BACKGROUND
LDI is committed to the health and safety of its’ employees and compliance with all appropriate regulation.
This written hazard communication program not only meets OSHA requirements, but also ensures that LDI employees are effectively informed concerning potential and existing chemical hazards. Hazard Communication is one important aspect of LDI’s Occupational Safety and Health Program, which includes:
- Management commitment and active support.
- Engineering controls for safety and health hazards.
- Enforcement of safety rules and programs.
- Recognition, Evaluation, and control of occupational safety and health hazards.
- Medical Surveillance.
- Assigned safety and health responsibility and accountability.
PURPOSE
The purpose of this Hazard Communication Program is to inform our employees to the best of our abilities of potential or existing chemical hazards.
APPROACH
The method used to inform employees includes:
- Container labeling and other forms of warning.
- Safety Data Sheets (SDS’s).
- Employee education and training.
APPLICATION
This hazard communication program applies to:
- Known occupational safety and health hazards.
- Chemicals known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.
DETERMINING CHEMICAL HAZARDS:
LDI is responsible for identifying chemical hazards from safety data sheets (SDS’s) provided by chemical manufacturers and distributors.
SAFETY DATA SHEETS (SDS‘s)
SDS’s are prepared and distributed by manufacturers and distributors of hazardous materials. All chemical manufacturers and distributors must obtain or develop a SDS for each hazardous material they produce or import. A hazardous material is one that is either a physical hazard (i.e., flammable, oxidizer, etc.) or a health hazard (i.e., causes acute or chronic health effects).
LDI maintains the SDS file for all hazardous materials used or handled in our workplace.
LDI reviews each data sheet to make sure it is complete and that there are not obvious errors, and replaces old data sheets with the new ones that accompany shipments of materials.
SDS’s are in English and contain the following information:
- The identity of the chemical.
- The physical and chemical characteristics.
- The physical and health hazards.
- Primary routes of entry.
- Exposure limits.
- Precautions for safe handling.
- Controls to limit exposure.
- Emergency and first aid procedures.
- Name of manufacturer or distributor.
SDS AVAILABILITY
LDI maintains copies of SDS’s for most hazardous material in the workplace and makes them readily accessible during each work shift to employees when they are in their work area(s). Employees may review the SDS’s for the materials they work with at the time, while they are in their work area. They also may request a copy of an SDS if they wish. Copies of SDS’s for materials used in each work area are maintained in that work area, during all shifts. Upon request, the National Institute for Occupational Safety and Health (NIOSH) and OSHA has access to our SDS’s.
MATERIAL INVENTORY
Below is a list of the hazardous chemical(s) used or stored at this location. These chemicals are referenced to their appropriate SDS’s and are as follows:
- Canon GPR-24 Toner Black Product Code: 1872B003AA
- Canon GPR-38 Black Toner Product Code: 3764B003AA
- Canon GPR-31 Black Toner Product Code: 2790B003AA
- Canon GPR-30 Black Toner Product Code: 2789B003AB
- Canon IPQ-1 Black Toner Product Code: 0397B003AA
Employees wishing to see this list should contact their supervisor.
LABELS AND OTHER FORMS OF WARNINGS
Chemical manufacturers, importers, and distributors provide labels, tags, or other markings for containers of hazardous chemicals. This identification includes the following information:
- Identity of the hazardous chemical.
- Appropriate hazard warnings.
- Name and address of the chemical manufacturer, distributor, or other responsible parties.
LDI requires that containers of hazardous materials in the workplace are labeled, tagged or marked with the identity of the hazardous chemical and appropriate hazard warning. Occasionally, signs, placards, process sheets, batch tickets, operating procedures, or similar accessible written materials are used, instead of affixing labels to individual containers.
Portable containers of hazardous chemicals do not have to be labeled if they contain chemicals transferred from labeled containers, which are intended only for the immediate use of the employee who performs the transfer.
All labels on incoming containers must not be defaced in any way. Missing or defaced labels must be immediately reported to Finishing Supervisors so appropriate labels can be reapplied immediately.
EMPLOYEE INFORMATION, EDUCATION, AND TRAINING
Any information, education, and training program is provided by LDI to make sure employees know about hazardous chemicals in the workplace and the appropriate control measures to reduce exposure to them. This program is coordinated by LDI.
New employees receive appropriate safety and health information, education, and training during their initial assignment. This training includes information about hazardous materials and processes in the workplace through the use of printed materials and classroom instruction.
The new employee safety and health training program begins upon hire by the personnel department and continues with on-site training by the new employee’s department supervisor. The specific information in the safety and health training program includes:
- General chemical hazards.
- Hazards associated with non-routine tasks.
- Recognition, evaluation, and control of hazardous chemicals.
- Chemical labeling.
- Hazards associated with unlabelled piping and processing systems.
- SDS’s.
- Access to information on hazardous chemicals.
- Compliance with safety and health rules and regulations.
- Requirements of Federal Hazard Communication Regulations.
- Specific hazards present in the work areas.
- The location and availability of the written Hazard Communication Program and supporting information.
- The measures employees can take to protect themselves from hazards, including pertinent work practices, company emergency procedures, and personal protective equipment.
All employees are informed by a supervisor concerning the LDI Hazard Communication Program and an explanation of the company’s labeling system, SDS’s and how appropriate hazard information may be obtained by employees.
RETRAINING
It is necessary for work area supervision to provide additional employee training concerning workplace hazards when:
- New materials or processes are introduced into the workplace.
- Process or equipment changes are made that could cause new or increased employee exposure.
- Procedures or work practices are introduced, or changed, which could cause changes in the employees’ exposure.
- Employees are transferred from one work area to another where different hazards are present.
A permanent record of all employee training is maintained in the employee’s personnel folder.
NON-ROUTINE TASKS
The supervisor of an employee performing a non-routine task, such as cleaning process equipment, is responsible for properly training the employee concerning the potential hazards associated with the task. The employee also shares in this responsibility by making sure that his/her immediate supervisor knows that the non-routine task will be performed.
CONTRACTOR
All contractors working on company property are notified by company management of hazardous materials to which the contractor’s employees will be exposed to while working on company property. Also, proper controls will be established to ensure that LDI’s operations do not expose the contractor’s employees to safety and health hazards. Copies of SDS’s for all materials the contractor’s employees may be exposed to will be provided to the contractor by LDI (management).
PROGRAM AVAILABILITY
LDI’s Hazard Communication Program is available upon request to:
- Employees.
- OSHA Representatives.
- NIOSH Representatives.
