3.2 Identify Responsible Staff Person to Manage the Program Compliance with the HCS is not a “one shot deal” so hazard communication must be a continuing program in your business. For it to be successful you must assign responsibility for both the initial and ongoing compliance activities. Identify, by job title, someone that has responsibilities for file preparation and maintenance, training, labeling containers, etc. In most MOLLY MAID franchises, particularly new ones, this will be you, the franchise owner. The success of any safety and health program depends on commitment at every level of the organization. This is particularly true for hazard communication, where success requires specific behavior that occurs only when you understand the program and are committed to its success, and if employees are motivated by the people presenting the information to them. 3.3 Identify Hazardous Chemicals in the Workplace The standard requires a list of hazardous chemicals in the workplace. The list will eventually serve as an inventory of everything for which an SDS must be maintained. Start the list by doing a comprehensive inventory of all the chemicals in the office. The broadest possible perspective should be taken when doing the survey and not limit your thinking to only liquids in containers. The HCS covers chemicals in all physical forms—a liquid, solids, gases, vapors, fumes, and mists—whether they are “contained” or not. The hazardous nature of the chemical and the potential for exposure are the factors that determine whether a chemical is covered. If it’s not hazardous, it’s not covered. Make a list of all chemical products in the workplace that your teams use. You may also want to note on the list the location(s) of the products within the workplace, where they are used, and an indication of the hazards as found on the label to help you as you prepare the rest of your program. Once you have compiled as complete a list as possible, determine if you have received SDSs for all of them. Check your files against the inventory you have just compiled and if any are missing, contact your supplier and request one. It is a good idea to document these requests, either by copy of a letter or a note regarding telephone conversations. If you have SDSs for products that are not on your list, figure out why. Maybe you don’t use the product anymore. Do not allow employees to use any products for which you have not obtained an SDS. 3.4 Prepare and Implement a Hazard Communication Program All workplaces where employees are exposed to hazardous chemicals must have a written plan that describes how the standard will be implemented. Preparation of a plan is not just
MOLLY MAID Safety Manual
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