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8.8.1​ Written Hazard Communication Program

​​​​​All locations must create, implement, and maintain a written hazard communication (HAZCOM) program. The plan administrator is responsible for overseeing the HAZCOM program.

California's Department of Industrial Relations has provided a HAZCOM program template. The Department of Industrial Relations and Cal/OSHA have provided additional information about the HAZCOM program in the Guide to the California Hazard Communication Regulation.

A HAZCOM program must address the following elements:

If a location engages contractors who bring hazardous chemicals onto the premises, the location shall prepare and issue SDS and appropriate warnings.

8.8.1.1 Chemical Inventory and Safety Data Sheets

Prepare a chemical inventory at each location that uses SDS. List the chemicals located at each work site, including laboratories. Before a new chemical is purchased, the plan administrator must review it to see if SDS are needed. When the new chemical is received, the plan administrator shall review the SDS.

The plan administrator or designee shall ensure that staff members can readily access SDS for each hazardous chemical in the workplace.

Staff members who are involved in science lab teaching, whether at the ele​mentary school or high school level, must participate in the archdiocese science safety course offered in cooperation with Los Angeles County Office of Education.

8.8.1.2 Labels and Other Forms of Warning

All containers of chemicals used by staff and students shall be labeled to provide an immediate visual warning in English and Spanish (where available) of the substances in the containers.

Primary Means of Labeling

  • Use the manufacturer's label.

  • Do not remove or deface the label on a chemical container.

Secondary Means of Labeling

  • The secondary or backup label should be similar to the manufacturer's label. This will assist staff and students in easily identifying the product and reduce the possibility of an error.

  • Use the SDS in each case where a label is lost or illegible.

8.8.1.3Training Procedures

At the time of their initial assignment and whenever a new hazard is introduced into their work area, staff members shall receive information and training on hazardous chemicals in their work area. Staff members are to be trained by either the supplier representative or the plan administrator​ as soon as they are assigned to work with a hazardous chemical (see the Employee Training Verification Form). Retraining is to be done as directed by the plan administrator. Staff members who are involved in science lab teaching, whether at the elementary school or high school level, must participate in the archdiocese science safety course offered in cooperation with Los Angeles County Office of Education.

Train all students who come in contact with hazardous chemicals.

Training Requirements

Effective training should include an opportunity for staff and students to ask questions to ensure that they understand the information presented to them. Specifically, the training should include the following:

  • The operations in the staff members' and students' work area where hazardous materials are present

  • Methods and observations that may be used to detect the presence or release of a hazardous chemical (visual appearance, odor, monitoring, etc.)

  • Physical and health hazards of the chemicals

  • The details of the location's hazard communication program, the location and availability of the written program, an explanation of the labeling system and the SDS, and how staff and students can obtain and use the information

  • The personal protection equipment​ required for the staff member's or student's specific task