This Employee Right-To-Know Plan (Plan) is designed to help the St Cloud School District comply with the Minnesota Occupational Safety and Health (OSHA) Employee Right-To-Know Standard, Chapter 5206.0100-1200. This standard is intended to ensure that employees are aware of the dangers involved with the use of hazardous substances, harmful physical agents and infectious agents that they may be routinely exposed to in the workplace. A reference compliance checklist can be found in Appendix A.
It is recommended that the Plan be reviewed and updated annually or as needed upon the introduction of new hazardous substances, physical agents or infectious agents. Actual use of the Plan is limited to Resource Training & Solutions and the St Cloud School District.
Note: School district laboratories (for example, chemistry laboratories) which use hazardous chemicals must comply with OSHA 29 CFR 1910.1450. Where applicable, the school district should refer to their Chemical Hygiene Plan. Under the Minnesota Employee Right-To-Know standard, laboratories in compliance with OSHA 29 CFR 1910.1450 are exempt from having to comply with the Employee Right- To-Know standard. However, due to multi-operations within the facility and the comprehensiveness of Employee Right-To-Know standard, the school district should include all routinely exposed laboratory personnel in their Employee Right-To-Know Plan.
Employee Right-to-Know Management Plan Review and Update Report
Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.
|3/23/16||Removed material from safety data sheets
Training content: (5) additions for the revised hazard communication standard
Labeling: (5) additions and secondary container labeling information
Change MSDS to SDS throughout plan
added: appendix F: Pictograms and hazards
Appendix D: uploaded new hazardous substance inventory form
Definitions: removed material from safety data sheets
Harmful Physical Agent means a physical agent that presents a significant risk to worker health or safety or imminent danger of or serious physical harm to an employee. These include temperature extremes, ionizing and non-ionizing radiation, and noise.
Hazardous Substance means a substance or mixture which is toxic, irritating, combustible or flammable, reactive, carcinogenic, a mutagen, a reproductive toxic agent, or in some other way may cause injury or illness to an employee.
Immediate-Use Container is a container in which a substance is transferred into and will be under the control of and only used by the employee transferring the substance. In addition, all of the transferred substance will be used up within the workshift.
Infectious Agent means a communicable bacterial, viral, fungal or other microbiological agent that may cause illness to an exposed employee. This includes infectious agents that are present in human blood (blood-borne pathogens).
Material Safety Data Sheet is a document prepared by a manufacturer of a hazardous product or substance which describes the characteristics of the substance, its health effects, safe-handling procedures and first-aid procedures in case of overexposure.
Routinely Exposed means the reasonable potential for employee exposure exists during the normal course of work. It does not include an employee walking through an area where a hazardous substance container exists and no exposure is likely unless a spill should occur.
The Minnesota Employee Right-To-Know law applies to school districts. Hazardous substances, harmful physical agents and infectious agents that may endanger the health and well being of school employees while at work are covered under this law. Administrative, janitorial, maintenance, kitchen and laundry personnel, industrial shop instructors (wood, metal, auto body shops) as well as classroom instructors, are examples of those covered by the law. This Plan covers the basic requirements for compliance with Minnesota Employee Right-To-Know. It should be used to identify and document workplace hazards as well as educate school district employees on how to safely deal with these hazards.
B. Responsibilities Under Plan
If several different hazardous substances of harmful physical agents are used in a similar fashion and have a similar content or hazard, it is acceptable to group these substances or agents together in the training. For instance several brands of motor oil and other lubricating oils can be grouped together for training purposes if the usage and hazard is essentially the same. However, each product should have its own SDS on file and be made available to the employees who use these products.
In some cases, products that are used for similar tasks may have different hazardous ingredients that present different levels and types of hazard to the employee. This is often true for cleaners, strippers, and other chemical products. In these instances each should be covered separately in the training session.
Infectious agents (where applicable) training requirements should follow those outlined in the St Cloud School District's Blood-borne Pathogens Exposure Control Plan.
To provide a training session, the trainer must thoroughly understand the Minnesota Employee Right-To-Know standard, the St Cloud School District's program, and be able to discuss the health and safety hazards associated with the hazardous substances or harmful physical agents.
The St Cloud School District must maintain a document that lists the employee's name, job title, the date, trainer's name, title and qualifications, and a summary of the materials covered (or copy of outline) at the training session. The St Cloud School District shall retain all training records for three (3) years minimum. A training log can be found in Appendix D.
The training is to include an overview of the Minnesota Employee Right- To-Know standard and the district's Minnesota Employee Right-To-Know Plan. All school employees covered must be notified as to the location and availability of the written Plan. Employees must receive training on each hazardous substance, harmful physical agent and infectious agent to which he/she is routinely exposed to on the job. This training must take place:
Minnesota Employee Right-To-Know places ultimate responsibility for adequate labeling on the employer (the St Cloud School District).
All secondary containers to which the substance(s) will be transferred need to exhibit the label information. If labels are not available the three minimum requirements are 1. Manufacturer name 2. Product name 3. hazard statement. Labels are not required for immediate use containers, in which the employee dispenses a product which is directly used up in a task performed by that same individual during a single work-shift. Labeling requirements do not include piping systems.
2. Labeling of harmful physical agents
The St Cloud School District will ensure that all equipment or work areas that generate harmful physical agents at a level that may be expected to approximate or exceed OSHA or other applicable standards are labeled with the following:
e. Labeling of infectious agents
The St Cloud School District shall label all infectious agents in accordance with their Blood-borne Pathogens Exposure Control Plan.
f. Non-routine hazards
At times, employees will be required to perform tasks involving hazardous materials or harmful physical agents which have not been covered in their training. Prior to starting work on such projects, each affected employee must receive instruction about the hazards involved with the task. This training must include:
Examples of hazardous non-routine tasks performed are: opening a plugged drain with a sulfuric acid based material or acid etching on a concrete floor using hydrochloric (muriatic) acid.
g. Protective equipment
Any special personal protective equipment required to safely handle exposure to a hazardous substance or harmful physical agent will be provided at the expense of the St Cloud School District.
h. Outside or contractor personnel
The St Cloud School District is responsible to provide contractors (or other outside personnel) information about hazards to which they may be exposed to while working on school district properties. The chemicals or physical agents to be encountered must be disclosed along with required protective measures, safe handling procedures and location and availability of SDSs.
In turn, the St Cloud School District must obtain hazard information (SDSs) from the contractor prior to hazardous chemicals or harmful physical agents being brought on site by the contractor. If there will be affected employees, special training may be required.
i. Program Review
The St Cloud School District will review the Minnesota Employee Right-To- Know program at least annually and update as needed. Changes to the program will be required because of:
C. Responsibilities/Rights of the Employee
The employee is responsible to learn and implement the Minnesota Employee Right-To-Know training received into their daily work routine. The employee has the right to request information about workplace hazards covered under the law and have that information readily available.
Employees are expected to use the safety equipment supplied to them by the employer when procedures require their use. It is the employee's responsibility to see that the equipment is in good repair prior to using it. If the provided safety equipment is damaged/it should be brought to their immediate supervisor's attention to be repaired or replaced.
It is the employee's responsibility to ask the St Cloud School District management questions about the school district's Minnesota Employee Right-To-Know program or about the safe use of hazardous substances or exposure to harmful physical agents. Only by working together in a cooperative manner will the school district have a safe work environment.
The following checklist is intended to provide a quick reference for an individual school district to evaluate their level of compliance with Minnesota OSHA 5206.
Note: This checklist is not intended to be comprehensive in nature. The St Cloud School District should refer to their respective Minnesota Employee Right-To-Know Plan which further outlines general compliance requirements.
Hazardous Substances Inventory Form
District Name/Building: _____________________
Department Supervisor: ______________________________________________
Prepared by: _______________________________________________________
Date of Completion/Latest Revision: _____________________________________
CHAPTER 5206, HAZARDOUS SUBSTANCES; EMPLOYEE RIGHT-TO-KNOW
Table of Parts
5206.0300 SCOPE; EXCEPTIONS.
5206.0400 HAZARDOUS SUBSTANCES.
5206.0500 HARMFUL PHYSICAL AGENTS.
5206.0600 INFECTIOUS AGENTS.
5206.0800 AVAILABILITY OF INFORMATION.
5206.0900 [REPEALED, 17 SR 1456]
5206.1000 LABELING HAZARDOUS SUBSTANCES.
5206.1100 LABELING HARMFUL PHYSICAL AGENTS; LABEL CONTENT.
5206.1200 CERTIFICATION OF EXISTING LABELING PROGRAM.