Document gBkYGEqM8dBBjz5V5enR7Zqa

(conoco Interoffice Communication TO: Safety Directors FROM: T. G. Grumbles DATE: July 17, 1984 SUBJ: HAZARD COMMUNICATION STANDARD ACTION ITEMS Below are the basic steps that must be taken to comply with the subject standard. As we discussed at the IH meeting, we all should begin working toward compliance to avoid last minute problems in 1985 and 1986. 1. Do the in-plant hazard determination and develop inventory list of hazardous materials (covered in separate letter). 2. Determine additional training needs and develop programs as needed. As discussed, we should develop generic topic programs where possible. Content of the programs is specified in the Standard. 3. Develop methods to inform contractors of hazardous materials in their work areas. This is a "performance" requirement and any effective method can be used. 4. Assure purchasing practices in-plant include obtaining MSDSs for all hazardous materials. In order to avoid decision making by purchasing as to what is hazardous, I would recommend an "approved list" be developed from your initial hazard determination effort, and your policy state a MSDS be requested for all materials not on that list. A draft letter of request is enclosed. This letter would assure documentation of non-hazardous materials. As discussed the approved list would avoid requesting a MSDS every time a material Is purchased but would force us to depend on manufacturers to send us updated MSDSs. 5. Determine in-plant labeling and sign-posting requirements. Container labels in-plant (tanks, vessels, etc.) should list the content of the container and appropriate hazard warning. In the case of mixtures, particularly complex mixtures, a generic description can be used if that material is described elsewhere (i.e., the nearest control room) in a MSDS or other similar material with the same name. The hazard warning would be the most relevant one for anticipated exposures (i.e., flammable, inhalation hazard, carcinogen). VVV 000016424 Safety Directors Page 2 July 17, 1984 Product shipments from the plant should he reviewed. As we currently understand the regulation, bulk shipments need only have the required DOT markings. Any drummed or other similarly packaged materials should have the proper label. This includes samples. 6. Determine in-plant USDS distribution. These must be readily available at all times for employees in work areas where hazardous materials are present. 7. Assure a method exists to inform employees of the hazards of non-routine tasks. This includes maintenance operations, emergency response, etc. Our current work permit system may meet this requirement or could be expanded to do so. 8. As required in the standard, document all of the above in a written hazard communication program. This must include items specified in the standard. I plan to develop an outline to be used in developing this program. I'm sure all of the above items will be discussed a great deal in the next 12 months. Based on current plant programs, some of the required items do exist but will have to be formalized as part of the overall hazard communication program. Please review the items listed. Eventually we should decide on a schedule for the above to assure they are accomplished by the compliance dates. c ---------------------- " Thomas G. Grumbles aj o cc Plant Managers J. R. Drumwright, M.D. R. D. Gamblin M. M. Malloy VVV 000016425 (conoco)J*Ml Conoco Chemicals Company A Division of Conoco Inc. 15990 North Barker's Landing Road P.0. Box 19029 Houston, TX 77224 July 17, 1984 Mr. Lee T. Freeland DuPont 6870 Shanahan Beaumont, TX 77706 Dear Lee: I agree that the Item you sent us should be followed closely. I also agree that we do not need a specific person to monitor this activity. The procedure as outlined would have some of the normal practical problems associated with a large group of diversified individuals coming to a mutually agreed upon opinion. That is, if the chapter were to address an issue in comment or testimony, how would we get agreement on the content of the response? This is a question the national AIHA is battling with know as well. However, I do see this an important issue from the standpoint of the local chapter keeping the membership informed and aware of implications of proposed legislation. I would hope our peers in Austin would keep us up to date on relevant issues. Sincerely, Thomas G. Grumbles, C.I.H. Director, Industrial Hygiene ajo VVV 000016426