PAGE 1 OF 7 Hazard Communication Program Right to Know PURPOSE: It is the intention of BMT and all of its subsidiary companies to conduct its operations in such a manner that not only complies with health, safety and environmental measures required by law, but also to act positively to prevent injury, ill health, damage and loss arising from its operation. PROCEDURE: Scope It is with that intention in mind that the Company has chosen to apply measures taken to satisfy the United States Department of Labor Occupational Safety and Health Administration (OSHA) requirements for Hazard Communication to all locations, domestic and foreign, UNLESS A HOST COUNTRY PROGRAM OR STANDARD APPLIES, SUCH AS THE UK. CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH ACTS. Reference The exact requirements for the U.S. Federal OSHA Hazard Communication Standard can be found in the code of Federal Register 29 CFR Parts 1910.1200. The intent of the Hazard Communication Standard is to ensure that both the health and physical hazards of all chemicals used at the work place are identified and information is given on ways to protect employees while working with these chemicals. Requirements A. Hazard Evaluation Material Safety Data Sheets (MSDS) will be requested for chemicals and products purchased by the Company. We will rely on the evaluation performed by the manufacturer on chemicals and products purchased by the Company. 1. Physical Hazards: Substances that burn easily, explode, or react in some way. 2. Health Hazards: Substances that may be irritating, corrosive, sensitive or toxic. This information will be maintained on each work site and made available to all employees working on that work site. The MSDS will be maintained in a binder and Right-to-Know station signs will be conspicuously posted where permanent work sites or facilities exist.
PAGE 2 OF 7 B. Warning Labels 1. Once the physical and health hazards are identified, manufacturers are required to communicate these hazards. This is accomplished by labeling containers. The labels can assist the employees by identifying the physical and chemical hazards of the products in their work areas. Safety precautions to be taken when working with the substance are also listed. The label must contain the following: a) Appropriate hazard warning. b) The contents of the container. c) The name, address, and emergency telephone number of the chemical manufacturer. 2. Each container in the workplace must have a label, tag or mark that indicates the appropriate hazard warning. The field foreman, shop superintendent, etc., or designated person, will be responsible for ensuring that all chemical containers received on location have the approved warning label and that those labels are not defaced or removed. 3. Satellite containers of materials which have been transferred from their original containers must have approved warning labels attached. Approved labels include those outlined in the NFPA 704-M labeling system. Material Safety Data Sheets (MSDS) 1. The MSDS for all chemicals will be maintained at the work site. The MSDS form provides more detailed information about a product than the warning label. MSDS copies will be maintained at each work site. 2. The following information is provided on all MSDS sheets: a) Identification o/the Chemical: This section gives the chemical name, trade name, and any synonyms for the chemical. The CAS number and formula are also given. b) Physical and Chemical Characteristics of the Hazardous Chemical: This section will help identify the substance by observing its physical properties. It describes the chemicals, appearance, odor, boiling point, Ph and other technical data. c) Hazardous Ingredients or Components: Listed in this section are any hazardous ingredients that make up at least one percent (1%) of the total mixture. The Threshold Limit Value (TL V) will be listed, as well as the Health Hazard, Flammability and Reactivity values. d) Fire and Explosion Hazard: This section gives information on fire control, flash point and flammability limits of the material. e) Reactivity Data: This section gives information on conditions and materials that could increase the hazard of the chemical. Some materials react
PAGE 3 OF 7 dangerously or become unstable when in the presence of other chemicals or under certain conditions. f) Health Hazard Data: The TL V, health effects and emergency or first aid procedures are listed in this section. g) Spill or Leak Procedures: This section lists the procedures for cleanup of material. h) Special Protection: This section lists the manufacturer's recommendations for (personal protective equipment that should be used when working with the chemical. i) Special Precautions: This section details the required handling and storage procedures for the chemical. Information and Training All employees are required to attend a detailed Hazard Communication and Right-to- Know training session that covers the following topics: 1. Identification of hazardous material. 2. Toxicology. 3. Types: flammable, corrosive, radiation, etc. 4. Respirators: APR, SAR, SCBA. 5. Material Safety Data Sheet (MSDS). 6. Sign sheet. Non-Routine Tasks From time-to-time, employees may be required to perform tasks that are non-routine and may pose different hazards than those found in their normal workplace. Prior to beginning any such hazardous non-routine task, the regional manager or his designated representative is responsible for informing the employees of the appropriate safe handling methods for each chemical to be used. The specific chemical hazards, and the Company's policy on protective measures to be adhered to, including personal protective equipment, emergency procedures, ventilating respirator use and employee assistance will be communicated to the employees performing the task. Documentation of employee training of non-routine tasks shall be maintained. Adequate documentation consists of recording each trainee's name, social security number, training date, trainer's name, nature and extent of training, and date completed. Multi-Employer Workplaces
PAGE 4 OF 7 Many worksites may be classified as multi-employer workplaces. Where non- Company personnel may be exposed to the potential hazards of chemical substances that are brought to the workplace by the Company, MSDS sheets shall be made available for review by employees of other employers with whom we share the site. The Company onsite foreman will maintain a current inventory and copies of MSDS sheets of chemicals brought onsite. Employees shall be informed of marking and sign systems in use as well as precautionary measures to be taken in the event of a chemical release or exposure. All employees are expected to speak and understand English. Markings and signs may be.provided in the primary other language. Non-English speaking employees must understand markings and signs. Scope and Purpose HAZARD RECOGNITION (ASSESSMENTS) A study of industrial accident statistics reveals that almost six times as many industrial accidents occur as a result of unsafe acts of employees as compared to the unsafe physical conditions in the workplace, and yet, very little is done to understand or control the human element. A hazard detection and control program, that does not take into account the human element, is almost certain to fail. Definitions Hazard: An unassessed risk or a potential threat for a loss. An unsafe condition or an unsafe practice (act) that, if not corrected or controlled, has the potential to cause, contribute to or intensify an undesired or unintended event (accident). Accident: An unintended event that has the potential to cause damage to property, injury, illness or death. Loss: The bodily injury, death, financial or property damage arising out of an accident. Unsafe Condition: A physical condition within the environment with the potential to cause or contribute to an accident. Unsafe Practice (Act): A knowing or unknowing violation of the standard accepted procedures or practices with the potential to cause or contribute to an accident. If
PAGE 5 OF 7 hazards such as unsafe conditions and/or unsafe practices can be detected, action can be taken to eliminate or modify them. This action can help prevent an accident from occurring and, hence, prevent a loss. To do this successfully, it is important to understand the nature of unsafe conditions and unsafe acts and the reasons for their occurrence. If a hazard cannot be prevented, the strategy should be to control its frequency and severity. A. Types of Hazards Hazards from unsafe conditions can be temporary or permanent. They generally remain in the environment until found (i.e., by inspection or by accident) and tend to worsen with elapsed time. An important characteristic of these types of hazards is that once the fundamental cause of their existence is found and acted upon, they do not normally reoccur for any extended period of time. Unsafe condition type hazards can be caused by: 1. Unsafe practices. 2. Previous accidents. 3. Damaged equipment. 4. Normal wear and tear. 5. Poor maintenance. 6. Fabrication and/or design defects. 7. Improper arrangement or layout. 8. Environmental contamination. 9. By products of an operation. B. Unsafe Practice Type Hazards Hazards from unsafe work practices are not always easily identified compared to those from unsafe conditions. However, they will often result in a larger percentage of accidents. These hazards are often brought about by: 1. Lack of knowledge or skill. 2. Incentive to commit an unsafe act (deliberate act). 3. Existing poor work habits. 4. Habit interference reaction. 5. Mental or physical impairment. Because unsafe practices are harder to detect than the unsafe condition type hazards, they are much more difficult to control. They occur intermittently and are usually of short duration. The reasons for their occurrence can vary from individual to individual as well as varying reasons for the same individual. Analysis of unsafe
PAGE 6 OF 7 work practices requires an understanding of human nature in order to target a specific solution to each case. Hazard Detection A good safety program always starts with hazard detection that consists of a deliberate search and identification of various unsafe conditions and unsafe practices in the workplace. It requires a good knowledge of acceptable standards, codes, regulations and safe work practices. The tools that are most commonly used in hazard detection include: A. Physical Inspection A physical (or facility) inspection is a program of systematic and planned plant observations for the effective prevention of accidents, and efficient management of the people, equipment, machines and environment. Inspections can be formal or informal and are very suitable for detecting unsafe condition type hazards. A program of regular physical inspections can help spot developing unsafe conditions before they become, dangerous and produce an accident. The main weakness is the physical inspections are not as suitable for detecting hazards from '" unsafe work practices. They also may not reflect the actual accident experience and may have a tendency to overlook less obvious unsafe condition type hazards. B. Accident Investigation An accident investigation is basically an objective account, analysis and evaluation of an accident based on all facts, opinions, statements and related information. A true accident investigation also includes a recommended corrective action to prevent a reoccurrence of the accident. C. Accident Analysis An accident analysis is a collective analysis of data obtained from a variety of accident information. If accident reports and investigations, including First Aid records, are included.in this analysis, it significantly enhances its effectiveness in detecting unsafe conditions and unsafe practice type hazards. Accident and Incident Analysis looks at the total loss experience to highlight the vital few accidents that result in significant loss. This provides valuable insight into the loss data that may not be apparent in a single accident. It is most useful in providing a focus for corrective actions when the resources for any remedial action are scarce. A successful accident analysis requires a good knowledge of various
PAGE 7 OF 7 factors involved, but is only as good as the accident data available. Therefore, good accident record keeping is essential. Hazard Control 1. Unsafe conditions associated with normal wear and tear are some of the easiest to correct by instituting a good maintenance program. Hazards caused by defects in tools, equipment and workplace require more in-depth analysis like Process and Equipment Hazard Review and Ergonomic Analysis. Unsafe conditions arising out of environmental contamination may require engineering controls. It is important to note that unsafe practices like poor work habits also create unsafe conditions. Once correctly identified, control of unsafe condition hazards is usually a matter of allocating adequate resources for the corrective action. 2. Unsafe acts committed out of lack of knowledge are usually the most dangerous, but probably the easiest to control by providing proper instructions and training (i.e., employee orientation). 3. Unsafe acts committed because of poor or unsafe work habits can be corrected by training and periodically retraining until the unsafe habits are replaced by safe ones. 4. Unsafe acts that are committed knowingly or deliberately can be addressed by providing a stronger incentive to choose a safe practice over an unsafe one. These incentives can be positive (i.e., rewards) or negative (i.e., punishments). The incentive value of various objects and activities varies with different individuals and (situations. They pose a creative challenge to management. A person committing an unsafe act knowingly is generally aware of the danger and might take a compensating action to protect himself (i.e., a driver running a red light will often make certain that no police officer is around to issue a ticket). 5. Employee physicals and other careful job placement measures may help minimize ---adverse effects of an individual's physical or mental disability. Hazard Assessment Tools 1. Safe Work Checklist (Confined Space Entry). 2. Hazard Assessments (PPE). 3. Job Safety Analysis.