HAZARD COMMUNICATION Plan Globally Harmonized System GENERAL: In order to comply with 29 CFR 1910.1200, the following written Hazard Communication Program (HCP) is to be implemented for personnel of this office. It will be used by ALL personnel. The Safety & Health Manager will be responsible for ensuring the program is current and enforced. A copy of this program is to be made available to an employee(s) upon hiring, and a copy will be supplied to any employee(s) upon request. The Safety & Health Manager will be contacted when a copy of the program is needed. The program will be updated when new chemicals or hazards are introduced into the working environment, and reviewed annually. The Safety & Health Manager will check all incoming dental products for the Safety Data Sheet (SDS) to ensure the most up-to-date one is on file. CONTAINER LABELING: Primary Containers The Safety & Health Manager will be responsible for all containers of hazardous dental products or chemicals entering the workplace and will assure that the chemical containers are properly labeled with: Chemical name. Hazard warnings, to include target organ. Name and address of the manufacturer, importer, or responsible party. Under the new Globally Harmonized System of Hazard Communication, the label must have four additional items of information: Signal Word Pictograms Hazard Statement Precautionary Statement Signal words: a single word used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. The signal words used are "danger" and "warning." "Danger" is used for the more severe hazards, while "warning" is used for less severe hazards. 1
Pictogram: a symbol plus a red border that is intended to convey specific information about the hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red diamond frame. There are nine pictograms under the Globally Harmonized System. However, only eight pictograms are required under the Hazard Communication Sandard. Hazard Statement: a statement assigned to a hazard class and category that describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree of hazard. Precautionary Statement: a phrase that describes recommended measures to be taken to minimize or prevent adverse effects resulting from exposure to a hazardous chemical, or improper storage or handling of a hazardous chemical. HCS Pictograms and Hazards Health Hazard Flame Exclamation Mark Carcinogen Mutagenicity Reproductive Toxicity Respiratory Sensitizer Target Organ Toxicity Aspiration Toxicity Flammables Pyrophorics Self-Heating Emits Flammable Gas Self-Reactives Organic Peroxides Irritant (skin and eye) Skin Sensitizer Acute Toxicity (harmful) Narcotic Effects Respiratory Tract Irritant Hazardous to Ozone Layer (Non Mandatory) Gas Cylinder Corrosion Exploding Bomb Gases under Pressure Flame over Circle Skin Corrosion/ burns Eye Damage Corrosive to Metals Environment (Non Mandatory) Explosives Self-Reactives Organic Peroxides Skull and Crossbones Oxidizers Aquatic Toxicity Acute Toxicity (fatal or toxic) 2
Secondary Containers If a chemical or dental product is to be transferred to a separate container, the Safety & Health Manager will ensure that the new container is properly labeled; i.e., that all secondary containers are labeled with a reproduced copy of the original manufacturer's label or with generic labels which have: The name of the product The hazard warning to include the target organ The Safety and Health Manager will review the labeling system annually and update as required as well as: ensure that the outlets for piped-in oxygen and nitrous oxide are labeled and identified properly. inform employees of the hazards associated with chemicals contained in pipes within the work areas. SAFETY DATA SHEETS (SDS): The Safety and Health Manager will be responsible for the following duties; Obtaining and Maintaining the SDS system, Review incoming data sheets for new and significant health and safety information and ENSURE that this new information is given to affected employees, Annually review the SDS system for accuracy and completeness. The SDS system shall include: Current list of all Safety Data Sheets ( hazardous chemicals or dental products) indexed by numerical number to the SDS referenced on the inventory list. The identity used on the SDS shall be the same as used on the container label. The chemical and common name of all ingredients determined to present a hazard shall appear on all SDS. SDS Standard Format The revised Hazard Communication Standard requires that the information on the SDS be presented using consistent headings in a specified sequence. Section 1. Identification Section 2. Hazard(s) identification Section 3. Composition/information on ingredients Section 4. First-Aid measures Section 5. Fire-fighting measures Section 6. Accidental release measures Section 7. Handling and storage Section 8. Exposure controls/personal protection Section 9. Physical and chemical properties 3
Section 10. Stability and reactivity Section 11. Toxicological information Section 12. Ecological information Section 13. Disposal considerations Section 14. Transport information Section 15. Regulatory information Section 16. Other information, including date of preparation or last revision Sections 12-15 may be included in the SDS, but are not required by OSHA. EMPLOYEE TRAINING AND INFORMATION: Before starting work, the Safety and Health Manager will go over the Hazard Communication Plan and the SDS with the new employee. This instruction may be accomplished with hand-outs an verbal instruction. The following media was also used: Before any new dental product or chemical is used, all employees will be informed of its use, will be instructed on safe use, and will be trained on hazards associated with the new product. All employees will attend additional training, as appropriate, to review the Hazard Communication Plan and the Safety Data Sheets. The minimum orientation and training for a new employee is: An overview of the requirements contained in the Hazard Communication Standard, 29 CFR 1910.1200. Chemicals present in their workplace operations and this office. Location and availability of the written Hazard Communication Plan. Physical and health effects of the hazardous chemicals listed on the inventory list of this program. 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 usage of engineering controls, work practices and personal protective equipment. Steps taken by our office to lessen or prevent exposure to the chemicals listed on the inventory list. Emergency procedures to follow if exposed to any chemicals. Location of SDS file and location of hazardous inventory list. Prior to a new dental product or chemical being introduced into any section of the workplace, each employee will be given information and training as outlined above by the Safety and Health Manager who is responsible for ensuring that SDS on the new chemical(s) are available prior to use. 4
INVENTORY LIST OF HAZARDOUS CHEMICALS: A list of the SDS (hazardous dental products or chemicals) used in this workplace is located in the Further information can be obtained from the SDS attached to this program or from the Safety and Health Manager. NON-ROUTINE TASKS: No non-routine tasks are known to exist at the time of preparation of this program. However, if any non-routine task is performed, employees shall be advised they must contact the Safety & Health Manager for special precautions to follow and then the Safety & Health Manager shall inform any other personnel who could be exposed. In the event such tasks are required, the Safety & Health Manager will provide the following information about such activity as it relates to the specific chemicals expected to be encountered: Specific chemical name(s) and hazard(s). Personal protective equipment required and safety measures to be taken. Measures that have been taken to lessen the hazards, including ventilation, respirators, presence of other employees, and emergency procedures. OTHER PERSONNEL EXPOSURE (CONTRACTORS): It will be the responsibility of the Safety & Health Manager to provide other personnel or outside contractors with the following information: Hazardous chemicals to which they may be exposed while in the workplace. Measures to lessen the possibility of exposure. Location of SDS for all hazardous dental products or chemicals. Procedures to follow if they are exposed. The Safety & Health Manager will also be responsible for contacting each contractor before work is started to gather and disseminate any information concerning chemical hazards the contractor is bringing into the workplace. 5
Procedures To Follow In The Event Of An Exposure or Chemical Spill EXPOSURE TO HAZARDOUS MATERIALS 1. Determine hazard from material label. 2. First aid or emergency procedures indicated on SDS. 3. If serious, medical evaluation by physician. 4. Continuous medical re-evaluation if necessary. CHEMICAL SPILL 1. Determine hazard from material label. 2. Wear appropriate protective clothing (Usually gloves, mask, eye wear, and gown). 3. Contain and remove chemicals with a chemical spill kit. 4. Place contaminated materials in appropriate containers. 5. Label containers. 6. Notify waste collector as to what chemical is contained. 7. If spill is of a very hazardous nature, call manufacturer whose phone number is on the SDS. 8. Document chemical spill- when, what, and how it was disposed. MERCURY SPILL 1. Open the Mercury Spill Kit. 2. Put on protective clothing (gloves, eyewear, masks). 3. Collect the spilled mercury in the dust pan using the scraper. 4. Place the collected mercury in the amalgam waste container. 5. Use mercury sponges to clean up residual mercury in the spill area. 6. Place contaminated mercury sponges in disposal bag. 6
EXAMPLES OF SECONDARY CONTAINERS REQUIRING LABELING X-RAY PROCESSOR TANKS DISINFECTING TUBS PLASTER & STONE BINS OXYGEN & NITROUS OXIDE OUTLETS AMALGAM CAPSULES PLACED IN OPERATORIES ANY UNLABELED BOTTLES OR CONTAINERS MAKING YOUR OWN CHEMICAL SPILL KIT USE A CONTAINER SUCH AS A PAIL THAT HAS A LABEL "CHEMICAL SPILL KIT" CHEMICAL SPILL INSTRUCTIONS UTILITY GLOVES & PROTECTIVE EYE WEAR KITTY LITTER BAKING SODA DUST PAN & WHISK BROOM & SPONGES 7
CHECKLIST FOR HAZARD COMMUNICATION PROGRAM Date: Initials: The key elements that each employer must implement are a written program, employee training, and program availability. 1. Have you prepared a written list or inventory of all the hazardous dental products or chemicals present in the workplace? 2. Are you prepared to update your hazardous chemical list? 3. Do you have up-to-date Safety Data Sheets (SDS) for those materials on your hazardous chemical lists? 4. Is the list of hazardous chemicals cross-referenced (have an SDS index number) so that identifiers on the list refer to the SDS? 5. Have you developed a system to ensure that all incoming hazardous products or chemicals are received with proper labels and SDS? 6. Do you have procedures in your workplace to ensure proper labeling for secondary containers that hold hazardous products or chemicals? 7. Do you have a complete list of the chemical hazards and precautions that you can give to outside contractors? 8. Have your employees been informed of the hazards associated with performing non-routine tasks (i.e., confined space, repair and maintenance operations)? 9. Is your hazard communication program in writing and available to your employees? 8
INFORMATION AND TRAINING Have you developed an employee information and training program which includes the following: 10. Does the training cover all types of harmful products and chemicals with which the employee may come into contact under normal usage and unforeseeable emergency? 11. Are your employees aware of the specific requirements in the Hazard Communication Program (HCP)? 12. Does your program train employees in location and availability of your written Hazard Communication Plan, including lists of dental products and SDS? 13. Does your training program include the explanation of labels and warnings that have been established in their work areas? 14. Do your employees understand methods to detect presence or release of chemicals in the workplace? Visual and odor in dentistry. 15. Are employees trained in the proper work practices and personal protective equipment in relation to the hazardous products or chemicals in the work area? 16. Does the training include an explanation of the labeling system and the SDS the employees can obtain and use? 17. Have you worked out a system to ensure that new employees are trained? 18. Do you have a system to ensure that the current (up-to-date) SDS are in work areas where the products or chemicals are used? 19. If you become aware of new hazards relating to a dental product or chemical in use, do you have a system for informing the employees? 9