Hazard Communication

The purpose of the program is to ensure that all hazardous substances are identified and that appropriate information is available and accessible to all employees and employee organizations. 

The comprehensive program communicates information on hazardous substances through:

1. A written Hazard Communication Program.
2. An Inventory of hazardous substances.
3. Material Safety Data Sheet (MSDS) acquisition.
4. Container warning labels.
5. Employee notification and training.
6. Documentation of compliance.

An MCOE Safety Officer will compile and maintain a list of all hazardous substances known as present in the work place.

The hazardous substance list is based on an initial survey, which will list the product, stock number, manufacturer, date and signature of the individual who conducted the survey. Survey forms are retained indefinitely.

The hazardous substance list is organized by each MCOE department (i.e., custodial, print shop, etc.) and is updated when new hazardous substances are obtained.

• The safety officer shall request and maintain a current file of Material Safety Data Sheets (MSDS) — a document that provides information about potential hazards of chemical materials — for all hazardous substances purchased by the MCOE.
• MSDS should be obtained from the vendor and/or manufacturer or importer for each hazardous substance found in the work place.
• MSDS will contain the following information:
  • The identity used on the product label.
  • The chemical and common names of all ingredients determined as health hazards and comprise one percent (1%) or greater of the composition, except for carcinogens, which are listed if in one tenth of one percent (.1%) or greater quantities.
  • The Chemical Abstracts Service (CAS) number of all hazardous ingredients.
  • The physical and chemical properties (e.g. flash point, potential for fire, explosion, reactivity, incompatibility with other chemicals, etc.).
  • Health hazards, acute or chronic; symptoms of overexposure, medical conditions aggravated by exposure, potential routes of entry, Occupational Safety and Health Administration (OSHA) permissible exposure limits, etc.
  • Information concerning whether the hazardous substance is listed in the National toxicology Program (NTP) or has been found to be carcinogenic by the International Agency for Research of Cancer (IARC).
  • Precautions for safe handling and use. Procedures for cleanup of leaks and spills. Procedures for disposal.
  • Control measures which are known to the manufacturer or importer such as appropriate engineering controls, work practices and personal protective equipment.
  • Emergency and first-aid procedures.
  • The date of preparation of the MSDS. The name, address, and telephone number of the manufacturer or importer.
  • Specific potential health risks of hazardous substances, in simplified terms.
• The safety officer shall establish and maintain a file of MSDS for each hazardous substance known under MCOE jurisdiction. MSDS shall be requested during the bid or quote process, or at the time of order.
  • If the material arrives before the MSDS, the safety officer may stop payment and hold material in a quarantined area in the warehouse until the MSDS has been received from the vendor or manufacturer.
  • In the case of (1. above), the safety officer shall request, in writing, a current MSDS within seven (7) days after receipt of material.
  • If no response has been received within 25 working days of the request for the MSDS, the Safety Officer shall send the Director of Industrial Relations a copy of the request, with a notation that no response has been received.
    • OSHA Director of Industrial Relations, 525 Golden Gate Avenue, San Francisco, CA. 94102
• MSDS shall be made available to the employee, employee organizations, OSHA, and the employee's physician. The MSDS file will be maintained in the Purchasing Office, Room J-10, 632 West 13th Street, Merced, CA. 95340.
• Supervisors are responsible for insuring that MSDS are available to their employees. It shall be the responsibility of the supervisor to review new MSDS for new and/or significant safety and health information. Supervisors are responsible for reviewing the contents of such MSDS with employees as soon as possible, but in no case longer than 30 days after receipt. If a MSDS is missing or incomplete, supervisors will contact the safety officer, who will request a copy from the supplier or manufacturer.

• Employees who work with hazardous substances shall receive an explanation of what a MSDS is, the labeling requirements, information (per the MSDS) of the hazards involved with specific substances regularly used, instructions for handling, protective equipment, detection of symptoms of overexposure, safety precautions and emergency procedures.
• Employees who deal with hazardous substances shall be notified that they cannot be discharged or discriminated against for requesting MSDS and safety information.
• Before performing non-routine tasks, employees shall be trained and informed by their supervisor concerning:
  • Special hazards involved.
  • Protective measures to mitigate hazards.
• Outside contractors performing work at the MCOE shall be notified by the Supervisor of Maintenance and Operations of any hazardous substance which they may come into contact. The MCOE will make MSDS available to such personnel.
• The Safety Officer shall post a notice to inform all employees not directly involved with hazardous materials (administrative, secretarial, etc) of their rights in obtaining copies of MSDS and the written MCOE Hazard Communication Program. The Notices shall be posted in:
  • Employee lounge.
  • Maintenance Shop.
  • Other Areas, as Appropriate.

In case of emergency or exposure to hazardous materials:

• General Assistance: 911
• Merced County Environmental Health: 385-7391, 385 E. 13TH ST, Merced, CA, 95340.
• Chemtrec (Emergency Chemical Advice): (800) 424-9300
• CA State Office of Emergency Services: (800) 852-7550 or (916) 427-4341
• National Response Center (NRC) for Toxic Chemical and Oil Spills: (800) 424-8802
• Environmental Protection Agency: (800) 231-3075 (800) 424-9346, (415) 974-7290
• Office of Local Assistance (OLA): (916) 445-9327, 501 J. St. Suite 350, Sacramento, CA. 95814.
• Merced Community Medical Center: 385-7111
• Fresno Community Hospital: 445-1222
• Riggs Ambulance Service: (723) 042-1510 W. 19TH ST, 383-2747 Merced, CA, 95340.
• Poison Control Center:  (415) 666-2845
• Chemical Waste Management: 386-9711, P.O. BOX 471, 35251 Old Skyline Road, Kettleman City, CA 93239.
• Keenan and Associates: 251-4249, 2002 N. Gateway Blvd., Suite 109, Fresno, CA, 93727.
• Hazard management Services: 577-8209, P.O. Box 7012, Modesto, CA, 95355.

• All training programs are documented. Training records will indicate the following:
  • Name and signature of employee.
  • Name and signature of instructor.
  • Date of instruction.
  • Brief outline of course content.
• Training records are retained indefinitely.

• MCOE Purchasing shall make every effort to purchase properly labeled products. Container labeling should communicate at least the following information:
  • Substance identification.
  • Hazard warning (words or pictures).
  • Name/address of manufacturer or importer.
  • Safety precautions.
• Hazardous materials which are received without a proper label should be returned to the vendor. At times when it is not possible to purchase needed items with acceptable labels, the Safety Officer shall make certain that hazardous materials are properly labeled using a modified HMIS (Hazardous Materials Identification System) and/or NFPA (National Fire Protection Association) 0-4 hazard rating system that will indicate the common chemical name, the relative health, flammability, and reactivity hazards, as well as personal protective equipment needed for safe handling of the product.

• The RED square indicates FIRE HAZARD:
  • 4 Indicates flash point below 73 degrees F.
  • 3 Indicates flash point below 100 degrees F.
  • 2 Indicates flash point below 200 degrees F.
  • 1 Indicates flash point above 200 degrees F.
  • 0 indicates product will not burn.
• The BLUE square indicates HEALTH HAZARD:
  • 4 Indicates deadly substance.
  • 3 Indicates extremely dangerous substance.
  • 2 Indicates hazardous substance.
  • 1 Indicates slightly hazardous substance.
  • 0 Indicates non hazardous material.
• The YELLOW square indicates REACTIVITY HAZARD:
  • 4 Indicates substance may detonate.
  • 3 Indicates shock and heat may detonate substance.
  • 2 Indicates violent chemical change possible.
  • 1 Indicates unstable if heated.
  • 0 Indicates stable substance.
• The WHITE square indicates SPECIFIC HAZARDS such as:
  • OX - Oxidizer.
  • ACID.
  • ALK - Alkali.
  • COR - Corrosive.
  • -W- -Use NO WATER.
• Radiation hazard.
  • The MCOE will not release into use any container with a hazardous substance if it is missing a label.
  • Under supervision of the Safety Officer, it will be the responsibility of the receiving department to check for proper labeling, and to label unlabeled containers as they are received.
  • It will be the responsibility of the end user to label small containers from chemicals after the chemicals have been transferred from a large, labeled container to a small quantity container. Portable containers filled and used in the same work shift by one employee do not require OSHA labeling.
  • The Safety Officer will be responsible for labeling all waste products being prepared for disposal.
  • Existing labels must not be defaced or removed.
  • Exceptions to the MSDS labeling and training requirements are:
    • Food, drugs, and cosmetics.
    • Pesticides (these fall under the law except for labeling requirement, which are already covered by other, more stringent labeling laws).
    • Consumer products covered under the Consumer Product Safety Act.
    • Distilled beverages and tobacco.
    • Wood or wood products.
    • Hazardous waste (this is covered under EPA regulations).