Course 606 - Hazard Communication for the Employee

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Employee Training

Introduction

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Each employee who may be “exposed” to hazardous chemicals when working must be provided information and be trained prior to initial assignment working with a hazardous chemical as well as whenever the hazard changes.

“Exposure” or “exposed” under the rule means an employee is subjected to a hazardous chemical in the course of employment through any route of entry (inhalation, ingestion, skin contact, or absorption) and includes potential (e.g., accidental or possible) exposure.

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 the workplace, then you may want to discuss each one individually. Where there are a large number of chemicals, or the chemicals change frequently, you will probably want to train generally based on the hazard categories (e.g., flammable liquids, corrosive materials, carcinogens). Employees will also have access to the substance-specific information on the labels and MSDSs. Employers must ensure, however, that employees are made aware of which hazard category a chemical falls within.

Training Requirements

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Employees must receive information and training that ensures their awareness of the chemical hazards used in their work area. Employers also must provide this information when an employee is initially assigned to a work area where hazardous chemicals are present and before assignments involving new exposure situations.

Employees must be informed of:

  • the requirements of the HCS 2012
  • any operations in their work area where hazardous chemicals are present
  • the location and availability of the written hazard communication program (including the required list(s) of hazardous chemicals and SDSs required by the HCS)

Training Requirements (Continued)

In addition, employees must know the following:

  • contents of the occupational exposure standard and its appendices
  • The location and availability of the employer's chemical hygiene plan Potential Exposure Limits (PELs).
  • The PELs for the hazardous substances to which employees are exposed.
  • The signs and symptoms associated with exposures to hazardous chemicals used in the workplace.
  • The location and availability of known reference material on the chemical hazards, and their safe handling, storage, and disposal including, but not limited to, Material Safety Data Sheets (MSDSs) received from chemical suppliers.

Training Requirements (Continued)

Employee training must include at least:

  • The 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, health hazards, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area.

Note: 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 labels received on shipped containers and the workplace labeling system used by their employer; the safety data sheet, including the order of information and how employees can obtain and use the appropriate hazard information.

For more information on creating a workplace HAZCOM program, see OSHAcademy course 705 Hazard Communications Program.

Remember, an employer has a responsibility to evaluate an employee's level of knowledge with regard to the hazards in the workplace, their familiarity with the requirements of the standard, and the employer's hazard communication program.

Scenario

In 2012, a 37-year-old female technician employed by a surface-refinishing business died from inhalation exposure to methylene chloride and methanol vapors while she used a chemical stripper to prep the surface of a bathtub for refinishing. The technician was working alone without respiratory protection or ventilation controls in a small bathroom of a rental apartment.

When the technician did not pick up her children at the end of the day, her parents contacted her employer, who then called the apartment complex manager after determining the victim’s personal vehicle was still at the refinishing company’s parking lot. The apartment complex manager went to the apartment unit where the employee had been working and called 911 upon finding the employee unresponsive, slumped over the bathtub.

The apartment manager and first responders reported a strong chemical odor in the second story apartment. There was an uncapped gallon can of Klean Strip Aircraft® Low Odor Paint Remover (80-90% methylene chloride, 5-10% methanol) in the bathroom. The employee’s tools and knee pad were found in the tub, suggesting the employee had been kneeling and leaning over the tub wall to manually remove the loosened original bathtub finish coat.

The factors contributing to this lethal exposure include use of a highly concentrated methylene chloride chemical stripper having poor warning properties (“Low Odor”); working in a small room without local exhaust ventilation to remove chemical vapors or provide fresh air; and working without a respirator that could have protected the employee from exposure.

The following recommendations are made to prevent future occurrences:

  • Provide all employees with training regarding the hazardous substances in their work area at the time of initial assignment and when new chemical hazards are introduced, in accordance with OSHA’s hazard communication standard.
  • Substitute less hazardous products or methods to remove tub or sink surfaces that do not involve methylene chloride compounds.
  • If using methylene chloride based products, adhere to requirements of OSHA’s methylene chloride standard regarding hazard communication, regulated areas, exposure monitoring, medical surveillance, and exposure control methods to maintain exposures below the Action Level.

GHS Hazard Communication

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

1. Each employee who may be “exposed” to hazardous chemicals at work must be trained _____ to initial assignment.

2. Exposure under the rule means an employee is subjected to a hazardous chemical through any route of entry.

3. An employer has a _____ to evaluate an employee’s level of knowledge with regard to hazards in the workplace.

4. Employees must be informed of _____.

5. Employers should not provide training for individual chemicals. The training must only be done by categories of hazards.


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Important! You will receive an "error" message unless all questions are answered.