CHEMICAL SAFETY

MANAGEMENT

CHEMICAL SAFETY MANAGEMENT SYSTEM

Purpose: To systematically identify, evaluate, prevent, and control risks arising from hazardous
chemicals throughout the manufacturing, storage, handling, and disposal processes. This
ensures legal compliance, protects worker health, and safeguards the environment, in line with
national and international standards.

Scope: This system applies to all chemicals used or produced at the facility—including solvents,
resins, pigments, additives, cleaning agents, and waste—at every stage: procurement, storage,
handling, processing, distribution, and disposal. It covers employees, contractors, visitors, and
affected external parties.

CHEMICAL SAFETY POLICY

- Zero Harm: Commitment to no injuries, illnesses, or environmental harm from chemical use.
- Legal Compliance: Adherence to Health and Safety in Employment Act 1992, Approved
Code of Practice for Paint Manufacture, and global best-practice
- Continual Improvement: Regular review and upgrade of safety measures, training, and
controls for chemicals.

CHEMICAL INVENTORY & REGISTER

- Maintain a comprehensive Chemical Register (name, supplier, CAS number, hazardous
nature, storage location, quantities, expiry, and SDS).
- All chemicals must be approved prior to procurement and recorded in the register.
- Review and update: Semi-annually, and immediately when new chemicals are introduced.

HAZARD COMMUNICATION
Purpose: To ensure that all employees, contractors, and visitors at the Nippon Paint
Manufacturing Facility are fully informed and trained regarding the hazardous chemicals and
associated risks present in the workplace. Effective hazard communication supports the
prevention of occupational incidents, illnesses, and environmental harm by facilitating clear
identification, understanding, and control of chemical hazards.

All chemical substances stored, handled, or used at all locations within the facility, including
production lines, storage areas, laboratories, maintenance zones, and waste disposal points.

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CHEMICAL IDENTIFICATION AND CLASSIFICATION

Chemical Inventory and Listing

Maintain an up-to-date inventory of all hazardous chemical substances on site, identifying them
by:

- Chemical name (common and IUPAC)

- CAS number
- Supplier/manufacturer information
- Hazard classification according to GHS categories, including physical, health, and
environmental hazards

Classification System: Classify hazardous chemicals uniformly following GHS principles to

ensure consistent hazard communication throughout the facility.

LABELING OF CHEMICALS

Label Requirements

All containers (bulk, intermediate, and final use) must bear a legible and durable label indicating:

- Chemical identity
- Appropriate hazard pictograms according to GHS
- Signal words: “Danger” or “Warning” based on hazard severity
- Hazard statements describing the nature and degree of hazard
- Precautionary statements including safe handling, storage, and emergency measures
- Suppliers contact information
- Temporary or transferred containers must be labeled immediately upon filling

SAFETY DATA SHEETS (SDS)

SDS Content and Format

Maintain current Safety Data Sheets for every hazardous chemical, conforming to ISO 11014-1
and OSHA requirements, covering:

1. Identification

2. Hazard(s) identification

3. Composition/information on ingredients
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4. First-aid measures

5. Fire-fighting measures

6. Accidental release measures

7. Handling and storage

8. Exposure controls/personal protection

9. Physical and chemical properties

10. Stability and reactivity

11. Toxicological information

12. Ecological information

13. Disposal considerations

14. Transport information

15. Regulatory information

16. Other information

Accessibility

- SDSs must be readily accessible in all chemical use and storage areas, both in printed and
electronic forms
- Employees must be informed of SDS availability and trained in their interpretation

HAZARD COMMUNICATION

Information Dissemination

- Provide clear, concise hazard information through multiple channels: labels, SDS, posted
notices, and digital databases
- Maintain signage at chemical storage and use areas identifying key hazards and emergency
contacts

SAFE HANDLING PROCEDURES

Standard Operating Procedures (SOPs)

- Develop and maintain SOPs that incorporate hazard communication elements around
chemical acquisition, storage, handling, use, and disposal
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- SOPs must explicitly reference hazard information and necessary precautions as per SDS
and labels

Monitoring and Review

Program Monitoring

Periodic audits of label integrity, SDS availability, employee knowledge, and compliance with
hazard communication standards

Review all training records and feedback for program effectiveness

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CHEMICAL RISK ASSESSMENT

To identify, evaluate, and control risks associated with the use, handling, storage, processing,
and disposal of chemicals at the facility. Chemical risk assessment aims to prevent occupational
illnesses, accidents, and environmental harm by systematically analyzing hazards and applying
appropriate controls.

Scope: Applies to all chemicals (solvents, pigments, resins, additives, intermediates,

cleaning agents, waste) managed within the facility. It covers all activities from procurement,
storage, handling, use, to disposal, affecting employees, contractors, visitors, and the
environment.

CHEMICAL RISK ASSESSMENT PROCESS

Identification of Chemicals and Hazards

- Compile a comprehensive list of all chemicals present, using chemical inventory and
registers.
- Obtain hazard information from SDS/MSDS, labels, and supplier documentation.
- Classify chemicals by physical, health, and environmental hazards following GHS. Common
paint-related hazards include:
a) Flammable solvents (e.g., toluene, xylene)
b) Toxic heavy metals (e.g., lead chromate, cadmium pigments)
c) Respiratory sensitizers (isocyanates)
d) Corrosive substances (acids, alkalis)
e) Reactive or oxidizing agents (organic peroxides)

Exposure Assessment

- Identify routes of exposure: inhalation, skin absorption, ingestion, eye contact.

- Evaluate frequency, duration (e.g., continuous, intermittent), and levels of exposure using
monitoring data (air sampling, biological monitoring).
- Compare exposure levels with applicable limits such as Workplace Exposure Standards,
Occupational Exposure Limits (OELs), or Biological Exposure Indices (BEIs).

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Risk Characterization

Rate the risks by combining hazard severity and exposure likelihood:

Risk Level Characteristics Example Controls Needed

Immediate control via elimination or

Severe hazard + high
High engineering controls, full PPE, health
exposure potential
surveillance

Moderate hazard or Engineering and administrative controls,

Medium
exposure routine PPE

Low hazard and limited

Low Periodic review and PPE
exposure

Utilize simple matrix risk evaluations to prioritize action, considering chemical hazards,
quantities, and operational factors.

Risk Control Hierarchy

Apply controls in order of effectiveness:

1) Elimination: Remove hazardous chemical if possible.

2) Substitution: Replace with less hazardous chemicals or processes.
3) Engineering Controls: Isolate hazards via ventilation (local exhaust, spray booths),
enclosed systems, or process automation.
4) Administrative Controls: Work practices, scheduling, training, signage, and SOPs.
5) Personal Protective Equipment (PPE): Use only as a last line of defense.

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STORAGE & HANDLING

Purpose: To establish standardized procedures and controls for the safe storage and handling
of chemicals, raw materials, intermediates, and finished products used or produced at the facility.
This ensures prevention of chemical incidents, protects worker health, prevents environmental
contamination, and maintains regulatory compliance.

Scope: Applies to all substances at Nippon Paint Manufacturing Facility including solvents,
pigments, resins, additives, finished paint products, and waste chemicals throughout their onsite
lifecycle—from receipt, transfer, storage, use, packaging, transport, to disposal.

STORAGE REQUIREMENTS

General Principles

- Store chemicals according to their hazard classification with segregation of incompatible

substances
- Ensure all stored chemicals are clearly labelled with identity, hazard warning, and
precautions.
- Maintain Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) accessible near
storage locations.
- Stock rotation ("first in, first out") to prevent expiry and degradation.
- Secure storage areas to prevent unauthorized access.
- Avoid storage near ignition sources, heat, direct sunlight, or moisture unless required and
controlled.

Flammable and Combustible Liquids

- Store flammables in accordance with regulations, ensuring use of approved flameproof

cabinets or dedicated storage rooms with suitable ventilation and fire suppression.
- Maintain safe separation distances between storage of flammable liquids and ignition sources
or other hazardous materials.
- Use grounded and bonded containers during storage and transfer to mitigate static electricity
risks
- Storage quantities should not exceed daily operational needs except in approved bulk
storage areas.

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Solids, Pigments, and Powders

- Store pigment powders in covered, dry areas with dust containment measures.
- Use sealed containers or bags with clear labelling.
- Dry powders should be segregated to prevent cross-contamination and limit dust generation.
- Maintain dust control systems (vacuum and wet cleaning) and limit manual handling where
possible.

Corrosive and Reactive Chemicals

- Use corrosion-resistant shelving and containers.

- Segregate reactive substances to prevent accidental mixing.
- Ensure safety signage and appropriate spill containment measures are in place.
- Store caustic and acidic substances separately with clear labelling.

Bulk Storage Tanks

- Design and maintain bulk tanks per relevant engineering standards with secondary
containment (bunding) capable of containing at least 110% of the tank volume.
- Equip tanks with pressure and temperature controls, level indicators, and emergency vents.
- Conduct routine inspections and maintenance of tanks including leak detection.

Waste and Hazardous Waste Storage

- Store hazardous wastes separately in clearly marked, secure areas until collection or
disposal.
- Follow regulatory requirements for hazardous waste storage times and containment integrity.
- Maintain waste records including quantity, type, storage date, and final disposal.

Housekeeping in Storage Areas

- Keep storage areas clean, dry, and well-lit.

- Remove spills immediately using appropriate PPE and spill kits.
- Maintain clear access and egress routes free of obstructions and trip hazards.
- Control pests and prevent contamination through good maintenance.

HANDLING PROCEDURES

Receiving and Unloading

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- Verify deliveries against purchase orders and ensure all chemicals are accompanied by
SDS.
- Check container integrity and labels before acceptance.
- Use appropriate equipment (forklifts, drum handling tools) to minimize manual lifting.
- Implement spill prevention and containment during unloading.

Transfer and Decanting

- Use closed systems or mechanical pumps for transfer wherever feasible.

- Ground and bond containers to prevent static discharge during transfer
- Avoid manual pouring from drums; if unavoidable, use funneling and spill trays to reduce
exposure and spills.
- Use appropriate PPE during transfer operations.

Manual Handling and Ergonomics

- Train personnel in safe manual handling techniques to prevent injury and exposure.
- Use mechanical aids or teamwork for moving heavy loads.
- Limit manual handling of powders and chemicals prone to spillage or dust.

Packaging and Labelling

- Ensure all outgoing materials are correctly packaged to prevent leaks and contamination.
- Labels must comply with GHS standards including hazard pictograms and precautionary
statements.
- Maintain traceability records for all packaged materials.

Inspection, Maintenance, and Monitoring

- Conduct regular inspections of storage areas, tanks, containers, and handling equipment to
identify leaks, corrosion, damage, and compliance with safety requirements.
- Maintain inspection logs and corrective action records.
- Monitor environmental conditions (temperature, humidity) to prevent degradation or
hazardous reactions.
- Perform functional tests of grounding and bonding systems.

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Appendices & Sample Forms

Appendix A: Chemical Assessment Record (Sample)

Chemical Hazard PPE Needed Storage Risk Control SDS

Category Measures Present

Toluene T/F Gloves Flammable High LEV, Bond/Earth Yes

cabinet

Lead T Respirator, Secure, High Only if essential, Yes

Chromate Gloves locked strict PPE

Appendix B: Emergency Contact List

Role Name/Contact

HSE Manager ...

Poison Centre ...

Fire Service ...

Appendix C: Training Record Template

Employee Date Trained Topics Trainer Next Review

Monitoring and Review

Program Monitoring

- Periodic audits of label integrity, SDS availability, employee knowledge, and compliance with
hazard communication standards
- Review all training records and feedback for program effectiveness
- Conduct regular workplace air monitoring and health surveillance for high-risk substances
(e.g., lead, isocyanates).

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- Review risk assessments at least annually or whenever new chemicals/processes are

introduced, or incidents occur.
- Update controls and training based on surveillance results and technological or regulatory
changes.

Monitoring and Performance (dust control)

- Conduct periodic airborne dust monitoring at worker breathing zones using gravimetric or
real-time dust monitors to verify exposure is below the relevant OEL/WES (e.g., total
inhalable dust <10 mg/m³; respirable dust <3 mg/m³).
- Maintain maintenance logs and inspection records for dust control equipment and corrective
actions.
- Review control system performance annually or after process changes or dust-related
incidents.
-

Documentation and Communication

- Document all risk assessment findings, control measures, and assigned responsibilities in
risk registers.
- Ensure availability and accessibility of SDS for all chemicals.
- Communicate risk information via training, signage, labels, and SOPs to employees and
contractors regularly

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7.7 Technical HSE Data Reference T

Common Exposure Limits
Chemical/Group Key Control Measures Notes
Hazards (WES/OEL)

CNS effects,
WES: 100 ppm LEV, bonding & earthing, Defatting effect
Toluene flammable
(375 mg/m3) PPE, monitoring on skin
vapor

Enclosed handling, PPE

Toxic, OEL: 0.05 Strict hygiene
Lead Chromate (respirators, gloves),
carcinogen mg/m3 (Pb) controls needed
health monitoring

Respiratory Total enclosure, full-face Medical

Isocyanates (TDI,
sensitizer, OEL: 0.005 ppm air supply respirators, surveillance
MDI)
irritant monitoring essential

Flammable,
Follow NFPA 704 Minimal storage, PPE, spill Avoid
Organic Peroxides reactive,
and local regs containment contamination
oxidizer

Flammability, Use composite Ventilation, PPE, spill Use MSDS

Solvent mixtures
toxicity OELs control guidance

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 .

Appendix 7A: Sample Chemical Risk Assessment Table

Chemical Hazard Exposure Exposure Risk Control Measures Comments
Classification Route Frequency Rating

Xylene Flammable, Inhalation, Daily, 8 hrs Medium LEV, PPE (gloves, Monitor
CNS skin respirators), exposure
depressant restricted levels
storage

Lead Toxic, Inhalation Intermittent High Enclosure, Ban

Chromate carcinogen medical eating/smoking
surveillance, rules
hygiene protocol

Isocyanate Sensitizer, Inhalation Limited High Respiratory PPE, Use permits,

s (TDI) respiratory air monitoring, training
hazard health checks needed

Organic Reactive, fire Contact Low Medium PPE, minimized Follow disposal
Peroxides hazard quantity, proper regulations
storage

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SUMMARY TABLE: CONTROL MEASURES AND ASSOCIATED STANDARDS

Control Area Description Standards/Codes Referenced

Ventilation LEV & dilution ventilation, AS 1668, NZS 5807, OSHA, NFPA 33
spray booths

Explosion & Static Electrical classification, NFPA 70, AS 1020, Myanmar Dangerous
grounding Goods Regulations

Spill Containment Bunds, secondary Local environmental laws, NFPA 30, ISO
containment 14001

Equipment Safety Guards, LOTO, maintenance OSHA 29 CFR 1910, Myanmar Factories Act

SOPs and Permits Work permits, procedures Nippon HSE Procedures, BHEL HSEP 12,
OSHA

Training & Induction, refresher trainings ISO 45001, Myanmar OSHA Standards
Competency

PPE Selection, use, maintenance ISO 45001, NZS 5812, Nippon PPE
Standards

Emergency Spill kits, fire extinguishers, NFPA 10, OSHA, Local fire codes
Response drills

Housekeeping &Clean work areas, restrictedNippon HSE policy, Myanmar OSHA

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Access access

11.7 Roles and Responsibilities

Role Responsibilities

Emergency Activate emergency response, coordinate responders, notify authorities,

Coordinator oversee incident management.

HSE Manager Maintain emergency procedures, organize training/drills, ensure

availability of resources.

Supervisors/ Ensure personnel compliance with evacuation, conduct headcounts,

Managers support coordination with emergency teams.

Employees and Follow emergency instructions, participate in drills, use emergency

Contractors equipment properly, report incidents promptly.

Visitors Comply with site emergency procedures, evacuate when instructed,

follow escort instructions.

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12.6 Roles and Responsibilities

Role Responsibilities

Management Ensure resources and systems for environmental monitoring and health
surveillance. Approve policies and review outcomes.

HSE Manager Develop monitoring programs, coordinate with occupational health

providers, maintain records, ensure corrective actions.

Occupational Health Conduct medical examinations, biological monitoring, maintain

Professionals confidential records, advise on fitness and risk.

Supervisors Facilitate access for workers to participate, enforce exposure controls,

report abnormal health incidents.

Employees Participate in health surveillance, report symptoms or exposures,

adhere to controls and PPE usage.

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Appendix 12A: Typical Workplace Exposure Standards (Indicative Examples)

Substance WES (Time-Weighted Route of Notes

Average) Exposure

Toluene 100 ppm (375 mg/m³) Inhalation, Skin CNS effects, defatting
skin

Xylene 100 ppm (434 mg/m³) Inhalation, Skin CNS effects

Methyl Ethyl 200 ppm (590 mg/m³) Inhalation, Skin Irritant

Ketone

Lead Compounds 0.05 mg/m³ (as Pb) Inhalation Carcinogen, neurotoxic

Isocyanates (TDI, 0.005 ppm Inhalation, Skin Respiratory sensitizers

MDI)

Respirable Dust 3 mg/m³ Inhalation Dust-related respiratory

risk

Implementation Guidance:
 Tailor monitoring and health surveillance programs based on your specific chemical inventory, process hazards, and workforce.
 Engage certified occupational hygienists and medical professionals experienced in industrial chemical hazards.

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 Use data-driven approaches to improve workplace safety continuously.

14.8 Roles and Responsibilities

Role Responsibilities

Manageme Ensure adequate resources for investigation and correction; review incident reports
nt and ensure closure of CAPA.

HSE Oversee incident reporting system, lead investigations, coordinate CAPA, and
Manager maintain records.

Supervisors Report incidents promptly, preserve scene, participate in investigations, and

enforce corrective actions in their areas.

Employees Immediately report all incidents and hazards; cooperate in investigations; follow
corrective measures.

Contractors Comply with incident reporting and investigation procedures; ensure subordinates
cooperate fully.

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