HAZARD COMMUNICATION PROGRAM

1.0 PURPOSE

The Occupational Safety and Health Administration’s (OSHA) Final Hazard Communication Rule, 29CFR 1910.1200 was promulgated in February 1994. The purpose of the rule is to ensure that the hazards of all chemicals produced, imported or used within the United States manufacturing sector are evaluated and that this information is transmitted to the affected employers and employees. The purpose of this written Hazard Communication Program is to define requirements and establish procedures and criteria, which will ensure that:

· Each container of hazardous chemicals in the workplace is properly labeled, tagged or otherwise demarcated in accordance with the requirements of 29 CFR 1910.1200 (f).

· Each container of hazardous chemicals leaving the workplace is properly labeled in accordance with the requirements of 29 CFR 1910.1200 (f).

· Material Safety Data Sheets (MSDS) are obtained or developed for each hazardous chemical produced or purchased.

· Employees are trained in accordance with the requirements of 29 CFR 1910.1200 (h).

· Hazardous chemical lists, which reference appropriate MSDSs, are compiled for each work area.

· Employees are informed of the hazards of non-routine tasks.

· Contract employers, with employees working within the facility, are informed of the hazardous chemicals their employees may be exposed to while performing their work and the suggestions for appropriate measures to take to prevent exposures to these chemicals.

2.0 SCOPE

All chemicals manufactured, mixed used and/or stored at Cheyenne Drilling facilities or rig locations, and which may present a potential health, safety and/or environmental hazard, are covered under this program. In addition, all employees and contract employers potentially exposed to these chemicals will be covered under the training requirements of the program.

3.0 REFERENCES

Title 29 Code of Federal Regulations, Subpart Z, 1910.1200.

4.0 DEFINITIONS

In order to perform Hazard Communication properly certain terms must be defined. A list of such terms and their definitions may be found in appendix C of this part.

5.0 Procedure

5.1 Background Information

The Hazard Communication/Right-To-Know Law was established so employees would be aware of the hazardous chemicals they work with or around. The main components of the program are information sheets (MSDSs), labeling and training

5.2 Responsibility

All Drilling Managers, Toolpushers and supervisors are responsible for the establishment and maintenance of good health and safety practices. Participation and support of the Hazard Communication Program by managers, operations, sales, administrative employees and contractors is essential for this program to be successful.

5.2.1 The HSE Manager or a designee is responsible for implementation and administration of the Hazard Communication Program. The HSE Manager or a designee will:

· Maintain and update the Chemical Lists and MSDS Binders.

· Verify that all incoming and secondary containers housing hazardous chemicals are clearly labeled and that all chemicals on-site are listed on the chemical list, and have a MSDS on file.

· Review all new chemical products MSDSs prior to use to ensure proper precautions are in place.

· Implement a training program for hazardous materials.

· Conduct quarterly inspections and/or spot checks to ensure compliance with this program

· File annual reports with the Federal and/or State OSHA and Local Fire Departments as required.

5.2.2 Supervisors have the primary responsibility for the implementation and compliance aspects of the Hazard Communication Program in their assigned areas. Supervisors will:

· Ensure no employee is assigned to a task using a hazardous chemical prior to the proper training being held.

· Ensure all containers used in the workplace are properly labeled.

· Ensure no hazardous chemicals are brought into the workplace without the correct MSDS being available.

· Ensure all contractors meet with them for a safety and hazard communication orientation

5.2.3 Employees are responsible for adhering to all Hazard Communication Program requirements. Employees will:

· Work with or around chemicals only after being trained on the hazards of that chemical.

· Label all secondary containers they put hazardous chemicals into.

· Bring no chemicals into the workplace without first obtaining a proper MSDS.

5.3 Program Elements

The Hazard Communication Program is comprised of:

5.3.1 List of Hazardous Materials/Chemicals

See Appendix E for Chemical List.

Further information regarding materials or chemicals may be obtained by reviewing the Material Safety Data Sheet (MSDS) as referenced. The MSDSs may be viewed at the Right-To-Know station, located in MSDS binder form on all rigs and at all shops. The Chemical List refers to the MSDS binder where the particular product MSDS is located. Within the binder, an index is provided with the MSDSs in alphabetical order by the issuer (manufacturer and/or distributor) of the product. The HSE Manager or a designee is responsible for maintaining the MSDS listings and updating the list of hazardous materials and chemicals.

Note: Based on recent OSHA interpretations, common household-type chemicals are purchased and used much as a consumer would, are not included in the Hazard Communication Program. These may include, but not be limited to: window cleaner, furniture polish, correction fluid, common household cleaners, etc.

5.3.2 Container Labeling

· The HSE Manager or a designee will verify that all incoming and portable containers, which house hazardous materials, are clearly labeled as to contents and that the contents as acknowledged correspond to the MSDS issued for such contents, and that each such container has the appropriate hazard label affixed.

· The Area Supervisor, which may include a Toolpusher, Shop Foreman, Superintendent or Driller will ensure that all secondary containers (if any) are labeled consistently with the original manufacturer’s label. Each employee is responsible for reporting unlabeled containers to the Area Supervisor.

· The HSE Manager or a designee will review the labeling system every twelve months to insure compliance with this policy and will update labels as required.

5.3.3 Material Safety Data Sheets

· The HSE Manager will be responsible for obtaining and maintaining current Material Safety Data Sheets (MSDSs) as applicable to this facility. Copies of MSDSs will be available at the Right-To-Know station. MSDSs will be available to all employees during each work shift. MSDSs shall not be removed, defaced or altered in any way.

· No new product containing industrial chemicals may be placed in use at this facility until a MSDS is made available to the HSE Manager or a designee for review.

5.3.4 Hazardous Non-Routine Tasks

In the event an employee is assigned a task that is considered non-routine with respect to that employee’s normal duties, and the assigned duty entails a possible exposure to hazardous materials, that employee will be provided appropriate information with respect to the potential exposure prior to initiation of the task. The information to be provided includes, but is not limited to the following:

· Specific hazardous materials associated with the task

· Protective/safety measures expected to be taken.

· Measures the company has implemented to lessen the associated hazard including: ventilation, personal protective equipment, and presence of another employee and emergency procedures.

The Supervisor is responsible for identifying non-routine tasks that may expose an employee to hazardous materials.

5.3.5 Site Contractors

Prior to the commencement of work on the site by outside contractors, such contractors shall be required to attend a safety and hazard communication orientation. Contractors will also present a list of hazardous materials to be used on site and any corresponding MSDS(s). It is the responsibility of the Area Foreman or Toolpusher to document this meeting and to provide contractors the following information:

· A list of hazardous materials to which they may be exposed during the course of their work.

· Precautions the contractor may take to mitigate exposure to hazardous materials.

· Location and availability of MSDSs.

5.3.6 Inspections

The HSE Manager will conduct annual inspections in an effort to assess compliance with the foregoing program as amended. The following items will be addressed:

· Compliance with labeling requirements

· Training administration

· MSDS availability and completeness, including a chemical inventory.

· Status of hazardous materials on site and adequacy of storage of such materials as applicable.

· Use of appropriate personal protective equipment, both for routine and non-routine tasks.

· Records concerning contractor orientations.

Results of the annual inspections will be documented. The inspection forms, quantified results and subsequent communications shall be deemed permanent records of this facility, and as such shall be retained indefinitely.

6.0 EMPLOYEE TRAINING

Employee training is required upon initial assignment where chemicals are used, whenever new chemicals are brought into the workplace, and whenever an employee’s performance indicates re-training is necessary. Refresher training is required annually for Cheyenne Drilling employees. The HSE Manager is responsible for implementation of a training program, which shall include the following:

· An overview of the requirements contained in the Hazard Communication Standard/Right-To-Know laws.

· Hazardous Materials present in the workplace.

· Location and availability of this written program.

· Physical and health effects of the hazardous materials present on site.

· Methods and observation techniques utilized to determine the presence of hazardous materials in the workplace.

· Prevention or mitigation of exposures to hazardous materials through usage of proper work practices and use of personal protective equipment.

· Actions the company has initiated to lessen or prevent exposure to hazardous materials.

· An emergency procedure to follow in the event an exposure occurs.

· Interpretation of hazards labels and MSDSs.

· Location of MSDSs and the hazardous materials listings.

· Inform employees how they may access medical surveillance records in accordance with 29 CFR 1910.1020. This must occur within 15 days of the employee request.

· Attendance documentation.

In the event an employee is transferred between departments, rigs or divisions, the transferring employee will be trained as to the presence of hazardous materials as appropriate.

7.0 RECORDKEEPING

The HSE Manager will:

· Maintain written records of the names of the persons trained, the type of training provided, and the dates of the training. Records shall be maintained for at least three years.

· Maintain the current MSDS binders and an historical file of previously used MSDSs.

· Maintain the chemical list and send to the state the required annual Workplace Chemical List.

· Keep records of any related medical surveillance.

· Document the annual program inspections.