Document 3Nw6LRo7Ln4v9ZazwM7ja7vQ0

Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training 12.4.1 Scope Hazcom Reference Document Facility Hazard Communication Program This document serves as the facility written Hazard Communication (Hazcom) Program. This document resides in the Industrial Hygiene Section of the Plant Operating Discipline Files. This document, containing hazard communication policies and practices specific to this facility, when used in conjunction with the Hazcom reference document, comprises the written Hazcom program for this facility. The current version of the Hazcom reference document is available electronically on one of the following File Servers using the paths listed: o Michigan Div. Operating Discipline File Server (via MD0633): MDCV03/OPERDISC/DOS/IND,,HYG/IHREFERENCE DOCS/HAZREF MDCV03/OPERDISC/MAC/INDHYG/IHREFERENCE DOCS/HAZREF The current version of the Hazcom Facility Template is available electronically on one of the following File Servers using the paths listed: o Michigan Div. Operating Discipline File Server (via MD0633): MDCV03/OPERDISC/DOS/IND_HYG/IHTEMPLATES/HAZCOM MDCV03/OPERDISC/MAC/INDHYG/IHTEMPLATES/HAZCOM Material Safety Data Sheets (MSDS's) This section describes how the facility obtains and files MSDS. MSDS Coordinator Location/Accessibility How Filed Obtaining MSDS's if Not Available From File The following is responsible for overseeing the MSDS file: o IH Coordinator If an updated/revised MSDS is received, it is filed in the MSDS file and the old MSDS is discarded. In Michigan, revised/updated MSDS are listed on the MIOSHA new/revised MSDS poster. The MSDS for chemicals handled or stored in the plant are maintained in the Hazard Communication Manual which is located in Bldg. 1617 (Control Room) and are accessible 24 hours a day. MSDS's are filed according to the following: o MSDS are filed alphabetically and organized by usage category (raw material, lab chemical, shop chemical etc.) For non-QA/QC facilities, contact the facility MSDS coordinator who will contact purchasing and/or the vendor and request that an MSDS be sent/faxed "as soon as possible". Another option is to call Industrial Hygiene. COnftdfNttal Published: May 23, 1996 Revised: November 27, 1996 Restrictedfor use within the Dow Chemical Compan 1 DO 007703 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training Hazard Communication List Hazardous chemicals handled and stored in this facility are listed on the Hazcom list. This section describes how the Hazcom list for this facility is maintained. Hazcom List Format Hazcom List Updating Hazcom List Responsibility Hazcom List Records Management Location of Hazcom list The Hazcom list contains all hazardous chemicals (as defined in 1910.1200) handled by this facility and the year the list was generated. The Hazcom list is maintained as: Hazcom list spreadsheet maintained in the Manual The Hazcom list is updated through the following: The Hazcom list is updated by the facility annually The following individual is responsible for creating and maintaining the facility's Hazcom list: IH Coordinator The Hazcom list is retained for the period defined in the Dow record retention guidelines (Industrial Hygiene: Section number 1502B). A copy of the current year's Hazcom list is filed behind the The Hazardous Chemicals List in the Manual Labeling Responsibility The following individual(s) are responsible for overseeing the labeling of hazardous chemicals found in the listed containers/vessels: Containers/vessels Shipped containers In-plant portable containers Stationary Vessels Person(s) Responsible Plant Logistics Coordinator Person who filled the Container Plant Maintenance Supervisor All employees are responsible for ensuring that containers they are handling are properly labeled. Stationary Vessel Labeling The chemical identity of chemicals contained in stationary vessels can be derived using the following method(s). The appropriate hazard warnings are obtained by reviewing the applicable MSDS's. Option 1 2 Method MOD graphics Labeling Description Vessel identification is determinedfrom MOD graphics in the control room. Contents of vessels can be determinedfrom the computer/computer graphics. Labeling (e.g., label, sign or placard)with the appropriate identification (vessel or chemical identity). Published: May 23. 1996 Revised: November 27, 1996 CONFIDENT! A1 Restrictedfor use within the Dow Chemical Company 12.4.1-2 DO 007704 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training 3 Vessel A written table which enables an employee to determine a Identification vessel's contents given its name and/or identification number Table is used. Vessel identification table should include: vessel name and/or number vessel location vessel chemical contents The List is located in the Plant Operating Disciplinefiles and in the Manual. 4 P&lDs Piping and Instrumentation Diagrams and process flow sheets are used to identify the chemical contents of vessels. Bldg. 1617 and Bldg. 1701 5 Written process Contents identification are defined in a written process description description, as commonlyfound in Sop's which are maintained in the Plant Operating Discipline files. Non-Stationary Container Labeling Labeling supplies for this facility can be found in Bldg. 1604 (Loading Lab), Bldg. 1702 (Warehouse), and Bldg. 1703 (Process Lab). The following methods are used to label portable containers: Option 1 Method Fill out the Label using labeling guide 2 Use Example Label Description Facility personnel complete labels using a label guide. 1) The Dow internal sample labeling guide (the Dow labeling standard can be found in Appendix G of the Hazcom Reference Document) in combination with MSD sheets/ T.I.M.E. sheets or 2) The T.I.M.E. "L" report Facility personnel use an example ofa properly completed label as basis for creating new label. Identification of The contents of unlabeled pipelines may be obtained by using any of the following methods: Pipeline Contents 1) Piping and Instrumentation Diagrams 2) Mod graphics 3) Tracing the line back to an identifiable vessel Once the contents of the pipeline have been identified, the hazards of the pipeline contents can be obtained by reviewing the appropriate MSDS, Employee Education and Training The three basic types of Hazcom training are 1) Facility-Specific, 2) New Chemical Hazard, and 3) Non-routine Tasks Hazard Communication OONFTDFNTTAL Published: May 23, 1996 Revised: November 27, 1996 Restrictedfor use within the Dow Chemical Company 12.4.1-3 DO 007705 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training Facility-Specific Hazcom Training Facility-Specific Hazcom Training Responsibility Facility-Specific Hazcom training is a one time (per person) required training conducted prior to assuming job responsibilities (for additional information refer to Hazcom reference document). The following individual is responsible for overseeing Facility-Specific Hazcom training: Method(s) of Training IH Coordinator Safety Coordinator Facility-Specific Hazcom training is conducted using the following methods: 1. The facility Safety/Health orientation video is reviewed, 2. One-on-one training is conducted by a knowledgeable person (e.g., compliance specialist, safety contact, industrial hygiene contact, or area industrial hygienist) 3, Hazcom training information is presented using a Hazcom checklist (found as an attachment at end of this program) Facility-Specific Training Documentation 4, Selfpaced study using a training notebook with an opportunityfor question and answers Facility-specific training is documented using the following: 1. Documented using DPS course number 8105 New Chemical Hazard Training New Chemical Hazard Training Responsibility 2. A hard copy of the training checklist/attendance sheet is maintained at the facility. The documentation is located in the Employee Training Files (Bldg, 1617). Training on the hazards associated with a new chemical hazard brought into the facility is conducted for employees who will be potentially exposed prior to beginning work with that chemical (for additional information refer to the Hazcom reference document) The following individual is responsible for overseeing New Chemical Hazard training: New Chemical Hazard Training Method IH Coordinator Industrial Hygienist New Chemical Hazard training is accomplished through the following method(s): 1. Safety Meeting (e.g., monthly or pre-job) 2. Management of Change 3. Hazard information is presented using a Hazcom checklist (found as an attachment at end of this program) with an opportunity for Q&A 4. Pre-start-up review Published: May 23, 1996 Revised: November 27, 1996 Restrictedfor use within the Dow Chemical Company 12.4.1-4 conftdfntiai. DO 007706 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training New Chemical Hazard New chemical hazard training is documented using the Training Documentation following: 1. A hard copy of the training checklist/attendance sheet is maintained at thefacility. The documentation is located in the Employee Training Files (Bldg. 1617). Non-Routine Task Hazard Communication Before non-routine tasks are performed, employees are instructed in the potential hazards of the tasks and are informed of the appropriate work practices to be followed. The hazards of non-routine tasks are communicated to employees through the use of one or more of the following: 1) Permits such as the Safe Work Permit, Line and Equipment Opening Permit, Confined Space Entry Permit, Hot work permits, etc.. 2) Pre-job safety meetings 3) Safety standards which describe in detail the measures which should be followed when conducting non-routine tasks 4) Following a written procedure for this task 5) Management of Change Facility-SpecificContractor employees working in this facility are apprised of: Contractor Hazard 1) How to access MSDS's for chemical's they may be exposed to Communication^) Precautionary measures that need to be taken to protect employees during normal conditions and in a foreseeable emergency 3) How to obtain label information The above information is communicated to contractors through the following methods : 1) Pre-job safety conference meeting minutes. 2) Work Permits (Confined Space Entry Permit, Safe Work Permit, Hot Work Permit). 3) Reviewing facility safety orientation video. The following person(s) is/are responsible for overseeing contractor hazard communication: Maintenance Supervisor IH Coordinator Safety Coordinator Permit Writer f ONFTDFNTTAL Published: May 23, 1996 Revised: November 27, 1996 Restrictedfor use within the Dow Chemical Company DO 007707 12.4.1-5 Operating Discipline 12 Industrial Hygiene Solvents/EDC 1 12.4 Communication and Training Hazcom Standard A copy of the applicable OSHA Hazard Communication standard can be found in Appendix F of the Hazcom reference document. Published: May 23, 1996 Revised: November 27, 1996 CONFTDFNTTAt Restrictedfor use within the Dow Chemical Company 12.4.1-6 DO 007708