All employees of FOX who may come into contact with, or be potentially exposed, to chemical materials, will be informed of the associated hazards by means of labels and other forms of warning, material safety data sheets, and information and training.

1.0          INTRODUCTION

The purpose of the Hazard Communication Program is to increase employee awareness regarding hazardous substances used in the workplace. This document outlines how this will be accomplished.

FOX’s Hazard Communication Program is available upon request, to any employee, their designated representatives, and government regulators. This written program can be obtained or requested:

1. In person by visiting the EHS office
2. By contacting the Environmental, Health, and Safety (EHS) Office by email: FOXSafety@FOX.com
3. By calling by calling (310) 369-2671 

2.0          SCOPE

FOX EHS will provide and maintain this Program for all work areas where employees may potentially be exposed to hazardous substances.

The Hazard Communication Program applies to all employees and contractors who work with hazardous materials. Such materials include, but are not limited to, chemicals, paints, inks, glues, cleaning agents, and compressed gases. Affected employees must be familiar with and adhere to the requirements of this document.

Exempt or Provisionally Exempt Operations and Substances

Certain operations and substances are exempt or provisionally exempt from the Hazard Communication Program.

Work operations where employees only handle chemicals in sealed containers that are not opened under normal conditions are provisionally exempt from the Hazard Communication Program under the following conditions:

1. Labels on  incoming  containers  of  hazardous  chemicals  are  not  removed or defaced;
2. Safety data sheets are accessible to employees by having hard copies or electronic access; and
3. Employees receive Hazard Communication training provided by EHS.

Such operations may include stockrooms and shipping/receiving areas.

The following substances are exempt from the requirements of this Hazard Communication Program

1. Hazardous waste;
2. Tobacco and tobacco products;
3. Wood and wood products that the only hazard they pose to employees is  the potential  for flammability or combustion;
4. Manufactured items that are
   1. formed in a specific shape or design during manufacture;
   2. which have end use function(s) dependent upon their shape or design during end use; and
   3. `which do not release hazardous chemicals under normal conditions of use or in a reasonably foreseeable emergency;
5. Foods, drugs, and cosmetics intended for personal consumptions by employees; and
6. Consumer products used in the workplace as a typical consumer would use them.

3.0          Responsibilities

In addition to required Environmental, Health and Safety (EHS) Program responsibilities discussed in EHS001, EHS Policy, the responsibilities described below are necessary to ensure the effectiveness of the procedure.

3.1          Department Heads & Supervisors

Department Heads & Supervisors for which this procedure applies will:

1. Ensure workers are properly informed and trained about the hazards of the chemical products, which they use in their workplaces (see Section 4.4)
2. Ensure all chemical products are properly labeled, stored, and accounted for on MSDS Online.
3. Maintain a listing of chemical products belonging to their Department via MSDS Online.
4. Perform an inventory of chemical products each January and provide an updated chemical listing to the EHS Department and uploading the inventory to MSDS Online
5. Ensure any vendor or contractor working for their Department comply with the requirements of Section 4.5.

3.2          Environmental, Health and Safety Department

The EHS Department will:

1. Maintain, review, and update the written Hazard Communication Program at least annually to ensure that all requirements are current with all local, state, and federal requirements.
2. Aid supervisors with identifying hazardous substances in the work area, evaluate potential hazards of operations, and training
3. Approve the issuance of a chemical product identified as posing a significant hazard to any affected Department
4. Maintain a copy of each affected Department’s chemical materials inventory via MSDS Online

3.3          Employees

Employees are responsible for:

1. Adhering to the precautions outlined on container labels, SDSs, and established procedures;
2. Job-specific training, and requesting any additional training on hazards that they are unfamiliar with before beginning work;
3. Reviewing Safety Data Sheets on MSDS Online to become familiar with the hazards and precautionary measures for working with hazardous materials in their work area; and
4. Using personal protective equipment as deemed

4.0          Procedure

This program applies to any hazardous substance known to be present in the workplace in such a manner that employees might be exposed, under normal conditions of usage, or in a reasonably foreseeable emergency, resulting from workplace operations.

The Hazard Communication Program consists of four basic parts, which are:

1. A written Hazard Communication Program, which is provided by this Program
2. Safety Data Sheets (SDS) which are available on MSDS Online for all hazardous substances in the workplace
3. Labels and labeling of hazardous substance containers
4. Employee training, including general information and workplace-specific training.

4.1          Identification of Hazardous Materials

Safety Data Sheets (SDSs), product labels, and various published regulatory and advisory agency lists may be utilized when assessing hazardous materials in the workplace. Additionally, any other substances determined by scientific evidence to present a hazard should also be considered hazardous. EHS is available to assist with identifying hazardous materials.

See Section 6.0 References for published regulatory and advisory lists of hazardous materials.

Identification of hazardous materials in the workplace is needed in order to fulfill the requirement for maintaining a hazardous materials list. Department Heads & Supervisors are responsible for maintaining the hazardous materials list via MSDS Online and shall update it at least annually.

4.2          Procurement Procedures

1. SDS must accompany all chemical products purchased for use in FOX activities (except consumer products).
2. A boilerplate statement must be attached to all purchase orders, on request, in order to obtain the SDS for each hazardous substance.
   1. 1. 1. 1. 1. 1. “Safety Data Sheets are mandatory with this order.”
3. SDSs not included with the product upon delivery, must have a statement, which indicates that the product is exempt from the regulations and does not require an SDS.
4. If an SDS is not already available and the vendor cannot provide an SDS at the time of procurement, the material must not be purchased.
5. No hazardous substance requiring a SDS will be introduced in any work area by petty cash purchase, supplier samples, or other means without obtaining a SDS.

4.2.1      Container Labeling

Each container of any chemical product purchased or used by FOX must be labeled, tagged, or marked with the following information:

1. Name of the commodity or item
2. Identity of the hazardous substance(s) contained in the commodity
3. Appropriate hazard warnings; using a National Fire Protection Association (NFPA) 704-type label (or similar), the hazard rating of the material will be noted with respect to flammability, health hazard, and reactivity.
4. Chemical incompatibility issues will also be noted.
5. Labels on incoming purchased chemicals are not to be removed or defaced. Container size is not the determining factor in deciding if a label is required. All containers of chemical products must be labeled.
6. Where hazardous substances are stored/dispensed from a permanent fixed location, a wall placard or sign may be used in lieu of a label.
7. The placard or sign will be affixed next to the container in clear view.
8. Each placard or sign will identify the hazardous substance and any hazards present, or it can be a duplicate of the manufacturer’s label.
9. If a chemical product is transferred from its original container, the receiving container must be labeled with the chemical identity and hazard warning.
10. The only exception to this requirement involves the transfer of the chemical from a labeled container for the immediate use of the employee who performs the transfer during his/her workshift.
11. The term “immediate use” means that the chemical product will be exclusively under the control of, and used by, the person performing the transfer within the duration of the current workshift.

4.3          Chemical Product Management

4.3.1      Chemical Product Inventory on MSDS Online

Each FOX Department Head/Supervisor will be responsible for maintaining an inventory of all chemical materials under its control. He /She will be assigned an Admin login to MSDS Online. If you do not have an admin login, it can be requested by contacting the Environmental, Health, and Safety (EHS) Department by email: FoxSafety@fox.com

1. Refer to the References Section 6.0 for a viewer user guide for staff members (which do not require a login) and also a user guide for admins to manage your department’s chemical inventory.
2. During January of each year, every FOX Department will conduct a physical inventory to verify and update the information contained on the MSDS eBinder.

4.3.2      Safety Data Sheets

Each individual FOX Department will maintain their online inventory of SDSs on MSDS Online, which contains the SDSs for chemical product noted on the Department’s chemical product inventory.

1. SDSs for new items must be obtained at the time of initial procurement
2. MSDS Online will be maintained and accessible to all Department personnel.
3. All personnel must be briefed about the location and access procedure.

All FOX personnel will be aware of how to access MSDS Online and access SDSs for their workplace and will have unrestricted access to the MSDS Online system during all work shifts.

4.4          Hazard Communication Training

All FOX employees will receive the following Hazard Communication Training.

Training documentation will be maintained by each FOX Department for all its employees.

4.4.1      General Training

At the time of initial hire, FOX employees must receive training in Hazard Communication to include:

1. An overview of the requirements contained in the Hazard Communication Regulation, including each employee’s rights under this law
2. Description of an SDS and an explanation about how to read the document
3. Explanation of labels used by manufacturers to identify hazardous substances
4. Methods and observation techniques used to determine the presence or release of hazardous substances in the workplace (smell, odor, appearance, irritation of eyes, smoke, etc.)
5. Measures workers can take to lessen or prevent exposure to hazardous substances (knowledge of chemicals, storage practices, personal protective equipment, labels, emergency eyewashes, etc.)
6. Emergency and first aid procedures to follow in the event of an employee exposure to a hazardous substance.

4.4.2      Job-Specific Training

Employees must be trained in the specific chemical materials and hazards associated with their workplace.

Each Department Head is responsible for ensuring that new employees are trained in the following, within thirty (30) days of their hire:

1. Explanation of FOX’s Hazard Communication policy, as specified in this Procedure
2. Location and availability of MSDS Online and supporting materials for the employee’s workplace
3. The specific hazardous substances in each employee’s workplace, including the operations and locations where they are present.
4. Explanation of the physical and health hazards associated with hazardous substances and the required protective measures needed to ensure that the products will be used safely.

4.4.3      Annual Refresher Training

Yearly refresher training in regard to hazard communication will be provided for all employees.

Each Department Head is responsible for ensuring that this training is provided and that it addresses the following topics:

1. An overview of the requirements contained in the Hazard Communication Regulation, including each employee’s rights under this law
2. Description of an SDS and an explanation about how to read the document
3. Explanation of labels used by manufacturers to identify hazardous substances
4. Explanation of FOX’s Hazard Communication policy, as specified in this Procedure
5. Location and availability of MSDS Online and supporting materials for the employee’s workplace
6. Specific hazardous substances in the workplace, including the operations and locations where they are present
7. Explanation of the physical and health hazards associated with hazardous substances, and the required protective measures needed to ensure that the products will be used safely.

4.4.4      Non-routine Tasks

1. Periodically, employees might be required to perform non-routine work or tasks, using hazardous chemicals, or to work in associated hazardous locations.
2. Prior to starting such projects, the Department Head and Supervisor is responsible for ensuring that each affected employee is given information about the chemicals and exposure hazards associated with the activity.

4.5          Outside Organizations

Whenever outside contractors are engaged to perform work at a FOX facility, the contractor will be required to provide:

1. A list of chemical products that the contractor will bring to the FOX site.
2. Before work begins, the project manager will require the contractor to provide FOX with copies of SDSs for each item.
3. A list of the precautions, controls, and appropriate protective measures to be used by the contractor, to lessen or prevent possible exposure hazards to FOX personnel.
4. The department coordinating the contractor’s work will review all information provided by the contractor, so that safety precautions and training (if necessary) can be instituted to prevent possible exposure to any hazardous substances.
5. Copies of all contractor-supplied SDSs must be maintained at worksites. 

5.0          Emergency Response

All employees must be familiar with their emergency escape routes, procedures, and  follow the guidance of Floor Wardens and Building Coordinators in the event an emergency or hazardous materials incident.

For direct or suspected chemical contact or exposure, consult the SDS for first aid procedures.

General guidelines for chemical contact or exposure include:

1. Remove contaminated clothing;
2. Flush the affected area with water for at least 15 minutes;
3. Remove employee to fresh air in the event of inhalation of hazardous materials;
4. Contact employee’s Supervisor/Manager immediately;
5. If injuries are beyond what is treatable by local first-aid, seek professional medical attention as quickly as possible by contacting FOX Security by direct dial to (310) 369-6555.
6. FOX Security will contact appropriate authorities such as Fire, Emergency Services, and the EHS department.

In an emergency, please dial 310-369-6555

 If a chemical spill occurs, consult the SDS for guidance on how to respond to the spill. Only trained and knowledgeable personnel with access to the proper containment materials to clean a spill can do so.

Depending on the nature of the spill (such as the hazards involved, size of the spill, and/or if an injury has occurred) it may be considered an emergency. In such a case, immediately dial 310-369-6555.

Additional information on emergency response procedures are available upon request from the EHS Office by email: FOXSafety@FOX.com  or by direct dial to (310) 369-2671.

 

6.0          REFERENCES

EHS 001, EHS Policy

EHS 101, Injury and Illness Prevention Policy

MSDS Online User Guide

MSDS Online Fox Corporation Link

MSDS Online Admin – How do I manage my chemical inventory

Chemicals on the Director’s List of Hazardous Substances, 8 CCR 339

Chemicals on the Toxic and Hazardous Substances List, 29 CFR 1910, Subpart Z

Chemicals containing    Threshold    Limit    Values    by   the    American   Conference   of Governmental Hygienists

Chemicals identified in the 14^th Report on Carcinogens (RoC) by the National Toxicology Program

Chemicals identified by the International Agency for Research on Cancer (IARC)

Chemicals found listed on Proposition 65

Chemicals found to present a personal hazard as determined by scientific evidence

 

7.0          ATTACHMENTS

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