Education is the beginning point for developing and maintaining a world-class HAZCOM program. This module focuses on communicating information about hazards and training employees to work safely while being exposed to those hazards. This module discusses basic employer responsibilities for effectively communicating the HAZCOM to employees.
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 chemical hazard the employees have not previously been trained about is introduced into their work area.
Employees must be informed of:
Any operations in their work area where hazardous chemicals are present; and,
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 SDSs. More on this later.
Employee training must include at least:
Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area.
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;
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.
The employer must also evaluate each employee's knowledge about:
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 the training is to inform employees 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.
Also, training requirements are not satisfied solely by giving employees the SDS to read. An employer's training program is to be a forum for explaining the who, what, where, why and when (the education) to employees of the hazards of the chemicals in their work area, but also how (the training) to work safely using safe procedures as required by the hazard communication program. This can be accomplished in many ways, including:
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:
Example 1: If a new solvent is brought into the workplace, and it has hazards similar to existing chemicals for which training has already been conducted, then no new training is required. However, as with initial training, and in keeping with the intent of the standard, the employer must:
Example 2: If the newly introduced solvent is a suspect carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new training for carcinogenic hazards must be conducted for employees in those work areas where employees will be exposed.
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.
Remember, it is likely that additional training will be needed since employees must know the specifics of their new employers' programs such as where the SDSs are located, details of the employer's in-plant labeling system, and the hazards of new chemicals to which they will be exposed.
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 is a responsibility that is shared between the host employer and temporary agency.
Host Employer. The host employer is responsible for training on the company's HCS program including specific labeling, chemical hazards and safe work procedures in their workplace.
Temporary Agency. The temporary agency, in turn, maintains a continuing relationship with its employees and would be expected to inform employees of the general requirements of the HCS standard.
Contracts between the temporary agency and the host-employer should be examined to determine if they clearly set out the training responsibilities of both parties, in order to ensure that the employers have complied with all requirements of the regulation.
A frequently overlooked portion of the training provisions is that dealing with emergency procedures. In workplaces where there is a potential for emergencies, the employer’s HCS training program would have to address the HAZWOPER emergency response plan and/or emergency action plan.
The scope and extent of employee training regarding emergency procedures will depend upon the employer's Emergency Response Plan (ERP).
If the employer merely intends to evacuate the work area, the training in emergency procedures could be limited to, for example, information on the emergency alarm system in use at the worksite, evacuation routes, and reporting areas as detailed in the employer's emergency action plan.
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, Hazardous Waste and Emergency Operations (HAZWOPER), would be required.
It's important to remember that the Hazard Communication Standard (HCS) only covers response to incidental hazardous substance spills that:
Training for responding to incidental spills is covered under the Hazard Communication Standard (HCS) and includes spill cleanup procedures and the use of appropriate PPE.
If there is an uncontrollable release of hazardous substances, OSHA Standard 1910.120, Hazardous waste operations and emergency response (HAZWOPER). OSHA's HAZWOPER standard and its training requirements apply to efforts that are "HAZWOPER emergency responses" and hazardous waste site cleanups. Remember, training required for emergency response workers is quite different than that required for hazardous waste site workers. See OSHA's Emergency Preparedness and Response page.
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