SAFETY MANUAL

SAMPLE Section: HAZARD COMMUNICATION PROGRAM

Date revised: 20 April 2004 Page 1 of 9

[Link], Inc. has not made and does not make any warranty of any kind whatever,
express or implied, with respect to this sample written program; and all implied warranties
of merchantability and fitness for a particular purpose are hereby disclaimed by
[Link], Inc. [Link], Inc. will not be liable to anyone with respect to any
damages, loss or claim whatsoever, no matter how occasioned, in connection with the
preparation of or access to or use of this sample written program.

 2003. Aon [Link], Inc. All rights reserved.

 SAFETY MANUAL
SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 2 of 9

Table of Contents
1 Purpose.................................................................................................................. 3
2 Scope..................................................................................................................... 3
3 References............................................................................................................. 3
4 Definitions .............................................................................................................. 4
5 Procedures............................................................................................................. 4
5.1 Hazard Determination ..................................................................................... 4
5.2 Material Safety Data Sheets (MSDS’s) ........................................................... 4
5.3 Labels ............................................................................................................. 4
5.4 Non-Routine Tasks ......................................................................................... 4
5.5 Contractors ..................................................................................................... 4
5.6 Chemical Inventory ......................................................................................... 4
6 Training .................................................................................................................. 5
7 Inspections and Program Assessment................................................................... 5
7.1 Program Assessment...................................................................................... 5
8 Recordkeeping, Reporting, and Communication.................................................... 5
8.1 Recordkeeping................................................................................................ 5
8.2 Communication ............................................................................................... 5
Abbreviation ........................................................................................................... 8
Definition ................................................................................................................ 8

 2003. Aon [Link], Inc. All rights reserved.

 SAFETY MANUAL
SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 3 of 9

1 Purpose
The purpose of this section is to ensure that the hazards of all chemicals used at
(Company Name) are evaluated, and that information concerning their hazards is
provided to employees.

2 Scope
This procedure applies to all chemicals, which are produced or purchased for used in
any areas other than Research and Development Laboratories. See the (Company
Name) Chemical Hygiene Plan for chemical safety procedures in R&D labs. (Note that
Quality Control labs are considered to be part of production operations, and are covered
by this Hazard Communication Program.)
If chemicals are only stored/moved in closed containers, and never opened, then
(Company Name) will ensure that the containers are properly labeled, maintain Material
Safety Data Sheets, and give employees enough information to know what to do in case
of a leak or spill.
The OSHA Hazard Communication Standard does not apply to:
• Hazardous wastes regulated by EPA;
• Hazardous substances which are undergoing remediation/removal under EPA
regulations;

However, (Company Name) may choose to apply portions of this procedure (such as
labeling and obtaining Material Safety Data Sheets) to non-covered chemicals, in order
to provide the highest level of safety for employees.

3 References
• Hazard Communication (OSHA 29CFR1910.1200)
• Toxic and Hazardous Substances (OSHA 29CFR1910 Subpart Z)
• Threshold Limit Values for Chemical Substances and Physical Agents in the Work
Environment," ACGIH - latest edition
• IARC Monographs Database (this can be accessed online at [Link]

 2003. Aon [Link], Inc. All rights reserved.

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SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 4 of 9

• NTP Annual Report on Carcinogens (this can be accessed online at [Link]

[Link]/NewHomeRoc/[Link])

4 Definitions
Article - a manufactured item other than a fluid or particle: (i) which is formed to a
specific shape or design during manufacture; (ii) which has end use function(s)
dependent in whole or in part upon its shape or design during end use; and (iii) which
under normal conditions of use does not release more than minute or trace amounts of
a hazardous chemical, and does not pose a physical hazard or health risk to
employees. Examples of articles include pencils (even though they contain lead), cast
metal items (as long as they will not be cut or otherwise worked on), etc.
Hazardous Chemical – any chemical, which is a physical or health hazard
Physical hazard - a chemical for which there is scientifically valid evidence that it is a
combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an
oxidizer, pyrophoric, unstable (reactive) or water-reactive
A glossary of abbreviations, which are commonly used in Material Safety Data Sheets,
is included as Appendix C.

5 Procedures
5.1 Hazard Determination
A. Purchased Chemicals
(Company Name) relies on the hazard determinations performed by the
manufacturer or importers of all purchased chemicals. (Note that the term
“purchased chemicals” includes samples, which are brought in for evaluation, or any
other situations where a hazardous chemical comes on-site but may not technically
have been paid for.)

5.6 Chemical Inventory

(Insert Chemical Inventory here, or describe where it is kept and how employees can
see it whenever they need to).

 2003. Aon [Link], Inc. All rights reserved.

 SAFETY MANUAL
SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 5 of 9

6 Training
Training and information will be provided for all employees prior to exposure to
hazardous chemicals and when new chemicals are introduced to the work area. This
will cover:
• The existence and requirements of the OSHA Standard;
• Methods and observations that may be used to detect the presence or release of a
hazardous chemical in the work area (such as continuous monitoring devices, visual
appearance or odor of hazardous chemicals when being released, etc.);
• The physical and health hazards of the chemicals in the work area (this may discuss
classes of chemicals, not necessarily each and every individual chemical);

7 Inspections and Program Assessment

7.1 Program Assessment
(Title) is responsible for reviewing the Hazard Communication Program, including the
chemical inventory, at least annually, to ensure that it is up-to-date.

8 Recordkeeping, Reporting, and Communication

8.1 Recordkeeping
Training documentation will be maintained by (Title/Department).
Copies of all MSDS’s for chemicals, which have been used on site, including outdated
versions, should be kept on site for reference is case of questions regarding possible
past exposures.

8.2 Communication
All employees are entitled to review a copy of this Hazard Communication Program,
and/or the full OSHA Hazard Communication Standard at any time. To do so,
employees should (Describe Procedure).
This procedure shall also be made available to OSHA upon request.

 2003. Aon [Link], Inc. All rights reserved.

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SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 6 of 9

APPENDIX A- REQUEST FOR MATERIAL SAFETY DATA SHEETS

Dear :

(Company Name) is updating our file of Material Safety Data Sheets for hazardous
chemicals. This is a requirement of the OSHA Hazard Communication Standard
(29CFR1910.1200).
The following are chemical(s) you supply that are currently in use at our facility, for
which we do not have an MSDS:

1.
2.
3.

Please send your current Material Safety Data Sheet for each of the above to my
attention at the following address:

Sincerely,

Name
Title

 2003. Aon [Link], Inc. All rights reserved.

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SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 7 of 9

APPENDIX B – CONTRACTOR ACKNOWLEDGEMENT OF HAZARD INFORMATION

Date ________

Name of Contractor’s Company: ______________________________________

Name of Contractor’s Employees:

____________________________________________________

_____________________________________________________

_____________________________________________________

My signature below signifies that (Company Name’s) Hazard Communication Program,

including the potential chemical hazards; the labeling system, and the location of MSDS(s) has
been explained to me. I have also been informed of any applicable emergency response
procedures

While working at (Company Name), I will be bringing the following chemicals on-site. I am
providing MSDS(s) to (Company Name) and will ensure all my containers are properly labeled.

Chemicals Used by Contractor (if none, state NONE)

Signatures: Contractors: ___________________________________________

__________________________________________

(Company Name) Representative: ________________________________

 2003. Aon [Link], Inc. All rights reserved.

 SAFETY MANUAL
SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 8 of 9
Send completed form to (Title/Department)
APPENDIX C- GLOSSARY OF MSDS TERMS

Abbreviation Definition
ACGIH American Conference of Governmental Industrial Hygienists
C Ceiling exposure limit that should never be exceeded during a
workday.

CAS Chemical Abstract Service Registry Number – this number is

unique to a chemical, and can be used to help determine if
chemicals with similar-sounding names are the same material or
not.
FP Flash point of a chemical – the temperature at which a flammable
material will start burning.

IARC International Agency for Research on Cancer

LD50 Lethal dose 50. The single dose of a substance that causes the
death of 50% of a test animal population. Expressed as
milligrams or grams of material per kilogram of animal weight
(mg/kg or g/kg).
LEL / LFL Lower Explosive Limit (also called Lower Flammable Limit) of a
chemical. The minimum concentration of the chemical (in air)
that will burn.
mg/m3 Milligrams per cubic meter of air. This is a concentration ratio
expressed as weight of chemical per volume of air. Used to
compare personal exposure monitoring results to exposure
standards.
NIOSH National Institute for Occupational Safety and Health
pH A value used to express the strength of an acid or a base. A
value of 7 is neutral. From 7 up to 14 is an increasingly strong
base. From 7 down to 0 is an increasingly strong acid.
PEL Permissible Exposure Limit. This is the OSHA limit for chemical
exposures, expressed as an 8-hour average.

PPM Parts per million. This is a concentration ratio expressed as

volume of chemical per volume of air. Used to compare personal

 2003. Aon [Link], Inc. All rights reserved.

 SAFETY MANUAL
SAMPLE Section: HAZARD COMMUNICATION PROGRAM
Date revised: 20 April 2004 Page 9 of 9
exposure monitoring results to exposure standards.
S or STEL Short Term Exposure Limit. The maximum concentration that
anyone can be exposed to for any 15-minute period over the
course of the day.
RTECS Registry of Toxic Effects of Chemical Substances
T or TWA Eight hour Time Weighted Average for exposures
TLV Threshold Limit Value: issued by ACGIH, these recommended
exposure standards are updated on a more regular basis than an
OSHA PEL. Also expressed as 8-hour averages.
UEL / UFL Upper Explosive Limit (also called the Upper Flammable Limit) of
a chemical. The maximum concentration of the chemical (in air)
that will burn. (At higher concentrations, there is no longer
enough oxygen present to sustain a fire).

 2003. Aon [Link], Inc. All rights reserved.