazard: Flash point (lowest temperature that the liquid gives off enough vapor to ignite in air when exposed to an ignition source), flammable limits (range of vapor concentration which will explode when ignition source is present), extinguishing media, special fire fighting procedures, unusual fire/explosion hazard.

5. Reactivity: Stability (conditions that affect the chemical: heat, shock mishandling, incompatibility, (materials to avoid)), hazardous by-products, and chemical reactions.

6. Health Hazards: Route of entry, hazard (chronic which is long term, acute which is immediate), carcinogenicity (causes cancer) symptoms of exposure, first aid.

7. Precautions for Safe Handling: Steps to take in case of spills, disposal methods, handling and storage precautions.

8. Control Measures: Measures taken when using the product such as respirators, ventilation, personal protection.

The superintendent shall review with the employee the following for each hazardous product.

1. How to spot the hazard.

2. What are the physical and health hazards?

3. What protection is required when working with the product?

4. First aid.

Each employee shall be shown the MSDS file and informed of its location (not "in the office").

The superintendent shall explain SMC's labeling system as described at the end of this section.

When a new product and MSDS arrive on site, the superintendent shall review the data sheets and the product with each employee who will be working with the product before he uses it, as outlined in item 6 in this section. The superintendent shall train the remaining employees at the next safety meeting per item 6 in this section. This shall be done with each new hazardous product.

Each time a non-routine task is to be performed, i.e. tie-in, the superintendent shall train those employees directly involved, per item 6 in this section, of the hazardous material that may be encountered using the data sheet. A copy of the data sheet shall be given to each employee.

After the training is completed, the superintendent shall file a copy of the training sheet in each of the employee’s file. The original training sheet shall be sent to the safety coordinator.

8. Contractor's Data Sheets

It is a requirement that the superintendent inform his employees of the hazardous materials of other contractors and subcontractors.

The safety coordinator shall attempt to obtain a copy of the owner's MSDS prior to the start of the job. If obtained, the copy shall be given to the project superintendent.

In the event he cannot obtain them, a letter shall be sent requesting them (Attachment 2). In any event the superintendent shall be made aware of the location of the owner's MSDS and their labeling system. A copy of the hazardous materials should be given to the superintendent.

The superintendent shall be responsible for obtaining all contractors’ MSDS and labeling systems. He shall do this through the use of the form letter to the contractor (Attachment 6). If after (7) days the MSDS have not been received, a follow up letter shall be issued (Attachment 7).

The superintendent shall distribute a copy of his MSDS log sheets and labeling system to all contractors on the job site via a transmittal.

9. Employee Exposure and Medical Records

These are available by completing the Authorization Release form.

BACKGROUND HEALTH RISK FLAMMABILITY

GREEN LOW 0 LOW

YELLOW MODERATE 1 FLAMMABLE

RED HIGH 2 EXTREMELY FLAMMABLE

STANDARD MAINTENANCE COMPANY, LLC

INVENTORY OF HAZARDOUS CHEMICALS

ARTICLES

HAZARDOUS CHEMICAL	TRADE NAME	MANUFACTURER	MSDS RECEIVED

STANDARD MAINTENANCE COMPANY, LLC

INVENTORY OF HAZARDOUS CHEMICALS

COMPRESSED GASES

HAZARDOUS CHEMICAL	TRADE NAME	MANUFACTURER	MSDS RECEIVED

STANDARD MAINTENANCE COMPANY, LLC

INVENTORY OF HAZARDOUS CHEMICALS

FLAMMABLE/COMBUSTIBLE

HAZARDOUS CHEMICAL	TRADE NAME	MANUFACTURER	MSDS RECEIVED

STANDARD MAINTENANCE COMPANY, LLC

INVENTORY OF HAZARDOUS CHEMICALS

TOXINS

HAZARDOUS CHEMICAL	TRADE NAME	MANUFACTURER	MSDS RECEIVED

STANDARD MAINTENANCE COMPANY, LLC

Training Attendance Report

Date____________ Time________________ Topic___________________________________

Name Name

1. ____________________________________ 2. ________________________________

3. ____________________________________ 4. ________________________________

5. ____________________________________ 6. ________________________________

7. ____________________________________ 8. ________________________________

9. ____________________________________ 10. ________________________________

11. ___________________________________ 12. ________________________________

13. ___________________________________ 14. ________________________________

15. ___________________________________ 16. ________________________________

17.___________________________________ 18. ________________________________

19. ___________________________________ 20. ________________________________

21. ___________________________________ 22. ________________________________

23. ___________________________________ 24. ________________________________

25.___________________________________ 26. ________________________________

Comments/Suggestions: ________________________________________________________

_____________________________________________________________________________

Meeting Leader: ______________________________________________________________

(Signature)

Job No. _____________________________________________________________________

Attachment 2

Date:__________________________

______________________________

Subject:_______________________

Dear__________________________ :

In order to comply with the OSHA Hazardous Communication Standard, we need the current Material Safety Data Sheet for the following item(s):

____________________________________________________________

Please send the MSDS for the product listed above to the address above. If there are any questions please contact ______________________ at ___________________________.

Sincerely,

STANDARD MAINTENANCE COMPANY, LLC

1898 Vanderhorn Dr.

Memphis, TN 38134

Name

Title

Attachment 3

Date:__________________________

______________________________

Subject:_______________________

Dear__________________________ :

On ______________________, we requested the Material Safety Data Sheet for the following item(s) _______________________________________________. To date, we have not received the requested MSDS.

In order to comply with the Hazardous Communication Standard, this must be provided to us. Please send the MSDS to the address stated above to the attention of ____________________. If the MSDS has already been sent, please disregard this letter.

Sincerely,

STANDARD MAINTENANCE COMPANY, LLC

1898 Vanderhorn Dr.

Memphis, TN 38134

Name

Title

Attachment 6

Date:__________________________

______________________________

Subject:_______________________

Dear__________________________ :

Employees of our company will be working on the ( ) construction site at the same time as your company. Our employees may be in close proximity to hazardous substances your company may produce, store or use on site. In order to comply with the OSHA Hazard Communication Standard, all contractors who could cause hazard exposures to another company's employees are required to exchange information about the hazardous chemicals used on site.

Please advise us where your MSDS's are kept and give us any information regarding any precautionary measures needed to protect employees, any foreseeable emergency situations, and your labeling system used on the work site. All correspondence should be directed to the address above. We are enclosing similar information on the hazardous chemicals our company will have on the site.

Thank you for your timely response to this request. If you have any questions concerning this matter, please contact ( ) at ( ).

Sincerely,

STANDARD MAINTENANCE COMPANY, LLC

1898 Vanderhorn Dr.

Memphis, TN 38134

Name

Title

Attachment 7

Date:__________________________

______________________________

Subject:_______________________

Dear__________________________ :

Recently we requested that you advise us where your MSDS's are kept for all hazardous substances produced, used or stored on ( ) construction site. We also requested information regarding any precautionary measures to protect employees during normal operations and in foreseeable emergencies and your labeling system used on the work site.

In order for our firm and yours to be in compliance with the OSHA Hazard Communication Standard, we must receive the requested information. Your prompt attention to this matter is greatly appreciated.

Sincerely,

STANDARD MAINTENANCE COMPANY, LLC

1898 Vanderhorn Dr.

Memphis, TN 38134

Name

Title

_______________________________________

THIS COMPANY HAS A WRITTEN

HAZARDOUS

COMMUNICATION

PROGRAM

IN COMPLIANCE WITH OSHA 1926.59

IN ACCORDANCE WITH THE STANDARD, THE FOLLOWING ITEMS ARE AVAILABLE TO YOU UPON REQUEST.

____ COPY OF THE COMPANY'S WRITTEN HAZARDOUS COMMUNICATION PROGRAM

____ COPY OF THE OSHA HAZARDOUS COMMUNICATION STANDARD

____ COPY OF THE COMPANY'S LIST OF HAZARDOUS CHEMICALS FOR YOUR WORKPLACE

____ COPIES OF MATERIAL SAFETY DATA SHEETS FOR ANY COVERED CHEMICALS TO WHICH YOU MAY BE EXPOSED

TO OBTAIN ANY OR ALL OF THIS INFORMATION,

CONTACT YOUR SUPERVISOR

OR COMPANY SAFETY COORDINATOR AT:

Bill Funderburk 1-901-382-3040

NOTICE TO OTHER

EMPLOYERS

IN ACCORDANCE WITH OSHA HAZARDOUS

COMMUNICATION STANDARDS

WE WILL MAKE AVAILABLE TO YOU ON REQUEST

MATERIAL SAFETY DATA SHEETS

FOR COVERED MATERIALS WE ARE USING

AND TO WHICH YOUR EMPLOYEES MAY BE EXPOSED.

STANDARD MAINTENANCE COMPANY, LLC

1898 Vanderhorn Dr. Memphis, TN 38134

Bill Funderburk 1-901-382-3040

(CONTACT PERSON) (PHONE)

IN ADDITION, YOU ARE REQUESTED TO CHECK IN WITH OUR SUPERVISOR BEFORE ALLOWING YOUR WORKERS INTO ANY AREA WHERE WE ARE USING CHEMICALS COVERED BY THE STANDARD AND RECEIVE INFORMATION YOU WILL NEED TO ENSURE YOUR EMPLOYEE'S SAFETY.

IT IS OUR COMPANY POLICY TO USE MANUFACTURED-LABELED CONTAINERS OR TO ATTACH MATERIAL SAFETY DATA SHEETS TO COVERED PRODUCTS.

AUTHORIZATION FOR THE RELEASE OF EMPLOYEE MEDICAL RECORD INFORMATION

I, _______________________________ (full name of employee) hereby authorize STANDARD MAINTENANCE COMPANY, LLC to release to ____________________________________________ (individual or organization authorized to receive medical information), the following medical information from my personal medical records:

________________________________________________________________________

____________________________________

Employee Signature

____________________________________

Social Security Number

____________________________________

Date

This letter will be valid for 180 days from the above date.