POLICY 11  HAZARD COMMUNICATION/RIGHT-TO-KNOW PROGRAM
OSHA 1910.1200
September 5, 2006
I.   PURPOSE
   The purpose of this program is to ensure that employees of the Town of Middletown are able to recognize hazards in the workplace and to make them aware of how to best protect themselves and others against these hazards. The goal of this program is to reduce the incidence of chemical source illness and injuries.
II.   POLICY
   The Town of Middletown shall provide necessary hazard information to employees so that they can participate in, understand and support the protective measures in effect at their workplace. This program shall include provisions for container labeling, collection and availability of Material Safety Data Sheets (MSDSs), and employee training.
III.   PROGRAM
   The Hazard Communication Program shall be maintained in the Town of Middletown Risk Management Manual.
IV.   RESPONSIBILITIES
   A.   The Town of Middletown Safety Officer and the Town Safety Committee shall be responsible for the development, implementation, and maintenance of the Town’s Hazard Communication Program.
   B.   Department managers or their designees shall be responsible for documenting employee training, maintaining departmental hazardous chemical inventories and MSDSs, performing an annual hazardous chemical inventory, and ensuring appropriate labeling of all hazardous substances in their department.
   C.   A central file of applicable MSDSs shall be maintained at the DPW, Police Station, Fire Station, Library, Senior Center and Town Hall.
   D.   The department manager or their designee shall provide employees with a copy of a requested MSDS during his or her work shift.
V.   REQUIREMENTS
   A.   Labels and Other Forms of Warning
      1.   Each container of hazardous chemical that is received at the workplace shall be labeled, tagged or marked with the identity, appropriate hazard warnings, and the name and address of the manufacturer or other responsible party.
      2.   Labels or other forms of warning must be legible, in English and prominently displayed on the container or readily available in the work area throughout each work shift.
      3.   Labels on incoming containers of hazardous chemicals shall not be removed or defaced. If the existing label is damaged, it shall be immediately marked by the department supervisor/manager with the required information.
      4.   Containers received without appropriate labels or other forms of warning shall be labeled with the required information by the designated staff member.
      5.   Labels are not required on portable, secondary containers into which hazardous chemicals are transferred into from labeled containers when:
         a)   they are intended only for the immediate use by the employee who performs the transfer and
         b)   the contents of the portable, secondary containers must be emptied by the end of the work shift.
      6.   If the above circumstances are not applicable, then the portable, secondary container must be labeled with the appropriate information by the individual performing the transfer from the labeled primary container.
   B.   Material Safety Data Sheets (MSDSs)
      1.   A request to receive MSDSs shall accompany the initial order for any hazardous chemical purchased by the Town of Middletown.
      2.   MSDSs shall be in English and shall be complete and meet the requirements of 29 CFR 1910.1200 Standard.
      3.   Upon receipt of a MSDS, it shall be forwarded to the appropriate department manager/supervisor or designee for review.
      4.   The user department manager/supervisor or designee shall provide employees with appropriate recommendations and/or comments pertaining to the use of the hazardous chemical. The MSDS shall be maintained in a central filing system.
      5.   If the MSDS is not provided with a shipment that has been labeled as a hazardous chemical, the department manager/supervisor or designee shall immediately request the MSDS from the chemical manufacturer.
      6.   The department manager/supervisor or designee shall maintain copies of the required MSDSs for each hazardous chemical in the workplace, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s).
   C.   Employee Information and Training
      1.   Employees shall be provided with information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new hazard is introduced into their work.
      2.   Employees shall be trained annually on the following topics:
         a)   methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area.
         b)   the physical and health hazards of the chemicals in the work area.
         c)   measures employees can take to protect themselves and others from these hazards:
            1.   environmental control practices.
            2.   appropriate work practices.
            3.   emergency procedures.
            4.   use of personal protective equipment.
         d)   details of the Hazard Communication Program.
         e)   explanation of the labeling system and MSDS.
   D.   Hazards of Non-Routine Tasks
      The hazards of non-routine tasks are to be communicated to employees on a case-by-case basis by the employee’s supervisor. There are written procedures for some tasks, such as a hazardous chemical spill.
   E.   Hazardous Chemical Inventory
      An inventory of hazardous chemical products shall:
      1.   be maintained by the department manager/supervisor or designee for their respective department.
      2.   be reviewed/revised annually by the department manager/supervisor or designee.
      3.   be verified against the corresponding MSDS for each hazardous chemical listed on the department’s hazardous chemical inventory annually.
Town of Middletown
Hazard Communication/ Right-To-Know Program
OSHA 1910.1200
__________________________________________________________________________________________________________________________________________
The undersigned acknowledges the receipt and understanding of the Town of Middletown Hazard Communication/Right-To-Know Program (29 CFR 1910.1200 OSHA Hazard Communication Standard).
                                                                                                                                                             
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