Visitor Hazard Communication ... - International Paper
Visitor Hazard Communication ... - International Paper
Visitor Hazard Communication ... - International Paper
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HAZCOM Safety & Health Manual INTERNATIONAL PAPER<br />
Approval Date: 12/13/04 Franklin, VA<br />
Effective Date: 3/1/05 Page 1 of 40<br />
1.0 PURPOSE<br />
HAZARD COMMUNICATION POLICY<br />
The purpose of this procedure is to ensure: (1) that the physical and health hazards of all<br />
chemicals are properly evaluated and controlled, and, (2) that the information concerning such hazards, as<br />
well as the appropriate protective measures, is effectively communicated to those who may be exposed.<br />
2.0 SCOPE<br />
2.1 This procedure applies to all chemicals known to be present in the workplace in such a manner<br />
that workers may be exposed under normal conditions of use or in foreseeable emergencies.<br />
2.2 This policy does not apply to the following chemicals:<br />
2.2.1 <strong>Hazard</strong>ous Wastes as defined by the US Environmental Protection<br />
Agency’s Resource Conservation and Recovery Act (RCRA).<br />
2.2.2 <strong>Hazard</strong>ous Substances as defined by EPA’s Comprehensive Environmental Response<br />
Compensation and Liability Act (CERCLA) only when the hazardous substance is the<br />
focus of remedial or removal action being conducted under CERCLA regulations.<br />
2.2.3 Tobacco or Tobacco Products<br />
2.2.4 Wood or wood products which will not be processed (i.e., sawed,<br />
cut, or treated)<br />
2.2.5 Articles as defined by this procedure<br />
2.2.6 Food which is sold, used or prepared in a retail establishment and foods (including<br />
beverages) intended for personal consumption<br />
2.2.7 Drugs and cosmetics intended for personal consumption or use<br />
2.3 The essential features of this program includes:<br />
2.3.1 The chemical approval and control process<br />
2.3.2 The approved chemical list maintained by Loss Prevention<br />
2.3.3 The hazard determination process for site generated chemicals<br />
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2.3.4 <strong>International</strong> <strong>Paper</strong> and manufacturer Material Safety Data Sheets (MSDS)<br />
2.3.5 Labels and other forms of warnings for incoming and for outbound containers and<br />
pipes and piping systems.<br />
2.3.6 Information and training provided to <strong>International</strong> <strong>Paper</strong> employees, contractors,<br />
unescorted visitors, and those individuals with specific responsibilities with this<br />
procedure.<br />
2.3.7 How trade secret information is provided during both emergency and non-<br />
emergency situations.<br />
3.0 RESPONSIBILITIES<br />
2.3.8 The chemical audit process for the site.<br />
2.3.9 Identification of how the hazards and the necessary control measures associated with nonroutine<br />
tasks will be communicated to employees.<br />
3.1 Loss Prevention<br />
3.1.1 Oversee the various administrative functions associated with this policy.<br />
3.1.2 Perform hazard determinations on all new or trial, process and non-process, <strong>International</strong><br />
<strong>Paper</strong> and manufacturer chemicals.<br />
3.1.3 Develop and maintain the original MSDSs and approval forms and review all incoming<br />
MSDSs for completeness prior to posting.<br />
3.1.3.1 When MSDSs are received by mail or obtained when the product is received, the<br />
Loss Prevention Department shall verify that the incoming chemical is on the<br />
Chemical Inventory List, and assess whether the MSDS received has been<br />
updated. If new hazard information has been identified, Loss Prevention will be<br />
responsible for the distribution of the information.<br />
3.1.4 Maintain the master list of chemical products which are approved for use on the Franklin<br />
Mill site. This list shall be maintained for at least 30 years.<br />
3.1.5 Perform an annual chemical inventory audit for certain hazardous chemicals (ie., those<br />
with a designated threshold quantity).<br />
3.1.6 Perform a millwide chemical inventory audit every five (5) years.<br />
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Effective Date: 3/1/05 Page 3 of 40<br />
3.1.8 Perform an annual formal documented audit to assess whether this policy is being<br />
maintained and effectively implemented. This audit may be conducted as part of the<br />
annual safety and health audit.<br />
3.1.9 Provide product hazard information in the event of an offsite chemical spill.<br />
3.2 Department Management<br />
3.2.1 Provide designated areas where eating, drinking, smoking and/or applying cosmetics are<br />
permitted, such that the employee is not exposed to the hazardous chemicals which are<br />
used or produced within the area of work.<br />
3.2.2 Conduct an annual inspection of all bulk or portable container labels to ensure that labels<br />
have not been removed or damaged. If damaged or removed labels have been identified, a<br />
system must be established to ensure that labels are appropriately replaced.<br />
3.2.3 Perform all general and specific hazard communication training as outlined within this<br />
policy.<br />
3.2.4 Provide employees with training on the hazards associated with a Non-Routine Task prior<br />
to the task being performed (Refer to 6.10 for additional details)<br />
3.2.5 Assist the Loss Prevention Department in performing hazard determinations of all new or<br />
trial process and non-process chemicals and instituting the appropriate control measures<br />
for the hazards identified.<br />
3.2.6 Assist the Loss Prevention Department in performing an annual chemical inventory audit<br />
for certain hazardous chemicals (i.e., those with a designated threshold quantities), as<br />
well as a millwide chemical inventory audit every five (5) years.<br />
3.2.7 Send all MSDSs from vendors, manufacturers or mail to the Loss Prevention Department.<br />
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Effective Date: 3/1/05 Page 4 of 40<br />
3.3 Purchasing / Storeroom<br />
3.3.1 Send all MSDSs (new or updated) received from vendors, manufacturers, or the like<br />
through the mail, through product packaging, or through shipping papers to the Loss<br />
Prevention Department.<br />
3.3.2 Provide chemical safety and emergency response information to visitors, vendors,<br />
common carriers and delivery personnel in accordance with Attachment 7.0.<br />
3.3.3 Responsible for obtaining the appropriate OSHA labels when it has been identified that a<br />
supplier of a hazardous chemical has not provided the appropriate OSHA label defined in<br />
6.5.4<br />
3.4 Contractor Manager<br />
3.4.1 Ensure that contractors are aware of the IP chemical hazards that they may encounter<br />
while working at the Franklin Mill. Provide IP MSDSs to contractors when necessary.<br />
3.4.2 Ensure chemicals used by contractors have been reviewed and approved by Loss<br />
Prevention and Environmental as required by the Franklin Mill Chemical Management<br />
Procedure.<br />
3.5 All Employees<br />
3.5.1 Label all containers as described in section 6.5 of this policy, with the appropriate<br />
chemical identity, hazard warnings and target organ effects.<br />
3.5.2 Label all outbound hazardous chemicals leaving the workplace (eg: shipped) with the<br />
appropriate “OSHA” and “DOT” labels (Refer to section 6.5)<br />
3.5.3 Inform supervision or the mill industrial hygienist of any chemical hazard not identified<br />
on the material safety data sheet. (Refer to the TSCA Policy for additional details).<br />
3.5.4 Request that a hazard evaluation be performed in accordance with the site Industrial<br />
Hygiene Exposure Monitoring and Assessment Program, where chemical exposure<br />
concerns are identified.<br />
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3.6 Medical Department<br />
3.6.1 Provide medical response information upon request to health care professionals or<br />
emergency responders.<br />
3.6.2 Provide hazard information in the event of an on-site chemical emergency.<br />
3.7 Transportation<br />
4.0 DEFINITIONS<br />
3.7.1 Upon notification of an offsite chemical spill, perform appropriate response as defined in<br />
Attachment 8.0.<br />
4.1 Article - a finished product other than a fluid or a particle which:<br />
* Is formed to a specific shape or design during manufacture, and<br />
* Has end use function(s) dependent upon its shape or design during<br />
end use, and,<br />
* Under normal conditions of use does not release more than very small quantities<br />
(e.g., less than 1% by volume of a hazardous chemical or 0.1% by volume of a carcinogen),<br />
and does not pose a physical hazard or health risk to workers.<br />
NOTE: Examples of articles include: reams of paper, adhesive<br />
tape, office furniture, finished bags and boxes, and wooden pallets.<br />
4.2. Chemical - any element, chemical compound of mixture of elements and/or compounds,<br />
including: (1) finished products (2) isolated intermediates; (3) samples; (4) by-products; (5)<br />
known decomposition products; and, (6) wastes.<br />
4.2.1 <strong>Hazard</strong>ous Chemical - any chemical which is a physical hazard or health hazard.<br />
4.2.1.1 Physical <strong>Hazard</strong> - a chemical that is: (a) a combustible liquid; (b) a compressed<br />
gas (e.g., compressed air steam, LP gas, argon); (c) an explosive; (d) a flammable<br />
liquid or gas; (e) an organic peroxide; (f) an oxidizer; (g) pyrophoric; (h) unstable<br />
(reactive); or, (i) water-reactive.<br />
4.2.1.2 Health <strong>Hazard</strong> - a chemical for which there is statistically significant evidence<br />
based on at least one study which indicates acute or chronic health effects may<br />
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occur in exposed individuals. Health hazards include chemicals which are: (a)<br />
carcinogens; (b) toxic or highly toxic agents; (c) reproductive toxins; (d) irritants;<br />
(e) corrosives; (f) sensitizers; and (g) agents which damage the liver, kidneys,<br />
nervous system, blood system, lungs, skin, eyes, or mucous membranes.<br />
4.2.2 Non-<strong>Hazard</strong>ous Chemical - a chemical that is not considered to be a physical or health<br />
hazard as defined by this procedure.<br />
4.3 Chemical List - a listing of all of the hazardous and non-hazardous chemicals (excluding those<br />
exempted by Section 2.3) which is maintained by the Loss Prevention Department.<br />
4.4 Chemical Manufacturer - an employer who manufactures, process, formulates, blends, mixes, or<br />
repackages chemicals for use or distribution.<br />
NOTE: Chemical manufacturers include, but are not limited to facilities involved with mixing<br />
two or more chemicals (e.g, coating mixture, effluent) or those producing by products (e.g.,<br />
hydrogen sulfide) or wastes (e.g., used oil), with the exception of hazardous wastes regulated by<br />
EPA.<br />
4.5 Chemical Name - the scientific designation of a chemical in accordance with the nomenclature<br />
system developed by the <strong>International</strong> Union of Pure and Applied Chemistry (IUPAC) or the<br />
Chemical Abstract Service (CAS) rules of nomenclature, or a name which will clearly identify<br />
the chemical for the purpose of conducting a hazard determination.<br />
4.6 Common Name - any designation or identification such as code name or number, trade name,<br />
product name, brand name, or generic name used to identify a chemical, other than by its<br />
chemical name.<br />
4.7 Consumer Product - any retail product that is contained in consumer-type packaging and is used<br />
in a consumer manner as intended by the original chemical manufacturer. Whenever a consumer<br />
product is not used in a manner which is comparable to typical consumer use, it is covered by the<br />
requirements specified in this procedure. Since many consumer products are used in larger than<br />
normal quantities on the Franklin Mill site, consumer products are not exempt from this policy.<br />
4.8 Container - any bag, barrel, bottle, box, can, cylinder, drum, sample, tote, tank truck, dump truck,<br />
tank car, reaction vessel, storage tank, or other process equipment, or the like, that contains a<br />
chemical. containers may be stationary or portable. pipes or piping systems, and vehicle engines,<br />
vehicle fuel tanks, or other vehicle operating systems, are not considered to be containers.<br />
4.9 Exposure or Exposed to - encountering a hazardous chemical through any route of entry (e.g.,<br />
inhalation, ingestion, skin contact, or absorption). It includes potential exposures associated with<br />
foreseeable emergencies.<br />
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4.10 Foreseeable Emergency - any potential occurrence such as, but not limited to equipment failure,<br />
rupture of containers, or failure of control equipment, which could result in an uncontrolled<br />
release of a hazardous chemical.<br />
4.11 HAZCOM - <strong>Hazard</strong> <strong>Communication</strong>.<br />
4.12 <strong>Hazard</strong> Determination - the process of formally evaluating chemicals against a specified criteria<br />
to identify any potential physical and/or health hazards.<br />
4.13 <strong>Hazard</strong> Warning - any words, pictures, symbols, or combination thereof which convey the<br />
hazards(s) of the chemical(s) in the container.<br />
4.14 Importer - the first business which receives chemicals produced in other countries for the purpose<br />
of using or supplying them to distributors or employers within the receiving country.<br />
4.15 Isolated Intermediates - known and isolated chemicals that are produced during the processing or<br />
use of chemicals, which are intentionally removed from the manufacturing process equipment,<br />
stored or transferred to other containers.<br />
4.16 Label - any written, printed, or graphic material displayed on or affixed to a container of a<br />
chemical(s), which identifies the chemical name and the applicable hazard(s).<br />
4.17 Material Safety Data Sheet (MSDS) - any written or printed material concerning a hazardous<br />
chemical which is prepared in accordance with Section 5.3 of this procedure.<br />
4.18 Mixture - any combination of two or more chemicals, if the combination is not, in whole or in<br />
part, the result of a chemical reaction.<br />
4.19 Produce - to manufacture, process, formulate, blend, extract, generate, emit, repackage, or import<br />
for distribution.<br />
4.20 Toll Manufacturer - a third party who manufactures a product for another company.<br />
4.21 Trade Secret - any confidential formula, pattern, process, device, information or compilation of<br />
information, that is used in an employer’s business, and that gives an employer an advantage over<br />
competitors, who do not know or use it.<br />
4.22 Work Area - a room of defined space in, or associated with a workplace where chemicals are<br />
produced or used, and where employees may be present.<br />
4.23 Workplace - an establishment, job site, or project, at one geographical location containing one<br />
or more work areas.<br />
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5.0 REFERENCES<br />
5.1 Occupational Safety & Health Administration’s (OSHA) <strong>Hazard</strong> <strong>Communication</strong>s, 29 CFR<br />
1910.1200<br />
5.2 <strong>International</strong> <strong>Paper</strong> Franklin Mill’s Contractors on Premises Procedures Manual<br />
5.3 IP’s Pipe Labeling Specification, SDS-3<br />
5.4 <strong>International</strong> <strong>Paper</strong> Franklin Mill Transportation Department’s <strong>Hazard</strong>ous Materials<br />
Transportation Training Manual<br />
5.5 Department of Transportation, Code of Federal Regulations (49 CFR)<br />
5.6 American National Standard for <strong>Hazard</strong>ous Industrial Chemicals - Standard for the Preparation<br />
of Material Safety Data Sheets (ANSI Z400.1-1993)<br />
5.7 American National Standard for <strong>Hazard</strong>ous Industrial Chemicals – Precautionary Labeling<br />
(ANSI Z129.1-1994<br />
5.8 IP Franklin Mill, Chemical Management Policy<br />
5.9 IP Franklin Mill Toxic Substances Control Act (TSCA 8(c) and 8(e)) Environmental Allegations<br />
Policy<br />
5.10 National Fire Protection Association, NFPA 704<br />
5.11 IP Franklin Mill Emergency Management Plan<br />
6.0 PROCEDURE<br />
6.1 <strong>Hazard</strong> Determination<br />
6.1.1 <strong>Hazard</strong> determinations shall be conducted for chemicals used, produced, blended, mixed,<br />
generated, or imported by the site.<br />
6.1.2 The chemicals found in the workplace fall into two broad classes: purchased materials<br />
and manufactured materials.<br />
6.1.2.1 For those materials that are purchased, <strong>International</strong> <strong>Paper</strong> shall rely on the<br />
manufacturer’s MSDS, in good faith, as the first step in evaluating potential<br />
hazards associated with the materials.<br />
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6.1.2.1.1 All MSDS’s for purchased materials are then<br />
reviewed for completeness and identification of whether the<br />
chemical possess any physical and/or health characteristics which make it<br />
hazardous in accordance with the <strong>Hazard</strong> <strong>Communication</strong> Standard.<br />
6.1.2.1.2 Where a review shows the MSDS to be incomplete, a revised<br />
MSDS will be requested.<br />
6.1.2.1.3 The specific procedures for obtaining MSDS’s and conducting<br />
reviews are detailed in the Chemical Management Policy.<br />
6.1.2.2 For those materials that are produced or manufactured within the workplace,<br />
<strong>International</strong> <strong>Paper</strong> has decided to conduct its own hazard determination.<br />
6.1.2.2.1 This determination is conducted by the<br />
Technical Department, the Loss Prevention<br />
Department, and the Department producing or<br />
manufacturing the chemical.<br />
6.1.2.2.2 <strong>Hazard</strong> determinations for site-generated and<br />
imported chemicals shall be conducted in<br />
accordance with the <strong>Hazard</strong> Determination<br />
Procedure, outlined in Attachment No. 1.0.<br />
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6.2 Chemical List<br />
6.2.1 A Chemical List shall be developed and maintained by the Loss Prevention Department<br />
through the Chemical Management database for all chemicals used, produced, imported,<br />
or otherwise obtained on the Franklin Mill. This list includes both hazardous and nonhazardous<br />
chemicals. Additionally, the list includes chemicals brought on site by<br />
contractors or by other personnel, if <strong>International</strong> <strong>Paper</strong> employees are, or may be,<br />
exposed to these chemicals.<br />
6.2.2 Per the Chemical Management Policy, the Chemical List shall be updated whenever:<br />
6.2.2.1 A new chemical is brought on site, or,<br />
6.2.2.2 An existing chemical is approved for use in a new department.<br />
6.2.2.3 A Chemical is no longer used or stored on site.<br />
6.2.3 A chemical inventory audit shall be conducted at least once a year for certain hazardous<br />
chemicals (i.e., those with a designated threshold planning quantity). NOTE: Within the<br />
US these threshold planning quantities may range from 1 pound (lb.) to 10,000 lbs.<br />
depending upon the nature of the hazardous chemical. Also, keep in mind, that hazardous<br />
chemicals identified on the 40 CFR Part 355 List, as well as those hazardous chemicals<br />
(as defined by OSHA) that are stored over 10,000 lbs. during any time of the year, are<br />
subject to this inventory.<br />
6.2.3.1 This audit shall be performed by Environmental Engineering and is<br />
documented in the SARA 312 report.<br />
6.2.3.2 Any discrepancies identified during this audit must be communicated to the<br />
Loss Prevention Department, so that the appropriate changes can be made.<br />
6.2.4 A mill wide chemical inventory audit shall be conducted every five (5) years in order to:<br />
6.2.4.1 Identify missing MSDSs for hazardous chemicals<br />
6.2.4.2 Identify those products no longer used or stored on the Franklin Mill site.<br />
6.2.4.3 Identify chemicals that are presently used by additional departments.<br />
6.2.5 The Loss Prevention Department is responsible for updating the master chemical<br />
inventory list with the audit findings identified in 6.2.3 and 6.2.4.<br />
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6.2.6 The Chemical List and MSDSs for all hazardous chemicals shall be retained for at least<br />
30 years from the date that the hazardous chemical is no longer produced, stored, or used<br />
on the Franklin Mill site. Attachment 3.0 describes the minimum information that must<br />
be maintained on this list.<br />
6.2.6.1 An active and inactive chemical list shall be concurrently maintained at all times.<br />
The inactive chemical list shall indicate only those chemicals no longer stored,<br />
produced, or used on the Franklin Mill site.<br />
6.2.6.2 For <strong>International</strong> <strong>Paper</strong> MSDSs, the original and all subsequent revisions<br />
involving either new or significant hazard information shall be retained for at least<br />
30 years.<br />
6.2.6.3 For all other manufacturer MSDSs, the last original MSDS obtained from the<br />
manufacturer shall be retained for at least 30 years.<br />
6.3 Material Safety Data Sheets (MSDSs)<br />
6.3.1 A MSDS shall be obtained for each chemical used, produced, or stored on the Franklin<br />
Mill site, except for those exempted under Section 2.2 of this procedure.<br />
6.3.1.1 The Chemical Management Policy outlines the manner in which MSDSs are<br />
obtained. No chemical is permitted on site without an MSDS and a chemical<br />
approval. The chemical must be on the active chemical inventory list before the<br />
material can be ordered.<br />
6.3.1.1.1 All incoming MSDSs shall be reviewed for completeness. This<br />
includes ensuring that there are no blank sections, that there are the<br />
proper number of pages, and that it is legible.<br />
6.3.1.1.2 If the MSDS is incomplete or illegible, the required information<br />
shall be requested from the chemical manufacturer.<br />
6.3.1.1.3 All suppliers are required to supply MSDS’s with initial product<br />
shipments to <strong>International</strong> <strong>Paper</strong> and any time that an MSDS is<br />
updated for a particular product. If a material safety data sheet is<br />
obtained when the product is received, this MSDS must be routed<br />
to Loss Prevention for review.<br />
6.3.1.1.4 When the MSDS is received, the Loss Prevention<br />
Department shall verify that the incoming chemical is on<br />
the active Chemical Inventory List, or is added to this chemical<br />
inventory list once approved.<br />
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6.3.1.1.5 In the event that new and significant information becomes<br />
available on purchased or plant generated chemicals, an updated MSDS<br />
will be provided to the users.<br />
6.3.1.2 For those materials not requiring a formal chemical review as per the Chemical<br />
Management Policy (eg: stainless steel, wood, cadmium dipped bolts), Loss<br />
Prevention will be responsible for obtaining the appropriate MSDS.<br />
6.3.1.2.1 Materials not indicated on the present chemical inventory list<br />
shall be identified through chemical audits.<br />
6.3.2 MSDSs shall be maintained in the workplace and shall be readily accessible to<br />
<strong>International</strong> <strong>Paper</strong> employees, contractors, and visitors in their work area(s) during each<br />
shift. This could include electronic access or other alternatives to maintaining paper<br />
copies of the MSDSs, provided that there are no barriers to immediate employee access.<br />
6.3.2.1 MSDSs must also be readily available to health care professionals and<br />
emergency responders upon request.<br />
6.3.2.1.1 In the event of an on-site emergency, the Medical Department shall be<br />
the primary contact for obtaining and providing the necessary hazard<br />
information.<br />
6.3.2.1.2 In the event of an off site chemical spill which involves an<br />
<strong>International</strong> <strong>Paper</strong> product, refer to Attachment 8.0 for the specific<br />
handling protocol.<br />
6.3.3 The Loss Prevention Department will be responsible for maintaining the master file of<br />
MSDSs and Chemical Reviews on the Franklin Mill site.<br />
6.3.4 MSDSs are available to all employees on the SAROS document management system.<br />
6.3.5 A new chemical cannot be used until:<br />
6.3.5.1 A MSDS, or the equivalent hazard information and the necessary<br />
precautions, are received. Refer to the Chemical Management Policy for<br />
additional details.<br />
6.3.5.2 If a new hazard is identified during the chemical review process in which the<br />
employee(s) using the product has not previously receiving training, the hazards, as<br />
well as necessary precautions must be communicated to the affected employee<br />
prior to its use.<br />
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6.3.5.2.1 The Loss Prevention Department is responsible for<br />
identifying this requirement to the appropriate<br />
department manager(s).<br />
6.3.6 Outbound <strong>Hazard</strong>ous Chemicals that are being shipped by <strong>International</strong> <strong>Paper</strong> must be<br />
distributed with the appropriate MSDS or hazard information. Refer to Attachment 4.0,<br />
Section 1.4 and Attachment 2.0, Section 1.3 for requirements.<br />
6.4 Chemical Approval and Control<br />
6.4.1 The Chemical Management Policy, located in the Industrial Hygiene Manual outlines the<br />
review process used to approve the use of chemicals located on the Franklin Mill. The<br />
process addresses the necessary safety, health, and environmental control measures to be<br />
put in place prior to the chemicals use. These control measures include:<br />
* Installation of effective engineering controls<br />
* Development and implementation of appropriate work practice controls (e.g.,<br />
standard operating procedures, training, establishment of a regulated area, etc.),<br />
and/or,<br />
* Identification and implementation of appropriate personal protective equipment.<br />
6.4.2 As part of the review and approval process, an evaluation shall be made to determine if a<br />
less hazardous or less toxic chemical is available for use.<br />
6.4.3 Designated areas where eating, drinking, smoking, and/or applying cosmetics are<br />
permitted, shall be established if hazardous chemicals are used or produced in such a way<br />
that workers’ may be exposed.<br />
6.5 Container Labeling<br />
6.5.1 Any material placed in a container must be labeled in accordance with this policy<br />
6.5.1.1 The labeling requirements associated with this procedure do not apply to the<br />
following:<br />
6.5.1.1.1 This procedure exempts labeling of portable transfer<br />
containers intended only for immediate use by the<br />
employee who performs the transfer. It is<br />
recommended that portable transfer containers be labeled<br />
if they are routinely used for transferring the same hazardous<br />
chemical.<br />
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6.5.1.1.2 Any pesticide subject to, and labeled in accordance<br />
with the EPA’s Federal Insecticide, Fungicide, and<br />
Rodenticide Act (FIFRA)<br />
6.5.1.1.3 Any food, food additive, color additive, drug,<br />
cosmetic, or medical device or product, including<br />
materials intended for use as ingredients in such<br />
products (e.g., flavors and fragrances as defined in the<br />
Food and Drug Administration or the Department of<br />
Agriculture)<br />
6.5.1.1.4 Any manufacturer product, as defined by this<br />
procedure and labeled in accordance with the<br />
Consumer Product Safety Act and,<br />
6.5.1.1.5 Any agricultural or vegetable seed treated with<br />
pesticides and labeled in accordance with the Federal<br />
Seed Act.<br />
Note: Refer to Section 2.2 for additional details on<br />
the exemptions.<br />
6.5.2 The labeling requirements are applicable to containers in the workplace, as well as those<br />
leaving the workplace. Container means any bag, barrel, bottle, box, can, cylinder, drum,<br />
reaction vessel, storage tank or the like that contains a material.<br />
6.5.3 For those containers that are used in the workplace (both large and small), each employee<br />
is responsible for proper labeling.<br />
6.5.3.1 If the appropriate labeling information is not known, the Loss<br />
Prevention Department must be contacted for the proper information.<br />
6.5.3.2 The Brady Labelizer and equivalent systems are available within<br />
the Loss Prevention Department, Storeroom, and Technical Department in order for<br />
multiple printed labels to be obtained in lieu of handwritten labels.<br />
6.5.4 Chemical containers supplied by manufacturers should not require further labeling since<br />
manufacturers are required to label containers under the OSHA <strong>Hazard</strong> <strong>Communication</strong><br />
standard. However, if the label is removed or defaced, then a new label must be installed.<br />
If a label is not provided by the supplier/manufacturer and the material is known to be<br />
hazardous, steps shall be taken by the department manager, in conjunction with the<br />
Purchasing Department.<br />
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6.5.4.1 Manufactures supplying process chemicals for use on the Franklin Mill must<br />
proved hazard warning labels which meet the requirements outlined under ANSI<br />
Z129.1-1994 and NFPA 704.<br />
6.5.4.2 Manufacturers supplying non-process chemicals for use on the<br />
Franklin Mill site may use ANSI, NFPA, or HMIS hazard warning<br />
labels which meet the requirements specified under 6.5.5.<br />
6.5.4.3 Until the appropriate manufacturer label can be obtained, the IP labeling<br />
system described in Attachment 4.0 shall be used.<br />
6.5.4.3.1 If the appropriate manufacturer MSDS is not<br />
available, the chemical shall be quarantined in<br />
accordance with the Chemical Management Policy.<br />
6.5.5 All containers must be labeled with the identity of the hazardous chemical(s) the<br />
appropriate hazard warning (s), and target organs.<br />
6.5.6 The Loss Prevention Department is responsible for maintaining an up to date list of fixed<br />
bulk container labels for the department or location.<br />
6.5.6.1 An annual inspection must be conducted by each department to ensure that<br />
labels have not been removed or damaged. If labels have been found to be removed or<br />
damaged, the container must be relabeled. Refer to Attachment 4.0 for detail.<br />
6.5.7 Empty containers, which previously contained chemicals are to be disposed or recycled,<br />
shall be labeled in accordance with <strong>International</strong> <strong>Paper</strong> Empty Container Disposal Policy.<br />
6.5.8 Outbound hazardous chemicals leaving the workplace (eg: shipped) for example to a<br />
laboratory for analysis, to customer for use (eg: black liquor to the Eastover Mill) must be<br />
labeled with the appropriate “OSHA” and “DOT” labels.<br />
6.5.8.1 The following information must be present on the “OSHA” label.<br />
6.5.8.1.1 IDENTITY OF THE HAZARDOUS CHEMICAL<br />
6.5.8.1.1.1 This identity can be any chemical or<br />
common name designation for the<br />
individual chemical or mixture, so long<br />
as the term used is also used on the list of<br />
hazardous chemicals and the associated Material<br />
Safety Data Sheet.<br />
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6.5.8.1.2 APPROPRIATE HAZARD WARNING<br />
6.5.8.1.2.1 A hazard warning is to be any type<br />
of wording which conveys the<br />
hazards of the chemical(s) in the<br />
container.<br />
This wording shall be prepared in<br />
accordance with the guidelines in the<br />
American National Standards<br />
Institute (ANSI) standard on<br />
labeling, and must be consistent with<br />
the hazard information identified on<br />
the MSDS.<br />
6.5.8.1.2.2 The NFPA 704 System may be used<br />
in addition to the hazard information<br />
identified in 6.5.8.1.2.1.<br />
6.5.8.1.3. APPROPRIATE TARGET ORGANS<br />
6.5.8.1.4. NAME AND ADDRESS OF INTERNATIONAL PAPERAS THE<br />
CHEMICAL MANUFACTURER AND RESPONSIBLE PARTY<br />
6.5.8.1.4.1 This labeling shall be completed in a manner which<br />
does not conflict with the requirements of<br />
the Department of Transportation (such as placards,<br />
identification numbers, etc.) identified within the<br />
<strong>International</strong> <strong>Paper</strong> Franklin Mill <strong>Hazard</strong>ous<br />
Materials Transportation Training Manual.<br />
6.5.8.2 Refer to the <strong>International</strong> <strong>Paper</strong> Franklin Mill’s <strong>Hazard</strong>ous Materials<br />
Transportation Training Manual for DOT Labeling Requirements.<br />
6.5.8.3 The person shipping the hazardous chemical is responsible for adhering the<br />
appropriate OSHA and DOT labels to the product being shipped. Refer to<br />
Attachment 4.0 for further details.<br />
6.5.9 The standard hazard warning label used on the Franklin Mill site for labeling containers<br />
not previously labeled by the manufacturer is the National Fire Protection Associations<br />
(NFPA) labeling system. This label must be modified to include the target organ effects<br />
associated with the chemical. Refer to Attachment 4.0 for further details on the site<br />
specific labeling requirements.<br />
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6.5.10 Container labeling in the workplace includes installing custom made fiberglass signs or<br />
pressure sensitive labels. The signs and labels include the name of the material or<br />
chemical, the appropriate hazard warning, odor and appearance of the hazard, target<br />
organs, and a referral to consult the corresponding MSDS for further information. (See<br />
Attachment 4.0 for a diagram of the approved IP Chemical Label.)<br />
6.6 Pipe Labeling<br />
6.6.1 The <strong>International</strong> <strong>Paper</strong> labeling system also applies to pipes. All pipes containing<br />
hazardous chemicals have been labeled with the identity, and are color coded based on its<br />
hazard labeling requirements for all piping systems. Refer to IP Franklin Mill’s Safety<br />
Design Specifications for Pipe Labeling for more information.<br />
6.7 Information and Training<br />
6.7.1 The information and training requirements detailed in this procedure do not apply to the<br />
following:<br />
6.7.1.1 IP employees, such as office workers, who are not exposed to hazardous<br />
chemicals in the workplace,<br />
6.7.1.2 Contractors who are not exposed to hazardous chemicals in the<br />
workplace<br />
6.7.1.3 Unescorted visitors who are not exposed to hazardous chemicals in<br />
the workplace and,<br />
6.7.1.4 Escorted visitors.<br />
6.7.2 All employees who frequent areas or work in areas where hazardous chemicals are found<br />
will receive information and training to make them aware of the basic concepts of<br />
chemical safety as well as the <strong>International</strong> <strong>Paper</strong> <strong>Hazard</strong> <strong>Communication</strong> Program. Two<br />
types of training will be provided to all <strong>International</strong> <strong>Paper</strong> employees exposed to<br />
hazardous chemicals located in their work area. They are as follows:<br />
6.7.2.1 General HAZCOM Training<br />
6.7.2.2 Specific HAZCOM Training<br />
6.7.3 Contractor Managers must inform contractors of the chemical hazards present in a<br />
contractor’s work area through the Contractor Safety Briefing.<br />
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6.7.5 Training Frequency<br />
6.7.5.1 As a minimum, the generic <strong>Hazard</strong> <strong>Communication</strong> information and training shall<br />
be provided at the time of the employees initial assignment and once every two<br />
years thereafter. This session must be completed before the employee is allowed<br />
to work in areas where hazardous chemicals are present.<br />
6.7.5.2 As a minimum, the chemical-specific HAZCOM training shall be provided at the<br />
time of the employee’s initial assignment and at least once every four years<br />
thereafter. More frequent training is required under the following circumstances:<br />
* Before a new hazard, not necessarily a new chemical, is introduced into<br />
the work area,<br />
NOTE: This provision is also applicable to hazardous chemicals that are<br />
brought into the work area by contractors.<br />
* Before beginning work in a new department with any new or unique<br />
hazards associated with that department.<br />
6.7.6 Training Documentation<br />
6.7.6.1 Attachment 5.0 outlines the general and specific hazard communication<br />
documentation requirements in more detail.<br />
6.7.6.2 Training on the chemical groups or specific chemicals provided to the employee<br />
shall be documented using the form shown in Attachment 5.0 entitled “Chemical<br />
Safety Training Record”.<br />
6.7.6.3 Attendance to this training shall be documented on the Safety Training Database.<br />
6.7.6.4 Records of attendance are to be maintained in the departmental employee files.<br />
6.7.6.5 Training records are to be forwarded to the employee’s new department (by the<br />
old department) in the event of a transfer.<br />
6.7.7 New and Transfer Employee Training<br />
6.7.7.1 Employees transferring from one department to another will receive training on<br />
the hazards associated with the new department’s specific chemical.<br />
6.7.8 New <strong>Hazard</strong> Training<br />
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6.8 Contractor<br />
6.7.8.1 Retraining of employees will be done when a new hazard is introduced into the<br />
work area, not a new chemical.<br />
6.7.8.2 Retraining of employees on new hazards introduced to the work area is the<br />
responsibility of the department or location manager. This training shall be<br />
documented on the employee’s Chemical Safety Training Record form shown in<br />
Appendix 1.0 of Attachment 5.0.<br />
6.8.1 Contractors are not permitted to bring any unapproved chemicals onto the Franklin Mill<br />
site. The contractor chemical approval process is outlined within the Chemical<br />
Management Policy.<br />
6.8.2 If the contractor’s chemicals are approved for use and <strong>International</strong> <strong>Paper</strong> employees are,<br />
or may be exposed, the Chemical List (Section 5.5) shall be updated. If appropriate, the<br />
applicable MSDSs shall be maintained in accordance with this procedure.<br />
6.8.3 If a new hazard is being introduced into the work area where <strong>International</strong> <strong>Paper</strong><br />
employees are, or may be exposed, the appropriate management personnel shall be<br />
notified of the necessary training requirements, through the chemical review process.<br />
6.8.4 The IP Contractor Manager shall ensure that the contractor is provided with the<br />
appropriate <strong>Hazard</strong> <strong>Communication</strong> information and training.<br />
6.8.7 Refer to Attachment 7.0 for additional details.<br />
6.9 Trade Secrets<br />
6.9.1 <strong>International</strong> <strong>Paper</strong> “Trade Secret” Chemicals<br />
6.9.1.1 Where appropriate, IP Franklin Mill produced chemicals shall be evaluated<br />
against the criteria established in the Trade Secret Procedure (Attachment No. 6.0)<br />
to determine if they are bonafide trade secrets.<br />
6.9.1.2 If the IP-Franklin Mill produced chemical is classified as a trade secret, a system<br />
for providing appropriate information on the trade secret(s) shall be created. This<br />
information shall be maintained with the MSDS of the IP chemical classified as a<br />
trade secret.<br />
6.9.2 Manufacturer Trade Secret Chemicals<br />
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6.9.2.1 In a medical emergency, the chemical manufacturer must disclose the trade secret<br />
identity to a treating physician or nurse, if necessary, for emergency or first aid<br />
treatment. This information can be obtained by calling the emergency telephone<br />
number on the MSDS. It is important to note that in both emergency and nonemergency<br />
situations the chemical manufacturer may require a confidentiality<br />
agreement.<br />
6.10 <strong>Hazard</strong>s of Non-Routine Tasks<br />
6.11 Audit<br />
6.10.1 Training on the hazards associated with a Non-Routine Task must be provided to the<br />
employee prior to performing the work.<br />
6.10.2 The following steps must be followed prior to the non-routine work being performed:<br />
6.10.2.1 Identify the non-routine task or job that is to be done.<br />
6.10.2.2 Define the work procedures necessary to complete the job.<br />
6.10.2.3 Identify the chemicals or materials that will be used, handled or present in the<br />
work area during these procedures.<br />
6.10.2.4 Use the material safety data sheets to determine which of these chemicals or<br />
materials are hazardous.<br />
6.10.2.5 Identify the appropriate control measures for working with the hazardous<br />
materials - respirators, protective gloves, goggles, ventilation, no smoking, etc.<br />
6.10.2.6 Inform employees of the hazards, protective measures, and emergency<br />
procedures for the job prior to their beginning the job.<br />
6.10.2.7 Implement the control measures prior to beginning the job. The employee<br />
performing the task has the responsibility of using the appropriate protective<br />
measures.<br />
6.10.2.8 Monitor employees throughout the course of the job to ensure that proper<br />
procedures and control measures are being followed.<br />
6.11.1 To verify that this procedure has been effectively implemented and is being maintained, a<br />
formal documented annual audit shall be conducted. This audit can be conducted as part<br />
of the annual safety and health audit of the facility.<br />
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7.0 Attachments<br />
7.1 Attachment 1.0 - <strong>Hazard</strong> Determination Procedure<br />
7.2 Attachment 2.0 - MSDS Preparation Procedure<br />
7.3 Attachment 3.0 - Chemical List Requirements<br />
7.4 Attachment 4.0 - <strong>Hazard</strong> <strong>Communication</strong><br />
7.5 Attachment 5.0 - <strong>Hazard</strong> <strong>Communication</strong> Information and Training Requirements<br />
7.6 Attachment 6.0 - Trade Secret Information<br />
7.7 Attachment 7.0 - Contractor/<strong>Visitor</strong>/Vendor HazCom Information/Training<br />
7.8 Attachment 8.0 - Offsite Chemical Spills Emergency Response Protocol<br />
7.9 Attachment 9.0 - <strong>Hazard</strong> <strong>Communication</strong> Policy Index<br />
8.0 APPROVAL AND ISSUE<br />
8.1 This policy has been approved and issued by the Safety and Health Committee.<br />
1. Acute Health Effects:<br />
APPENDIX NO. 1 OF ATTACHMENT NO. 1.0<br />
HEALTH HAZARD DEFINITIONS<br />
Health effects which occur rapidly as a result of short-term exposures and are of short duration.<br />
examples include irritation, sensitization, corrosivity and lethal dose.<br />
2. Chronic Health Effects:<br />
Health effects which occur as a result of long-term exposure and are of long duration. examples include<br />
carcinogenicity, teratogenicity and mutagenicity.<br />
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3. Carcinogen:<br />
A chemical or material that is categorized as being a confirmed or suspected carcinogen by the following<br />
sources (use latest editions):<br />
* <strong>International</strong> Agency for Research on Cancer (IARC) Monographs.<br />
* National Toxicology Program (NTP) Annual Report on Carcinogens.<br />
* OSHA Regulations, 29 CFR 1910, Subpart Z.<br />
4. Irritant:<br />
A material which causes reversible inflammatory effects on living tissue. Thus the exposed skin heals<br />
following exposure. Testing in rabbits is used to determine skin irritation and/or eye irritation.<br />
5. Corrosive:<br />
A material which causes reversible inflammatory effects on living tissue. The exposed skin does not<br />
completely heal following exposure.<br />
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6. Sensitizer:<br />
A material that causes a substantial proportion of animals or humans to develop an allergic reaction in<br />
normal tissue after repeated exposure to the chemical.<br />
7. Target Organ Effects:<br />
There are a large range of potential hazards to consider. Examples of chemical toxicities include effects<br />
on the liver (hepatotoxins, nervous system (neurotoxins), kidneys (nephrotoxins), blood/hematopoietic<br />
system, reproductive system, lungs, skin and eyes.<br />
8. Toxic and Highly Toxic Effects:<br />
LD50 a<br />
LD50 LC50 b<br />
Category Oral (rats) Skin (rabbits) c Inhalation (rats) d<br />
Highly Toxic < 50 mg/kg < 200 mg/kg < 200 ppm Gas/vapor<br />
< 2 mg/L Mist/fume/dust<br />
Toxic > 50 mg/kg > 200 mg//kg > 200 ppm but < 2000 ppm<br />
but < but < Gas/vapor<br />
500 mg/kg 1000 mg/kg > 2 mg /L Mist/Fume/Dust<br />
but < 20 mg/L<br />
a LD50 = Median Lethal Dose<br />
b LC50 = Median Lethal Concentration<br />
c The skin exposure is for 24 hours<br />
d The inhalation exposure is for 1 hour<br />
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1. Combustible Liquid:<br />
APPENDIX NO. 2.0 OF ATTACHMENT NO. 1.0<br />
PHYSICAL HAZARD DEFINITIONS<br />
Any liquid having a flash point at or above 100 o F (37.8 o C) but below 200 o F (93.3 o C), except any<br />
mixture having components with flash points of 200 o F (93.3 o C) or higher, the total volume of which<br />
makes up ninety-nine percent (99%), or more, of the total volume of the mixture.<br />
2. Compressed Gas:<br />
a. A gas or mixture of gases having, in a container, an absolute pressure exceeding 40 psi at 70 o F<br />
(21.1 o C).<br />
b. A gas or mixture of gases having, in a container, an absolute pressure exceeding 104 psi at 130 o F<br />
54.4 o C), regardless of the pressure at 70 o F (21.1 o C).<br />
c. A liquid having a vapor pressure exceeding 40 psi at 100 o F (37.8 o C) as determined by ASTM D-<br />
323-72.<br />
3. Explosive:<br />
A chemical that causes a sudden, almost instantaneous, release of pressure, gas, and heat when subjected<br />
to sudden shock, pressure or high temperature.<br />
4. Flammable:<br />
A chemical that falls into one of the following categories:<br />
a. “Aerosol, Flammable” means an aerosol that, when tested by the method described in 16 CFR<br />
1500.45, yields a flame projection exceeding 18 inches at full valve opening or a flashback flame<br />
extending back to the valve at any degree of valve opening.<br />
b. “Gas, flammable” means:<br />
1. A gas that at ambient temperature and pressure, forms a flammable mixture at a<br />
concentration of 13 percent (13%) by volume, or less.<br />
2. A gas that, at ambient temperature and pressure, forms a range of flammable mixtures<br />
with air wider than 12 percent (12%) by volume, regardless of the lower limit.<br />
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c. “Liquid, flammable” means any liquid having a flash point below 100 o F (37.8 o C), except any<br />
mixture having components with flash points of 100 o F (37.8 o C) or higher, the total of which<br />
makes up ninety-nine percent (99%), or more, of the total volume of the mixture.<br />
d. “Solid, Flammable” means a solid, other than a blasting agent or explosive as defined<br />
in 29 CFR 1910.109(a), that is liable to cause fire through friction, absorption of moisture, spontaneous<br />
chemical change, or retained heat from manufacturing or processing, or which can be ignited<br />
readily and, when ignited, burns so vigorously and persistently as to create a serious hazard. A<br />
chemical shall be considered to be a flammable solid if, when tested by the method described in<br />
16 CFR 1500.44, it ignites and burns with a self-sustained flame at a rate greater than one-tenth<br />
inch (1/10”) per second along its major axis.<br />
5. Organic Peroxides:<br />
Compounds containing an oxygen-to-oxygen (O-to-O) linkage. They are encountered generally in very<br />
small amounts as impurities in many organic compounds where they have been slowly formed by the<br />
action of oxygen.<br />
6. Oxidizer:<br />
A chemical other than a blasting agent or explosive, as defined in 29 CFR 1910.109(a), that initiates or<br />
promotes combustion in other materials, thereby causing fire either of itself or through the release of<br />
oxygen or other gases.<br />
7. Pyrophoric:<br />
A chemical that will ignite spontaneously in air at a temperature of 130 o F (54.4 o C) or below.<br />
8. Unstable (Reactive):<br />
A chemical which in the pure state, or as produced or transported, will vigorously polymerize,<br />
decompose, condense, or will become self-reactive under conditions of shocks, pressure, or temperature.<br />
9. Water Reactive:<br />
A chemical that reacts with water to release a gas that is either flammable or presents a health hazard<br />
2.0 DOCUMENTATION<br />
Appendix No. 1.0 MSDS Checklist<br />
Appendix No. 2.0 summary of ANSI Z400.1-1993 format for MSDSs<br />
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1.0 PROCEDURE<br />
ATTACHMENT NO. 3.0<br />
CHEMICAL LIST REQUIREMENTS<br />
1.1 Each year a Chemical List shall be developed and maintained for chemicals used,<br />
produced, imported or otherwise obtained within the facility or department,<br />
and for which <strong>International</strong> <strong>Paper</strong> employees are, or may be exposed.<br />
1.1.1 When a chemical is no longer used, produced, or imported and<br />
physically removed from the site or a particular department, it shall<br />
be deleted from the active Chemical List and placed on the “inactive”<br />
Chemical List.<br />
1.2 As a minimum, the active and inactive Chemical List shall contain the following<br />
information:<br />
* Preparation Date of the annual Chemical List<br />
* Chemical Name/Common Name, as specified on the MSDS and hazard<br />
warning label<br />
* The Manufacturer’s/Supplier’s Name<br />
* Process/Non-Process Designation<br />
* Contractor Chemical (Yes/No)<br />
* Department(s)/Work Area where used/produced<br />
* Maximum Inventory Allowed On-Site (must only be designated for those<br />
hazardous chemicals subject to specific regulatory inventory/reporting<br />
controls)<br />
* MSDS’s Preparation/Revision Date<br />
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1.0 PROCEDURE<br />
ATTACHMENT NO. 4.0<br />
HAZCOM LABELING PROCEDURE<br />
1.1 General Labeling Requirements:<br />
1.1.1 All labels shall be legible, and prominently displayed on containers of<br />
chemicals.<br />
1.1.2 The chemical name used on the label must be the same as the chemical<br />
name identified on the corresponding MSDS and the Chemical List.<br />
1.2 In Coming Container Labeling Requirements:<br />
1.2.1 In coming containers of chemicals shall be spot checked to verify the<br />
presence of an adequate <strong>Hazard</strong> <strong>Communication</strong> label. Unless specified<br />
otherwise, the chemical manufacturer’s hazard warning label shall be<br />
relied upon, and considered to be adequate.<br />
1.2.1.1 The labels on all incoming containers of hazardous chemicals<br />
shall at a minimum contain:<br />
1.2.1.1.1 The chemical name or trade name<br />
1.2.1.1.2 The appropriate hazard warning statements,<br />
including target organ effects, and,<br />
1.2.1.1.3 The chemical manufacturer’s name and address.<br />
1.2.2 Within the US, DOT markings, labels, and placards on any bulk container<br />
( > 110 gallons) of a hazardous material (as defined by DOT), must be<br />
retained in such a manner that they are readily visible, until the container is<br />
properly cleaned of the hazardous material.<br />
1.2.3 Within the US, DOT markings and labels on any non-bulk package ( < 110<br />
gallons) that will be reshipped, must be retained in such a manner that they<br />
are readily visible.<br />
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1.3 Additional In Plant Container and Pipe Labeling Labeling Requirements:<br />
1.3.1 Stationary process containers, and pipes and piping systems shall be<br />
labeled in accordance with the <strong>International</strong> <strong>Paper</strong> Franklin Mill Safety<br />
Design Specification (SDS No. 3) Pipe Labeling.<br />
1.3.2 Portable containers of chemicals shall be labeled with the chemical name<br />
or trade name, the appropriate hazard warning statement(s) and/or NFPA<br />
numbering system, and target organ effects.<br />
1.4 Outbound Container Labeling Requirements:<br />
1.4.1 <strong>Hazard</strong> warning labels shall be developed for all hazardous chemicals<br />
(including mixtures) produced by <strong>International</strong> <strong>Paper</strong>.<br />
1.4.1.1 <strong>Hazard</strong> warning labels shall be revised within ninety (90) days of<br />
receiving any new and significant changes to the hazard<br />
information.<br />
1.4.1.2 The Loss Prevention Department can provide a supply of the<br />
appropriate hazard warning labels for products being sent off-site.<br />
1.4.2 Labels for outbound containers of hazardous chemicals shall contain at a<br />
minimum:<br />
1.4.2.1 The chemical name or trade name (as it appears on the<br />
corresponding MSDS and the site Chemical List)<br />
1.4.2.2 The appropriate hazard warning statements which include target<br />
organ effects, and,<br />
1.4.2.3 The <strong>International</strong> <strong>Paper</strong> name, address, and 24-hour emergency<br />
contact telephone number.<br />
1.4.2.3.1 The following information must be present on the<br />
label:<br />
INTERNATIONAL PAPER<br />
34040 Union Camp Drive<br />
Franklin, VA 23851<br />
(757) 569-4666 (24 hours)<br />
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1.4.3 As a minimum, the hazard warning statements shall comply with the<br />
guidelines set forth in American National Standard for <strong>Hazard</strong>ous<br />
Industrial Chemicals Precautionary Labeling (ANSI Z129.1-1994), or<br />
equivalent.<br />
1.4.3.1 The NFPA 704 code based labeling system must be modified to<br />
include the appropriate hazard warning information and target<br />
organ effects. Refer to Appendix 1.0 of Attachment 4.0 for further<br />
details.<br />
1.4.4 Labels for outbound containers of non-hazardous chemicals shall contain<br />
the chemical name or trade name (as it appears on the corresponding<br />
MSDS and the Chemical List). It is recommended that the label also<br />
include a “Non-<strong>Hazard</strong>ous” designation and the <strong>International</strong> <strong>Paper</strong> name,<br />
address, and 24-hour emergency contact telephone number.<br />
1.4.5 Within the US, the <strong>Hazard</strong> <strong>Communication</strong> label cannot conflict with the<br />
DOT hazardous materials labeling requirements. Details on DOT labeling<br />
requirements are specified in <strong>International</strong> <strong>Paper</strong> Franklin Mills<br />
Transportation Department <strong>Hazard</strong>ous Materials Transportation Training<br />
Manual. Consult the Franklin Mill Transportation Department for details<br />
on these labeling requirements.<br />
1.4.6 Bulk containers (e.g., tank trucks, dump trucks, rail cars, totes, or other<br />
vehicles carrying a hazardous chemical which is not already in a labeled<br />
container), shall be labeled. These containers may be labeled by either<br />
affixing the appropriate <strong>Hazard</strong> <strong>Communication</strong> label underneath a dome<br />
lid, or attaching the label to the accompanying shipping papers or bill of<br />
lading. The label shall not be shipped separately.<br />
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Appendix 1.0 of Attachment 4.0<br />
Examples of Outbound Container Labeling Systems<br />
1.0 The label shown in 1.3 is an example of the ANSI Z129.1-1994 system of labeling. This<br />
label can be used for outbound <strong>International</strong> <strong>Paper</strong> chemicals, in place of a modified<br />
NFPA 704 label.<br />
1.2 The information to be placed on the ANSI label should be obtained from the Loss<br />
Prevention Department. (The Brady Labelizer is not able to print the label shown in 1.3)<br />
1.3 Example of ANSI label:<br />
EXAMPLE ONLY!!!<br />
INTERNATIONAL PAPER<br />
34040 Union Camp Drive<br />
Franklin, VA 23851<br />
(757) 569-4666 (24 hour)<br />
WOOD CHIPS AND DUST<br />
(PINE AND HARDWOOD CHIPS, WOOD DUST, SAWDUST, PLANER MILL<br />
SHAVINGS AND BARK)<br />
CAUTION!<br />
SHAKING, DUMPING, AGITATING OR OTHERWISE DISTURBING THESE<br />
PRODUCTS CAN RELEASE WOOD DUST INTO THE AIR WHICH CAN<br />
CAUSE A FLAMMABLE OR EXPLOSIVE HAZARD.<br />
WOOD DUST MAY CAUSE LUNG, UPPER RESPIRATORY TRACT, EYE AND<br />
SKIN IRRITATION. SOME WOOD SPECIES MAY CAUSE DERMATITIS<br />
AND/OR RESPIRATORY ALLERGIC EFFECTS. THE INTERNATIONAL<br />
AGENCY FOR RESEARCH ON CANCER HAS CLASSIFIED WOOD DUST AS<br />
A CARCINOGEN IN HUMANS.<br />
� Avoid dust contact with ignition source.<br />
� Sweep or vacuum dust for recovery or disposal.<br />
� Avoid prolonged or repeated breathing of wood dust in air.<br />
� Avoid dust contact with eyes and skin.<br />
FIRST AID: If inhaled, remove to fresh air. In case of contact, flush eyes<br />
and skin with water. If irritation persists, call a physician.<br />
For additional information, see the Material Safety Data Sheet.<br />
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2.0 If the NFPA 704 labeling system is used for labeling outbound chemicals, the label must<br />
be modified to include the target organ effects of the chemical, the <strong>International</strong> <strong>Paper</strong><br />
address and emergency telephone number, as well as a written description of the hazard<br />
that the chemical exhibits.<br />
2.2 The information to be placed on the NFPA label should be obtained from the Loss<br />
Prevention Department.<br />
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1.0 PROCEDURE<br />
ATTACHMENT NO. 5.0<br />
HAZARD COMMUNICATION<br />
INFORMATION & TRAINING REQUIREMENTS<br />
1.1 Generic Information and Training Requirements:<br />
1.1.1 Generic <strong>Hazard</strong> <strong>Communication</strong> information and training shall be<br />
provided to <strong>International</strong> <strong>Paper</strong> employees, and unescorted visitors, unless<br />
exempted by Section 6.7.3 of the <strong>Hazard</strong> <strong>Communication</strong> Policy.<br />
1.1.2 As a minimum, the generic <strong>Hazard</strong> <strong>Communication</strong> information and<br />
training shall include a review of the following:<br />
* Written Franklin Mill <strong>Hazard</strong> <strong>Communication</strong> & Chemical<br />
Management Policies and the applicable requirements<br />
* Location and availability of the site MSDSs, as well as how to find<br />
and use pertinent information from the MSDSs<br />
* Location of hazardous chemicals<br />
* Location of the Chemical List(s) and how to use the list to locate<br />
MSDSs<br />
* How to label chemical containers.<br />
* How to recognize and interpret the in-plant container and pipe<br />
labeling systems, as well as other manufacturers’ hazard warning<br />
labeling systems<br />
* Name(s) of the individual(s) who can be contacted for additional<br />
information such as the necessary protective measures, and,<br />
* Means of obtaining trade secret information for either hazardous<br />
chemicals produced or used in the workplace.<br />
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1.2 Chemical-Specific Training Requirements:<br />
1.2.1 In addition to the generic information and training, chemical-specific<br />
<strong>Hazard</strong> <strong>Communication</strong> training shall be provided to <strong>International</strong> <strong>Paper</strong><br />
employees, contractors, and unescorted visitors.<br />
1.2.2 As a minimum, the chemical-specific training shall include:<br />
1.2.2.1 Identification of the hazardous chemicals or classes of hazardous<br />
chemicals found in their work area(s).<br />
NOTE: Where large numbers of chemicals are used or<br />
produced and where chemicals change frequently, it may<br />
be appropriate to group the chemicals by hazard type<br />
(e.g., corrosives, carcinogens, flammables, etc.), and train<br />
on all hazard types that could be within the facility.<br />
Where the potential chemical hazards cannot be<br />
grouped, the individual chemical hazard must be included<br />
in the training.<br />
1.2.2.2 Methods and observations to detect the presence or release of<br />
chemicals in the workplace, including:<br />
* Relevant industrial hygiene monitoring that has been<br />
conducted<br />
* Location, type, capabilities, and limitations of any installed<br />
continuous monitoring devices and,<br />
* Visual appearance or odor of hazardous chemicals when<br />
released.<br />
1.2.2.3 Review of the chemicals’ physical and health hazards or the classes<br />
of hazards present in their work area, including:<br />
* Signs and symptoms associated with overexposure<br />
* Any medical condition known to be aggravated by exposure<br />
and,<br />
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* Target organ effects, if the in-plant labeling system utilizes<br />
hazard warning codes (e.g., NFPA/HMIS) in lieu of the<br />
actual hazard warning statements.<br />
1.2.2.4 Necessary protective measures, such as:<br />
* Installed engineering controls<br />
* Established work practices and procedures and,<br />
* Appropriate personal protective equipment.<br />
1.2.2.5 Basic emergency response procedures, including:<br />
* Recognizing and reporting incidents<br />
* Where to evacuate to (if necessary) during an emergency<br />
* Medical follow-up when an overexposure has occurred or is<br />
suspected of occurring<br />
* Proper cleanup procedures for spills or releases<br />
* Appropriate personal protective equipment<br />
* Applicable decontamination procedures and,<br />
* Emergency shut-down procedures, and,<br />
1.2.2.6 Procedures to properly deal with hazards associated with nonroutine<br />
tasks (e.g., opening hazardous systems, confined space<br />
entry work, contractors’ work, etc.).<br />
1.2.3 Specific Chemical training outlines and videos can be obtained from the<br />
Loss Prevention Department.<br />
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<strong>Visitor</strong> <strong>Hazard</strong> <strong>Communication</strong> Acknowledgement Form<br />
WELCOME VISITOR!<br />
PLEASE COMPLETE AND GIVE TO THE RECEPTIONIST<br />
By signing the form, the undersigned is granted permission to enter upon the premises of<br />
<strong>International</strong> <strong>Paper</strong> located in Isle of Wight county, for the date below; and I understand that the<br />
area or areas I may visit are places where <strong>International</strong> <strong>Paper</strong> employees are operating heavy<br />
equipment and are handling materials which could inflict personal injury to me. I accept and<br />
assume the risk of such injury. I also acknowledge that <strong>International</strong> <strong>Paper</strong> has provided me with<br />
a summary of chemicals used in the Franklin Mill. I have received and reviewed that<br />
information.<br />
In consideration of the granting of the permission to enter <strong>International</strong> <strong>Paper</strong>’s premises, I<br />
release <strong>International</strong> <strong>Paper</strong>, its officers, agents, and employees from any and all claims, demands,<br />
rights of action, or liability that may accrue to my heirs, assigns, or legal representatives such as a<br />
result of any injury of any kind to me (including death arising therefrom) occurring upon the<br />
premises of <strong>International</strong> <strong>Paper</strong> and arising out of the exercise of the permission granted without<br />
regard to any negligent acts or omissions of <strong>International</strong> <strong>Paper</strong>, its officers, agents, and<br />
employees which may cause or contribute in any way to my possible injury or death. I fully<br />
assume any and all risks of injury while on the premises of <strong>International</strong> <strong>Paper</strong> and release and<br />
indemnify <strong>International</strong> <strong>Paper</strong>, its officers, agents, and employees from and against any and all<br />
such liability.<br />
______________________________________<br />
Signature Date<br />
YOUR NAME (PRINT):<br />
COMPANY OR ORGANIZATION REPRESENTED TELEPHONE NUMBER<br />
CITY AND STATE<br />
SPECIFY TYPE OF PRODUCT OR SERVICE IS THIS YOUR FIRST VISIT:<br />
YES NO<br />
EMPLOYEE(S) YOU WISH TO VISIT DEPARTMENT PASS, TYPE, & NUMBER<br />
TO BE FILLED IN BY<br />
RECEPTIONIST<br />
1)<br />
2)<br />
3)<br />
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1.0 Purpose<br />
Attachment 8.0<br />
Offsite Chemical Spills Emergency Response Protocol<br />
In the event of an offsite chemical spill which involves a <strong>International</strong> <strong>Paper</strong> product, and<br />
CHEMTREC or other applicable emergency response organization is notified for<br />
emergency response information, the following procedure should be followed to provide<br />
the appropriate assistance.<br />
2.0 References<br />
2.1 IP Franklin Mill Transportation Department <strong>Hazard</strong>ous Materials Transportation<br />
Training Manual<br />
2.2 IP Franklin Mill Emergency Management Plan<br />
3.0 Procedure<br />
3.1 CHEMTREC shall initially notify the Corporate Health and Safety Office through<br />
the IP Emergency Line. The personnel answering the IP emergency line will<br />
notify the appropriate <strong>International</strong> <strong>Paper</strong> facility which transported the chemical.<br />
3.2 The Franklin Mill must provide a contact for CHEMTREC on a 24-hour /7-day a<br />
week basis in order to answer medical or product questions. Therefore, in order<br />
to provide the appropriate assistance to CHEMTREC, the following people shall<br />
be contacted:<br />
3.2.1 For Transportation Information<br />
3.2.1.1 The Franklin Mill Shift Coordinator shall be contacted.<br />
Telephone Number: (757)-569-5062<br />
3.2.2 For Medical Information<br />
3.2.2.1 The EMT on duty shall be contacted.<br />
Telephone Number: (757)-569-4666<br />
3.2.2.3 If no answer, call the Main Gate at (757)-569-4434 and ask the<br />
guard to page the EMT.<br />
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3.2.3 For Additional Product Information<br />
3.2.3.1 The primary contact is the Emergency Response Coordinator,<br />
Michele Byrum, Pager Number: (757)-516-5672<br />
3.2.3.2 If no answer, contact the IP Medical Department (757) 569-<br />
4666.<br />
3.3 The Material Safety Data Sheet must be referenced when discussing the product<br />
involved in the emergency.<br />
3.4 Complete the attached form when responding to any call received by<br />
CHEMTREC or any other emergency response organization. (Appendix 1.0 of<br />
Attachment 8.0)<br />
3.5 The Franklin Mill Manager or Designee, and the Public Relations Manager or<br />
Designee, must be immediately notified of the incident facts, following<br />
completion of assistance with the emergency response organization.<br />
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EMERGENCY RESPONSE INFORMATION REQUEST FORM<br />
<strong>International</strong> <strong>Paper</strong> Employee Responding to Call:<br />
Date: . Time: .<br />
Name of Person Making Request: .<br />
Agency : .<br />
Telephone Number: .<br />
Location of Emergency: .<br />
Type of Emergency: .<br />
Chemical Involved: .<br />
D.O.T. Proper Shipping Name: .<br />
D.O.T. <strong>Hazard</strong> Class or Division: .<br />
D.O.T. Identification Number: .<br />
MSDS Available: yes no<br />
Information Requested: .<br />
Response Information Provided: .<br />
Follow-up Action Required: .<br />
Upon completion of form contact the Franklin Mill Manager or Designee, and the Public<br />
Relations Manager or Designee, to inform them of the incident.<br />
Send Completed Form to Loss Prevention Department<br />
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