Written Hazard Communication Plan

Written Hazard Communication Plan

I. PURPOSE

As part of its commitment to employee health and safety, ENPOINTE has developed this written Hazard Communication (or Right-to-Know) Plan in accordance with the requirements established by OSHA 29 CFR 1910.1200 and enhanced by MN Rules Chapter 5206. This plan is designed to provide ENPOINTE employees with the “right-to-know” about workplace hazards which they may encounter while working at the facility. While ENPOINTE continuously strives to reduce or eliminate the use of hazardous chemicals from its production processes, employees must be aware of the hazards certain chemicals and other potentially harmful physical agents can present.

II. SCOPE

This ENPOINTE Hazard Communication Plan will:

  • explain how to access and understand SDSs for chemicals used on site;
  • describe procedures for labeling containers to convey chemical hazards;
  • describe how and when employees receive Employee Right-to-Know (RTK) Training; and
  • assign duties for managing SDSs, labeling containers and providing RTK Training.

III. POLICY

It is ENPOINTE’s policy to:

  • purchase and use the least hazardous substance whenever possible;
  • maintain an inventory list (see SDS Book(s) table of contents) of all hazardous materials stored and used at the facility;
  • maintain a complete, up-to-date, well-organized collection of SDSs for all chemicals used;
  • ensure employees are aware of precautions to observe when handling hazardous materials;
  • ensure that appropriate personal protective equipment (PPE) is available and used in required areas; and
  • provide initial and annual training to all employees who encounter hazardous chemicals or other physical hazards as part of their routine job duties (includes all production employees).

IV. SAFETY DATA SHEETS

Hazard information for chemicals used at ENPOINTE can be found in Safety Data Sheets or SDSs. SDSs are readily available to all ENPOINTE Employees. SDSs provide key safety information about the chemical constituents of each product used including:

  • emergency and first aid information;
  • spill prevention, handling, disposal and spill clean-up measures;
  • toxicological properties including OSHA permissible exposure limit (PEL) information;
  • routes of entry (e.g, inhalation, skin penetration); and personal protective equipment (PPE) recommendations to prevent exposure.

V. OTHER PHYSICAL HAZARDS

ENPOINTE’s work environment presents hazards other than chemicals. Noise, heat, non-ionizing radiation (i.e., non-radioactive light sources), electrical hazards, and confined spaces are all examples of “non-chemical” hazards which may be present on site. ENPOINTE has separate programs for addressing noise (see hearing conservation), electrical hazards (see lockout/tagout), and confined spaces (see confined space entry program). Employees working around potentially hazardous light sources and hot surfaces receive job-specific training to make them aware of these hazards (since these hazards are easily controlled, no formal program has been developed in these areas).

VI. LABELS AND WARNINGS

All chemical and physical agents must be properly labeled indicating their hazards. For chemicals used directly from vendor-supplied commercial containers, ENPOINTE will rely on the hazard information provided on those labels (these containers are periodically reviewed to assure that adequately descriptive hazard information is provided). When product use requires transferring chemicals into safety cans or “bench-top” containers, ENPOINTE will label these containers using the Hazardous Materials Identification System (HMIS). These labels will include chemical or product name, chemical manufacturer, and HMIS codes for health, flammability, reactivity (4=highest hazard, 0=lowest), and personal protective equipment (A= safety glasses, B= glasses and gloves, etc.). An HMIS poster is located at the Employee Right-to-Know center to provide these code definitions.

All equipment or work areas that generate harmful physical agents at a level that approximates or exceeds permissible exposure limits (e.g., “hearing protection required”) or common sense-based safety standards (e.g., “eye protection required” at grinding wheel) will be identified with appropriate signs.

VII. EMPLOYEE TRAINING

All ENPOINTE employees who encounter chemical or physical hazards in the course of their job duties receive hazard communication or “Right-to-Know” training on an annual basis. New employees are provided with a one-on-one session instructed by the Department Manager and/or Human Resources prior to commencing job duties.

Right-to-Know training includes:

  • How to read and understand SDSs;
  • How to properly label containers and understand the HMIS labeling system;
  • PPE and safe work practices; and
  • A basic introduction to toxicology to help employees better understand the effects of chemical exposures

VIII. PROGRAM IMPLEMENTATION RESPONSE

Safety is everyone’s responsibility at ENPOINTE Employees should make their Department Manager aware of any concerns regarding chemical or physical hazards. If an SDS cannot be found, it should be reported to the Department Manager for immediate action.

While every ENPOINTE employee should contribute, Department Managers are responsible for maintaining SDSs; the Compliance Manager’s quarterly check-ups and annual audit will serve as a check on proper container labeling and hazard signing; and the Compliance Manager will conduct annually-required Right-to-Know training for all affected employees.

The Compliance Manager will set conventions for container labeling; however, the ENPOINTE policy is: If it’s your container, you label it! By each employee contributing, ENPOINTE can assure a safe and healthy working environment for all.

 

Reviewed 10/31/22