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NORTHERN COCHISE COMMUNITY HOSPITAL
HAZARD COMMUNICATIONS PROGRAM


DEPARTMENT: Safety
SUBJECT: Hazard Communications Program

Reviewed By:
Review Date:
Committee
11/17/17
Med Staff
11/28/17
Governing Board
11/28/17

REFERENCES: OSHA and CMS Standards.

SCOPE: This program applies to all normal and Emergency work operations, required by local, state, and Federal regulations.

POLICY: Hazard Communications Program

PROCEDURE:
    Introduction

      In order to fulfill its obligation to protect the health and safety of Employees, Northern Cochise Community Hospital - NCCH, has developed the following Hazard Communications Standard (HCS) program to comply with Occupational Safety and Health Administration (OSHA) Standard 29 CFR 1910.1200 and 29 CFR 1926.50.

      NCCH will develop hazardous chemical lists, obtain SDS's for each hazardous material used and provide training to our employees so they have a thorough understanding of what is required by the standard.

      The Program administrator will be the Director of Safety, Bill Hopkins, Copies of the written program, including chemical inventory Safety Data Sheets (SDS), will be made available on request.  Additionally, a copy of the written program will be kept at each department.  A master copy will be retained in Safety Director's office, to include hard copy and online electronic copy.

    Chemical Inventory List

      A chemical inventory list will be developed by the program administrator.  The master list will be kept at the Safety office.  When new chemicals arrive, a copy will be made of the SDS, and the original will be maintained in master file and added to the inventory list.

    Hazard Determination

      It will be the policy of NCCH not to evaluate hazardous chemicals purchased from suppliers or manufacturers.  The suppliers and Manufacturers will be relied on to supply the information needed to satisfy standard requirements. 
       The SDS's will be reviewed for completeness and additional information from the manufacturer will be requested in needed.

    Safety Data Sheets (SDS)

      All SDS's will be maintained by the Safety Director, Master copy (hard copy and Electronic copy) will be maintained of SDS's.  In addition each Department will also maintain a SDS Binder.  If a chemical arrives without an SDS the Safety Director will be notified and begin the process of obtaining the SDS.

    Container and Warning Labels

      The Safety Director will have the responsibility of acquiring hazard warning labels and making them available to all locations, where needed.  They will contain, at minimum, the following information:

      • Identify the Chemical.

      • All potential Hazards associated with the chemical.

      • Manufacturer's Name, address and telephone number.

      The Safety Director and Department Managers will have responsibility of ensuring all labels are affixed on containers properly.  If a container is in need of a label, the Director of Safety or Department Manager will affix one.  No product will be used until it is properly labeled.  All portable containers will dedicate to a single chemical and labeled with the appropriate information.  It is the responsibility of the user, the Dept. Manager and the Safety Director to ensure the container is labeled, unlabeled containers will be removed from service until new label is affixed.

    Non-routine Tasks

      On occasion, NCCH may be required to perform non-routine tasks that may involve use of a hazardous substance.  If such a need arises, a special training course will be conducted to inform employees of potentially hazardous chemical they may be exposed to during non-routine operation and measures they can take to avoid those exposures.

    Informing Contractors

      Any contractor with employees working in the NCCH workplace will be informed of the hazardous chemicals to which the contractors' employees may be exposed while performing their work.  The contractor will take appropriate protective measures as set forth in SDS's provided.  NCCH management also will confer with the contractors' management as appropriate to discuss any hazards particular either to the work the contractor will be performing or the work area in which the work will be conducted.  Management or the Safety Director will describe the labeling system the company uses.

      In addition NCCH will require any contractor who intends to bring any hazardous chemical to the workplace to provide SDS's for each chemical.  The contractor will further be required to explain (verbally or in writing), and precautionary measures necessary to protect employees who may be exposed to hazardous chemicals used by the contractor as provided in the employees training section.

    Training

      Employees who potentially could be exposed to hazardous chemicals will receive training in the elements of the Hazardous Communications Standards.  During their initial training, they also will receive an overview of the chemicals typically used in healthcare operations.  As new hazards are introduced, additional training will be conducted.  Occasionally, we will use a safety briefing safety talks to discuss a specific chemical used.  The typical training session will address the following:

      • A summary of the Company's written program and the OSHA Hazard Communications Standards (HCS).

      • Methods of detecting hazardous chemicals, including a description of the hazards chemical and physical properties.

      • Health hazards and signs or symptoms of exposure.

      • Proper work practices for working with a hazardous substance.

      • PPE selection.

      • Emergency procedures and first aid for spills and other exposure.

      • Locations of MSDS's and the written program.

      • How to read SDA's.

      • The type of labeling system the company uses and how to interpret the information on the labels.

      • How to obtain additional information.

      This training program will be conducted initially and as new hazards are introduced.  Periodic training will be conducted to further inform our employees of hazardous chemicals and the methods of safeguarding themselves.  At least annually, refresher training will be conducted to reacquaint everyone with the standard and discuss any changes made to the program.

      Training program elements will be reviewed at least annually.  At the conclusion of each training session, a question and answer period will be held so employees can voice any further concerns on the topic.  Each employee will sign an attendance form and indicate where and when the training was completed.  It will be dated and signed by the trainer. If a particular MSDS was discussed, a copy will be attached to the training record.

    SAFE-POL-005