Elements of Your Training Program | Hazard Communication
A properly conducted training program will ensure comprehension and understanding. It is not sufficient to either just read material to the trainees, or simply hand them material to read. You want to create a climate where workers feel free to ask questions. This will help you to ensure that the information is understood. Always remember that the underlying purpose of hazard communication is to reduce the incidence of chemical source illnesses and injuries.
Your training program can take any form, as long as the required information is conveyed and understood. You will probably need to make adjustments, depending upon the level of employee you are training. Take into consideration the education and technical background of the trainees. At a minimum, cover the following topics.
Employees must be informed of the existence of the HCS, what the standard requires, and what it will do for them. Explain that the purpose of the HCS is to ensure that the hazards of all chemicals produced are evaluated, and that information concerning these hazards is transmitted to employers and employees.
Before you proceed too far with your training program, clarify the language you will use. Don’t assume that workers know what an MSDS is, or a hazard warning. The less educated your workers, the more you will need to explain the terminology. Use handouts, diagrams, draw pictures on a chalk board — whatever is necessary to communicate your message.
Determine ahead of time how much MSDS information you feel is necessary and will be useful and understood. Explain what the MSDS is and its purpose. Explain the categories on the MSDS, the kind of information found in each section, and what some of the terms mean. Don’t overload the employees with terminology. They should just understand what is relevant and important to their interaction with chemicals.
Knowing the effects of overexposure of chemicals they use everyday is extremely important. Their understanding of the value of the information in “routes of entry” can increase PPE use. Emphasize the areas that should matter to them. Bring the information into the “real” world. Use examples of how this information can protect them in their own workplace.
The most vital information in this part of the training is explaining where the data sheets are kept and how to access them. If you are keeping your MSDSs in a binder or book, hold it up, pass it around, familiarize the trainees with it. Make sure the book or binder is clearly marked and explain where to find it in the work area. Remember, during an inspection, OSHA will ask employees if they know where to find the MSDSs.
Labels are the most visible and most frequent contact your employees will have with chemical information. Labels are intended to serve as an immediate visual warning of the hazards of the chemical. It is very important that employees have a thorough understanding of how to interpret the information being presented on the label, so that they can modify their handling of the chemical accordingly.
The written program is your documentation of how you have complied with the Hazard Communication Standard in your company. This program must be made available to your employees. Tell them how they can review the complete written program.
This section will comprise the largest part of your training program. You should give specific details on what chemicals the employee has contact with and how to safely handle those chemicals.
Cover how to detect the presence or release of the chemical (visual appearance or odor when being released, monitoring devices, and what they indicate). Thoroughly describe the physical and health hazards of the chemicals in their work area.
You do not need to cover each chemical. Break your chemicals down into groups, such as paints or solvents, and discuss the hazards and precautions of the group as a whole. This saves a lot of time, but also is more effective as a training technique.
Explain the proper use of protective equipment that is required for the safe handling of the chemicals. Demonstrate how to use the PPE and clearly indicate when the device is to be used, how to care for it, and where it is stored. Explain your company policy regarding the use of protective equipment.
Make sure workers understand what first aid and emergency procedures should be used in the event of exposure or overexposure to the hazardous chemicals they work with. Point out where they can find this information on the MSDS, if they have questions in an emergency situation.
Although the Hazard Communication Standard does not require that you record that employees have been trained, it’s a good idea to document who has been trained and when they received training.
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