The Honolulu Police Department shall maintain a hazard
communication and training program, as outlined herein,
in accordance with federal and state regulations and
guidelines prescribed by law.
FEDERAL AND STATE REQUIREMENTS
A. The Occupational Safety and Health Administration
(OSHA), U.S. Department of Labor, has established a
standard titled “Hazard Communication.” It is designed
to help prevent the safety and health problems associated
with chemical hazards in the workplace. The standard
creates uniform requirements to ensure that all chemicals
are evaluated and that the resulting hazard information
is transmitted to potentially affected employers and employees.
B. The Occupational Safety and Health Division, State
of Hawaii Department of Labor and Industrial Relations,
requires that comprehensive hazard communication programs
be implemented throughout the state.
DEPARTMENTAL HAZARD COMMUNICATION PROGRAM/COORDINATOR
A. For the purposes of this directive, the term
“chemical” shall also refer to products that are
composed of chemicals that may be hazardous.
B. The departmental hazard communication program
coordinator is the department’s Safety Specialist,
who is assigned to the Professional Standards
Office. The coordinator bears overall responsibility
for the program and shall:
1. Review each element’s procedures to ensure that
they are consistent with the program; and
2. Monitor and direct changes in program requirements
and element procedures as necessary.
The department relies upon a manufacturer’s hazard
assessment of a chemical that it produces. A list
of all known hazards about a chemical is listed on
its container labels and Safety Data Sheet (SDS),
both of which are provided by the manufacturer.
The SDSs (Attachment A) are printed on letter-size
sheets and include information on components and
quantities, physical and chemical characteristics,
hazards, reactivity, and precautions for its handling
and use. As stated in sections V C and D below, an
element’s SDSs shall be available to all of its employees at all times.
ELEMENT HAZARD COMMUNICATION PROGRAM
A. The hazard communication program coordinator
shall issue a Hazardous Communications Program
File (loose-leaf SDSs binder) to each element
that uses or stores hazardous chemicals.
B. Each element that uses or stores hazardous
chemicals shall maintain an element hazard
communication program that follows the guidelines
established by this directive. It shall also
include materials provided by the hazard
communication program coordinator and an element
program file (as described below).
C. Each element that uses or stores hazardous
chemicals shall maintain at each of its work
facilities a written Hazardous Communications
Program File (a loose-leaf SDSs binder) that
contains all applicable SDSs and other written
materials specifically required for this program.
D. Each element’s safety officer (usually the
element’s executive officer) shall ensure that
all materials issued by the hazard communication
program coordinator, current SDS for chemicals
in the workspace, and the element’s Hazardous
Communications Program File, are always readily
available for the employees’ review.
E. Appropriate instructions and program references
shall be added to each element’s Manual of Operations.
HAZARD COMMUNICATION PROGRAM COMPONENTS
The general components of the hazard communication
program are spelled out below.
A. Lists of Hazardous Chemicals
1. Each element shall maintain a list of the
hazardous chemicals known to be present in
that element’s work facilities. Each chemical
shall be identified by reference to the name on the appropriate SDS.
2. The list shall be maintained as a part of
the element’s program file. It shall be
updated whenever there is a change in the kind
of chemicals that are at a facility.
3. Chemicals that are no longer in use shall be
purged from the Hazardous Communications Program File.
4. Each element shall submit a copy of their current
list to the hazard communication program coordinator every January.
1. Element commanders shall ensure that every
container of hazardous chemicals in their facilities
are labeled with the following information:
a. The chemical name and common name of the hazardous
chemicals in the container;
b. Appropriate hazard warnings; and
c. Name and address for the chemical’s manufacturer.
When a chemical is ordered, the requesting element
shall indicate on the purchase order that the container
of the chemical is to be labeled with all of this information.
The employee receiving the chemical shall not accept
the delivery if any of this information is omitted.
2. Labels provided by the vendors with chemical
information shall not be removed or defaced and shall
be kept on chemical containers until the chemical is
completely used or properly disposed.
3. In-House Labeling
Whenever a hazardous material is transferred into
a secondary container, the employee transferring
the material shall attach a label to the container.
The In-House Labeling form (see required information
in Attachment B) shall be used in the following
circumstances. This form shall contain the information
in sections B 1 a and b above.
a. The form shall be used when chemicals are
transferred to secondary containers. The
employee making the transfer shall ensure that
the form is used to label the secondary containers.
Secondary containers need not be labeled if the
chemical is intended only for immediate use by
the employee who performed the transfer, and no
risk is posed by the chemical residue of that secondary container.
b. The form shall be used when a manufacturer’s
label for a container has been removed or becomes
illegible. The chemical’s manufacturer is the
resource for obtaining the required information.
1. No new hazardous material shall be purchased
by an element without a SDS first being reviewed
by the element commander and safety officer for
hazards associated with the chemical. The element
shall maintain copies of all current SDSs within
their work areas. The safety officer shall determine
if a less-hazardous alternative to the requested
chemical should be considered. Along with the SDS,
the following factors shall be considered in making
a. The environment in which the chemical is to be used;
b. The availability of the proper protective equipment
required for handling the chemical; and
c. Any qualifications/training required for using
the protective equipment and/or handling the chemical.
2. An employee shall not accept the delivery
of a chemical if a current SDS for it is not available.
3. Element safety officers shall review all SDSs
for current and complete product and hazard information
and ensure that all SDSs are reviewed, updated,
and purged annually. Copies of the current SDSs
may be uploaded to the intranet, but a hard copy
shall be kept in the Hazardous Communications Program File.
4. Element safety officers shall ensure that
employees are properly trained to handle any
chemical that is being used, and a SDS for all
chemicals shall be made available for review
prior to working with the hazardous material.
5. A Hazardous Chemical Inventory List, noting
all known hazardous chemicals at a work facility,
shall be kept with the Hazardous Communications
Program File (SDSs binder) for that facility in
a readily available location, and all employees
shall be notified of that location.
6. Any unavailable SDSs may be requested from
the element safety officer. If the SDS cannot
be obtained from the safety officer, a request
may be made to the hazard communication program
coordinator, and the chemical shall be removed
from service until the SDS can be obtained.
D. Employee Information and Training
1. Any employee who is newly assigned to an element
shall receive safety and health training before
handling any chemical. The element’s safety officer
is responsible for scheduling or conducting this
training. Commanders are responsible for ensuring
that the new employee receives this training.
The training, which may be oral and/or a video
presentation, shall cover the following topics:
a. An overview of the OSHA Hazard Communication
Standard and this policy;
b. Chemicals present in the work environment.
This includes a review of the contents and location
of the element’s or that facility’s Hazardous
Chemical Inventory List and Hazardous Communications
Program File (SDSs Binder);
c. Physical and health effects of hazardous chemicals
used in the workplace;
d. The labeling system and how to use it;
e. Reading, interpreting, and locating SDSs;
f. Methods of detecting the presence or release
of hazardous chemicals in the area;
g. Personal protective equipment (PPE) and work
practices to minimize exposure to hazardous chemicals;
h. Measures taken by the department to minimize
exposure to hazardous chemicals; and
i. Emergency safety procedures for exposure.
2. An annual review and training of the SDSs
of all chemicals will be conducted by each
element’s safety officer in January.
3. Following each training session, employees
are required to verify their attendance by
signing and dating a training record. A list
of topics covered in the training shall be
attached to this training record and maintained
by the element commander for review.
4. An employee whose work requires the use of
PPE or may expose the person to hazardous chemicals
shall complete training as described in
sections 1 a through j above before starting such work.
5. Additional training shall be provided to
affected employees with the introduction of
each new chemical hazard and this training
shall also be documented.
E. Nonroutine Tasks
Supervisors and element safety officers shall
identify nonroutine tasks which may be hazardous.
Safety officers shall be responsible for informing
employees of the hazards, requirements for safely
performing the task, and the need for PPE before
employees begin the work.
F. Unlabeled Pipes
Employees may work in areas with sealed, unlabeled
pipes that transfer chemicals. However, element
safety officers shall inform employees working in
these areas of (1) what chemicals are in the pipes,
(2) potential hazards, and (3) required safety
precautions before the work begins.
G. On-site Contractors
1. Before an on-site contractor works where he
or she is likely to be exposed to hazardous
chemicals, the element’s safety officer for
that area shall inform the contractor of the
types and locations of chemicals and the
locations of the hazard communication policy
and Hazardous Communications Program File
(SDSs Binder). Elements that use more chemicals
than the normal office operation should be
particularly attentive to contractors at their work sites.
2. If an on-site contractor works where he or
she is not likely to be exposed to hazardous
chemicals, the element’s safety officer for
that area shall make the hazard communication
policy and Hazardous Communications Program
File (SDSs binder) available upon request by
PROCEDURES FOR EMERGENCIES
If the circumstances of a hazardous material
emergency call for immediate action to protect
the public health or welfare, the guidelines
established in Policy 4.42, HAZARDOUS MATERIALS
AND WEAPONS OF MASS DESTRUCTION EMERGENCIES,
shall be followed.
This policy shall be reviewed each February
by the departmental hazard communication program
coordinator and updated when necessary.