Hazard Communication Plan

Hazard Communication Plan for Commercial Real Estate

Purpose

The purpose of the Hazard Communication Plan is to develop and implement the procedures for the identification, use, care, of Hazardous Chemicals by employees for the prevention of illness and injury. Property Management is committed to preventing accidents and ensuring the safety and health of our employees. We will comply with all applicable federal and state health and safety rules. Under this program employees are informed of the contents of the OSHA Hazard Communications Standard, the hazardous properties of chemicals with which they work, safe handling procedures and measures to take to protect themselves from these chemicals. These chemicals may be physical or health related. This written hazard communication plan is available at the following location for review by all employees:

?All employees are required to follow the minimum procedures outlined in this program. Any deviations from this program must be immediately brought to the attention of the Program Administrator.

?Scope

This policy applies to Hazard Communications at Property Management and related facilities and operations. This program is integrated into our organization’s written safety and health program and is a collaborative effort that includes all employees. The Program Administrator is responsible for the program’s implementation, management, training, and recordkeeping requirements.

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Program Responsibilities

?Management. Property Management is committed to the safety and health of its workers. Management supports the efforts of the Hazard Communication Plan Program Administrator by pledging financial and leadership support for the identification of hazards and implementation of appropriate PPE for those hazards. Management will regularly communicate with employees about this program.

Program Administrator. The Program Administrator which is in most cases the Property Manager reports directly to upper management and is responsible for the hazard assessments, implementation, training, and administration of the program. The Program Administrator will monitor the results of the program to determine additional areas of focus as needed. The Program Administrator will also:

·????????Conduct workplace hazard assessments to determine the presence of hazardous Chemicals

·????????Review, update, and provide SDS Safety Data Sheets for employees:

o??For all current chemicals on the property

o??A new chemical is used

o??There has been an accident

o??A supervisor or employee requests it

·????????Maintain record of a Chemical List

·????????Recommend PPE for each Chemical if required

·????????Review, update and evaluate the overall effectiveness of policies, and program

Property Managers have the primary responsibility for implementing and enforcing Plans including, but not limited to:

·????????Create site list of chemicals and attach to this document in Appendix B.

·????????Create Site specific SDS binder

·????????Providing appropriate PPE and making it available to employees

·????????Ensuring that employees are trained on the proper use, care, storage, of chemicals

·????????Ensuring that employees properly use and maintain their PPE

·????????Notifying the Program Administrator when new hazards are introduced or when processes are added or changed

·????????Ensuring that defective or damaged PPE is immediately disposed of and replaced

Employees are responsible for following the requirements of the Hazard Communication Plan, including, but not limited to:

·????????Reading SDS sheets for chemicals prior to use

·????????Properly wearing PPE as required in accordance with the PPE Plan.

·????????Attending required training sessions

·????????Properly caring for, cleaning, storing, maintaining, and inspecting hazardous chemicals as required

·????????Following plan policies and rules

·????????Know and understand Appendix A

·????????Review and suggest additions and removals to Appendix B

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Employees who repeatedly disregard and do not follow Plan procedures and rules will face disciplinary action up to and including termination.

General Requirements

Identifying Hazardous Chemicals

A list needs to be created and attached to this plan that identifies all hazardous chemicals with a potential for employee exposure at this workplace. (Attach site specific list of chemicals used at the property at the end of document). Detailed information about the physical, health, and other hazards of each chemical is included in a Safety Data Sheet (SDS); the product identifier for each chemical on the list matches and can be easily cross-referenced with the product identifier on its label and on its Safety Data Sheet.

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Identifying Containers of Hazardous Chemicals

The labeling system to be used by Property Management will follow the requirements in the 2012 revision of the OSHA Hazard Communication Standard to be consistent with the United Nations Globally Harmonized System (GHS) of Classification of Labeling of Chemicals. The label on the chemical is intended to convey information about the hazards posed by the chemical through standardized label elements, including symbols, signal words and hazard statements. All hazardous chemical containers used at this workplace will have:

·????????The original manufacturer’s label that includes a product identifier, an appropriate signal word, hazard statement(s), pictogram(s), precautionary statement(s) and the name, address, and telephone number of the chemical manufacturer, importer, or other responsible party

·????????A label with the appropriate label elements just described 3. Workplace labeling that includes the product identifier and words, pictures, symbols, or combination that provides at least general information regarding the hazards of the chemicals. (Name of person or job title) will ensure that all containers are appropriately labeled. No container will be released for use until this information is verified. Workplace labels must be legible and in English. Information in other languages is available at: (Identify the location if they are stored in a paper file. Describe how to access this information.)

·????????Small quantities intended for immediate use may be placed in a container without a label, provided that the individual keeps it in their possession at all times and the product is used up during the work shift or properly disposed of at the end of the work day. However, the container should be marked with its contents.

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Keeping Safety Data Sheets or SDS (previously known as Material Safety Data Sheets)

The manufacturer or importer of a chemical is required by OSHA to develop a Safety Data Sheet (SDS) that contains specific, detailed information about the chemical’s hazard using a specified format. The distributor or supplier of the chemical is required to provide this SDS to the purchaser. SDS’s are readily available to all employees during their work shifts. Employees can review SDS for all hazardous chemicals used at this workplace. SDS Sheets are stored in the SDS binder located in the Property Managers Office, created by the Property Manager. The SDS’s are updated and managed by the Property Manager. If an SDS is not immediately available for a hazardous chemical, employees can obtain the required information by going to the website of the chemical manufacture on any web browser.

Training Employees

Training Employees about Chemical Hazards Before they start their jobs or are exposed to new hazardous chemicals, employees must attend a hazard communication training that covers the following topics:

·????????Documentation of the review of this plan in Appendix D.

·????????Hazardous chemicals present in their workplace.

·????????Any operations in their work area where hazardous chemicals are used.

·????????The location of the written hazard communication plan and where it may be reviewed.

·????????How to understand and use the information on labels and in Safety Data Sheets.

·????????Physical and health hazards of the chemicals in their work areas.

·????????Methods used to detect the presence or release of hazardous chemicals in the work area.

·????????Steps we have taken to prevent or reduce exposure to these chemicals.

·????????How employees can protect themselves from exposure to these hazardous chemicals through use of engineering controls/work practices and personal protective equipment.

·????????An explanation of any special labeling present in the workplace.

o??What are pictograms?

o??What are the signal words??

o??What are the hazard statements?

o??What are the precautionary statements?

·????????Emergency procedures to follow if an employee is exposed to these chemicals. The Property Manager; is responsible to ensure that employees receive this training. After attending the training, employees will sign a form verifying that they understand the above topics and how the topics are related to our hazard communication plan. Prior to introducing a new chemical hazard into any department, each employee in that department will be given information and training as outlined above for the new chemical hazard.

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Special Task

Informing Employees who do Special Tasks Before employees perform special (non-routine) tasks that may expose them to hazardous chemicals, their supervisors will inform them about the chemicals’ hazards. Their supervisors also will inform them about how to control exposure and what to do in an emergency. The employer will evaluate the hazards of these tasks and provide appropriate controls including Personal Protective Equipment all additional training as required. Examples of special tasks that may expose employees to hazardous chemicals include the following: (include examples of special (non-routine) tasks).

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Periodic Program Review

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At least annually, the Program Administrator will conduct a program review to assess the progress and success of the program. The review will consider the following:

·????????Evaluation of Plan documented in Appendix C

·????????The need for retraining of managers, supervisors, and employees

·????????The jobs, processes or areas that have produced a high incidence rate of injuries or illnesses

·????????The Program’s success will be determined and reported to senior management based upon comparison to previous years, using the following criteria:

o??Cost and frequency of workers’ compensation cases

o??Employee and supervisor feedback through direct interviews and questionnaires

Annual reviews will be documented with the form in this plan

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Outside Contractors

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Informing contractors and other employers about our hazardous chemicals If employees of other employer(s) may be exposed to hazardous chemicals at our workplace (for example, employees of a construction contractor working on-site) It is the responsibility of (name of person or job title) to provide contractors and their employees with the following information:

·????????The identity of the chemicals, how to review our Safety Data Sheets, and an explanation of the container labeling system.

·????????Safe work practices to prevent exposure. (name of person or job title) will also obtain a Safety Data Sheet for any hazardous chemical

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Record Retention

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Written records will be kept which include trainee names, the type of training provided and the dates when training occurred. The Program Administrator will maintain these training records for 3 years.

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An up to date Chemical List and SDS Binder shall be kept in the office indefinitely and reviewed annually or any time a new chemical is used in operations.

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Appendix A - HCS Pictograms and Hazards?

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Appendix B

Hazardous Chemicals List

1.??????Each Property Must create a site-specific list of all chemicals used by staff on the property

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