Introduction

The "Prime Directive" Employers must provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets.

• The requirements of the hazard communication standard (1910.1200);
• Any operations in their work area where hazardous chemicals are present; and,
• The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and material safety data sheets required by this section.

• Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.);

• The physical and health hazards of the chemicals in the work area;
  Training need not be conducted on each specific chemical found in the workplace, but may be conducted by categories of hazard (e.g., carcinogens, sensitizers, acutely toxic agents) that are or may be encountered by an employee during the course of his duties.

• The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used;

• The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information.

It's important to understand that employees must be trained at the time they are assigned to work with a hazardous chemical. The intent of this provision is to have information prior to exposure to prevent the occurrence of adverse health effects. Of course, this intent cannot be met if training is delayed until a later date.

• Classroom instruction
• Interactive video
• Hands-on demonstration

Regardless of the training method, all employees should have an opportunity to ask questions to ensure that they understand the information presented to them. Furthermore, the training must be comprehensible. If employees receive job instructions in a language other than English, then the HAZCOM training and information will also need to be conducted in that foreign language.

And, here's a subtle, but important point to remember: Additional training is to be done whenever a new physical or health hazard is introduced into the work area, not a new chemical. Here's a couple of examples that help to understand this requirement:

• make employees specifically aware which hazard category (i.e., corrosive, irritant, etc.) the solvent falls within.
• make the substance-specific data sheet available, and
• properly label the new product.

What about retraining new hires? It is not necessary that the employer retrain each new hire if that employee has received prior training by a past employer, an employee union, or any other entity. The new employee should be able show proof that training on the hazardous substances to which they would be exposed on the job has been conducted. General information, such as the rudiments of the HCS could be expected to remain with an employee from one position to another. The employer, however, maintains the responsibility and is held accountable to ensure that their employees are adequately trained and are equipped with the knowledge and information necessary to conduct their jobs safely.

Training at multi-employer worksites The training requirements also apply if the employer becomes aware via the multi-employer worksite provision of exposures of his/her employees to hazards for which they have not been previously trained.

Training temporary employees

• The host-employer holds the primary responsibility for training since the host employer uses or produces chemicals, creates and controls the hazards, and is, therefore, best suited to inform employees of the chemical hazards specific to the workplace environment.

• The temporary agency, in turn, maintains a continuing relationship with its employees, and would be, at a minimum, expected to inform employees of the requirements of the standard.

How extensive should training be?

In situations where employees are expected to moderate or control the impact of the emergency in a manner similar to an emergency responder, training under 1910.120 would be required. Employers who fall under the scope of HAZWOPER must have either a written emergency response plan or an emergency action plan. If employers expect their own employees to respond to a potential emergency involving a hazardous substance, then the employer must create an emergency response plan and the employees must be trained to perform the duties expected.

What about uncontrollable releases of hazardous substances?

There you have it? Almost everything you need to know. Time to take the module review quiz, so let's go. Answer each question as best you can. Scroll up the page to review if you like.