Training Employees | Hazard Communication
Training is critical to effective hazard communication. It is the forum in which hazard information can best be presented. Under the Hazard Communication Standard, all covered facilities are required to establish an effective training and information program for every employee routinely exposed to hazardous chemicals.
This training serves to explain and reinforce the information presented through labels and data sheets. The use of labels and MSDSs will only be successful when workers understand the hazards of chemicals and the actions to take to avoid or minimize chemical exposures.
The key term here is “understanding.” Not only do employees have to be trained, but they must walk away from that training understanding what they are working with. Giving an employee a data sheet to read does not satisfy the intent of the HCS. The training should include an opportunity for them to ask questions, thus ensuring that they understand the information.
Prior to the initial job assignment, each employee who has exposure risks to hazardous chemicals must be provided information and training. Additional training has to be done whenever a new physical or health hazard is introduced into their work area.
“Exposure” or “exposed” means that an employee is subjected to a hazardous chemical in the course of employment through any route of entry, including:
§ Skin contact, or
Information and training may be done either by individual chemical, or by categories of hazards, such as flammability or carcinogenicity. If there are only a few chemicals in your workplace, then you may want to discuss each one individually. Where there are large numbers of chemicals, or the chemicals change frequently, you will probably want to train generally, based on the hazard categories such as flammable liquids, corrosive materials, or carcinogens. Employees will have access to the substance-specific information on the labels and MSDSs in their work areas.
The Hazard Communication Standard is performance-oriented, that is, it specifies the results but does not mandate the methods used to get there. You are free to select any method of training that fits into your operation. Additionally, the standard does not state how long the training must take, only that it adequately covers the material.
Revison 12/05 If you already do some safety training, you may want to include HCS training with your current program. However, if you have different groups of chemicals used in several departments, it may be simpler to do your HCS training on a department level. That way you can train workers in the hazards of only those specific chemicals they use in their work area. This approach will not only shorten the training time, but also keep trainees from becoming bored by having to listen to irrelevant information.
There are a number of different approaches that can be taken. You could use videos, interactive computer programs, classroom instruction, or a combination of methods. The best approach is to set up training which allows employees an opportunity to ask questions to ensure that they understand the information presented to them. Giving an employee a data sheet to read does not satisfy the intent of the standard. OSHA does not expect that every worker will be able to recite all of the information about each chemical in the workplace. In general, the most important aspects of hazard communication training are to ensure that employees:
§ Are aware that they are exposed to hazardous chemicals,
§ Know how to read and apply the information on labels and material safety data sheets, and
§ Are following the appropriate protective measures.
It is OSHA’s position that training may be provided by the current employer, a past employer, an employee union, or any other entity, so long as the employees receive adequate training according to the HCS. If it is determined that an employee has not received training or is not adequately trained, the current employer will be held responsible regardless of who trained the employee. It’s important to evaluate the employee’s level of knowledge against the training and information requirements of the standard.
You may want to split the training into two parts:
§ The information section, and
§ The chemical-specific training.
Then one trainer can give all employees the information training, and the area supervisor can handle the training for the chemicals used in their work areas.
Be sure that whoever does the chemical-specific training thoroughly understands the safe handling aspects of the chemicals being covered. Many times a supervisor is more production-oriented rather than safety-oriented, and may emphasize shortcuts that are not recommended for the safe use of a hazardous substance. If you have several people, such as supervisors, conducting training for their work areas, sit in on a session or two to observe how the training is being handled and to show your support for safety in the workplace.
NOTE: A temporary agency and the employer (the host) which creates and controls hazards must share responsibility for assuring that leased employees are protected from the host’s workplace hazards.
All employees with hazard chemical exposure risks must receive training. OSHA defines an “employee” as any worker who may be exposed to hazardous chemicals under normal operating conditions or in foreseeable emergencies. It is better to train too many people rather than too few. If you have some employees who are occasionally in an area where chemicals are stored or used and you are undecided whether they are “routinely exposed,” include them in your training program.
“Normal operating conditions” are those which employees encounter in performing their job duties in their assigned work areas. For example, if the receptionist in a facility receives and delivers a telephone message for someone in a different work area where hazardous chemicals are present, this does not mean that the receptionist would be covered under the rule by virtue of the one potential exposure from delivering the message.
However, if performance of the receptionist’s job entails walking through the production area every day and thus being potentially exposed during the performance of regular duties, that job would be covered under the rule. Moreover, a housekeeping staff member who is expected to handle clean-up of hazardous substances, such as mercury from a broken thermometer, would require training.
Under the Hazard Communication Standard, refresher training is not required on a routine basis, such as annually. However, receiving a new MSDS or chemical compels the employer to evaluate the information provided in the MSDS and decide whether the new product represents a new health or physical hazard to employees. Training needs to be provided to affected employees when new hazards are introduced into the workplace (not necessarily new chemicals).
Realistically, providing training once, then assuming that several years later your employees are still knowledgeable is a risky assumption. It is wise to set up a system for periodic retraining. It does not have to be an annual, full-blown training session. If you have monthly or quarterly safety meetings, interject some quick reminders such as where the MSDSs are located or what the information in the red, blue, and yellow bars or squares means on container labels. Any system that works will be satisfactory to OSHA.
The HCS does not require employers to maintain employee training records, but many employers choose to do so. Documenting the training helps you monitor your own program and ensure that all employees are appropriately trained.
Prior to beginning any training program, you will need to collect certain information. First, review your hazardous chemical inventory list. The chemicals on this list are the ones for which you will need to provide training.
Unless you deal with a small number of chemicals, you will want to cross-reference the chemical inventory list with a list of employees and the substances they are exposed to in their work area. This cross-reference tells you which chemicals must be included in the training for Area A, for Area B, etc.
Next, make sure that you have all the MSDSs for the chemicals that will be discussed during training. Read through them and use them as a primary source of information for the chemical-specific part of the training program. It’s a good idea to have a chemical dictionary on hand to look up answers to employees’ questions, as well as complete information on the use of safety equipment. Read through all materials so that you are comfortable with what you are going to present.
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