Hazards Communications

Policy Key Points

• Program Availability and Review: Available to all employees across every work shift; reviewed annually and revised based on operational or regulatory changes.
• Management Support and Communication: Communicated across the entire organization regardless of shift or headcount to establish clear hazard control objectives.
• Labeling & Safety Data Sheets (SDS): Proper Globally Harmonized System (GHS) container labeling is mandatory. Electronic SDS binders are accessible 24/7 online and via dedicated cafeteria touchscreen kiosks.
• Employee Information and Training: Mandatory training at initial assignment, periodic refreshers, and whenever new chemical hazards are introduced. Covers chemical hazards, PPE, secondary container labeling, and emergency spill response.
• Field Service & Contractors: Field associates use host-facility SDS databases or contact EHS directly. Contractors must provide SDSs and ensure all chemical containers are GHS-labeled prior to entering Yaskawa property.
• Pictograms & Hazard Classification: Standard GHS pictograms are utilized to rapidly identify Health, Physical, and Environmental hazard classifications.
• Chemical Approval Process: Prior EHS review and approval is strictly required before purchasing or bringing any new chemical into a Yaskawa facility.

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Policy

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 the 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 of Safety Data Sheets (SDS).
• Describe how employee information and training requirements will be met, including:
  • Generating a list of hazardous chemicals known to be present in each department (Access Electronic SDS Binder | Username: Yaskawa / Password: Yaskawa). Dedicated kiosks are located in cafeterias for associates without computer access.
  • Detailing methods used to inform employees of the hazards of non-routine tasks (overseen by immediate supervisors).
  • Identifying precautionary measures required to protect employees during normal operations and 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 hazard is introduced.

Information

All associates shall be informed of:

• Any operations in their work area where hazardous chemicals are present.
• The location and availability of the written HAZCOM program, chemical lists, and SDSs (available via 3E Online / VelocityEHS and cafeteria kiosks).

Training

Employee hazard communication training shall be conducted prior to initial chemical exposure. New associates receive general HAZCOM training during orientation via LMS e-learning modules, while direct supervisors conduct work-area-specific hazard training.

Training emphasizes the following core elements:

• Summary of the Hazard Communication Standard and this written program.
• Physical and health hazards associated with potential chemical exposures.
• Protective procedures, including PPE selection, safe handling, and emergency response.
• Primary and secondary container labeling requirements.
• Hazardous chemical spill and leak protocols.
• How to locate, interpret, and apply information found on Safety Data Sheets.

Responsibilities

EHS Department: Administers the written program, develops/delivers general HAZCOM training, procures/reviews SDSs for new chemical requests, and maintains the 3E Online database.

Supervisors & Management: Ensure assigned associates complete required HAZCOM training and provide work-area-specific chemical hazard instruction.

All Associates: Successfully complete training, use chemicals strictly for intended purposes with required PPE, and notify EHS (EHS@Yaskawa.com / 262-391-1697) prior to bringing new chemicals on-site or when labels become damaged.

Safety Data Sheets (SDS)

Safety Data Sheets are maintained for every chemical on the master chemical inventory via the 3E Online electronic binder (Username: Yaskawa / Password: Yaskawa).

Pre-Purchase Approval Process: Any associate requesting a new chemical must submit the chemical and manufacturer name to EHS. EHS evaluates the SDS. If approved, the SDS is uploaded to 3E Online and the requester is authorized to proceed. If unacceptable hazards are identified, the chemical is rejected and a less hazardous alternative must be selected.

Archival Mandate: Safety Data Sheets for discontinued or abandoned chemicals must be retained for a minimum of 30 years after removal from all Yaskawa facilities.

GHS Pictograms & Hazard Classifications

Chemicals are classified under the Globally Harmonized System (GHS) covering Health, Physical, and Environmental hazards:

Health Hazards

Physical & Environmental Hazards

Container Labels & Secondary Labeling

Field Service Operations

Yaskawa associates working at customer worksites must review the host employer's chemical inventory and SDSs prior to work. If the host lacks documentation, contact EHS (414-856-2452) to obtain the necessary SDS. If mandatory PPE is unavailable, the job must be rescheduled.

Contractor Requirements

Contractors bringing hazardous chemicals on-site must submit SDSs to EHS@Yaskawa.com in advance and ensure all containers are GHS-labeled. Contractors are oriented on site chemical hazards and cafeteria kiosk access.

Records Retention Schedule

General HAZCOM training logs are maintained in the LMS. Chemical exposure records are maintained confidentially by Human Resources for the duration of employment + 30 years.

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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 anonymous reporting method	5/11/2019	Thurwanger
3	Added Hazardous Chemicals Encountered 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	—
2/17/2026	Thurwanger	No	—