Hazard Communication Program

Policy Statement

The purpose of this plan is to establish a program and procedures for the safe use of hazardous chemical substances at SkyVine ITAD.

The Occupational Safety and Health Administration (OSHA) Hazard Communication Standard (HCS) 29 CFR 1910.1200 calls for the development of a hazard communication program when employees may be exposed to any chemical in the workplace under normal conditions of use or in a foreseeable emergency. In 2012, OSHA revised the HCS to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). As a result, this program has been revised to comply with the requirements of the OSHA HCS 2012. The written hazard communication program will include and address the following criteria in order to satisfy the minimum requirements of the OSHA HCS 2012:

• List of all hazardous chemicals known to be present in the workplace or individual work area

• Methods used to obtain and maintain safety data sheets (SDS)

• Methods used to provide employees with information and training on hazardous chemicals in their work areas

• Methods used to inform employees of the hazards of nonroutine work practices

• Methods used to provide the employees of other employers (e.g., consultants, construction contractors and temporary employees) on-site access to SDS’ for each hazardous chemical that the other employer’s employees may be exposed to while working in the workplace

• Methods used to inform the employees of other employers of precautionary measures that need to be taken to protect themselves during the workplace’s normal operating conditions and in foreseeable emergencies

• Methods used to inform the employees of other employers of the labeling system used in the workplace

The hazard communication program will identify the following:

• Key personnel responsible for the program

• Location of chemical inventory list and SDS

• Workplace labeling system

• Good work practices and procedures to minimize exposures

• How training will be performed

• Procedures to maintain the program and update the required information

• How records will be maintained

Responsibilities

The QEH&S Rep is responsible for program implementation and follow-up to ensure compliance.

This person is also responsible for:

• Reviewing the potential hazards and safe use of chemicals

• Maintaining a list of all hazardous chemicals and a master file of SDS’

• Ensuring that all containers are labeled, tagged or marked properly

• Providing new-hire and annual training for employees

• Maintaining training records

• Monitoring the air concentrations of hazardous chemicals in the work environment

• Properly selecting and caring for personal protective equipment

• Directing the cleanup and disposal operations of the spill control team

• Identifying hazardous chemicals used in nonroutine tasks and assessing their risks

• Informing outside contractors who are performing work on company property about potential hazards

• Reviewing the effectiveness of the hazard communication program and making sure that the program satisfies the requirements of all applicable federal, state or local hazard communication requirements

The QEH&S Rep is responsible for contacting chemical manufacturers and/or distributors to obtain SDS’ and secondary labels for hazardous chemicals used or stored in the workplace

The Receiving Department is responsible for:

• Reviewing incoming hazardous chemicals to verify correct labeling

• Holding hazardous chemicals in the receiving area until receipt of the SDS for the product

Employees are responsible for the following aspects of the hazard communication program:

• Identifying hazards before starting a job

• Reading container labels and SDS’

• Notifying the supervisor of torn, damaged or illegible labels or of unlabeled containers

• Using controls and/or personal protective equipment provided by the company to minimize exposure

• Following company instructions and warnings pertaining to chemical handling and usage

• Properly caring for personal protective equipment, including proper use, routine care and cleaning, storage, and replacement

• Knowing and understanding the consequences associated with not following company policy concerning the safe handling and use of chemicals

• Participating in training

Chemical Inventory List

An inventory of hazardous chemicals that employees may use or come into contact with at the SkyVine ITAD facility shall be generated. This list will contain the product identifier that is referenced on the appropriate SDS, the location or work area where the chemical is used, and the personal protective equipment and precautions for each chemical product. This list will be updated annually and whenever a new chemical is introduced to the workplace.

The location of the Hazardous Chemical Inventory is in front of the SDS binder. The SDS binder can be found near the Time clock.

Labels and Other Forms of Warning

Each container of hazardous chemicals received from the chemical manufacturer, importer or distributor will be labeled with the following information:

• Product identifier

• Signal word

• Hazard statement(s)

• Pictogram(s)

• Precautionary statement(s)

• Name, address and telephone number of the chemical manufacturer, importer or other responsible party

SkyVine ITAD will use the GHS labeling system for secondary containers. When a chemical is transferred from the original container to a portable or secondary container, the container will be labeled, tagged or marked with a GHS label containing the following information:

• Product identifier

• Signal word

• Hazard statement(s)

• Pictogram(s)

• Precautionary statement(s)

Portable containers into which hazardous chemicals are transferred from labeled containers and that are intended for the immediate use of the employee who performs the transfer do not require a label. If the portable container will be used by more than one employee or used over the course of more than one shift, the container must be labeled. Food and beverage containers should never be used for chemical storage.

Signs, placards, process sheets, batch tickets, operating procedures or other such written materials may be used in lieu of affixing labels to individual, stationary process containers as long as the alternative method identifies the containers to which it is applicable and conveys the information required for workplace labeling.

Where an area may have a hazardous chemical in the atmosphere (e.g., where extensive welding occurs), the entire area will be labeled with a warning placard.

Workplace labels or other forms of warning will be legible, in English and prominently displayed on the container or readily available in the work area throughout each work shift. If employees speak languages other than English, the information in the other language(s) may be added to the material presented as long as the information is presented in English as well.

Note: After Dec. 1, 2015, distributors may not ship containers labeled by the chemical manufacturer or importer unless the label on the container meets GHS labeling requirements.

Safety Data Sheets

An SDS will be obtained and maintained for each hazardous chemical in the workplace. SDS’ for each hazardous chemical will be readily accessible during each work shift to employees when they are in their work areas.

SDS’ will be obtained from the chemical manufacturer, importer or distributor. The name on the SDS will be the same as that listed on the chemical inventory list. SDS’ for chemicals or process streams produced by the company will be developed and provided by the safety coordinator.

The safety coordinator will maintain the master file of all original SDS’. Hard copies of the SDS’ will be located in the SDS binder located near the packing and shipping area.

SDS’ for new products or updated SDS’ for existing products will be obtained by the purchasing agent and forwarded to the safety coordinator. The safety coordinator will then update the master file with new and/or updated SDS’.

Employee Information and Training

Employees included in the hazard communication program will receive the following information and training prior to exposure to hazardous chemicals and when new chemical hazards are introduced to their work area:

• Requirements of the OSHA Hazard Communication Standard 29 CFR 1910.1200 and HCS 2012

• Operations in the work area where hazardous chemicals are present

• Location and availability of the hazard communication program, chemical inventory list and SDS’

• Methods and observations used to detect the presence or release of a hazardous chemical in the work area, such as monitoring devices, visual appearance or odor of hazardous chemicals when being released

• Physical, health, simple asphyxiation, combustible dust and pyrophoric gas hazards, as well as hazards not otherwise classified of the chemicals in the work area

• Measures employees can take to protect themselves from hazards, such as appropriate controls, work practices, emergency and spill cleanup procedures, and personal protective equipment to be used

• Explanation of the labels received on shipped containers

• Explanation of the workplace labeling system

• Explanation of the SDS, including order of information and how employees can obtain and use the appropriate hazard information

Note: To facilitate understanding of the new GHS system, the OSHA HCS requires that employees be trained regarding the new label elements and SDS format by Dec. 1, 2013. Employers are required to update the hazard communication program and to provide any additional training for newly identified physical or health hazards no later than June 1, 2016.

Non-routine Tasks

The safety coordinator and the immediate supervisor of an employee performing a nonroutine task, such as cleaning machinery and other process equipment, is responsible for ensuring that adequate training has been provided to the employee on any hazards associated with the nonroutine task. Employees share in this responsibility by ensuring that their immediate supervisor knows that the nonroutine task will be performed.

Contractors

Prior to beginning work, the safety coordinator will inform contractors with employees working on company property of any hazardous chemicals that the contractors’ employees may be exposed to while performing their work. The safety coordinator will also inform contractors of engineering or work practice control measures to be employed by the contractor, personal protective equipment to be worn by the contractors’ employees, and any other precautionary measures that need to be taken to protect their employees during the workplace’s normal operating conditions and in foreseeable emergencies.

Furthermore, the safety coordinator will advise contractors that they must comply with all OSHA standards while working on company property. Appropriate controls will be established with the contractor to ensure that company employees are not exposed to safety and health hazards from work being performed by the contractor and that company operations do not expose contractors’ employees to hazards.

The safety coordinator will inform contractors of the workplace labeling system and the availability and location of SDS’ for any chemical to which contractors’ employees may be exposed while performing their work.

Recordkeeping

Records pertaining to the hazard communication program will be maintained by the safety coordinator. The safety coordinator will keep the following records:

• Chemical inventory list

• Hazardous material reviews

• Employee training records

• Warnings issued to employees for not following the hazard communication program