Safety Tidbit #2 Hazard Communication Training

Hazard Communication Training

Hazard Communication – One of the most cited standards by OSHA Inspectors.  By now, most employers know the basics. They know they must have a written Hazard Communication Program [1910.1200(e)(1)], keep a list of hazardous chemicals on the site [1910.1200(e)(1)(i)]. And they proudly show their binder of Material Safety Data Sheets (now Safety Data Sheets) [1910.1200(g)(8)]. However, training workers seems to continue to confuse many – Who, What, When.

Let’s do the Who and When first. Who: All workers are to be trained as to the hazards of the chemicals in their workplace (1910.1200(h)(1)]. When: The employer must train new employees upon initial entry but also with the introduction of a new hazard [1910.1200(h)(1)]. Pretty straight forward, right?

What: Ah ha! Here is where it might get a little confusing. First, in paragraph 1910.1200(h)(1) “effective” training is specified. Effective is interpreted to mean that the workers must understand and retain the information about the hazards of the chemicals in their workplace.  Second, there are three parts to hazard communication training: 1. The Hazard Communication Standard [1910.1200(h)(2)(i)]; 2. Specific operations using chemicals [1910.1200(h)(2)(ii)]; 3. The company’s specific hazard communication program [1910.1200(h)(2)(iii)] and 4. An explanation of labeling both by the manufacturer and employer’s practice for workplace containers [1910.1200(h)(3)(iv)]. For practical purposes, parts 1, 3, and four above are routinely combined.

Interestingly, Part 2 of the Hazard Communication training is often overlooked.  However, the OSHA standard specifies quite a bit of information to be conveyed to the workers:

A.    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.) [1910.1200(h)(3)(i)].

B.    The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise classified, of the chemicals in the work area [1910.1200(h)(3)(ii)].

C.    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 [1910.1200(h)(3)(iii)].