NU-SAF-101 — HAZARD COMMUNICATION & SDS
Tier 2/3 — Procedure + Field Card + Tier-4 Form · Rev DRAFT (v1.0) · Drafted August 1, 2026 · Owner: Field Supervisor [Adam: confirm owner]
Parent: NU-SAF-100 (Safety & Health Program), §5 element 2.
Standard: 29 CFR 1910.1200 (Hazard Communication), applied to construction through 29 CFR 1926.59, which adopts it by reference.
THE GATE
If a chemical isn't on the inventory (NU-SAF-101-F) with its SDS in the truck binder, it doesn't get loaded or used — and anything new that gets bought goes on the list with its SDS the same day, before first use. And no chemical ever rides in an unlabeled container — a drink bottle with anything but a drink in it is a stop-work.
The record for this gate is the chemical inventory itself plus the SDS binder on each truck: the crew verifies the binder during the Friday deep-clean safety-kit step (NU-FLT-301, step 5 — the same step that already checks first aid, extinguisher, and eye wash per NU-SAF-100 §9), and the Supervisor scores it on the Friday truck audit scorecard (NU-PPL-403 Part 3). A gate that produces no record is a suggestion.
1. WHY THIS PAGE EXISTS
Nova's crews handle chemicals all day without thinking of them as chemicals: a man cuts a bentonite bag over the mixing tank and stands in the dust, tops off a rig from a fuel can, checks a hydraulic line, cleans a fitting with degreaser, shakes a can of marking paint. None of that is exotic. All of it is covered by the most-cited health standard in the industry.
The compliance picture, stated accurately:
- HazCom is the single most commonly cited gap on small utility contractors. It is routinely at or near the top of OSHA's most-frequently-cited list across all industries, and the citation is almost never about a spill — it is about the paperwork that doesn't exist: no written program, no inventory, no SDS on site, unlabeled containers.
- The standard requires four things, and this document is all four: a written program (§2), a chemical inventory (§3, per 1910.1200(e)(1)(i)), SDS access for every man on every shift (§4, per 1910.1200(g)), and labels plus training (§5 and §7, per 1910.1200(f) and (h)).
- Every serious prequal — Congruex Unify, ISNetworld, Avetta — asks for the written HazCom program by name. This page is the answer.
And the real reason, beyond the citation: the man mixing drilling fluid breathes that dust every morning of his working life. §6 is the part of this document that is actually about his lungs.
2. THE WRITTEN PROGRAM (this document is it)
1910.1200(e) requires a written hazard communication program. This document, plus the inventory in §11, plus the SDS binders in §4, is Nova's written program. There is no second binder of policy language somewhere else.
What the program commits to:
- Every hazardous chemical Nova uses is on one inventory (§3).
- Every chemical on the inventory has a current SDS a crew can reach during the shift (§4).
- Every container is labeled — shipped containers keep the manufacturer's label, secondary containers get Nova's (§5).
- Every man is trained at hire and before any new chemical hazard shows up (§7).
- Multi-employer sites (1910.1200(e)(2)): when Nova works a site with a GC or other subs — which is most sites — the Crew Lead can produce Nova's SDS binder on request, and if another contractor's chemical use puts dust, fumes, or product where Nova's men work, the Crew Lead asks for their SDS the same way. It goes both directions. When Nova's chemical use can reach another contractor's crew, the Crew Lead also tells them the precaution (bentonite dust drift at mixing — §6; fuel and solvents on the truck — §5) and how Nova labels: manufacturer GHS labels stay on shipped containers, secondary containers carry a stenciled or paint-pen name-plus-hazard per §5.2.
- Non-routine tasks (a chemical job the crew doesn't do weekly — say, a solvent flush of a mud system) get covered in the JSA before the task starts, same as any other hazard.
3. THE CHEMICAL INVENTORY — ONE LIST, ONE OWNER
The inventory is the Tier-4 form in §11 (NU-SAF-101-F). The rules that keep it honest:
- One list for the whole company. Not one per truck, not one per crew. The trucks carry copies; the Supervisor owns the master.
[Adam: confirm the Field Supervisor owns the inventory — NU-SAF-100 §3 already makes him the day-to-day safety authority, so this document proposes him.] - The list updates when a chemical shows up, not at an annual cleanup. New product on a truck = on the list + SDS in the binder before first use. That is the gate.
- Parts-store purchases count. The fastest way this program fails is a man grabbing a can of brake cleaner at the parts counter and throwing it in the truck box. If it's a chemical and it rides a Nova truck, it's on the list. No hidden chemicals.
- Softr is the destination. Until the app is live, the master inventory is this document's §11 table; when Softr lands, the inventory becomes a table there — one row per product, SDS attached to the row — and this section just points to it.
4. SDS ACCESS — THE BINDER AND THE PHONE
1910.1200(g)(8) requires SDSs to be readily accessible to employees during each work shift, in their work area. For Nova, the work area is a road shoulder or an easement, sometimes with no signal. So access is two layers, and the paper layer is the one that never fails:
- One physical SDS binder per truck. Every chemical on the inventory, one SDS per tab, in inventory order.
[Adam: confirm the binder location — this document proposes the behind-the-seat safety-kit zone (NU-FLT-301: first-aid kit, spill kit, extinguisher — strapped or bracketed, checked stocked every Friday), same place on all 7 trucks, so any man on any crew finds it without asking and the binder rides the same Friday check the gate relies on.] - Digital copy of the full SDS set in the shared folder every crew phone can reach (Softr when live). Digital is the convenient copy; paper is the compliant copy when the site has no bars.
How a man actually uses an SDS in the field — three sections, in this order:
| SDS section | What it tells you | When you need it |
|---|---|---|
| Section 4 — First aid | Eyes, skin, swallowed, breathed | The only section that matters in the first five minutes |
| Section 2 — Hazards | What the product can do to you | Reading a new product before first use |
| Section 8 — Protection | Gloves, glasses, ventilation, respirator | Setting up the task |
Chemical in the eyes: eye wash is already on every truck (NU-SAF-100 §9) — flush first, read the SDS second, and anything beyond a rinse-and-fine is an incident under NU-SAF-121.
5. LABELS — THE RULE THAT GETS CITED
5.1 Shipped containers
The manufacturer's GHS label stays on, stays readable. A label soaked in oil until it's gone means the container gets re-labeled or it comes off the truck — the Supervisor decides disposal per the SDS (Section 13). Nobody guesses what's in a can.
5.2 Secondary containers — where Nova actually lives
1910.1200(f)(6): a container you fill from a bigger one needs a label with the product name and the hazard — words, a picture, or both. The standard has an exception for a portable container used immediately by the man who filled it (1910.1200(f)(8)), but Nova doesn't lean on it, because Nova's containers don't get used immediately — they ride the truck for weeks. So the Nova rule is simpler:
Every container is labeled. Always.
| Container | The label |
|---|---|
| Fuel cans | "GASOLINE — FLAMMABLE" or "DIESEL" — big, on the can, not the cap (caps get swapped). Nova's approved-safety-can color code (red = gasoline, yellow = diesel) plus the §7 training is the symbol system conveying general hazard information under 1910.1200(f)(6). This is also equipment protection: gasoline in a diesel machine is a dead machine. Cans are approved safety cans per 1926.152(a)(1), and every can gets its own tiedown in transit (NU-FLT-310). |
| Two-cycle mix | "2-CYCLE MIX — FLAMMABLE" — it looks exactly like straight gas until a four-stroke dies on it, and straight gas looks exactly like it until a saw seizes. |
| Mixed drilling fluid / additives in the tank or a bucket | Tank and transfer buckets marked "DRILLING FLUID" — plain, painted or stenciled once, done. Name-only is deliberate here: the trained hazard is the dust at mixing (§6), not the wet fluid in the tank. |
| Sprayers and squeeze bottles (degreaser, solvent) | Product name plus the hazard word written on the bottle in paint pen the day it's filled — "BRAKE CLEANER — FLAMMABLE". |
| Marking paint, pipe lube, oils, grease | Stay in manufacturer packaging — the label is already there. Keep it readable. |
5.3 The never-container
No chemical ever goes in a food or drink container. Not "just for today," not "it's only pipe lube." A water bottle of degreaser on a 95°F day next to twelve real water bottles is how a man ends up in an ER, and it is the single fastest HazCom citation an inspector can write. This is a stop-work for anyone who sees it, per NU-SAF-100 §4. The stop-work gets logged on the DFR per NU-SAF-100 §4, and the points land per NU-PPL-403 once §13.5 is assigned.
6. BENTONITE DUST — THE ONE THE CREW ACTUALLY BREATHES
Most of the inventory touches skin or sits in a can. Bentonite gets inhaled, every mixing cycle, by whoever runs the mud. That makes it the one chemical on the list with a daily exposure worth engineering around.
What it is: the dust cloud when a bag is cut and dumped. Bentonite itself is a clay, but the SDS for most bentonite products lists respirable crystalline silica (quartz) as a component — the same substance the silica standard (29 CFR 1926.1153) exists for. Read the SDS for the product actually on Nova's trucks: [Adam: fill — bentonite brand/supplier, so the right SDS is in the binder and §11.]
The mixing drill — costs nothing, cuts most of the dust:
- Stand upwind. Check which way the dust drifts on the first bag; move if it drifts at you.
- Cut the bag low, next to the water. Shoulder-height dumping makes a cloud; opening the bag at the tank lip and sliding the product in makes far less.
- Pour slow. The cloud is a speed problem.
- Use the hopper if the rig has one — a venturi/hopper feed pulls the dust down into the fluid instead of up into a face.
- Empty bags get wetted or bagged, not slapped and stacked. A dry empty bag is a dust generator every time it moves.
Dust mask: any man who wants an N95 for mixing gets one, company-supplied. That is voluntary use, which is allowed — and it obligates Nova to give him the one-page Appendix D of 29 CFR 1910.134 with the mask. If a future silica assessment under NU-SAF-111 ever requires respirators for a task, that stops being voluntary and becomes a full program under NU-SAF-114 — neither is built yet, both are on the NU-GOV-000 gap list.
The heat tie: mixing drilling fluid is already named one of the hottest jobs on a Nova site in NU-SAF-112 §4 — the man in the dust is also the man in the rotation. Same man, two documents watching him.
Spills and the creek: drilling fluid that leaves the site — a frac-out, a spilled tank — is an environmental event, not a HazCom event. That procedure is NU-FLD-212 (drilling fluid management & frac-out response, on the gap list, not built). Until it exists: contain it with the truck spill kit (behind the seat, NU-FLT-301), don't wash it toward a drain or a creek, call the Supervisor.
7. TRAINING — AT HIRE AND AT EVERY NEW CHEMICAL
1910.1200(h): training happens at initial assignment and whenever a new chemical hazard the crew hasn't been trained on is introduced. Nova already has the slots — this document does not build a new class, it loads an existing one:
- At hire: HazCom rides the Day 1–2 window (NU-PPL-405) — same slot the seven rules and the work zone already use. Fifteen minutes: the inventory exists and where it lives, where the truck binder is, how to read a label and the three SDS sections (§4 table), the bentonite mixing drill (§6), the never-container rule (§5.3), and what a release looks like on our work — dust you can see, fuel or solvent you can smell, a hydraulic fitting misting (the §6 mixing drill already teaches the bentonite case). The trainer walks the new hire to the actual binder on the actual truck. Sign-off lands on the NU-PPL-405 tracker.
[Adam: confirm adding a HazCom line to the Day 1–2 book checklist — same move NU-SAF-112 made for heat.] - New chemical on the truck: whoever brings it (Supervisor or Crew Lead) briefs the crew before first use — what it is, what it does to you, what you wear, where the SDS now sits. Two minutes at the huddle, noted on that day's JSA.
- Annual refresher: Week 21 of the drafted 52-week schedule (07_Toolbox_Talks_52wk.csv, HANDOFF folder: "HazCom — drilling fluid, bentonite, fuel and the SDS") — the schedule hands off to NU-SAF-104 when built; cite it, don't rebuild it. Until then the Supervisor runs it in the existing weekly toolbox slot (NU-SAF-100 §11). The signed toolbox sheet is the record.
8. WHERE THIS TOUCHES THE REST OF THE LIBRARY
| Doc | The connection |
|---|---|
| NU-SAF-100 | §5 element 2 — this document fills that row. Stop Work Authority (§4) backs the never-container rule. Eye wash on every truck (§9). |
| NU-SAF-112 | Mixing drilling fluid is on the hottest-jobs rotation (§4) — the dust man and the heat man are the same man. |
| NU-SAF-111 / 114 | Future silica and respirator docs — §6 hands off to them; sawcutting and coring are the bigger silica story and live there, not here. |
| NU-FLT-310 | Fuel cans and loose chemical containers get their own tiedowns in transit. |
| NU-FLT-301 | The crew verifies the SDS binder at the Friday deep-clean safety-kit step (step 5); the Supervisor scores it on the truck audit scorecard, NU-PPL-403 Part 3 (proposed — see §13). |
| NU-PPL-405 | Day 1–2 window carries the at-hire training; the tracker carries the sign-off. |
| 07_Toolbox_Talks_52wk.csv | Week 21 = the annual HazCom refresher, on the drafted schedule that hands off to NU-SAF-104 when built. Cite it, don't rebuild it. |
| NU-FLD-212 | (Not built) Spills, containment, frac-out — the environmental half of drilling fluid. |
| NU-SAF-121 | Any chemical exposure beyond rinse-and-fine is an incident, same day. |
| NU-PPL-403 | Enforcement — point classes to be assigned (§13). |
9. PROOF & RECORDS (what has to exist when this is done right)
| Record | Who | When | Where it goes |
|---|---|---|---|
| Chemical inventory current (NU-SAF-101-F) | Supervisor | On every new chemical + quarterly review | Master copy (Softr when live) |
| SDS binder present, complete, matches inventory | Crew checks (Friday deep clean, NU-FLT-301) / Supervisor scores | Friday deep clean | Truck audit scorecard (NU-PPL-403 Part 3) |
| HazCom training at hire | Trainer | Day 1–2 | NU-PPL-405 tracker |
| New-chemical crew brief | Supervisor / Crew Lead | Before first use | That day's JSA |
| Annual refresher (Week 21) | Supervisor | Yearly | Signed toolbox sheet |
| Any chemical exposure — eyes, skin burn, swallowed, breathed enough to matter | Crew Lead | Same day | Incident record, NU-SAF-121 |
10. NU-SAF-101-C — THE CHEMICAL CARD (print, laminate, binder front)
BEFORE YOU USE ANYTHING: - On the list + SDS in this binder? Use it. Not on the list? It waits. Call the Supervisor. - Read the label. No label = no use. Re-label it or hand it to the Supervisor.
FILLING A CONTAINER: - Fuel cans say DIESEL or GASOLINE — FLAMMABLE on the can. Mix can says 2-CYCLE MIX — FLAMMABLE. - Bottle or sprayer you fill = product name + hazard word on it, paint pen, that day (BRAKE CLEANER — FLAMMABLE). - NEVER a drink bottle. Ever. Seeing one is a stop-work — logged on the DFR.
MIXING MUD: - Upwind. Cut the bag low at the water. Pour slow. Hopper if you have one. Wet the empties. - Want an N95? Ask — company buys it.
SOMETHING GETS ON YOU / IN YOU: - Eyes → eye wash on the truck, flush 15 minutes, then SDS Section 4. - Swallowed or can't-breathe → 911 first, SDS in hand for the medics. - Anything beyond rinse-and-fine → Crew Lead, same day, NU-SAF-121.
SDS = three sections: 4 first aid · 2 what it does · 8 what you wear.
11. NU-SAF-101-F — CHEMICAL INVENTORY (Tier-4 form)
Owner: Field Supervisor [Adam: confirm] · Updated: on every new chemical + quarterly · Copies: master here / Softr; SDS binder per truck matches this table.
Seeded from what Nova's trucks and rigs actually carry. [Adam: verify this list against the trucks — walk one truck and one rig, add what's missing, strike what's gone. Manufacturer/brand column is blank on purpose: it must match the actual product so the right SDS goes in the binder.]
| # | Product | Brand / manufacturer | Where used | Where it lives | The hazard, in plain English | SDS in binder |
|---|---|---|---|---|---|---|
| 1 | Bentonite (drilling fluid base) | [Adam: fill] |
Mud mixing, all HDD | Rig / support truck | The dust — most SDSs list respirable silica. §6 drill applies every mix. | ☐ |
| 2 | Drilling-fluid additives (polymers etc.) | [Adam: fill — list each product] |
Mud mixing | Rig / support truck | Slick when wet; dust on some powders; read each SDS — "additive" is not one chemical. | ☐ |
| 3 | Diesel | — | Rigs, mini-ex, hydrovac | Labeled safety cans + machine tanks | Combustible; skin irritant; fumes in enclosed space. | ☐ |
| 4 | Gasoline | — | Trucks, small engines | Labeled safety cans | Flammable — vapor ignites at a distance; never near hot exhaust or a grinder. | ☐ |
| 5 | Two-cycle mix | — | Saws, small tools | Labeled mix can | Same as gasoline, plus the wrong-machine problem — label is the control. | ☐ |
| 6 | Hydraulic oil | [Adam: fill] |
All machines | Jugs on trucks | Pinhole leak injects through skin — never feel for a leak with a hand. Cardboard, not fingers. Hot oil burns. | ☐ |
| 7 | Engine oil & grease | [Adam: fill] |
PM on everything | Trucks | Long skin contact irritates; slip hazard on decks. Gloves, wipe the spills. | ☐ |
| 8 | Pipe lube | [Adam: fill] |
Pulls, conduit work | Trucks | Low hazard, but it's a chemical on a Nova truck, so it's on the list. Slick on hands and rungs. | ☐ |
| 9 | Marking paint (aerosol) | [Adam: fill] |
Locates, layout | Truck boxes | Flammable aerosol — not on the dash in a Georgia summer; don't breathe the plume; don't puncture cans. | ☐ |
| 10 | Solvents / degreasers (incl. brake cleaner) | [Adam: fill — list each] |
Cleaning fittings, tools | Truck boxes | Flammable, some strip skin, fumes in enclosed space; never on hot parts — some make toxic gas on heat. | ☐ |
| 11 | DEF (diesel exhaust fluid) | [Adam: fill] |
Diesel trucks & machines | Jugs on trucks | Low hazard — urea solution; mild skin/eye irritant; don't confuse the jug with coolant or water. | ☐ |
| 12 | Antifreeze / coolant | [Adam: fill] |
All machines & trucks | Jugs on trucks | Ethylene glycol is toxic swallowed — the sweet taste invites mistakes; wipe spills, keep it off the ground. | ☐ |
| 13 | Penetrating oil (WD-40 / PB Blaster) | [Adam: fill] |
Rusted fasteners, PM | Truck boxes | Flammable aerosol; fumes in enclosed space; slick overspray on hands and decks. | ☐ |
| 14 | Starting fluid (ether) | [Adam: fill] |
Cold starts | Truck boxes | Extremely flammable aerosol — same not-on-the-dash rule as marking paint; never near a hot manifold or open flame. | ☐ |
| 15 | Bar & chain oil | [Adam: fill] |
Chainsaws | Truck boxes | Low hazard; long skin contact irritates; slick on hands and rungs. | ☐ |
| 16 | [add rows as found on the trucks] |
☐ |
The empty-row rule: finding a chemical on a truck that isn't on this table is not a violation to hide — it's a row to add, same day, SDS in the binder before next use.
12. DONE WHEN / NEVER
Done when: - Every chemical on every truck appears on NU-SAF-101-F, and every row has its SDS in every truck binder. - Every fuel, mix, and refilled container on every truck carries a label. - Every new hire's HazCom sign-off is on the NU-PPL-405 tracker before he touches a chemical task. - The Friday deep clean checks the binder and the scorecard shows it. - The Week 21 toolbox sheet gets signed every year.
NEVER: - Never use a chemical that isn't on the inventory with an SDS in the binder. It waits. - Never put a chemical in a food or drink container. Stop-work on sight. - Never run an unlabeled container. Re-label it or it comes off the truck — the Supervisor decides disposal per the SDS (Section 13). No sniff tests. - Never dump a bentonite bag from shoulder height into a dust cloud. Low, slow, upwind. - Never feel for a hydraulic leak with a hand. Cardboard finds the leak; a hand catches an injection injury. - Never spray solvent or degreaser on hot parts. - Never wash a spill toward a drain, ditch, or creek. Contain it with the truck spill kit (behind the seat, NU-FLT-301) and call — NU-FLD-212 when built, Supervisor until then.
13. WHAT THIS DOCUMENT NEEDS FROM ADAM
- Verify the §11 inventory against the trucks. Walk one truck and one rig with the table; fill the brand column so the right SDSs go in the binders.
[Adam: verify against the trucks] - Confirm the binder location — proposed: the behind-the-seat safety-kit zone (NU-FLT-301: first-aid kit, spill kit, extinguisher — strapped or bracketed, checked stocked every Friday), same spot on all 7 trucks.
[Adam: confirm] - Confirm the inventory owner — proposed: Field Supervisor, consistent with NU-SAF-100 §3.
[Adam: confirm] - Confirm the fuel cans are approved safety cans and labeled (1926.152(a)(1)) — or buy the labeled cans; this is a one-purchase fix.
- Assign the point classes in NU-PPL-403: (a) chemical in a drink container, (b) unlabeled secondary container, (c) chemical in use with no SDS in the binder. (Recommendation: (a) Class C — it is a poisoning waiting on a thirsty man; (b) and (c) Class A/B paperwork tier.)
- Approve where the SDS-binder check lands in the existing records: the crew verifies the binder at the NU-FLT-301 Friday deep-clean safety-kit step (step 5), and the binder gets folded into item 3 "Behind-seat safety kit" on the Friday truck audit scorecard (NU-PPL-403 Part 3) — no new scorecard item, no renumbering, pass mark stays 16/20. That scorecard line is this document's standing record.
- On approval: flip the NU-SAF-100 §5 element-2 row from "Not built" to "NU-SAF-101 issued," and update the NU-GOV-000 register row.
NU-SAF-101 · Rev DRAFT (v1.0) · Nova Underground · Parent: NU-SAF-100 · Companion: NU-SAF-101-C card + NU-SAF-101-F inventory · Uncontrolled when printed.