CoatingsPro Magazine

MAY 2015

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COATINGSPRO MAY 2015 45 smoke when using this product."). • Name, address, and phone number of the responsible party. For containers you received already labeled from the supplier and that are used in the workplace, simply maintaining the label received from the supplier is the best and easiest option; however, the standard is fexible, and you may re-label these containers or label other containers used in the workplace with various options as long as employees have immediate access to the specifc information about the physical and health hazards of the chemical. Tis could be included in the workplace hazard communication program. Te standard also addresses portable containers into which the hazardous chemicals are transferred from a labeled container and which are for the immediate use of the employee who performs the transfer. Tese porta- ble containers do not have to be labeled. You must also make sure that labels in the workplace are legible and prominently displayed. W hile the label information must be in English, employers are free to add warnings in other languages if they have a bi-lin- gual workforce. If your workplace is inspected by OSHA, the compliance inspector will be looking for at least the following aspects of your labeling approach: 1. Designation of person(s) responsible for ensuring compliant labeling of shipped and in-plant containers; 2. Description of written alternatives to labeling of stationary process containers (if used); 3. Appropriate labels on all workplace containers, including those received from a supplier, secondary containers, and stationary process containers; 4. A description and explanation of labels on both shipped and workplace containers included in the employee training program; and, 5. Procedures to review and update workplace label information when necessary. 4. Maintain Up-to-Date SDSs Te second part in the approach to communicating information in HazCom 2012 is to maintain the SDSs. Te requirements in HazCom 2012 are based on an internationally agreed-upon, 16-section SDS; it is most likely already familiar to your employees. HazCom 2012 establishes section headings for the SDS, as well as the order in which they are to be provided and the minimum information required to be included in each section. Te infor- mation in some of the sections are non-mandatory because they address information that involve the require- ments of other government bodies and thus are not under OSHA's jurisdiction. Even though these sections are not considered mandatory by OSHA, the headings are still required to be present on the SDS. Tey will provide useful information for you to address other requirements you may need to follow. Keep in mind that you must maintain copies of SDSs on your worksite(s), and you must ensure that SDSs are readily accessible to your employees when they are in their work areas during their work shifts. Tis accessibility may be accom- plished in many diferent ways. You must decide what is appropriate for your particular workplace. Some employers keep the SDSs in a binder in a central location (e.g., in a pick-up truck on a construction site). Others, particularly in workplaces with large numbers of chemicals, provide access electronically. If access to SDSs is provided electronically, there must be an adequate back-up system in place in the event of a power outage, equipment failure, or other emergency involving the primary electronic system. As long as your employees can get the informa- tion when they need it, any approach may be used. W hen your employees must travel between workplaces during a work shift, SDSs may be kept at the primary workplace facility. No matter what system is used, you must ensure that your employees and medical personnel can immediately obtain the required information in an emergency. To ensure that you have a current SDS for each chemical at the worksite as required and that employee access is provided, an OSHA compliance ofcer will be looking for the following items in your program: 1. Designation of person(s) responsible for obtaining and maintaining the SDSs; 2. How such sheets are maintained in the workplace (e.g., in notebooks in the work area or areas or electron- ically), and how employees obtain access to them when they are in their work area during the work shift; 3. Procedures to follow when the SDS is not received at the time of the first shipment; 4. An SDS for each hazardous chemical in the workplace and training of employees that includes review of SDS format and use. To ensure that your hazard communication program improves safety and health with regard to chemi- cal use, you should review the SDSs and use the information to choose the needed protective measures to prevent or reduce exposures in your workplace. SDSs should be used to evaluate your workplace and establish a plan to ensure it is safe from all known chemi- cal hazards. 5. Inform and Train Your Employees Te third part of the hazard commu- nication approach in HazCom 2012 is employee information and training. For information and training to be efective, the employees in the train- ing must comprehend the hazards in the workplace and ways to protect themselves. OSHA does not expect that employees will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that employ- ees understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is Safety Watch

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