HAZARD COMMUNICATION PROGRAM

1. HAZARD COMMUNICATION PROGRAM OSHA Standard 29 CFR 1910.1200 The OSHA hazard communication standard was developed to ensure that the hazards of all chemicals produced or imported are evaluated and that information concerning their hazards is transmitted to employers and employees. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

2. ENVIRON’s Program Objectives Meet the requirements of the OSHA Hazard Communication Standard. Make hazardous material health and safety information available to employees and contractors. Provide employees with training about chemical hazards, safe work practices, and protective measures. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

3. Key Elements of ENVIRON’s Program • Program management • Employee training • Development of written program • Creation and maintenance of hazardous materials lists • Maintenance of Material Safety Data Sheets (MSDSs) • Labeling of containers • Notification of contractors • Notification of non-routine tasks HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

4. Program Management • Health and Safety Coordinator (“HSC”): Acts as Program Manager and oversees maintenance of the program. Updates hazardous materials list. Maintains MSDSs. Monitors in-house labeling. Coordinates training. Maintains training records. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

5. Program Management Project Manager: Notifies HSC of hazardous materials used at the workplace or job site. Ensures proper labeling of containers in work areas or job sites. Ensures that project personnel have been trained to deal with hazardous materials at each site. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

6. Program Management • Employees: • All employees should be familiar with the materials that they work with or are exposed to and should be able to handle these materials properly. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

7. Training Requirements Employees will receive training on the hazards of the materials they use at work and appropriate means of protecting themselves. Site-specific training for ENVIRON employees will be provided prior to any employee’s assignment to a work area or job site. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

8. Training includes: Scope and content of the OSHA hazard communication standard and of ENVIRON’s program. Availability and location of hazardous materials lists and MSDSs. Interpretation of MSDSs and labels. Methods employees may use to detect and protect themselves from hazardous materials. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

9. Written Hazard Communication Program ENVIRON’s written program provides a description of how we will meet the requirements of the hazard communication standard (29 CFR 1910.1200). A copy of the program is available at each ENVIRON facility. ENVIRON’s written Hazard Communication Program can be found by accessing the ENVIRON Exchange Health and Safety site. Site-specific Health and Safety Plans will address applicable elements of the Hazard Communication Program. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

10. Definition of a Hazardous Material/Chemical Any material or chemical that presents a physical injury or health hazard or if at least one valid statistically significant study has found an acute or chronic health effect caused by the material/chemical. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

11. What is a Hazardous Materials List? An up to date listing or index of all hazardous materials present in the workplace or at a job site that is designed to allow easy access to MSDSs. The HSC is responsible for maintaining the list at ENVIRON facilities and designated ENVIRON Site employees will be responsible for working with Host facilities to ensure that lists exist at client sites. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

12. How to Develop and Update a Hazardous Materials List Inventory all hazardous materials at your site. Create an alphabetical listing of the materials that can be used as a cross reference for MSDSs. Keep a copy of the list in the front of each MSDS notebook and in a master file. Update the list as new chemicals arrive. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

13. Material Safety Data Sheets An MSDS is a collection of health and safety information about a chemical, raw material, or product. The purpose of the MSDS is to provide information on the potential hazards associated with the material. MSDSs must be present in the workplace or at the job site and available to employees if chemicals are located at the site. Chemical manufacturers are required to provide MSDSs with shipments of hazardous material. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

14. Maintaining Material Safety Data Sheets Original MSDSs should be kept in a master file. MSDSs should be organized in a three-ring notebook. In most cases, one MSDS notebook per facility will be sufficient to comply with the OSHA standard MSDS notebooks should be maintained in work areas or job sites where hazardous materials are located. Missing MSDSs should be requested from the supplier of the hazardous material. Employees should not remove an MSDS from the notebook without permission from the HSC. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

15. Chemical Identities Must be Labeled on the MSDS Single chemical: chemical and common name Mixture (if tested as a whole):chemical and common names of component Mixture (if not tested as a whole):chemical and common names of hazardous substances in concentrations greater than 1% Mixture (if presence of more than 1% of hazardous substance is a potential carcinogen) Mixture (if, during use, airborne concentration of hazardous ingredients exceed OSHA PELs) HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

16. Other Requirements to be Listed on MSDSs Physical and health hazards of a chemical Physical and chemical characteristics of a chemical (i.e. flash point or boiling point) Proper safe handling procedures (hygienic practices and/or protective measures) Emergency procedures (hygienic practices and/or protective measures) Routes of entry (i.e. air, absorption, injection) Exposure values Exposure controls (engineering controls and/or PPE) Carcinogenic potential (if concentration is greater than 1% and is listed as a potential carcinogen by NTP, IARC, or OSHA) Preparation date (provided by manufacturer or importer) HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

17. Hazard Communication Labels A hazard communication label is a label, tag, sign, or other form of printed material that tells what chemical is inside a container and the potential hazards associated with the chemical. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

18. Types of Labels Original Labels: Labels accompanying the shipping or product container. Secondary Labels: Labels the employer attaches to secondary containers or process vessels. Secondary labels include containers into which the chemical is transferred for transport or for use in the workplace or at a job site. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

19. Labels Must Include: Chemical or product name Identity of hazard(s) Hazard warning(s) Manufacturer, or other responsible party, name and address (not required for secondary labels) Single-use containers (filled, used, and emptied by a single individual) do not have to be labeled. For example, sample bottles with preservatives, or fixatives that are filled, handled and transported by the same individual. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

20. How to Read a Label • Colored boxes are used to identify specific hazards. • Numbers or codes in the boxes tell you the value of the • hazard. • higher number = higher hazard HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

21. How to Read a Label • Fire Hazard • Health Hazard • Reactivity Hazard - explosive, unstable • Special Hazards - corrosive, radioactive, water, reactive, acid Red: Blue: Yellow: White: HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

22. If a Label is Difficult to Read... • Stop - do not use the chemical • Tell your supervisor • Read the MSDS and have another label put on the container HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

23. Contractors/Subcontractors Contractors and subcontractors must be informed in writing of the following: Hazardous materials present at the site Precautions to be taken to minimize the risk to contract employees ENVIRON employees working at a site must ensure that written documentation of all hazardous materials present, as well as any precautions that have been taken, are provided to all personnel (including subcontractors and contractors). ENVIRON employees should request this information from the host facility if ENVIRON is the contractor or subcontractor at the site. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

24. Subcontractor Responsibilities Subcontractor agreements should include: Designation of subcontractor contact person. Statement identifying the subcontractor’s responsibility to comply with health and safety regulations. Subcontractor’s agreement to provide and enforce the use of PPE as appropriate. Request for list of hazardous chemicals that may be introduced to the site during work. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

25. Non-Routine Tasks Non-routine tasks are work activities that place an employee at risk to materials that are not encountered during normal job responsibilities. Non-routine tasks are not typically conducted at ENVIRON facilities However, employees often frequent client facilities where non-routine tasks (such as periodic maintenance or repair tasks) are being performed. ENVIRON employees should always check with the host facility to see if any non-routine tasks are being performed during the site visit. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

26. What to do if a Non-Routine Task Occurs Identify the nature of the hazardous materials likely to be encountered. Identify the hazards associated with exposure. Identify the need for PPE. Identify special precautionary measures that should be taken. Contact the Project Manager or HSC with questions or concerns about performing non-routine tasks at a job site. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M

27. Summary • All employees who encounter hazardous materials during the course of their jobs should know where to find hazardous materials lists, MSDSs, and other information related to the health hazards of chemicals they may be exposed to while at work. They should also be familiar with hazardous material container labels and with the responsibilities they may have to notify contractors/subcontractors of potential risks from hazardous substances at job sites. HAZARD COMMUNICATIONS / E N V I R O N H & S T R A I N I N G P R O G R A M