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:
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.
Below are a couple of examples that help to understand this requirement:
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It is not necessary for employers to retrain new employees if:
New employees should be able show proof they received specific training on the hazardous substances to which they would be exposed in their new jobs. General information, such as OSHA Hazard Communication requirements, could be expected to remain with employees from one position to another. However, the employer is responsible for ensuring that new 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 required since employees must prove they know the specifics of their new employer's programs such as the location of SDSs, details of the in-plant container labeling system, and the hazards of new chemicals to which they will be exposed. New employees must demonstrate (show and tell) adequate KSAs to their supervisors before being assigned to their new jobs.
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. The scope and extent of employee training regarding emergency procedures will depend on what the employer expects employees to do when an emergency occurs:
It's important to remember that OSHA standard 1910.1200, 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.
An uncontrolled release is the release of a hazardous substance from its container. If not contained, stopped, and removed, the release would pose a hazard to the employees in the immediate area or in areas in the path of the release, or from its by-products or its effect (such as toxic vapors, fire, over-pressurization, toxic gases, or toxic particulate).
If there is an uncontrollable release of hazardous substances, OSHA Standard 1910.120, Hazardous waste operations and emergency response (HAZWOPER), and its training requirements will apply. 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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