a paper exercise; all of the elements must be implemented in the workplace in order to comply with the rule. We have provided a “Sample Written Hazard Communication Program” is a “Hazard Communication Employee Training Program” for you to use when training your employees about the cleaning products they use. It can be downloaded from the MOLLY MAID Team site. It is intended to be a blueprint for implementation of your program—an assurance that all aspects of the requirements have been addressed. Your program does not have to be lengthy or complicated. If OSHA inspects your workplace for compliance with the HCS, the OSHA compliance officer will ask to see your written plan at the outset of the inspection. Your written program must describe how the following requirements are met in your facility: Labels and other forms of warning Safety Data Sheets (SDSs) Employee information and training Labels and Other Forms of Warning As mentioned earlier in this chapter, chemical manufacturers, importers, and distributors are required to ensure that every container of hazardous chemicals they ship is appropriately labeled with the identity of the material, appropriate hazard warnings, and the name and address of the producer or other responsible party. You can rely on the labels provided by your suppliers. When you transfer the product from the original container to another one, you are responsible for providing proper labels for the new container. The key information on an OSHA-required label is the identity of the material and appropriate hazard warnings. The identity is any term that appears on the label, the SDS, and the list of chemicals, and thus links these three sources of information. The identity used by the supplier may be a common or trade name (e.g. Black Magic Formula) or a chemical name (1,1,1,-trichloroethane). The hazard warning is a brief statement of the hazardous effects of the chemical (e.g. flammable or causes lung damage). Labels frequently list precautionary measures (e.g do not use near open flame), but this information is provided voluntarily and is not required by the rule. Labels must be legible and prominently displayed. There are no specific requirements for size or color or any specified text. The OSHA compliance officer will be looking for the following information to ensure that labeling will be properly implemented in your facility: Designation of person(s) responsible for ensuring labeling of all containers Designation of person(s) responsible for ensuring labeling of any shipped containers Description of labeling system(s) used Description of written alternatives to labeling of all containers (if used) Procedures to review and update label information when necessary.
3.4.1
MOLLY MAID Safety Manual
Page 15
Copyright 2015, Molly Maid, Inc.
Proprietary and Confidential Information
Made with FlippingBook - Online magazine maker