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15 Hazard Communications

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15-1: Purpose and Applicability

In order to comply with 29 CFR 1910.1200 Hazard Communication, the following written Hazard Communication Program has been established for Sokudo. Under this program, you will be informed of the contents of the Hazard Communication Standard, the hazardous properties of chemicals with which you work, safe handling procedures, and measures to take to protect yourself from these chemicals. You will also be informed of the hazards associated with non-routine tasks, such as the cleaning in confined spaces, and the hazards associated with chemicals in unlabeled pipes.

This program applies to all work operations in our company where you may be exposed to hazardous chemical under normal working conditions or during an emergency situation.

15-2: Program Management

A.     Safety Manager

The Sokudo Safety Manager has responsibility for this program.

In order to have an effective Hazard Communication Program the program is reevaluated by the Safety Manager on an annual basis. The MSDS's will be renewed every three years in order to assure that all chemicals at this company are under the program. This written program is maintained on the SokudoWeb (Intranet) and is accessible to all employees.

The Safety Manager will post a list of all hazardous chemicals maintained by Sokudo, and will update the list as necessary. Additionally, information and MSDS for all of the chemicals normally used in this industry is maintained on the SokudoWeb.

15-3: Methods of Compliance

A.     List of Hazardous Chemicals

The Safety Manager will post a list of all hazardous chemicals and related work practices used or stored in any Sokudo office and will update the list as necessary. The manager of each Sokudo office is responsible for creating an inventory list of all hazardous material and chemicals stored or used in the Sokudo office. This list is to be sent to the Safety Manager, who will post all of the lists on the SokudoWeb. See 15-5 in this document (Chemical Inventories) for links to an inventory list for each Sokudo office.

B.     Container Labeling

Each supervisor or manager will verify that all containers received for use will:

1. Be clearly labeled (in English) as to the contents,
2. Note the appropriate hazard warning,
3. List the name and address of the manufacturer.
• Note: If label is not in English, it must be translated. The English translation must be placed on the container. If this requirement can not be met, the substance can not be maintained or used by Sokudo employees and must be disposed of according to local, State, and Federal regulations for disposal of hazardous materials.

The supervisor or manager will refer to the corresponding MSDS to assist in verifying label information. Containers that are shipped from Japan will be checked by the supervisor receiving the container to make sure all hazardous materials and chemicals are properly labeled.

If you transfer chemicals from a labeled container to a portable container that is intended only for your immediate use, no labels are required on the portable container.

C.     Material Safety Data Sheets

The Safety Manager will be responsible for obtaining and maintaining the data sheet system for the company. The Safety Manager will review incoming Material Safety Data Sheets for new health or safety information, and will see that any new information is passed on to the affected employees.

Copies of MSDS's for all hazardous chemicals to which employees of this company may be exposed are maintained on the SokudoWeb (Intranet). Links are also provided to large collections of MSDS's on the Internet.

MSDS's will be available to all employees in their work areas for review during each work shift. If MSDS's are not available or new chemicals in use do not have MSDS's, immediately contact the Safety Manager.

D.     Employee Training and Information

The Safety Manager is responsible for the employee training program and will ensure that all elements specified below are carried out.

Prior to starting work on or around any DNS equipment, or during the first week of employment for positions not exposed to DNS equipment,  each new Sokudo  employee will complete their assigned safety training courses (see Sokudo Safety Training Program for details on which courses to complete and how to access courses).

One of the courses required for all Sokudo employees is Hazard Communication. Additionally, a course that covers the chemicals present in the workplace and how to work with them is required of all employees that work on or around DNS equipment.

E.     Hazardous Non-Routine Tasks

Any maintenance, or other infrequent work shall be reviewed by the supervisor or manager for potential exposure to hazardous chemicals or other safety problems. The supervisor or manager shall ensure a written procedure is developed, detailing appropriate actions and safeguards for the control of exposure to any hazardous chemicals. This procedure shall be used whenever the work is to be performed. Appropriate lock-out and tag-out procedures shall be followed. (See Sokudo Lockout/Tagout Policy)

The written procedure will include:

1. Specific chemical hazards,
2. Personal protective equipment or safety measures the employee should use,
3. Measures the company has taken to lessen the hazards including ventilation, respirators, presence of other employees, emergency procedures, etc..

F.     Informing Contractors

It is the responsibility of the supervisor or manager requesting contractor work to provide contractors and employees the following information:

1. Hazardous chemicals to which they may be exposed to while on the job site,
2. Precautions the employees may take to lessen the possibility of exposure by usage of protective measures.

The supervisor or manager will be responsible for contacting each contractor before work is started in the company to gather and disseminate any information concerning chemical hazards that the contractor is bringing to our workplace. See the Sokudo Contractor Safety Handbook for more information.

15-4: Rights of Employees

A.     Employees shall not be required to work with a hazardous chemical from a container that does not have a label, except for a portable container intended for immediate use by the employee who performs the transfer.

B.     Employees that are routinely exposed to hazardous chemicals shall be informed of such exposures and shall have access to MSDSs for the hazardous chemicals. In addition, employees shall receive training on the hazards of the chemicals and on measures they can take to protect themselves from those hazards.

C.     Departments shall provide, at no expense to employees, appropriate personal protective equipment to protect employees from exposures to hazardous chemicals. Please note that the use of respiratory equipment must be in accordance with the Sokudo Respiratory Protection Program.

D.    No department shall discharge, cause to discharge, or otherwise discipline or in any manner discriminate against an employee because the employee has filed a complaint, assisted an inspector of the State or Federal government, or has instituted or caused to be instituted any proceeding under or related to the Occupational Safety and Health Act or the Right to Know Act or has testified or is about to testify in any such proceeding or because of the exercise of any rights afforded pursuant to the provisions of the Act on behalf of the employee or on behalf of others, nor shall pay, position, seniority or other benefits be lost for exercise of any right provided by the Act.    

15-5: Chemical Inventories