Hazard Communications (HazCom) and Process Safety Management (PSM)

Note: The following text for 1910.1200 has been updated to align with the UN Globally Harmonized System of Classification and Labelling of Chemicals (GHS), Revision 3, issued in the Federal Register, March 26, 2012. This rule became effective May 25, 2012.

1. Purpose

a) The purpose of this program is to communicate the Hazard Communication Program to all company personnel.

2. Objectives

a) To safeguard our employees’ health by providing a management guide for compliance.

b) To provide our employees with the necessary information concerning health and physical hazards of the chemical material used at our worksites.

c) To comply with OSHA Hazard Communication Standard 29 CFR 1926.59 and OSHA Hazard Communication Standard 29 CFR 1910.1200.

3. Scope

a) This compliance program will provide the means for transmission of the information necessary to apprise employees of the chemical products which are, or may be, hazardous and to which they may be exposed.  It will include the following:

i. Listing of the chemical products, which may be handled, used or stored on jobsite locations or company property.

ii. Assure that appropriate identifying labels are on containers of hazardous chemicals being used and handled.

iii. Safety Data Sheets (SDS) will be required and procured for all hazardous chemicals which employees of this company may or will encounter, and the master SDS will be available at the company headquarters office, and a copy will be available at the jobsite for all those chemicals to which employees could be exposed on the jobsite.

iv. Employees will be trained to recognize and interpret labels, warnings, color-coding, pictogram system and signs affixed to containers that they may handle in order to avoid and or make less severe potential hazards.

v. Proper use of SDS’s will be covered in a safety training meeting and indoctrination to availability and location at the jobsite will be covered.

vi. This written HAZCOM program will be available upon request to employees and emergency responders.

4. Chemical Inventory

a) An inventory of all hazardous chemicals used, or transported, or stored at jobsites or on company property will be made available, maintained, and updated monthly to reflect the hazardous chemical in use at that jobsite. This inventory shall include all products that contain respirable crystalline silica.

b) The owner/employer shall provide a procedure and or policy to insure compliance with the hazardous chemical inventory regulations.  The procedure and or policy shall include:

i. Inclusion on the purchase order form of a notice that purchase of a potentially hazardous material is conditional upon the receipt of the SDS for that substance.

ii. Inclusion on the purchase order form of a notice that all hazardous chemicals must be properly labeled.

iii. A system at company headquarters to verify that suppliers have met items 1 and 2 above, especially when hazardous chemicals are shipped and delivered directly to the jobsite.

5. Labeling

a) All containers of hazardous materials, regardless of size, must be labeled or tagged, each supervisor/or person in charge has the responsibility of labeling.

i. Original labels on containers containing hazardous chemicals are not to be removed.

ii. If a different material is placed on the container, the label for the hazardous material contents must be changed to reflect the true contents in the container.

iii. Container labels should include the following:

1. Name of substance in the container

2. Appropriate hazard warnings

3. Appropriate pictogram associated with hazardous chemical

4. Name and address of the manufacturer or distributor

6. Spill Prevention and Management 

a) ESCO Group realizes the importance of the environment and serious health hazard potentials for hazards created by chemical spills or accidental release. 

i. All chemicals will remain in original product containers to prevent transfer spills.

ii. All chemicals not in use will be stored in designated area, including flammable storage cabinet.

iii. Adequate and approved spill kits (assessment by ESCO Group safety representative to be completed prior to the use of any chemical to determine required spill materials) shall be made available throughout the duration of a project.  The spill kit will at a minimum include absorbent material with proper disposal container and personal protective equipment. Disposal arrangements with the host facility environmental manager shall be made if a spill occurs. 

iv. Housekeeping and storage of chemicals will be addressed routinely on all work sites by all supervisors and members of the safety department.  Chemicals shall be stored in closeable container (preferably the original container) and in an area that prevents exposure to storm water drainage systems.  Proper housekeeping and storage will prevent accidental spills and releases. 

v. Where required by client, ESCO Group will provide secondary containment to prevent a spill or equipment failure from endangering the environment.  An example of secondary containment would be the use of a metal trough around a portable generator.

vi. In the event of a spill or accidental release the ESCO Group Safety Department and applicable client department must be notified immediately.  Notification by either phone, radio or direct communication shall take place and include the: name of the chemical, quantity, location, time and measurements taken to prevent further spill and contamination. 

7. Training

a) Workers to Be Trained

i. All employees routinely exposed to hazardous materials through use, handling, transportation or other exposure shall be trained for the materials in use in their workplace.

ii. Orientation training for all employees who are newly hired, assigned or transferred to a department where they will routinely be exposed to hazardous materials or to a different set of hazardous materials shall be trained for the materials in use in their workplace.

b) Training Components

i. Explanations of Right to Know Laws

ii. Introduction to the written HAZCOM program

iii. Hazard determination

iv. Availability and interpretation of SDS including Global Harmonization System (GHS)- Designated 16 Sections

v. Labeling and placarding procedures (including pictogram system)

vi. Physical and health hazards of chemicals in the workplace:

1. Flammable materials

2. Corrosive materials

3. Toxic materials

4. Explosives

5. Oxidizers

6. Carcinogens

7. Adhesives

8. Lubricants

9. Irritants

10. Sensitizers

vii. Protective procedures

viii. Protective equipment

ix. Procedures for non-routine tasks including spill prevention and clean-up

x. Employees shall be trained annually.

8. Emergency Response

a) In addition to the placarding noted in other parts of this program, we shall submit a list of hazardous materials which are present in significant amounts to the local fire department corresponding to each jobsite under their jurisdiction.

b) The list shall be updated as the materials in use change and construction at the jobsite progresses. The fire chief or their representative shall be informed of all hazardous chemicals as specified by local authorities.

9. Records

a) Location and maintenance of hazardous substance lists

b) Location and maintenance of SDS’s

c) Employee Training Records

10. Responsibility

a) The ESCO Group Safety Director is responsible for updating SDS’s, coordination of training and revising standards to assure compliance with the Right to Know Laws.

b) Supervision will be held accountable for enforcing the established work rules for employees to ensure chemicals are being handled and used properly to eliminate or reduce exposures.

c) Every employee will accept responsibility for safely performing their work in accordance with established work practices and precautions outlined on hazardous materials.

11. Notifying Other Contractors

a) A copy of the SDS sheets and inventory for all chemicals on site will be given out before construction begins to other contractor.  Other contractors shall submit their SDS sheets and inventory lists to ESCO Group. An inventory sheet shall be kept on the jobsite for review for any person to request.

b) In non-routine type situations that employees might encounter with unlabeled pipes or containers; these items shall be addressed immediately to the ESCO Group Safety Department so they can be identified.  



PROCESS SAFETY MANAGEMENT (PSM)

1. Purpose

a) The purpose of this program is to inform and educate employees of the hazards associated with the catastrophic releases of toxic, reactive, flammable or explosive chemicals.   Employees shall be informed of prevention and minimization methods of a release of PSM qualifying chemicals.  

b) ESCO Group does not utilize or have processes that present a PSM hazard to the jobsite, they are still subject to the PSM guidelines due to their customer’s processes and the potential to perform work in said areas.  Several sites in which ESCO Group regularly performs work possess chemicals that meet the requirements of the standard. 

2. Application

a) This program applies to:

i. Processes which involve chemicals at or above OSHA designated threshold quantities (1910.119 Appendix A)

ii. Processes which involve flammable liquids or gases on site in one location, in a quantity of 10,000 pounds or more except for some hydrocarbon fuels used solely for workplace consumption and flammable liquids stored in atmospheric tanks that do not need the aid of a chilling or refrigeration system to keep it below normal boiling point.  

3. Objectives

a) Establish employee safe work practices to control the hazards during the operations such as: lockout/tagout, confined space entry, opening process equipment or piping.

b) Assure employees know the potential for: fire, explosion, and toxic release of applicable chemicals on applicable customer’s sites. 

c) Assure employees are aware of hot work requirements for areas within the PSM spectrum and obtain required hot work permit in accordance to policy and procedure.  No hot work shall commence until the customer’s permit is completed and authorized in accordance to policy.

d) To comply with OSHA Hazard Communication Standard 29 CFR 1910.119.

4. Scope

a) This compliance program will provide the means for transmission of the information necessary to apprise employees of the process safety management (PSM) chemical awareness when they have potential for interaction with PSM chemicals on the customer’s sites in which the employee is conducting work.  It will include the following:

i. Listing of applicable chemicals provided by customer for their property.

ii. Site specific training for customer requirements, procedures and recognition for: fire, explosion, and toxic release of applicable chemicals. 

iii. General awareness and avoidance of PSM restricted areas 

iv. Hazard recognition and prompt notification of apparent hazards to customer’s designated safety contact

v. Employees shall report any hazards found or created by any work or action taken by The ESCO Group to the customer’s safety contact immediately

vi. Immediate customer reporting methods and requirements for near misses and incidents with any association to the PSM controlled areas.

vii. Non-disclosure of our customer’s trade and process secrets.

5. Training

a) Workers to Be Trained:

i. All applicable employees exposed to PSM materials through: use, incidental interaction, or as required by customer’s policy.

ii. Training shall be documented initially and annually through weekly safety training format.

6. Training Components

a) Explanations of PSM chemicals found on site

b) Explanations of Right to Know laws

c) Availability and interpretation of SDS

d) Labeling and placarding procedures

e) Physical and health hazards of chemicals in the workplace:

i. Flammable materials

ii. Corrosive materials

iii. Toxic materials

iv. Explosives

v. Oxidizers

vi. Carcinogens

vii. Adhesives

viii. Lubricants

ix. Irritants

x. Sensitizers

f) Protective procedures

g) Protective equipment

h) Procedures for non-routine tasks

i) Emergency response procedure and 1st aid measures for exposure

j) Hazard recognition and reporting to the customer immediately 

k) Near miss and incident reporting 

l) Hot work permits and application

m) Customer trade secret requirements

7. Records

a) Location and maintenance of PSM chemicals (held by customer for their site)

b) Employee Training Records