Hazardous Communication Program
(Right to Know)
Background Information & Purpose
The Hazard Communication Program or "Right to know" law was adopted by Oregon Workers' Compensation Department (WCD) in June 1984. This law is supported by the Federal government and prior to this date only applied to private agencies. With WCD adoption of the law, it was expanded to accommodate public agencies as well. The intent of the law is to provide additional health protection to employers and employees through increased awareness of substances used in the workplace. Chemical manufactures are charged with the responsibility of determining if the final product contains a hazardous substance. If so, manufacturers then are to provide written information on a Material Safety Data Sheet (MSDS) regarding the chemical properties of a substance. Employers and users were required to have a complete program in effect by May 25, 1986.
The County's Risk Management Committee assigned Human Resources Department the task of development and implementation of this program. Elected Officials and Department Heads have designated an employee responsible for the program within that department and who serves as contact person. Each department will have MSDS's available to employees. Employees will be trained to properly handle hazardous products.
Hazard Communication Program
Douglas County has developed a Hazard Communication Program to remain in compliance with Department of Insurance and Finance administrative rules (OAR 437; Division 2). The County intends to provide information to employees regarding chemical hazards and the control of hazards with a Hazard Communication Program that includes container labeling, Material Safety Data Sheets, and employee training.
The written program will be available to all employees for review within each County Department and Human Resources Department. Department Heads will designate an employee to be responsible for the program and who will serve as contact person.
The following procedures outline the accomplishment of this program.
1. Container Labeling
The chemical manufacturer, importer, or distributor shall ensure each container of hazardous chemicals leaving their workplace is appropriately labeled. No container of hazardous chemicals received by Douglas County will be used until the following label information is verified.
- Identity of hazardous chemical(s)
- Appropriate hazard and necessary work practice warnings or practice warnings are noted
- The name and address of the manufacturer
When freight is received by departments, the designated employee will determine that containers in the shipment are appropriately labeled.
Secondary Containers are containers which chemicals are transferred to from the original container. To further ensure that employees are aware of the chemical hazards of materials used in their work areas, all secondary containers will be labeled as to:
- Identity of hazardous chemical(s)
- Appropriate hazard warnings
The designated department employee will ensure that all secondary containers are labeled with either an extra copy of the original manufacturer's label or with generic labels which have a block for identity and blocks for the hazard warning. Supplemental labels for this purpose are available in the Office Supply Stockroom.
This does not apply to portable containers into which hazardous chemicals are transferred from labeled containers, and which are intended only for immediate use.
2. Material Safety Data Sheets (MSDS)
Chemical manufacturers and importers will develop Material Safety Data Sheet (MSDS) for each hazardous chemical distributed. Some information the MSDS's will contain is:
- identity of all ingredients used to manufacture hazardous chemicals(s)
- the physical and health hazards of each chemical
- suggested precautionary handling practices
- name, address, and telephone number of manufacturer.
Each department will maintain a master file of each MSDS for specific chemicals used within that department. MSDS's will come to the ordering department in either of these ways: 1) included in a shipment received at the Courthouse, or 2) in shipment received directly by the department when a department orders direct. Douglas County purchase orders include a printed statement directing vendors to enclose a MSDS with each order. The designated employee will assume the responsibility of maintaining the department's master file. MSDS's will be organized so they are easily referenced.
MSDS's will be available to all employees in their work area for review during each work shift. If MSDS are not available or new chemicals in use do not have MSDS, the designated employee will obtain one directly from the manufacturer or request Purchasing to obtain it.
MSDS's will be updated or discarded when new products are used or old products discontinued.
3. Hazardous Chemicals List
A list of all known hazardous chemicals used in a department will be developed, maintained and attached to this written program. It will be available for employees to view. A copy will be sent to the Risk Manager, Human Resources Department for the County-wide file. The designated employee in each department will assume this responsibility. Further information on each noted chemicals can be obtained by reviewing the MSDS.
4. Employee Training
Employees assigned to a work place where hazardous chemicals may be involved will be given the following information and training.
- An overview of the requirements contained in the Hazard Communication Rules, OAR 437,
- Review of the chemicals present in their work area and where used,
- Location and availability of written hazard program,
- Physical and health hazards of the chemicals,
- Methods and observation techniques used to determine the presence or release of hazardous chemicals in the work area,
- How to lessen or prevent exposure to these hazardous chemicals through use of safe work practices and personal protective equipment,
- Safety emergency procedures to follow if exposed to chemicals,
- How to read labels and review MSDS to obtain appropriate hazard information.
Each department will designate a person responsible to conduct this training.
After receiving training, the employee will sign a form documenting receiving Hazardous Communication training for that department and is aware where the MSDS's are located to receive additional information. This form will be filed in the employee's department personnel file or the binder where the written hazard program is kept. The same procedures will be followed if new hazardous chemicals are introduced into the work area.
5. Hazardous Nonroutine Tasks
Periodically, employees may be required to perform hazardous nonroutine tasks. Prior to starting work on such projects, each affected employee will be given information by their supervisor about hazards to which they may be exposed during such activity.
This information will include:
- Specific chemical hazards,
- Protective/safety measures which must be utilized,
- Measures the County has taken to lessen the hazards including ventilation, respirators, presence of another employee and emergency procedures.
No employee is to begin any type of hazardous non-routine task without first receiving proper instruction from the designated departmental person.
6. Informing Contractors
To ensure that outside contractors work safely in County facilities, it is the responsibility of Building Facility Department and/or the Department engaging the contractor to provide contractors the following information:
- Hazardous chemicals to which they may be exposed while on the jobsite,
- Precautions the employees may take to lessen the possibility of exposure by usage of protective measures,
- Location of MSDS for the chemicals in the work area.
7. Chemicals in Unlabeled Pipes
To ensure that employees who work on unlabeled pipes have been informed as to the hazardous materials contained within, the following procedure has been established:
Prior to starting work on unlabeled pipes, employees will contact the designated departmental person for the following information:
- The chemical in the pipe,
- Potential hazards,
- Safety precautions to be taken.