Hazardous Communication

This program has been developed to communicate hazard and safety information about hazardous substances to employees and to comply with Occupational Safety and Health Administration ("OSHA") requirements. Key elements of this program include:

• Hazard identification

• Labeling

• Safety Data Sheets ("SDS") and Material Data Sheets ("MSDS")

• Training and communication

Application

The purpose of the Hazardous Communication Program is to provide support methods for informing employees about hazardous substances they may be exposed to in the workplace, including potential harmful effects and appropriate control measures.

Covered employees, operations, and substances

This program applies to:

• All Dow Aero, LLC ("Company") employees.

• Hazardous substances purchased and used by Company employees.

Exempted or partially exempted operations

The following operations are exempted or partially exempted from this program:

Warehouse operations

Warehouse operations where chemicals are only handled in sealed containers are exempted from the provisions of the Hazardous Communication Program. Such operations include:

• Warehouses

• Stockrooms

• Shipping/receiving

These operations shall:

• Ensure that labels are not removed or defaced (see Safety Data Sheets below).

• Maintain SDSs and ensure that SDSs are available to employees (see Hazardous Chemical Inventory below).

Exempted substances

The following substances are exempt from the requirements of this program:

• Tobacco or tobacco products.

• Wood or wood products, including lumber, if it will not be processed and the only hazard it poses to employees is the potential for flammability or combustibility.

• Food, drugs, or cosmetics intended for personal use.

• Consumer products used in the workplace, when used normally (e.g. White-Out or spray paint used for short, one-time applications).

Responsibilities

To ensure safe use, handling, and storage, personnel must be aware of the associated hazards before using hazardous substances. The responsibilities listed below supplement the core responsibilities outlined in the Injury and Illness Prevention Program (IIPP).

Environmental Health and Safety (EHS)

EHS is responsible for providing resources (i.e. reference materials) and technical support to ensure that employees are protected from hazardous substances. This includes:

• Developing, implementing, and evaluating the Hazardous Communication Program.

• Assisting supervisors in identifying hazardous substances present in the work area and evaluating potential operational hazards.

• Providing hazardous communication training to all employees covered under the Hazardous Communication Program.

• Assisting supervisors with job-specific employee training for all employees covered under the Hazardous Communication Program.

• Recommending appropriate engineering controls, administrative controls, and personal protective equipment.

Managers & Supervisors

Supervisors and managers are responsible for implementing the Hazard Communication Program at the local operational level. Supervisors and managers must ensure the safe use of hazardous substances in all areas under their supervision. This includes:

• Identify hazardous substances in the work area and potential hazards related to their use.

• Ensuring that hazardous substances are appropriately labeled or posted.

• Obtaining SDSs for hazardous substances used in the work area, and ensuring that SDSs are available to employees.

• Ensuring that employees know where to obtain SDSs.

• Updating SDSs when necessary.

• Maintaining an on-site binder with copies of SDSs.

• Ensuring that employees are trained in hazard communication and on physical hazards, health hazards, safe handling procedures, and emergency procedures for hazardous substances used in the work area.

• Ensuring that employees follow established safety procedures.

• Adequately alerting any non-Company personnel in the same work area of the hazardous substances that their employees may be exposed to.

• Update chemical inventory as needed.

Employees

Employees are responsible for:

• Knowing the hazards and precautionary procedures for all hazardous substances used in their work area.

• Completing hazardous communication training and job-specific training before working with hazardous substances.

• Knowing where to obtain SDSs and how to read SDSs.

• Planning and conducting operations in accordance with established procedures and good safety practices.

• Using personal protective equipment and clothing, in accordance with prescribed training.

• Consult supervisor when regarding hazards.

Labeling

General requirements for containers

When labeling hazardous substances:

• Every container of a hazardous substance must be labeled, tagged, or marked to identify the substance, and to provide appropriate warnings.

• The manufacturer’s original label shall provide:

  • Identity of the hazardous substance

  • Signal word

  • Hazard statement(s)

  • Pictograms (see below)

  • Precautionary statement(s)

  • Name and address of the manufacturer, importer, or responsible party.

• Labels shall be:

  • Legible

  • In English

  • Prominently displayed on the container.

• The original label shall not be removed or defaced unless the container is immediately marked with the required information.

• Non-hazardous substances (e.g. distilled water) should be labeled in order to avoid confusion.

• Alternative methods (e.g. signs, placards, process sheets, and operating procedures) are acceptable for individual stationary process containers, provided that the information is conveyed to all affected persons.

• Portable secondary containers used immediately by the person performing the transfer do not need labels.

Responsibilities

Managers and supervisors shall:

• Ensure that all containers are appropriately labeled.

• Ensure that employees know how to appropriately label non-original containers.

Employees must:

• Label containers of hazardous and non-hazardous substances appropriately.

Hazard Pictograms

These pictograms are used on labels to convey specific information about the hazards of a chemical (hover to see details):

Safety Data Sheets

The purpose of a safety data sheet (SDS), previously known as a material safety data sheet (MSDS), is to provide health and safety data about a specific hazardous substance. An SDS discloses:

• The chemical composition and properties of the hazardous substance.

• Health and physical hazards.

• Safe handling, storage, and control methods.

• Emergency response and first aid procedures.

General requirements

• An SDS shall be available for every hazardous substance used in a work area and shall be accessible to employees.

• The manufacturer/importer/distributor shall provide an SDS with or before the initial shipment of the hazardous substance(s) and with or before the first shipment after an SDS is updated.

• If the SDS is not provided with the shipment, the purchaser (i.e. shop supervisor) shall obtain one from the manufacturer, importer, or distributor before using the purchased material.

• SDSs shall be in English and shall contain the information specified on the OSHA Safety Data Sheet site.

• If employees travel between workplaces, SDSs may be kept at a central location (e.g. a shop). However, the required information shall be readily available in an emergency.

Obtaining SDSs

Employees can obtain SDSs from the following sources:

• MSDSOnline

Hazardous Chemical Inventory

General requirements

Company departments, shops, and/or warehouses shall maintain an inventory of hazardous substances present in their areas. Upon use of these materials, return to their proper storage location.

Training and Instruction

All employees who may come into contact with hazardous chemicals shall be trained in safe handling procedures, health and safety hazards, labeling, SDSs, and the use of personal protective equipment. Additional training is required when a process changes significantly or when a new substance is introduced into the work area.

Training requirements are fulfilled through the completion of two parts:

• Hazardous Communication Training.

• Local training covering Job Specific Chemical Hazard Information and Emergency Response Procedures, as covered in the Hazardous Substance Training.

Supervisors and managers must:

• Ensure that employees complete hazardous communication training, and provide job-specific training to employees.

• Review with employees the hazards, handling and storage procedures, and personal protective equipment required for hazardous substances.

• Include refresher training, if unsafe work practices involving hazardous substances are observed.

Employees must:

• Complete required training.

• Follow established safe practices for planning and carrying out work.

• Request training from supervisor and/or EHS when a process changes or new material is introduced.

Frequency of training

Employees shall be trained on hazardous substances in their work area:

• Upon initial assignment.

• Whenever a new hazard is introduced into the work area.

Recordkeeping of training

Human Resources shall maintain training records for at least one year.