SOP 511.34: Employee Hazardous Chemicals Protection and Right To Know and Understand
Summary
Key Topics
- hazardous chemicals
- chemical safety
- right to know
- employee protection
- chemical labeling
- safety data sheets
- SDS
- chemical inventory
- hazard communication
- OSHA compliance
- combustible dust
- caustic materials
- chemical exposure
- emergency response
- employee training
- chemical handling
- personal protective equipment
- workplace safety
Full Text
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|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|
|Policy Number: 511.34|Effective Date: 10/30/2017|Page Number:1 of 22|
|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
I. Introduction and Summary: This policy provides for implementation of
requirements of the Georgia Public Employee Hazardous Chemical Protection and
Right to Know Act of 1988 [Act] as defined by Georgia Department of Labor
[DOL] Safety Engineering Rule 300-3-19 [Rule 300-3-19].
All divisions, sections, facilities, and operations (sites) of the Georgia Department
of Corrections [GDC] are included in this program. Requirements of the Act as
defined by Rule 300-3-19 shall be fully implemented at all work areas. County
Institutions are excluded by an Attorney General's opinion dated September 6,
1989.
II. Authority:
A. Occupational Safety and Health Administration [OSHA] Hazard
Communication, 29 CFR § 1910.1200 (2013); OSHA Hazard Communication
- Final Rule, 77 FR 17574-01 (2012) [HCS or HCS 2012]; OSHA Instruction
CPL-02-00-150 - Field Operations Manual [FOM] (2011); OSHA Instruction
CPL 02-00-124 - Multi-Employer Citation Policy (1999); and OSHA
Instruction CPL 03-00-008 - Combustible Dust National Emphasis Program
(2008);
B. Georgia House Bills: 1988 GA H.B 503 and 1991 GA H.B. 217;
C. O.C.G.A. §§ 45-22-1 through 45-22-12;
D. Georgia Department of Labor Safety Engineering Rule 300-3-19;
E. GDC Board Rules: 125-1-2-.01(c), 125-1-2-.15, 125-2-1-.06, 125-3-1-.06, and
125-3-5;
F. GDC SOPs: 218.03 - Control and Dispensation of Gasoline and Hazardous
Materials, and 225.02 - Emergency Plans; and
G. ACA Standards: 2-CO-3B-02, 1-CTA-3B-06, 4-4215, and 4-4214.
III. Definitions:
A. Article - A manufactured item other than a fluid or particle: (i) which is formed
to a specific shape or design during manufacture; (ii) which has end-use
function(s) dependent in whole or in part upon its shape or design during enduse; and (iii) which under normal conditions of use does not release more than
very small quantities, (e.g., minute or trace amounts of a hazardous chemical
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|Originating Division: Facilities
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as determined under paragraph (d) of the Hazard Communication Standard
[HCS]), and does not pose a physical hazard or health risk to employees.
Examples of articles are stainless steel tables, vinyl upholstery, tires, and
adhesive tape.
B. Caustic Materials - Substances that can destroy or eat away by chemical
reaction (e.g., lye, caustic soda, sulfuric acid):
1. If a substance possesses more than one of the following properties:
flammable, toxic, or caustic, then the safety requirements for all
applicable properties should be considered.
2. All flammable, toxic, and caustic materials should be stored in secure
areas that are inaccessible to offenders, and a prescribed system should
be used to account for their distribution. Offenders should never
possess such items unless under the close supervision of qualified staff.
3. Substances that do not contain one or more of the above properties, but
that are labeled “Keep Out of Reach of Children” or “May Be Harmful
if Swallowed” are not prohibited; their use and control, however,
should be used under close supervision and distribution of them closely
accounted for.
C. Chemical - Any substance or mixture of substances. The HCS definition of
"chemical" is much broader than that which is commonly used. Thus, steel
coils which are cut and processed, castings which are subsequently ground or
welded upon, bricks that are dry sawed or drilled, and carbide blades which are
sharpened, are all examples of products that contain chemicals, which, if
available for exposure, are covered by the HCS.
D. Chemical Name - The scientific designation of a chemical in accordance with
the nomenclature system developed by the International Union of Pure and
Applied Chemistry [IUPAC] or the Chemical Abstracts Service [CAS] rules
of nomenclature, or a name that will clearly identify the chemical for the
purpose of conducting a hazard classification.
E. Classification - To identify the relevant data regarding the hazards of a
chemical, review those data to ascertain the hazards associated with the
chemical, and decide whether the chemical will be classified as hazardous
according to the definition of hazardous chemical in this section. In addition,
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|Originating Division: Facilities
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classification for health and physical hazards includes the determination of the
degree of hazard, where appropriate, by comparing the data with the criteria
for health and physical hazards.
F. Combustible Dust - A combustible particulate solid that presents a fire or
deflagration hazard when suspended in air or some other oxidizing medium
over a range of concentrations, regardless of particle size or shape. Distributor
means a business, other than a chemical manufacturer or importer, which
supplies hazardous chemicals to manufacturers, other distributors, or to
employers. A company that repackages, blends, mixes, or otherwise changes
the composition of a chemical is considered a chemical manufacturer under the
HCS.
G. Employee or Public Employee - Any person, including a contractor, who is
employed by any branch, department, board, bureau, commission, authority,
or other agency of the state and any offender under the jurisdiction of GDC
performing a work assignment which requires the handling of any hazardous
chemical. Such term shall not include those employees of the Environmental
Protection Division [EPD] or of the Department of Natural Resources [DNR]
who are responsible for on-site response and assistance in the case of
environmental emergencies while such employees are engaged in responding
to such emergencies. OCGA § 45-22-2(8).
H. Exposed or Exposure - Means that an employee is required by a public
employer to be subjected to a hazardous chemical in the course of employment
through any route of entry, including but not limited to, inhalation, ingestion,
skin contact, or absorption and include potential or accidental exposure. OCGA
45-22-2(10).
I. Foreseeable Emergency - Any potential occurrence such as, but not limited
to, equipment failure, rupture of containers, or failure of control equipment
which could result in an uncontrolled release of a hazardous chemical into the
workplace.
J. Hazard Category - The division of criteria within each hazard class (e.g. oral
acute toxicity and flammable liquids include four hazard categories). These
categories compare hazard severity within a hazard class and should not be
taken as a comparison of hazard categories more generally.
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K. Hazardous Chemical - Any chemical which is classified as a physical hazard
or a health hazard, a simple asphyxiate, combustible dust, pyrophoric gas, or
hazard not otherwise classified.
L. Hazard Class The nature of the physical or health hazards (e.g. flammable
solid, carcinogen, or oral acute toxicity).
M. Hazard Not Otherwise Classified (HNOC) - An adverse physical or health
effect identified through evaluation of scientific evidence during the
classification process that does not meet the specified criteria for the physical
and health hazard classes addressed in the standard.
N. Hazard Statement - A statement assigned to a hazard class and category that
describes the nature of the hazard(s) of a chemical, including, where
appropriate, the degree of hazard.
O. Health Hazard - A chemical which is classified as posing one of the following
hazardous effects: acute toxicity (any route of exposure); skin corrosion or
irritation; serious eye damage or eye irritation; respiratory or skin sensitization;
germ cell mutagenicity; carcinogenicity; reproductive toxicity; specific target
organ toxicity (single or repeated exposure); or aspiration hazard.
P. Label - An appropriate group of written, printed, or graphic information
elements concerning a hazardous chemical that is affixed to, printed on, or
attached to the immediate container of a hazardous chemical, or to the outside
packaging.
Q. Label Elements - The specified pictogram, hazard statement, signal word, and
precautionary statement for each hazard class and category.
R. Mixture - A combination or a solution composed of two or more substances
in which they do not react.
S. Physical Hazard - A chemical that is classified as posing one of the following
hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids);
oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); selfheating; organic peroxide; corrosive to metal; gas under pressure; or emits
flammable gas when in contact with water.
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T. Pictogram - A composition that may include a symbol, plus other graphic
elements, such as a border, background pattern, or color, that is intended to
convey specific information about the hazards of a chemical. Eight pictograms
are designated under this standard for application to a hazard category.
U. Plan of Action [POA] - An organized program of measures to be taken in
order to achieve a goal. A sequence of steps, specific tasks, time limits, and
resource allocations that must be performed in an emergency.
V. Precautionary Statement - Means a phrase that describes recommended
measures that should be taken to minimize or prevent adverse effects resulting
from exposure to a hazardous chemical, or improper storage or handling.
W. Product Identifier - The name or number used for a hazardous chemical on a
label or in the Safety Data Sheet [SDS]. It provides a unique means by which
the user can identify the chemical. The product identifier used shall permit
cross-references to be made among the list of hazardous chemicals required in
the written hazard communication program, the label and the SDS.
X. Pyrophoric Gas - Means a chemical in a gaseous state that will ignite
spontaneously in air at a temperature of 130 degrees F (54.4 degrees C) or
below.
Y. Safety Data Sheet [SDS] - The written or printed material concerning a
hazardous chemical that is prepared and provided by manufacturers in
accordance with the requirements of the OSHA’s Revised Hazard
Communication Standard (HCS 2012). The SDS identifies the chemical as
well as the recommended uses. It also provides the essential contact
information of the supplier. The information contained in the SDS must be in
English (although it may be in other languages as well). OSHA requires that
SDS preparers provide specific minimum information. The SDS is composed
of 16 mandatory and non-mandatory sections. The SDS preparers may also
include additional information in various section(s).
1. Mandatory Sections: Product Identification, Hazard Identification,
Composition/Information on Ingredients, First-Aid Measures, FireFighting Measure, Accidental Release Measures, Handling and
Storage, Exposure Control/Personal Protection, Physical and Chemical
Properties, Stability and Reactivity, Toxicological Information.
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2. Non-Mandatory Sections: Ecological Information, Disposal
Considerations, Transport Information, Regulatory Information, and
Other Information, including Date of Preparation or Last Revision.
Note: Specific contents of the 16 sections or the required format of Safety Data
Sheets may be found at: https://www.osha.gov/Publications/OSHA3514.html.
Z. Signal Word - A word used to indicate the relative level of severity of hazard
and alert the reader to a potential hazard on the label. The signal words used in
this section are "danger" and "warning." "Danger" is used for the more severe
hazards, while "warning" is used for the less severe hazards.
AA. Simple Asphyxiant - A substance or mixture that displaces oxygen in the
ambient atmosphere, and can thus cause oxygen deprivation in those who are
exposed, leading to unconsciousness and death .
BB. Substance - Chemical elements and their compounds in the natural state or
obtained by any production process, including any additive necessary to
preserve the stability of the product and any impurities deriving from the
process used, but excluding any solvent which may be separated without
affecting the stability of the substance or changing its composition .
CC. Toxic Materials - Substances that through chemical reaction or mixture can
produce possible injury or harm to the body by entering through the skin,
digestive tract, or respiratory tract (e.g., zinc chromate paint, ammonia,
chlorine, antifreeze, herbicides, pesticides).
DD. Trade Secret - Any confidential formula, pattern, process, device,
information, or compilation of information that is used in an employer's
business, and that gives the employer an opportunity to obtain an advantage
over competitors who do not know or use it.
EE. Work Area - A room or defined space in a workplace where hazardous
chemicals are produced or used, and where employees or offenders are present.
GDC work areas include, but are not limited to, vocational training shops,
maintenance shops, kitchens, warehouses, farm shops, Georgia Correctional
Industries’[GCI] shops, or any other area where these chemicals are stored or
used.
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
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FF. Workplace - An establishment, job site, or project, at one geographical location
containing one or more work areas (e.g. state facilities, community centers,
GCI Headquarters, and Indian Ford Farm are GDC workplaces).
IV. Statement of Policy and Applicable Procedures:
This policy is applicable to all facilities, centers, units, sections, and offices
operating under GDC management. The HCS which is now aligned with the
Globally Harmonized System of Classification and Labeling of Chemicals [GHS]
provides a common and coherent approach to classifying chemicals and
communicating hazard information on labels and safety data sheets. The HCS
mandates chemical safety in the workplace by ensuring that information about the
identities and hazards of the chemicals is made available and understandable to
workers.
A. DOL Responsibilities: The Department shall be required under the Act to
establish information and training standards for compliance under the Act. The
purpose of these rules is to ensure that all employees who are exposed to
hazardous chemicals listed in the State of Georgia Hazardous Chemical List
are informed of the hazards of these chemicals and of measures to protect
themselves.
B. GDC Responsibilities: GDC shall ensure that all employees within the agency
are aware of the Act, applicable regulations, and GDC’s responsibilities by
means of a written Hazardous Chemical Communication Program.
Accessibility to information about the identities and hazards of chemicals may
be accomplished in many different ways.
1. SDSs may be kept in a binder in a central location if employees have
immediate access to the information without leaving their work areas . In
workplaces with large numbers of chemicals, electronic access may be
provided. However, if SDSs are supplied electronically, there must be an
adequate back-up system in place in the event of a power outage,
equipment failure, or other emergency involving the primary electronic
system.
2. GDC must ensure that employees are trained on how to use any electronic
system to access SDSs and are able to obtain hard copies of the SDSs. In
the event of a medical emergency, hard copy SDSs must be immediately
available to medical personnel.
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3. The HCS requires the development and dissemination of such information
and requires that employers train employees (including offenders) on the
hazardous chemicals in their workplaces.
4. GDC is responsible for maintaining the labels on the containers, including,
but not limited to, tanks, totes, and drums. This means that labels must be
maintained on chemicals in a manner that continues to be legible and
ensures pertinent information (such as the hazards and directions for use)
does not get removed in any way.
5. GDC is not responsible for updating labels on shipped containers, even if
the shipped containers are labeled under HazCom 1994. GDC must relabel
items if the labels are removed or defaced. However, if GDC is aware of
newly-identified hazards that are not disclosed on the label, GDC must
ensure that employees are aware of the hazards as discussed below under
workplace labels.
6. GDC will appoint a Hazardous Chemicals Protection Communication
Coordinator. The Hazardous Chemicals Protection Coordinator will be
provided with authority sufficient to carry out the duties of the position. An
individual in an existing position within an agency may be assigned this
responsibility as an additional duty. The Hazardous Chemicals Protection
Communication Coordinator will assume the following responsibilities:
a. Act as a liaison between the agency and the DOL on hazardous
chemicals issues which may arise within his or her agency at the
state level;
b. Determine applicability of these rules to individual workplaces and
work areas within his agency using on-site inspections, review of
written records including Safety Data Sheets, and industrial
hygiene studies;
c. Ensure appropriate and adequate training is provided to all
employees;
d. Review GDC’s labeling system annually and update the same as
needed;
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e. Provide assistance to the manager of each workplace affected by
the Act in making determinations concerning whether a chemical is
hazardous, what safeguards should be provided, and in obtaining
technical assistance from outside approved sources such as the
DOL, Georgia Tech Research Institute, and others.
f. Compile a comprehensive list of all hazardous chemicals submitted
by workplace managers during January and July of each year. This
list will be maintained at GDC’s central office and made available
by executive staff for public inspection.
C. Facility Responsibilities:
The manager of every workplace within GDC (e.g. Warden, Superintendent,
Academy Director) shall ensure that work area supervisors maintain current
inventories of all hazardous chemicals stored or handled at each work area at
all times. Each manager at every workplace (Central Office, Central Training
Academy, Prison, or Center) shall designate a Safety Officer who will be
responsible for the following:
1. Compiling and maintain inventories of all hazardous chemicals stored or
handled at their worksites, in a central area;
2. With assistance of the business manager and the Right to Know
Coordinator, review all incoming SDSs for new and significant
health/safety information;
3. Ensure that SDSs for all hazardous chemicals maintained at their
workplaces are available and that any new information is passed on to
affected employees (including offenders);
4. When a new hazardous substance is to be brought into the workplace the
business manager and the Safety Officer will review the toxicity
information to determine if a less toxic substance can be used, and if
additional engineering controls and personal protective equipment will be
needed, before the final decision is made to acquire the substance; and
5. Provide local training staff with information concerning hazardous
chemicals inventory revisions and any new training requirements.
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D. Written Workplace-Specific Hazard Communication:
1. Each location/workplace shall develop a written Workplace-Specific
Hazard Communication Program. The program must describe how the
criteria specified for labels and other forms of warning, safety data sheets,
and employee information and training will be met, and include the
following:
a. A list of hazardous chemicals known to be present using a product
identifier that is referenced on the appropriate SDSs (the list may
be compiled for the entire workplace or for individual work areas).
The product identifier enables cross-references to be made among
the list of hazardous chemicals required in the written hazard
communication program, the label, and the SDSs;
b. Copies of SDSs for all hazardous chemicals to which employees
(including offenders) may be exposed in a work area will be
maintained in the work area supervisor’s office or other suitable
place at the work area;
c. Notification that, upon any employee’s request, at each workplace
within the agency, access shall be given to the most current SDSs
for those chemicals used in that workplace and which are included
on the Georgia Right to Know Hazardous Chemicals Lists;
d. The methods the location/workplace will use to inform employees
of the hazards of non-routine tasks (for example, the cleaning of a
boiler) and the hazards associated with chemicals contained in
unlabeled pipes in their work areas;
2. "Multi-employer workplaces". Employers who produce, use, or store
hazardous chemicals at a workplace in such a way that the employees of
other employer(s) may be exposed (for example, employees of a
construction contractor working on-site) shall additionally ensure that the
hazard communication programs developed and implemented, include the
following:
a. The methods the location/workplace will use to provide the other
employer(s) on-site access to SDSs for each hazardous chemical
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the other employer(s)' employees may be exposed to while
working;
b. The methods the location/workplace will use to inform the other
employer(s) of any precautionary measures that need to be taken to
protect employees during the workplace's normal operating
conditions and in foreseeable emergencies; and
c. The methods the location/workplace will use to inform the other
employer(s) of the labeling system used in the workplace.
3. The written hazard communication program shall be made available, upon
request, to employees, their designated representatives, the Director of the
National Institute for Occupational Safety and Health, U.S. Department of
Health and Human Services, or designee, in accordance with the
requirements of 29 CFR 1910.1020(e); and
4. Where employees must travel between workplaces during a work shift, i.e.
their work is carried out at more than one geographical location, the
written hazard communication program may be kept at the primary
workplace facility.
E. Contractors:
1. The workplace manager will assure that the following information is
provided to contractors performing work at a GDC workplace:
a. A list of hazardous chemicals to which they may be exposed while
on the job site; and
b. A list of any precautions the contractor's employees may take to
lessen the possibility of exposure by usage of appropriate protective
measures.
2. The workplace manager will be responsible for contacting each contractor
before work is started to gather and disseminate any information concerning
chemical hazards that the contractor is bringing to the GDC workplace.
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3. Documentation concerning chemical hazard information shall be given to the
contractor and obtained from the contractor, will be filed with the work
contract, and a copy will be maintained by the facility safety officer.
4. Each workplace manager shall forward, during December and June each
year, a list of new chemicals added since the last submission to the GDC Right
to Know Coordinator. Only new workplaces shall submit a complete list for
their first submission, then an updated list thereafter.
5. Each workplace manager shall ensure that employees are made aware of and
properly trained in the uses and hazards associated with chemicals to which
they are exposed in their workplaces before their initial assignment and when
new hazards are introduced into the work area. Additionally:
a. Employees must understand that they are exposed to hazardous chemicals;
b. Employees must understand that labels and SDSs can provide them with
information on the hazards of a chemical and should be consulted when
needed;
c. Employees must have a general understanding of what information is
provided on labels and SDSs, and how to access them;
d. Employees must be aware of the protective measures available in their
workplaces, how to use or implement these measures, and whom they
should contact if an issue arises;
e. Employee training on and notification of the use of hazardous chemicals in
the workplace must documented in each employee’s personnel file; and
f. Employees and offenders at each workplace within GDC must be provided
with personal protective equipment as required in each work environment
and receive adequate training on the use and maintenance of such
equipment. O.C.G.A. § 45-22-8.
F. Container Labeling: Chemical manufacturers and importers are required to
evaluate the hazards of the chemicals they produce or import and prepare labels
and SDSs to convey the hazard information. The manufacturer, importer, or
distributor shall ensure that each container of hazardous chemicals is labeled,
tagged, or marked in accordance with this SOP and in a manner which does not
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conflict with the requirements of the Hazardous Materials Transportation Act (49
U.S.C. § 1801 _et seq._ ) and regulations issued under that Act by the Department of
Transportation. Hazards not otherwise classified do not have to be addressed on
the container. The information shall be prominently displayed, in English (other
languages may also be included if appropriate), and must be located together on
the tag.
1. The following information shall be provided:
a. Product identifier;
b. Signal word;
c. Hazard statement(s);
d. Pictogram(s);
e. Precautionary statement(s); and
f. Name, address, and telephone number of the chemical manufacturer,
importer, or other responsible party.
2. Bulk Shipments of Hazardous Chemicals: The HCS requires either labeling the
immediate container with hazard information or transmitting the required label
with shipping papers, bills of lading, or by other technological or electronic
means so that it is immediately available to workers in printed form on the
receiving end of a shipment. The HCS requirements for shipped material apply
independently of whether the same material is subject to HMR labeling
requirements during transportation.
3. Solid Materials:
a. The required label may be transmitted to the customer at the time of the
initial shipment or with the safety data sheet that is to be provided prior to
or at the time of the first shipment, and need not be included with
subsequent shipments to the same employer unless the information on the
label changes for solid metal (such as a steel beam or a metal casting), solid
wood, or plastic items that are not exempted as articles due to their
downstream use, or shipments of whole grain;
|GEORGIA DEPARTMENT OF CORRECTIONS
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|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
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b. This exception to requiring labels on every container of hazardous
chemicals is only for the solid material itself, and does not apply to
hazardous chemicals used in conjunction or known to be present with the
material and to which employees handling the items in transit may be
exposed (for example, cutting fluids or pesticides in grains).
4. Workplace Labels:
a. GDC shall ensure that each container of hazardous chemicals in the
workplace is labeled, tagged, or marked with the information listed in
section F(i)-(vi) above or the product identifier and words, pictures,
symbols, or a combination thereof, that provide at least general
information regarding the hazards of the chemicals, and that, in
conjunction with the other information immediately available to
employees under the hazard communication program, will provide
employees with the specific information regarding the physical and
health hazards of the hazardous chemical.
b. The employer shall not remove or deface existing labels on incoming
containers of hazardous chemicals, unless the container is immediately
marked with the required information.
c. If an employer has an in-plant or workplace system of labeling that meets
the requirements of HazCom 1994, the employer may continue to use
this system in the workplace if this system, in conjunction with other
information immediately available to the employees, provides the
employees with the information on all the health and physical hazards of
the hazardous chemical. The workplace label systems may need to be
updated to make sure the information is consistent with any new
classifications.
d. This workplace labeling system may include signs, placards, process
sheets, batch tickets, operating procedures, or other such written
materials to identify hazardous chemicals.
e. Any of these labeling methods or a combination thereof may be used
instead of a label from the manufacturer, importer, or distributor if the
alternative method identifies the containers to which it is applicable and
conveys all of the information required for employees to have immediate
access to all of the information about the hazards of the chemical, and
|GEORGIA DEPARTMENT OF CORRECTIONS
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
the written materials are readily accessible to the employees in their work
areas throughout each work shift.
f. Workplace labels or other forms of warning must be legible, in English,
and prominently displayed on the container, or readily available in the
work area throughout each work shift. Employers with employees who
speak other languages may add the information in such employees’
languages to the material presented, as long as the information is
presented in English as well.
g. Employers may use additional instructional symbols on workplace labels
that are not included in OSHA’s HCS pictograms. An example of an
instructional pictogram is a person with goggles denoting that goggles
must be worn while handling the given chemical. Including both types
of pictograms on workplace labels is acceptable. The same is true if the
employer wants to list environmental pictograms or personal protective
equipment pictograms from the HMIS to identify protective measures
for those handling the chemical. If the employer chooses to use the
official pictograms on the workplace (or in-plant) labels, these
pictograms may have either a black or red border.
h. Employers may continue to use rating systems such as National Fire
Protection Association (NFPA) diamonds or HMIS requirements for
workplace labels as long as they are consistent with the requirements of
the HCS and employees have immediate access to the specific hazard
information as discussed above. An employer using NFPA or HMIS
labeling must, through training, ensure that its employees are fully aware
of the hazards of the chemicals used.
i. Employers who become newly aware of any significant information
regarding the hazards of a chemical shall revise the labels for the
chemical within six months of becoming aware of the new information,
and shall ensure that labels on containers of hazardous chemicals shipped
after that time contain the new information. If the chemical is not
currently produced or imported, the chemical manufacturer, importer,
distributor, or employer shall add the information to the label before the
chemical is shipped or introduced into the workplace again.
G. GDC Workplace Labeling System:
|GEORGIA DEPARTMENT OF CORRECTIONS
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|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
1. The Business Manager (purchasing agent) at each workplace, or his/her
designee, will verify that all containers received for use are:
a. Clearly labeled as to the containers contents;
b. Note the appropriate hazard statement;
c. List the name and address of the manufacturer; and
d. If all of the above are not present, ensure that it is corrected.
2. If SDSs are not available at the work area, or new chemicals in use do not have
a SDS, the Safety Officer or Business Manager should be contacted
immediately. If a copy of the SDS is not available from the Right to Know
Coordinator, a request in writing for the SDS should be forwarded immediately
to the vendor, distributor, or manufacturer.
3. The Business Manager or designee and the Safety Officer shall assist with
labeling as needed. All information for labels should come from the supplier's
original label and/or from the SDS.
4. If an employee transfers hazardous chemicals from a labeled container to a
portable container, such as a mop bucket that is intended only for immediate
use by the employee or offender who performs the transfer, then a label is not
required for the portable container.
5. The supervisor in each work area will ensure that all secondary (portable)
hazardous chemical containers requiring labels are labeled with either an extra
copy of the original manufacturer's label or a GDC approved generic label
containing the following information:
a. Signal Word (WARNING or DANGER)
b. Product Identifier
c. Precautionary Statement
d. Hazard Statement assigned to the Hazard Classification (example of
Hazard Classification is flammable solid, carcinogen, or oral acute
toxicity, etc.)
|GEORGIA DEPARTMENT OF CORRECTIONS
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|Authority: Commissioner
|Originating Division: Facilities
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e. In-house part number (if applicable)
f. Designated Pictogram
g. First Aid Information and Name, address and phone number of the
responsible party.
H. Training:
1. The GDC Director of Professional Development is responsible for
development, delivery, and content of the training program for paid
employees. General instruction/presentation techniques will be developed
by Staff Training for designated institutional personnel who will deliver
and document specific training for offenders. Staff Training personnel,
including institutional trainers, will not be utilized to train offenders. Each
workplace manager will ensure that all elements of the training program
are carried out. See OCGA § 45-22-8 and DOL Rule 300-3-19-.03.
2. All offenders will receive initial training at intake facilities during the
normal diagnostic process or during orientation at the offender’s assigned
facility. Additional training concerning specific chemicals located at
assigned work areas will be ensured by work area supervisor consistent
with the following:
a. The Chemical and Sanitation Officer (Safety Officer) is responsible
for conducing training for offenders and forwarding approved
training documentation for placement in each inmate’s institutional
file;
b. Prior to starting work, every new offender will attend an
orientation/training session and will receive information and
training. Training must be provided in the same manner as that
given to employees;
c. Training must include a lecture (explanation of Right to Know and
Understand), video (general explanation), handouts, questions and
answers session, additional training contingent on work assignment
with Signed Acknowledgement Form.
|GEORGIA DEPARTMENT OF CORRECTIONS
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
d. After attending the orientation/training class, each offender will
sign a form to verify that they attended the training, received
appropriate written materials, and understood the GDC policies and
procedures on Hazard Communication.
NOTE: Applicable to Offenders confined in state facilities only, County
Institutions are exempt.
3. Right to Know and Understand training will continue as part of annual in
service training for every employee. Annual in-service will include lecture
on the review of Right to Know and Understand, videos appropriate to
work assignment, handouts appropriate to work assignment, questions and
answers session, documentation of training.
4. Offenders will have training on an annual basis. This annual training will
include lecture on Review of Right to Know and Understand, videos
appropriate to work assignment, handouts appropriate to work assignment,
questions and answers session, documentation by signed
acknowledgement form.
5. All training sessions, for employees and offenders, will be conducted
utilizing approved lesson plans containing all requirements and methods of
documentation.
6. Documentation of employee (paid personnel) training will be furnished by
roster as with any other training. A copy of the roster(s) will be retained at
the workplace for a period of three (3) years.
7. The Director of Training will ensure that all required elements are included
in the Right to Know and Understand training curriculum appropriate for
management, supervisory, and other employees (including offenders).
Prior to starting work, every new employee, including temporary
employees and offenders, will attend an orientation/training session and
will receive information and training. Training must be provided in the
following manner:
a. Employees must be able to comprehend the information conveyed
during the training. If an employee does not speak English and is
given work instructions in a foreign language, then the training must
be provided in that language.
|GEORGIA DEPARTMENT OF CORRECTIONS
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
b. If employees have low literacy, training must be provided so they can
understand it (e.g. verbal instruction vs. reading documents).
c. A self-paced, interactive, computer-based training can serve as a
valuable training tool in the context of an over-all hazard
communication training program. However, use of computer-based
training by itself is not sufficient to meet the intent of the various
training requirements. Employees must have the opportunity to ask
questions and receive responses in a timely manner. Employees must
be informed and trained on the following:
i. Employee rights under the Act including the required
information they must be given;
ii. Any operations in their work area where hazardous chemicals
are present, handled and/or produced; and
iii. Methods and observations that may be used to detect the
presence or release of a hazardous chemical in the work area
(such as monitoring conducted by the employer, continuous
monitoring devices, visual appearance or odor of hazardous
chemicals when being released, etc.);
iv. The physical health, simple asphyxiation, combustible dust,
and pyrophoric gas hazards, as well as hazards not otherwise
classified, of the chemicals in the work area;
v. The measures employees can take to protect themselves from
these hazards and how to lessen or prevent exposure to these
hazardous chemicals through usage of control/work practices
and personal protective equipment;
vi. Specific procedures the GDC has implemented to protect
employees from exposure to hazardous chemicals, such as
appropriate work practices, emergency procedures, Plans of
Action per SOP 225.02 - Emergency Plans, and personal
protective equipment to be used;
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
vii. Locations, availability, and details of GDC’s written HCS
program, including the location of the required list(s) of
hazardous chemicals and SDSs;
viii. How to read SDSs and labels;
ix. The differences between MSDSs and SDSs;
x. The order of hazard information and how employees can
obtain and use the information;
xi. The standardized 16-section format of the SDS and the type
of information that can be found in the various sections; and
xii. The types of information that will be seen on the new labels,
including shipping containers, while ensuring employees
understand that the lack of pictograms, hazard statements,
etc., does not mean hazards do not exist (e.g. there are two
signal words: ‘Danger’ means a more severe hazard while
‘Warning’ means a less severe hazard within a warning class);
xiii. The workplace labeling system used by GDC. (e.g., if the
workplace labeling system includes HMIS or NFPA rating
systems, workers must be trained to understand what these
systems mean, how to utilize the information, etc.);
xiv. Emergency procedures; and
xv. Grievance procedures.
d. After attending the orientation/training class, each employee will sign
a form to verify that they attended the training, received appropriate
written materials, and understood the GDC policies and procedures on
hazard communication.
e. Prior to a newly-identified physical or health hazard being introduced
into any work area, or whenever a new chemical hazard the employee
has not previously been trained on is introduced into their work area,
each employee of that work area will be given the information outlined
above. If any employee is transferred into a new work area where
|GEORGIA DEPARTMENT OF CORRECTIONS
Standard Operating Procedures|Col2|Col3|
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|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|
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|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
exposure to hazardous chemicals new to the employee can occur, that
employee will receive additional training regarding those chemicals.
f. Periodically, employees and offenders are required to perform
hazardous non-routine tasks. Prior to starting work on such projects,
each affected employee will be given information by their work
supervisor about hazardous chemicals to which they may be exposed
during such activity. This information will include:
i. Specific chemical hazards;
ii. Protective/safety measures the employee can take; and
iii. Measures GDC has taken to lessen the hazards, including
ventilation, respirators, presence of another employee, and
emergency procedures.
g. All new employees including Administrators (executive staff,
superintendents, etc.) and Supervisory staff (program managers, shop
foremen, etc.) new (paid) employees, security and non-security will
receive the following training requirements:
i. Lecture (explanation of Right to Know and Understand)
ii. Video - general explanation
iii. Handouts
iv. Question and answer session
v. Documentation – Roster
h. In addition:
i. Security employees will receive additional training upon return
to facility contingent on post assignment;
ii. Non-security employees will receive additional training upon
return to facility contingent on work assignment.
|GEORGIA DEPARTMENT OF CORRECTIONS
Standard Operating Procedures|Col2|Col3|
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|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|Policy Name:Employee Hazardous Chemicals Protection and Right To Know and Understand|
|Policy Number: 511.34|Effective Date: 10/30/2017|Page Number:22 of 22|
|Authority: Commissioner
|Originating Division: Facilities
Division (Fire Services)|Access Listing:
Level I: All Access|
i. In-service training: (all employees)
i. Annual in-service training
ii. Lecture (Review of Right To Know and Understand)
iii. Videos appropriate to work assignment
iv. Handouts appropriate to work assignment
v. Question and answer session
vi. Documentation - Roster (in-service training)
Note: Employee training records shall be maintained by the Office of
Professional Development.
I. In addition to the training requirements outlined above, an information poster
describing employees’ (including offenders’) rights under the Act shall be
displayed at each GDC workplace. At those workplaces with geographically
dispersed work areas, a poster shall be placed in each work area.
Posters containing required information may be obtained from the DOL or may
otherwise be procured, but shall be worded pursuant to Attachment 2.
V. Attachments:
Attachment 1 - Model Written Hazard Communication Program;
Attachment 2 - It’s the Law Poster;
Attachment 3 - Acknowledgement Form; and
Attachment 4 - Example of Pictograms
VI. Record Retention of Forms Relevant to this Policy:
Attachments 1, 2, and 4 shall be maintained as instructed within this policy until
obsolete or replaced, then destroyed. Upon completion, Attachment 3 shall be
placed in the offender’s institutional file and maintained according to the retention
schedule for that file.