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 SDSs. Employers must ensure, however, that employees are made aware of which hazard category a chemical falls within.
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:
In addition, employees must know the following:
Employee training must include at least:
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.
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.
A 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.
The apartment complex manager went to the apartment unit where the employee had been working and called 911 and found her unresponsive, slumped over the bathtub.
The apartment manager and first responders reported a strong chemical odor in the 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 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:
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