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C.7. PRECIOUS METAL RECOVERY

PURPOSE
To establish procedures that ensure the safe recovery and recycling of all precious metals used in dental clinic operations, minimize metal exposure to both patients and dental staff, and comply with State regulations.

PROCEDURE

The [appropriate individual] will be responsible for all scrap precious metal collected in the dental clinic to specific officials for their disposal.



Amalgam

See Mercury Hygiene Policy



Silver (Omit this section if x-rays are not processed in the dental clinic)

A silver recovery system will be installed on all X ray film processors. The discharge from this system will be maintained by [appropriate individual] [frequency] according to manufacturer’s instructions. Recycling of recovered materials will be done according to manufacturer’s instructions and facility policies. To confirm that silver recovery is effective [appropriate individual] will test the effluent being discharged. Test papers and procedures will be obtained from silver recovery system manufacturer.

All out of date and non diagnostic radiographs will be collected and given to the [appropriate individual] for recycling.

Gold

All gold removed from a patient will be given to the patient. If the patient does not want the gold it will be placed with the amalgam scrap.



[Check with your amalgam recycler to confirm gold may be accepted with scrap amalgam]

C.8 HAZARDOUS COMMUNICATIONS

Review this policy to ensure conformity with general facility Hazardous Communications policies and forms. Forms or procedures covered in the General Facility Policies and Procedures may be omitted from the Dental Specific Policy and Procedure Manual.

PURPOSE
The purpose of this Written Hazard Communication program is to ensure that:


1. Hazardous substances present in the work place are properly identified and labeled.
2. Employees have access to information on the hazards of these substances.


  1. Employees are provided with information on how to prevent injuries or illnesses due to exposure to these substances.




  1. Identify by job title who has the responsibility for maintaining the program, the MSDS sheets, conduct training, etc.


Note: This program will be available to all employees for review and a copy will be located in the following area(s):
Location:

1.

2.

3.
PROCEDURE

The dental clinic will follow all Hazardous Communications policies and procedures in place at [facility]. [Insert dental specific HazCom procedures]


(If the facility does not have a comprehensive Haz Com policy, or if the dental clinic chooses to have a separate policy, use the OHSA recommended procedures below.)
AUTHORITY AND REFERENCE
Occupational Safety and Health Administration (OSHA) 29 CFR 1910.1200
Dept. of Commerce (Chapter 32) (COMM) 32.15

HAZARD DETERMINATION
A. A "hazardous substance" is a physical or health hazard that is listed as such in either:
1. 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration.
2. Threshold Limit Values for Chemical Substances and Physical Agents in the Work Environment (latest edition), American Conference of Governmental Industrial Hygienists (ACGIH).
B. A "hazardous substance" is regarded as a carcinogen or potential carcinogen if it is identified as such by:
1. National Toxicology Program (NTP), Annual Report on Carcinogens (latest edition).
2. International Agency for Research on Cancer (IARC) Monographs (latest edition).
3. 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety and Health Administration.
C. Manufacturers, importers and distributors will be relied upon to perform the appropriate hazard determination for the substances they produce or sell.
D. The following materials are not covered by the Hazard Communication Standard:
1. Any hazardous waste as defined by the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976, as amended (42 USC 6901 et seq.) when subject to regulations issued under that act by the Environmental Protection Agency.
2. Tobacco or tobacco products.
3. Wood or wood products. NOTE: Wood dust is not exempt since the hazards of wood dust are not "self-evident" as are the hazards of wood or wood products.
4. Consumer products (including pens, pencils, adhesive tape) used in the work place under typical consumer usage.
5. Articles (i.e. plastic chairs).
6. Foods, drugs, or cosmetics intended for personal consumption by employees while in the work place.
7. Foods, drugs, cosmetics, or alcoholic beverages in retail stores packaged for retail sale.
8. Any drug in solid form used for direct administration to the patient (i.e. tablets or pills).


APPLICATION
This program applies to the use of any hazardous substance which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.

RESPONSIBILITY FOR COMPLIANCE
A. The administration of this program will be the responsibility of (person/position designated). The administrative responsibilities of this individual/position will include:
1. Identification of the employees to be included in the Hazard Communication Program.
2. Development and maintenance of a hazardous substance master inventory.
3. Coordination and supervision of employee training.
4. Coordination and supervision of the facility's container labeling program.
5. Coordination of any necessary exposure monitoring.
6. Coordination and supervision of required recordkeeping.
7. Periodic evaluation of the overall program.
B. Employees are responsible for following all safe work practices and using proper precautions required by the guidelines in this program.
HAZARDOUS SUBSTANCE INVENTORY
A. (person/position designated) is responsible for compiling, maintaining, and updating, when necessary, a master list of hazardous substances used or produced in the facility. The inventory list will include the common identity or trade name of the product and the name and address of the manufacturer. Hazardous substances will be listed alphabetically by manufacturer. Substances which are not in containers will also be included on the inventory list, e.g., welding fumes, carbon monoxide from a fork lift, etc. (See Form #1)
LABELING
A. (person/position designated) is responsible for evaluating labels on incoming containers. Each label must contain the following information:
1. Identity of the substance.
2. Appropriate hazard warning.
3. Name and address of the manufacturer.

B. If the label is not appropriate, (person/position designated) will notify the manufacturer (or supplier) that the label is not adequate. (See Form #2)


(person/position designated) will send a second request to the manufacturer if the correct label is not received within 30 days. (See Form #3)
(person/position designated) is responsible for preparing an appropriate label if one is not supplied by the manufacturer within the second 30 days.
A container will not be released for use until an appropriate label is affixed to the container.
C. Labels will be removed if they are incorrect. When the container is empty it may be used for other materials provided it is properly cleaned and relabled.
D. Each department supervisor is responsible for ensuring that all containers used in his/her department are labeled properly and remain legible. Defacing labels or using them improperly is prohibited.
E. Unlabled portable containers, such as pails and buckets, should be used by one employee and emptied at the end of each shift. If the secondary containers are used by more than one employee and/or its contents are not emptied at the end of the shift, the department supervisor is responsible for labeling the container with either a copy of the original label or with a generic label which has a space available for appropriate hazard warnings.
*F. Piping systems shall be painted at access points and every 10 feet where the piping is 8 feet or closer to employee contact.
1. Piping shall be painted as follows:
a. (substance)(color)

b. (e.g., oxygen) (e.g., green)


MATERIAL SAFETY DATA SHEETS
A. MSDS's will be available to the employees on all hazardous substances to which there is potential or actual exposure. (person/position designated) is responsible for ensuring that MSDS are available on all incoming products. A product will not be released for use until a completed MSDS is on file. (See Form #4)
If the MSDS is not available, (person/position designated) will notify the manufacturer that MSDS is needed. (See Form #5).
(person/position designated) will send a second request to the manufacturer if the MSDS is not received within 30 days. (See Form #6)
B. (person/position designated) is responsible for the review of all incoming MSDS's. If the MSDS is not complete, it will be returned to the manufacturer with a request for the missing information. (See Form #7)
(person/position designated) will send a second request for the missing information if a complete MSDS is not received within 30 days. (See Form #8)
*C. (person/position designated) will request an MSDS on the purchase orders of all new products. (See Form #9)
D. (person/position designated) is responsible for compiling and updating the master MSDS file. This file will be kept at (Name of location).
Copies of MSDS's will be kept in the following areas:
Department Location
[state department] [state location]
E. Employees will have access to these MSDS's during all work shifts. Copies will be made available upon request to (person/position designated). (See Form #10)
F. (person/position designated) is responsible for updating the data sheets to include new information as it is received. A notice will be posted to inform employees that revised information has been received. (See Form #11)
EMPLOYEE TRAINING
A. Prior to starting work with hazardous substances, each employee will attend a Hazard Communication Training Session where they will receive information on the following topics:
1. Policies and procedures related to the Hazard Communication Standard.
2. Location of the written Hazard Communication Program.
3. How to read and interpret an MSDS.
4. Location of MSDS's.
5. Physical and health hazards of hazardous substances in their work area.
6. Methods and observation techniques to determine the presence or release of hazardous chemicals.
7. Work practices that may result in exposure.
8. How to prevent or reduce exposure to hazardous substances.
9. Personal protective equipment.
10. Procedures to follow if exposure occurs.
11. Emergency response procedures for hazardous chemical spills.
B. Upon completion of the training program, each employee will sign a form documenting that he/she has received the training. (See Form 12)
C. Whenever a new employee is transferred or hired, he/she will be provided training regarding the Hazard Communication Standard. The training session will be conducted by _________________ before the start of his/her employment if possible.
D. (person/position designated) is responsible for identifying and listing any non-routine hazardous task performed at this facility. (person/position designated) will conduct training on the specific hazards of the job and the appropriate personal protective equipment and safety precautions and procedures. (See Form 13)
E. When a new substance is added to the inventory list, (person/position designated) is responsible for reviewing the MSDS for potential health effects. If the product presents a new health hazard (causes health effects unlike those covered in the training session), the ((person/position designated)) is responsible for notifying all affected employees about the new health effects which result from exposure to the new substance.
*A copy of the new Material Safety Data Sheet (MSDS) will be posted by (person/position designated) for 30 days. Both the new Material Safety Data Sheet and the Employees New Substance Signature Form will be placed above or near the MSDS information binder. Each affected employee must read the MSDS and sign the signature form. (See Form #11)
INFORMATION TO CONTRACTORS
A. (person/position designated) is responsible for providing outside contractors with the following information:
1. Hazardous chemicals to which they may be exposed as a result of working in this facility.
2. Suggestions for appropriate protective measures.
B. Contractors that are potentially exposed to hazardous chemicals present at the facility will not be allowed to begin work until they have been provided information concerning these hazards and have signed a form to document this exchange. (See Form #14)
C. (person/position designated) is responsible for obtaining information from contractors on all hazardous substances to which State employees may be exposed as a result of the contractor's work at the facility. (See Form #15). (person/position designated) will notify affected

employees about the health affects that may result from exposure to each substance.


PERSONNEL POLICIES
When an employee is not following safety and health rules regarding working with a hazardous substance, disciplinary action will be taken.
RECORD KEEPING

A. All MSDS's will be kept for a period of ____ years after the use of the substance has been discontinued. EXCEPTION: If an employee exposure to a particular hazardous chemical occurs, the MSDS for that product will become part of the employee's medical records.

Medical records must be kept for 30 years.
Note: “Exposure” or “exposed” means that an employee is subjected to a toxic substance or harmful physical agent in the course of employment through any route of entry (inhalation, ingestion, skin contact or absorbtion, etc.), and includes past exposure,

but does not include situations where the employer can demonstrate that the toxic substance or harmful physical agent is not used, handled, stored, generated, or present

in the workplace in any manner different from typical non-occupational situations.
*B. The master inventory list will also be kept for ____ years.
COMMUNITY HAZARD COMMUNICATION
(person/position designated) is responsible for responding to requests from members of the community on hazardous substances used in the facility.
EMERGENCY RESPONSE PROCEDURES FOR HAZARDOUS CHEMICAL SPILLS
A. When a hazardous chemical spill occurs, follow these procedures:
1. Move all employees away from spill to a safe environment.
2. Call 911 or the designated emergency response number in your area to notify the

necessary response team for the hazardous chemical spill.


3. Retrieve the Hazard Communication Information Binder, if possible.
a. Locate the MSDS for the hazardous chemical which spilled.
b. If requested, provide the MSDS to the Emergency Response Team.

Note: Do not try to contain the spill. The Emergency or Hazardous Material

Response Team is trained to deal with hazardous chemical spills.


PROGRAM EVALUATION
[person/position designated] will conduct an evaluation of the Hazard Communication program annually. The individual responsible for the items identified for improvement will be notified in writing. It is expected that action will be taken to correct the item within five working days. (See Form #16)
* At least annually, ___(indicate number) employees will be interviewed to determine the effectiveness of the Hazard Communication Program. Each interview will access the employee's retention of information given during the training session, use of MSDS's and response to chemical spills (if applicable). The results of each interview will be recorded on the Employee Interview Form. (See Form #17) The Employee Interview Form will be retained on file for 12 months.

This written program has been developed by the Bureau of State Risk Management, Department of Administration and is available on computer disk. (File name a:\hazcom.doc). It may be adapted to fit the particular needs of your facility. The program was adapted from a written program originally developed by the Occupational Safety and Health Administration (OSHA).


Note: When there is an asterisk (*) placed in front of a guideline, then this policy is not required by the Hazard Communication Standard or the Employees Right-To-Know Law.

Form #1

HAZARDOUS SUBSTANCE INVENTORY


Organization :_______________________________________________ Location: ____________________________________


Manufacturer

Product Name

Quantity

MSDS

Yes/No

Work Area












































































































































































































































































































































Completed By: _________________________________________________________Date: _____________________________

Form #2 LETTER TO REQUEST A COMPLETE LABEL

TO: Chemical Manufacturer, Vendor, Distributor

FROM: (Agency Name, Address)

DATE:

RE: Chemical Labels

We are using (number) of your products and in evaluating the label(s) on (this/these) product(s), we determined that the label(s) (is/are) not appropriate for the following reason(s):
Product Name Reason Label Is Not Appropriate

Please clarify the wording on (this/these) label(s) or send (a) revised label(s). Your prompt attention is necessary for us to fully implement our Hazard Communication Program. Please respond to this request no later than (date 14 days after the date of this letter).
Thank you for your cooperation.


* A tickler file should be established to notify the responsible individual in 14 days that their request for a revised label has not been received and that a second notice is needed.

Form #3 SECOND REQUEST FOR A COMPLETE LABEL

TO: Chemical Manufacturer, Vendor, Distributor
FROM: (Agency Name, Address)
DATE:
RE: Labels

On (date) we notified you that the warning label for your product(s) was incomplete. The label is not appropriate for the following reason(s):
Product Name Reason Label Is Not Appropriate

We requested that you supply us with this information by (date). Please clarify the wording on (this/these) label(s) or send (a) revised label(s). Your prompt attention is necessary for us to fully implement our Hazard Communication Program. Please respond to this request no later than (date 14 days after the date of this letter).
Thank you for your cooperation.

Form #4 CHECKLIST OF REQUIRED MSDS INFORMATION
The Hazard Communication Standard 1910.1200 requires that 13 items of information be included in Material Safety Data Sheets provided to purchasers. There is no specified order for these items; they may be found anywhere on the MSDS. If the preparer of the MSDS has found no relevant information for a given item, the MSDS must be marked to indicate that no applicable information was found. This checklist should be used to determine the completeness of the MSDS. It does not assess the accuracy of the information.
Check Box If Item Is Complete
1. The identity used on the label.
2. Chemical and common names - may be the same as #1.
3. Physical and chemical characteristics of the hazardous ingredients (e.g., flash

point, appearance and odor).
4. Physical hazards (e.g., combustible, unstable).
5. Health hazards (e.g., corrosive) plus signs and symptoms of exposure and medical conditions aggravated by exposure.
6. Primary route(s) of entry (e.g., inhalation).
7. Air exposure limits (e.g., PEL, TLV).
8. Carcinogenicity.
9. Precautions for safe handling and use (e.g., storage, waste disposal).
10. Control measures (e.g., personal protection).
11. Emergency and first aid procedures.
12. Date of preparation of MSDS.
13. Name/address/phone number of responsible party.



PRODUCT:




MANUFACTURER:

CHECKED BY: DATE OF MSDS:

Form #5 LETTER TO REQUEST MSDS

TO: Chemical Manufacturer, Vendor, Distributor

FROM: (Agency Name, Address)

DATE:

RE: Material Safety Data Sheets (MSDS)

We are using (number) of your products and need (a) Material Safety Data Sheet(s) in order to complete our Hazard Communication Program.
Please send (a) Material Safety Data Sheet(s) on the following products:


Your prompt attention is necessary for us to fully implement our Hazard Communication Program. Please send the MSDS(s) no later than (date 15 days after the date of this letter).
Thank you for your cooperation.


* A tickler file should be established to notify the responsible individual in 15 days that their request for an MSDS has not been received and that a second notice is needed.

Form #6 SECOND REQUEST FOR MSDS


TO: Chemical Manufacturer, Vendor, Distributor
FROM: (Agency Name, Address)
DATE:
RE: Material Safety Data Sheets (MSDS)

On (date) we requested (an) Material Safety Data Sheet(s) on the following product(s):


We have not received (it/them). Your prompt attention to this is necessary for us to complete our Hazard Communication Program. Please respond to this second request by (date 15 days after the date of this letter).
Thank you for your cooperation.

Form #7 LETTER TO REQUEST A COMPLETE MSDS

TO: Chemical Manufacturer, Vendor, Distributor
FROM: (Agency Name, Address)
DATE:
RE: Material Safety Data Sheets (MSDS)

In reviewing the Material Safety Data Sheet(s) for your product(s), the following required information (according to the OSHA Hazard Communication Standard 1910.1200) was not on the MSDS:
Product Name Reason MSDS Is Not Complete

Please supply us with this information. Your prompt attention to this is necessary for us to fully implement our Hazard Communication Program. Please send this information by (date 15 days after the date of this letter).
Thank you for your cooperation.


* A tickler file should be established to notify the responsible individual in 15 days that their request for a revised MSDS has not been received and that a second notice is needed.
Form #8 SECOND REQUEST FOR A COMPLETE MSDS

TO: Chemical Manufacturer, Vendor, Distributor
FROM: (Agency Name, Address)
DATE:
RE: Material Safety Data Sheets (MSDS)

On (date) we notified you that the Material Safety Data Sheet(s) for your product(s) (was/were) incomplete. The following required information was not on the MSDS(s):
Product Name Reason MSDS Is Not Complete

We requested that you supply us with this information by (date) . We have not received this information. Your prompt attention to this is necessary for us to complete our Hazard Communication Program. Please respond to this second request by (date 15 days after the date of this letter).
Thank you for your cooperation.

Form #9

LETTER TO ACCOMPANY PURCHASE ORDERS



This is a notice to chemical vendors concerning the need for MSDS’s and container labeling. This letter should be attached to purchase orders for all chemicals or other hazardous substances.



TO: Chemical Manufacturer, Vendor, Distributor

FROM: Organization Name and Address

DATE:

RE: Hazard Communication Responsibilities

Attached to this letter is a purchase order for the chemicals which we plan to utilize in our facility. Our receiving personnel have been instructed to accept only containers which have been properly labeled and identified. Improperly labeled containers will result in refusal of the shipment. We would appreciate your cooperation in this matter.
We expect to receive Material Safety Data Sheets (MSDS) prior to receipt of our initial order and/or when an MSDS has been revised. If your policy is different, or has changed since our last order, please notify us as soon as possible. To assist us, we would appreciate if you would record the responsible party information on the shipping papers.
If you have any questions, please do not hesitate to contact me. Thank you for your cooperation. I look forward to working with you in the future.
Yours truly,


(Name of Purchasing Director/Program Director)

NOTE: THIS LETTER SHOULD BE ATTACHED TO THE INITIAL AND/OR TO EACH PURCHASE ORDER FOR CHEMICALS OR HAZARDOUS SUBSTANCES


Form #10
REQUEST FOR CHEMICAL HAZARD INFORMATION
(Use a separate form for eachchemical/material)
Name of Requester (S): Date:
Social Security Number:
Department:
Name of Chemical/Material:
Manufacturer:
Description:

(Please describe the material as completely as possible)





Date







Employee or Union Representative Signature



Received copy of MSDS: Yes No


Copy provided by: Date:

Form #11
Employee's New Chemical/Substance Signature Form
Name of New Chemical/Substance:
Vendor's Name:
Location:
Date the Chemical Arrived:
Date of Posting (MSDS) Form:
This chemical may have health effects not covered during your initial Hazard Communication Training Session. Each affected employee is asked to read the attached Material Safety Data Sheet (MSDS) to understand the new health effects for the following chemical:
Upon reading the Material Safety Data Sheet (MSDS), each employee must sign and date this form.
1. 6.
2. 7.
3. 8.
4. 9.
5. 10.


Form #12 EMPLOYEE HAZARD COMMUNICATION TRAINING RECORD
The following employee(s) have completed training in Hazard Communication. Each trained employee is now knowledgeable in all 11 different training topics covered in the Hazard Communication Written Training Program.
· Policies and procedures related to the Hazard Communication Standard.

· Location of the written Hazard Communication Program.

· Physical and health hazards of hazardous substances in their work area.

· How to prevent or reduce exposure to hazardous substances.

· Personal protective equipment.

· Methods/observation/techniques to determine the presence or release of hazardous chemicals.

· How to read and interpret MSDS.

· Location of MSDS.

· Work practices that result in exposure.

· Procedures to follow if exposure occurs.

· Emergency response procedures for hazardous chemical spills.


Employee's Name

Employee's Signature

Date of Training

Trainer

Trainer's Signature






































































































































































Form #13

Non-Routine Hazardous Task

Training Documentation Form

The following employee(s) has/have been trained to perform work in what is considered a "non-routine hazardous task."


Nonroutine Hazardous Task

Employee(s) Name

Date of Training

Trainer













Form #14

DOCUMENTATION OF INFORMATION GIVEN

TO CONTRACTORS PERTAINING TO HAZARD COMMUNICATION

Facility: _____________________________________ Location: ________________________________________


Date

Contractor

Information Given

Contractor’s Signature
























































































































































































Form #15
LETTER TO CONTRACTORS


Subject: OSHA HAZARD COMMUNICATION STANDARD
To Whom it May Concern:
The Occupational Safety & Health Administration (OSHA) Hazard Communication Standard (29CFR 1910.1200) states that contractors/suppliers must be informed of the hazardous chemicals their employees may be exposed to while performing their work and any appropriate protective measures. In order to comply with this requirement, (Name of facility) has developed a list of all the hazardous chemicals known to be present in our facility. A Material Safety Data Sheet (MSDS) is also on file for each of these chemicals and/or hazardous substances. This information is available to you and to your employees upon request.

In order to protect the safety and health of our own employes, contractors/suppliers must provide (upon request) an MSDS on any hazardous chemical(s) or material(s) which they bring into this facility. Failure to provide this information in a timely manner will result in the removal of the contractor/supplier from the premises.
Each employer is also responsible for notifying any subcontractor they employ regarding the requirements of OSHA's Hazard Communication Standard and other provisions described in this letter.
If we can be of any further assistance, please feel free to contact me at (phone number).

Sincerely,

Form #16

HAZARD COMMUNICATION ANNUAL

PROGRAM SUMMARY
Training




Number of Training

Courses Presented:


Number of Employees Trained:

New-employee training:







Work-area-specific training:







New-substance training:







Other training:







Total courses/employees

















Hazardous Substances








# of MSDS on File:

Previous Total:# of Different Hazardous Substances in Use:







New This Year:







Revised Total:


The following activities have been completed:
Written plan is up to date.

Hazardous substance inventory has been updated.

All training is up to date.

All MSDS are up to date.

All products are properly labeled.

All portable containers are properly labeled.
If any of the above activities are not complete, explain:

Completed By: __________________________________________ Date: ________________________

Form #17
EMPLOYEE HAZARD COMMUNICATION INTERVIEW
Date of Interview:

Interview conducted by:
!Unexpected End of Formula
Agency:
Location: ________________________________________________________________________
1. Do you feel that your organization's Hazard Communication Program is successful

overall? Yes ____ No ____ Why? ____________________________________________________________________________________________________________________________________________________________
2.What was the subject of the last training session you attended? _______________________________________________________________________

__________________________________________________________________________
3.Have you applied the information from that session? Yes ____ No ______ If yes,

how? _____________________________________________________________________

________________________________________________________________________
4. Have you had an occasion to refer to an MSDS in the last month? Yes ____ No _____

Which one?
a. Was the MSDS easy to understand? Yes ____ No ____

b. Why did you refer to the MSDS? ________________________________________________________________________
________________________________________________________________________


________________________________________________________________________

c. Did the MSDS have the information you were looking for? Yes ___ No ______

If no, what information was missing? ____________________________

___________________________________________________________________
5. Have all of the containers in your work area been properly labeled and marked?

Yes ____ No ____

6. Over the last six months, has your work area been involved in any chemical spill or emergency? Yes ____ No ____ If yes, describe

7. Were you prepared? Yes ____ No ____ If not, why not?____________________________

________________________________________________________________________

________________________________________________________________________


Form # 18

HAZARD COMMUNICATION CHECKLIST



No

Has a program for hazard communication training been established?

Yes

Has a program for hazard communication procedures been established

and is the program reviewed on an annual basis?




Are chemical injuries tracked for program improvement?




Have chemical hazard control procedures developed for each job?




Has a chemical inventory of the facility been conducted?




Are the procedures reviewed on an annual basis?










Do the hazard communication procedures include the following:

  • A statement of the intended use?

  • Steps for labeling of containers?

  • Steps for safe issuance, use, transfer and disposal of chemicals?





































Are control procedures inspected at least annually?




Are periodic inspections conducted by a competent employee?




Is the inspection designed to correct deviations or inadequacies?




Is the inspection documented?




Have MSDSs been produced in accordance with 29CFR 1910.1200?










Have employees been informed of:

  • The requirements of 29 CFR 1910.1200?

  • Any operations in their work area where hazardous chemicals are present?

  • The location and availability of the written HAZCOM program?

  • The location and availability of the lists of hazardous chemicals?














































Does employee training include at least:

  • Methods & means necessary to detect the presence or release of a chemical?

  • The physical and health hazards of the chemicals in the work area?

  • The steps employees can take to protect themselves from the chemicals?

  • The details of the written program?














































Have criteria for recurrent training been developed?




Is the training documented?




Is the training conducted by a competent person?

Is retraining required whenever there is a change in job assignments?








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