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)].

Safety Tidbit #1 OSHA 300 for Small Employers

Safety Tidbit #1 (6/19/2015)

Small employers are a special lot when it comes to their diversity. Sometimes the employer has 10 or fewer employees. Other times, they are in industries with a North American Industrial Classification System (NAICS) code that OSHA has specified as “low hazard” industries. To complicate matters, some of small businesses may have multiple facilities where they may be doing completely different operations. Therefore, I decided to put together three quick questions that will help small businesses ascertain whether a 300 log is required or not. That being said, I strongly recommend all employers use the 300 log (and the 301 and 300A) to track any incidents (injuries and near misses) they may experience.

So let’s get to it:

1. Is this a permanent establishment (one year or longer)? No – OSHA 300 not required. Keep injury/illness information with corporate records [1904.30(a)]. Answered yes? Continue to Question 2.

2. Is the primary industry at the permanent establishment listed as low hazard rating?  Yes – OSHA 300 not required [1904.2(a)(1)]. Answered no? Continue to Question 3.

3. Does the permanent establishment or the entire company have more than ten employees? No – OSHA 300 not required [1904.1(b)(1)] Answered Yes? Then an OSHA 300 must be kept for the permanent establishment.