Safety Policies & Programs

Written Program

This policy is Yaskawa America, Inc.’s written program and will be maintained in accordance with 29 CFR 1910.1200 and updated as required. Where no update is required this document shall be reviewed annually.

Effective implementation of this program requires support from all levels of management within this company. This program shall be communicated to all personnel that are affected by it. It encompasses the total workplace, regardless of number of workers employed or the number of work shifts. It is designed to establish clear goals, and objectives.

This written hazard communication program is available to all employees, during each work shift.

Yaskawa America, Inc. shall:

Annually review and revise this written hazard communication program based on company operational requirements or, as required by the OSHA Hazard Communication Standard.

Provide a program for proper labeling of containers, describe other needed forms of warning, and detail the use and purpose safety data sheets (SDS).

Describe how employee information and training requirements will be met, to include the following:

• Generate a list of the hazardous chemicals known to be present in each department using an identity that is referenced from the appropriate material safety data sheet.
  • This list is maintained and accessible here
  • User Name Yaskawa, Password is Yaskawa
  • Kiosks are located in the cafeterias of Yaskawa sites where there are associates who do not have other access to computers.
• Detail the method Yaskawa will use to inform employees of the hazards of non-routine tasks. Immediate supervisors of affected employees will oversee this requirement.
• Identify the methods Yaskawa will use to inform employee(s) of any precautionary measures that need to be taken to protect employees during normal operating conditions and in foreseeable emergencies.

Training Program

Yaskawa America, Inc. provides employees with information and training on hazardous chemicals in their work area at the time of their initial assignment, periodic refresher, and whenever a new chemical is introduced into their work area that could present a potential hazard.

Information

All associates shall be informed of:

• Any operations in their work area where hazardous chemicals are present, and
• The location and availability of the written hazard communication program, including a list(s) of hazardous chemicals used in their department, and the associated safety data sheet (SDS’s).
• SDS’s and chemical lists are maintained and accessible from https://www.3eonline.com/eeeonlineportal/DesktopDefault.aspx. User Name Yaskawa, Password is Yaskawa
• Kiosks are located in the cafeterias of Yaskawa sites where there are associates who do not have computers.

Training

Employee hazard communication training shall be conducted prior to the employee being exposed to chemical hazards.

During new associate orientation, new employees will receive training on the contents of this program and specific training on the chemical hazards that the individuals will be directly working with.

General hazard communication training is provided through an e-learning module accessible through Yaskawa’s learning management system. The e-learning module provides instruction for asking questions directly to an approved HAZCOM instructor.

Work area specific training shall be conducted by the new employee’s direct supervisor.

Additional training will be provided for employees whenever:

• A new chemical hazard is introduced into their work area, or
• Changes occur to Yaskawa’s Hazard Communication Policy,

The Hazard Communication training emphasizes the following elements:

• A summary of the Hazard Communication Standard and this written program,
• Physical and health hazards associated with potential exposure to hazardous chemicals,
• Procedures to protect against hazards, such as personal protective equipment, work practices and emergency procedures,
• Chemical container and secondary container labeling requirements,
• Hazardous chemical spill and leak procedures, and
• The location of Safety Data Sheets, how to understand their content, and how to obtain and use appropriate hazard information.

Responsibilities

EHS is responsible for:

• Administration of this policy/written program,
• Developing and delivering general HAZCOM training to new Yaskawa associates,
• Procuring safety data sheets for new hazardous chemicals brought into a Yaskawa facility, and
• Determining the method by which SDS’s are maintained, and training associates on said method.

Yaskawa Supervisors and above are responsible for:

• Ensuring assigned associates complete required HAZCOM training,
• Providing work area specific training pertaining to the specific hazards the associate may encounter while performing his/her work.

All Associates are responsible for:

• Successfully completing HAZCOM training and asking any questions necessary to fully grasp the training,
• Use hazardous chemicals only for their intended purpose, following all manufacturer recommendations including use of appropriate PPE,
• Notifying EHS at EHS@Yaskawa.com or 262-391-1697 of:
  • Any new chemicals prior to the chemical being brought into a Yaskawa facility,
  • Chemical container labels that are becoming illegible or go missing,
  • Any questions related to this policy/written program or proper use of hazardous chemicals.

Safety Data Sheets

Safety Data Sheets are maintained for every substance on the list of hazardous chemicals. These SDS’s are located on the 3E Online system available at this site.

• User Name is Yaskawa
• Password is Yaskawa

Any Yaskawa associate who wants to bring a hazardous chemical into a Yaskawa facility, either through purchase order or other means, shall first notify Yaskawa EHS and provide them with the chemical and manufacturer name. Yaskawa EHS will locate and review the Safety Data Sheet.

If the chemical is approved for Yaskawa use, the SDS will be loaded into the 3E Online system and the requester notified when they are allowed to bring in the chemical.

If the chemical presents hazards that are unacceptable for Yaskawa facilities, the requester will be notified that they cannot bring the hazardous chemical into any Yaskawa facility. The requester will be asked to find a less hazardous substance and restart the process.

Safety Data Sheets shall be maintained for all chemicals abandoned for use for a minimum of 30 years after the chemical is no longer in any Yaskawa facility.

Pictograms

Chemicals are classified using a Globally Harmonized System (GHS) that provides standard language for:

• Health Hazards
• Physical Hazards
• Environmental Hazards

Safety Data Sheets and Chemical Container Labels use pictograms to allow users to quickly identify the potential hazard classifications.

Health Hazards

Physical Hazards

Environmental Hazards

The Safety Brief below provides more detail about the meaning of each of these pictograms.

Container Labels

Field Service

Yaskawa associates working at non-Yaskawa facilities shall identify potential hazards using the host company’s list of hazardous chemicals and associated SDS’s.

If the customer does not have a hazardous chemical list, nor SDS’s, the field associate should contact Yaskawa EHS by calling 414-856-2452. EHS will locate an SDS and email it to the Yaskawa associate.

The Yaskawa associate in the field shall ensure that appropriate protective measures, including personal protective equipment, are available and utilized.

If appropriate PPE is not available, the job shall be rescheduled to a time when appropriate PPE is available.

Contractors

Each contractor bringing chemicals on-site must send the appropriate hazard information, including SDS’s, to EHS@Yaskawa.com prior to brining the chemical into a facility.

All containers of hazardous chemicals brought on-site by an outside contractor must be appropriately labeled in the GHS format.

Outside contractors and contract employees will be advised of any chemical hazards that may be encountered in the normal course of their work in the Yaskawa facility.

Outside contractors and contract employees will be notified of the location of HAZCOM kiosks and have an opportunity to complete instruction on using the 3E Online SDS system.

Records and Forms

Hazardous Chemical list and Safety Data Sheets are located on an electronic system located at www.YaskawaSafety.com.
User Name: Yaskawa Password: Yaskawa
General HAZCOM training records are located in Yaskawa’s learning management system (LMS)
Chemical exposure records are maintained by Human Resources for the employment life of the exposed associate plus 30 years.

Training

General HAZCOM training is required for all new associates and whenever a change to this policy/written program occurs.
Work area specific hazard training is provided by the associate’s immediate supervisor prior to the associate becoming exposed to the hazard.

Revision History

Rev #	Description	Release Date	Approved by
0	Initial release of electronic policy	6/10/2016	Thurwanger
1	Updated link to Safety Data Sheets	2/12/2018	Thurwanger
2	Added method for anomyous reporting method	5/11/2019	Thurwanger
3	Added Hazardous Chemicals Encounterd while in the field in Field Service section	3/23/2022	Thurwanger
4	Added link to SDS safety brief	8/6/2024	Thurwanger

Program Review

Review Date	Reviewed by	Changes Required (Yes/No)	Revision # if updated
2/15/2017	Thurwanger	No
1/10/2018	Thurwanger	Yes	1
1/17/2019	Thurwanger	Yes	2
1/9/2020	Thurwanger	No
1/19/2021	Thurwanger	No
1/13/2022	Thurwanger	Yes	3
1/26/2023	Thurwanger	No
1/11/2024	Thurwanger	No
1/16/2025	Thurwanger	No