Internal

West Michigan Compounding, LLC

Program Name: Hazard Communication Program Revision Level: 01
Program Number: 001 Review Date: 5/14/20
Originated By: West Michigan Compounding, LLC Reviewed By: Molly Mannion
Effective Date: 05/14/20 Page: 1 of 5
Hardcopies of this Document are for Reference Only. Only Documents Maintained on the Network are considered valid.

Hazard Communication Program

If you have any questions regarding this document, please contact your supervisor, Molly Mannion (Safety), or Lorenda
Davis (HR)

Document is UNCONTROLLED when printed.

Internal

West Michigan Compounding

Program Name: Hazard Communication Program Revision Level: 01
Program Number: 001 Review Date: 05/15/20
Originated By: West Michigan Compounding Reviewed By: Molly Mannion
Effective Date: 05/15/20 Page: 2 of 5
Hardcopies of this Document are for Reference Only. Only Documents Maintained on the Network are considered valid.

1. Purpose
The hazard communication program is designed to reduce the potential for occurrences of chemical-related occupational illnesses and
injuries by providing specific procedures to identify and evaluate the chemical hazards in the workplace. Training employees on those
hazards of the chemicals with which they work. Ensure that all employees at risk are adequately informed about the chemicals used and
stored at the two facilities, both located in Greenville, MI.
2. Regulatory requirements
 Occupational Safety & Health Administration general industry requirements for 29CFR 1910.120
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.120
3. Scope
This program is applicable to all WMC employees at the Greenville facilities, to all work conducted under the authority of West Michigan
Compounding. It applies to all equipment, materials, and property managed WMC at the Greenville facilities.
Exempt substances
 Tobacco or tobacco products, food, drugs, cleaning supplies, or cosmetics intended for personal consumption or use by employees.
Consumer-use items used in the workplace in the same fashion and amount as the ordinary consumer would use them. Wood or
wood products. (Note: Wood or wood products that have been treated by a hazardous chemical, which may be sawed or cut,
generating dust, are not exempt).
4. Roles and Responsibilities
In order for the Hazard communication program to be effective, all affected individuals must clearly understand and take an active role in
meeting their responsibilities. A thorough understanding of roles and responsibilities is necessary to meet the requirements of this program.
4.1 Management responsibilities
Evaluate and update written hazard communication program on an annual basis or as procedures or conditions change. Ensure all SDS’s and
this written hazard communication program is available for review by all employees on all shifts. Perform an annual review of the Chemical
Inventory list. Develop Hazard communication training for all affected employees. Recommend personal protective equipment and safe
handling procedures for specific operational needs.
4.2 Safety Dept. responsibility
 Ensure that Safety Data Sheets (SDS) are available for all hazardous substances in the workplace. Ensure SDS master inventory list
is maintained and updated. Ensure that hazardous chemical containers are properly labeled. Ensure that employees receive timely
hazard communication training or additional training when a new chemical is introduced or when substantial changes in chemical
usage or work practices occur. Provide technical assistance regarding hazardous materials purchase, use, SDS’s, hazard
identification, and protective measures. Evaluate the hazards of chemicals (through SDS). Report to management any violations of
this program.
4.3 Employee responsibility
 Participate in Hazard communication training before working with a hazardous material.Understand and read the SDS for each
hazardous material that he/she will handle or be exposed to.Follow the measures specified on the SDS.Follow all site-specific
procedures for safe storage, labeling, and handling of hazardous materials.
4.4 Contractor responsibility
 WMC shall communicate known hazards to contractors. Contractors are expected to manage Environmental, Health, and Safety
hazards, risks and programs for their employees and subcontractors.

5. Safety Data Sheets

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Internal

West Michigan Compounding

Program Name: Hazard Communication Program Revision Level: 01
Program Number: 001 Review Date: 05/15/20
Originated By: West Michigan Compounding Reviewed By: Molly Mannion
Effective Date: 05/15/20 Page: 3 of 5
Hardcopies of this Document are for Reference Only. Only Documents Maintained on the Network are considered valid.
The purpose of an SDS is to provide safety data about a specific hazardous substance. The SDS contains physical data and other information
specified by OSHA. A manufacturer or importer must generate an SDS for each hazardous substance covered by the hazard communication
standard.
Hazard determination
 WMC will rely on the information contained on the manufacturer’s Safety Data Sheets for evaluating any hazards associated with
chemicals and to meet determination requirements.Each time a new product is received, it will be evaluated to determine whether it
should be added to the inventory.The Program Administrator will be responsible for reviewing the SDS for significant health and
safety hazards and will forward all pertinent data to the appropriate party.
5.2. Inventory of Hazardous chemicals
 An inventory of all hazardous substances used throughout the site and is available at the SDS station. Inventory includes the
chemical name, product name, and manufacturer in an alphabetical format.
5.3. Accessibility to SDSs
Safety Data Sheets are located ….
5.4. SDS updates
 The Safety Dept. is responsible for updating the SDS file with new or revised SDSs obtained from the manufacturer.
 The Safety Dept. will be responsible for timely updates to the Chemical inventory list.
5.5. Receiving procedures
 The Safety Dept. shall be responsible for the inspection of each new SDS for completeness.
 If an SDS is missing, incomplete or illegible, a new SDS will be obtained.
6. Container Labeling
Each workplace container of hazardous substances shall be labeled, tagged, or marked to identify the material and to provide the
appropriate warnings. A label identifying the contents and providing a hazard warning will be affixed to all containers of hazardous
chemicals which could pose a physical or health hazard to exposed employees in the workplace. The chemical manufacturer or distributor
typically affixes appropriate labels.
General Requirements
 At a minimum, the label must identify the chemical, and contain hazard warnings. The chemical identity provided on the label must
be the same as or cross-referenced to the same identifier on the SDS and inventoryIncoming containers received with defaced or
missing labels should be rejected unless the contents are definitely known, and the container is immediately labeled with the
appropriate information.Labels shall not be removed or defaced, and must remain intact during use.All labels will be of prominent
size, legible and firmly attached to the container.The name and address of the chemical manufacturer, importer, distributor or other
responsible party. Empty containers will not be reused unless reused with the original contents. If container is to be used for other
substances other than the original contents, the container should be triple rinsed, the original label must be removed or defaced, and
a new label attached.
Secondary containers
 Chemicals may be transferred from the primary container in which they were originally received into a secondary container for more
convenient use.Secondary containers of chemicals that are used by more than one person or for longer than one work shift must be
labeled with a copy or facsimile of the original manufacturer's label, or a locally produced label.Locally produced labels must include
the identity of the chemical and the appropriate hazard warning. Employees should utilize the National Fire Prevention Association
(NFPA) or the Hazardous Materials identification System (HMIS) labeling systems for secondary container labeling. Containers into
which chemicals have been transferred for use during a single work shift, solely by the person performing the transfer, do not need
to be labeled; however, labeling of these containers is strongly encouraged as a good operating practice.

Container Labeling Exemptions

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Internal

West Michigan Compounding

Program Name: Hazard Communication Program Revision Level: 01
Program Number: 001 Review Date: 05/15/20
Originated By: West Michigan Compounding Reviewed By: Molly Mannion
Effective Date: 05/15/20 Page: 4 of 5
Hardcopies of this Document are for Reference Only. Only Documents Maintained on the Network are considered valid.
Consumer products having labels meeting requirements of the Consumer Product Safety Commission do not have to have additional
labeling under the Hazard Communication Standard.
 Various other chemical products (for example, pesticides, foods, drugs, cosmetics, beverage alcohols) that are subject to labeling
laws administered by other Federal agencies are also exempt from the labeling requirements of the Hazard Communication
Standard.

7.
Pipes and Piping Systems
 OSHA requires that pipes or piping systems in the workplace that contain a hazardous material shall be identified to an employee by
label, sign, placard, or other identification system that contains the same information displayed on a label. This label must be readily
accessible to each employee. Natural gas, water, and compressed air lines shall be identified throughout the Greenville facilities.

8. Non-Routine Tasks
Employees required to perform non-routine tasks involving the use of hazardous chemicals (such as might occur during a temporary
assignment to a different job) will be provided SDS information about the hazards of the new task and, where appropriate, additional
instruction and training by their supervisor.
9. Training
The purpose of training is to effectively communicate hazard information to employees. Solely giving employees the data sheets to read does
not satisfy this training. A training program is to be a forum for explaining to employees not only the hazards of the chemicals in their work
area, but also how to use the information generated in the hazard communication program. The training program is located at the following file
location:
Training Conditions
 Hazard communication training is required for any employee who either handles, stores, uses, ships, or may be potentially exposed
to, hazardous materials on a routine basis.
When any exposed employee is first hired. When chemical hazards in an exposed employee’s work area change. When a new
hazard is introduced. Attendance is mandatory for all exposed employees. Refresher training shall be conducted annually.
 Office workers who encounter hazardous chemicals only in isolated instances are not covered by the rule. OSHA considers most
office products (such as pens, pencils, adhesive tape) to be exempt under the provisions of the rule.
Curriculum
 Employee rights and responsibilities
 Hazard recognition and nature of hazards
 Understanding the SDS
 Labeling Systems
 Haz-com Quiz
Attendance records
 A post-training quiz shall be administered at the conclusion of the training program. Quiz will be signed and dated by the employee
and will serve as evidence of training. Documentation of training for each employee affected shall be kept on file in the safety
department and made available to on-site inspections or inquiries conducted by OSHA.

Document is UNCONTROLLED when printed.

Internal

West Michigan Compounding

Program Name: Hazard Communication Program Revision Level: 01
Program Number: 001 Review Date: 05/15/20
Originated By: West Michigan Compounding Reviewed By: Molly Mannion
Effective Date: 05/15/20 Page: 5 of 5
Hardcopies of this Document are for Reference Only. Only Documents Maintained on the Network are considered valid.
10. Program Evaluation
In order to ensure that this Hazard communication program continues to be effective, the program will be reviewed annually or on a more
frequent basis as procedures/conditions change to warrant a review. It will be the responsibility of the Safety Dept. to correct any
identified deficiencies in the program and to ensure that those changes are communicated to all affected employees.

Document is UNCONTROLLED when printed.