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7.14.15 Harlem – Hazard Communication

In order to comply with the Occupational Health and Safety Regulations, 29CFR 1910.1200, a Hazard Communication Program has been established for Open Door.  All departments and sections of the company are included in this program.  The written program will be available in all work units for review by any interested employee.

Open Door will meet the requirements of this rule as follows:

Hazard Determination

Open Door will rely on the Chemical Manufactures Safety Data Sheet (SDS) for Hazard Determination

Container Labeling

The Following labeling systems will be used at Open Door.

  • Each chemical container by the facility must meet all of the following criteria:
    • Has an intact legible label
    • The label is written in English
    • The label clearly identifies the product and lists the contents
    • Lists the name and address of the manufacturer
    • Notes the appropriate hazard warnings
    • The product is on our SDS list or a valid SDS accompanies the delivery
  • No container is to be removed from the delivery area until the appropriate supervisor has verified the information listed above.  Any container that fails to meet all of the criteria shall be refused.

Secondary Containers

Only containers that meet the above criteria shall be used.  No chemical shall be dispensed into another container (such as a spray bottle) that does not meet the above labeling criteria.

Exception:  A bucket containing a chemical that was dispensed and is being used by one employee does not need to be labeled if the employee remains in the vicinity of the bucket and uses it promptly.

Safety Data Sheets (SDS)

Safety Data Sheets are kept in each apartment, office, nursing office, and in the maintenance building.  These sheets provide information to employees about a specific chemical’s hazardous ingredients, physical and health hazards, physical characteristics, safety precautions, first aid measures, and other information.  The facility Safety Director is responsible for maintaining current SDS for all chemicals.  Employees receiving original or updated SDS shall forward them to the Safety Director.

List of Hazardous and Non-hazardous Chemicals

OSHA requires that employers inform employees of hazardous chemicals to which they may be exposed.

Chemicals are listed alphabetically by department, in the department where the chemical is most frequently used.  Additional information on each product may be obtained from the SDS in each apartment, the nursing office, the reception desk, or the maintenance building.

The following products are exempt from the OSHA Hazard Communication Standard:

            Alcoholic Beverages                              Tobacco Products

            Pharmaceuticals                                    Cosmetics

            Food & Beverages

Consumer Product Exemption

A consumer product that is used in a similar manner, at a similar frequency, duration, and exposure level as it would be in a consumer setting is exempt from the Hazard Communication Standard.  Examples of this exemption would include an office worker who used a product such as Windex or Pledge to clean their work area on a periodic basis.

Prohibitions

CHEMICALS:  Employees shall not bring any chemical into the facility, nor use any chemical in a location or for a purpose other than that for which it is intended.  The use of household bleach is limited to personal laundry, for machine use only, and in dish sanitation in recommended concentrations.  Only authorized employees shall mix any concentrate to create solutions.

Personal Protective Equipment

General
  • The facility will provide all necessary personal protective equipment, without charge to employees
  • Employees shall not perform any duties requiring personal protective equipment unless the equipment provided is used
  • Employees shall not utilize personal protective equipment for any purpose beyond its design capabilities or for any purpose other than that for which it is intended
  • Employees should not use damaged personal protective equipment that has not been approved or provided by the facility
  • All personal protective equipment shall be maintained in a sanitary condition
Specific Equipment

Gloves: Any glove that is torn, peeling, cracked, discolored, punctured, or otherwise damaged shall be discarded and not used.

Examine Gloves: FDA-approved latex or vinyl Examination Gloves shall be used for all activities as outlined under Universal Precautions, and clean-up of Blood and Body Fluid Spills (Single Use)

Industrial Gloves: Heavy-duty latex rubber gloves shall be used by all personnel in all situations where contact with blood or body fluids is likely, such as handling soiled linen or eating utensils, and when required to protect skin from contact with chemicals (Single employee use)

Oven Mitts: EMPLOYEES handling hot objects shall wear oven mitts (Group use)

Miscellaneous Gloves: EMPLOYEES shall wear appropriate gloves when their hands may be exposed to extremes in temperature or abrasion (Single Employee use)

Sanitation Designations

Single use:  Used one time, by one employee.  Discarded when the task is complete

Single Employee use: Used by one employee.  Labeled with employee name.  Discarded when damaged or unsanitary.

Group use: Used by multiple employees.  Discarded when damaged or unsanitary.

Disinfectable: Used by multiple employees.  Disinfected between each use.

Respirator: Mist and dust respirators meeting ANSI Z88.2 shall be used in the presence of nuisance dust.  Activities requiring more sophisticated respiratory protective equipment shall be performed by qualified maintenance personnel (Single-use)

Goggles: Goggles meeting ANSI Z87.1 shall be used by employees in all departments, as outlined under Universal Precautions, and in any situation where Safety Data Sheets require (Single employee use) or (Disinfectable)

Face Shields: Face shields meeting ANSI Z87.1 shall be used by employees in all departments, as outlined under Universal Precautions, and in any situation where Safety Data Sheets require (Disinfectable)

Safety Glasses: Safety glasses meeting ANSI Z87.1 shall be used by employees in any situation where the potential for eye injury exists, including (but not limited to) all power equipment operation, and all sawing, drilling, and cutting operations.  (Single employee use) or (Disinfectable)

Steel-toe shoes and protectors:  All employees shall wear steel-toed shoes/protectors meeting ANSI Z41.1 when required to protect feet from injury (Group use)

Chemicals in Unlabeled Pipes

NATURAL GAS: Natural gas is present in unlabeled pipes throughout the facility.  Natural gas has a distinctive odor.  It is highly flammable and can ignite explosively.

Do not damage piping; do not hang from, stand on, strike, or attach anything to pipes.  Do not use torches on or near these pipes.  Do not attempt to relight the pilot light on the hot water heater.  Qualified maintenance personnel are available at any time to perform repair or service tasks.

For additional information on the contents of any unlabeled pipe contact the Safety Director.

Informing Contract Labor/Contractors

The Safety Director will be responsible for notifying contractors of the existence of our program and the requirements for chemicals introduced into the wo

Signed by:

Rebecca Sharp Porter
Chief Executive Director

Last Revised: 10/11/23

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