Disclaimer: The 2020 SSG emphasis program is designed for owners and managers to ensure they are adhering to, and maintaining the technical elements of their OSHA compliance and safety program. Although some may be used for employee training, it was not designed as such. Check out the link below to gain access to our employee-based, OSHA-compliant trainings on numerous topics.
Full Video Script:
“Welcome back to the 4th and final video for our month-long series on some of the most fundamental things you need to be doing within your Hazard communication program. All of these 2020 emphasis trainings are brought to you by Safety Consulting NOW, and I encourage you to sign up for free at training.safetyconsultingnow.com to gain access to these emphasis trainings, as well as a full learning management and training platform, and a place for any and all employees involved in safety within their operations to share their perspectives in a social media style community. It is an awesome platform. I promise you you’ll love it.
Now, this week we dive into a critical component of every topic we’ll cover this year and one we will allude to in every training we do. Why? Well, because it’s the cornerstone of literally everything we talk about. That being the training and the way you train yourself and your team on the hazards found in each of these topics we’re covering. Specifically, the training piece for HAZCOM is found in (paragraph (h) titled appropriately as Employee Information and Training. The key requirement i want you to focus in on is in paragraph (h)(1) that states “Employers shall 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. Information and training may be designed to cover categories of hazards (such as, flammability, carcinogenicity) or specific chemicals. When you’re training on chemicals, specific information must always be available through labels and safety data sheets. For information and training to be effective, the workers in the training must comprehend the hazards in the workplace and ways to protect themselves. This is important: OSHA does not expect that workers will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they’re exposed to hazardous chemicals, that they know how to read labels and SDSs, and that they have a general understanding of what information is provided in these documents, and how to access these tools. Workers must also be aware of the protective measures available in their workplace, how to use or implement these measures, and who they should contact if an issue arises. Information and training may be done either by individual chemical, or by hazard classes and categories (such as acute toxicity or flammable liquids). If there are only a few chemicals in the workplace, then you should probably discuss each one individually. In cases where there are large numbers of chemicals, or the chemicals change frequently, you should train generally based on the hazard classes and categories.
Now listen, workers must have access to the substance-specific information on the labels and SDSs. As we’ve noted before, HazCom 2012 requires employers train their employees to be informed of the following:
- The general requirements of the Hazard Communication Standard;
- Where hazardous chemicals are located in their work areas and during which operations exposure may occur); and third,
- What the workplace hazard communication program includes, and where and how they can access the program.
Now that’s the standard, but the actual training needs to be a more active process. Please listen up, because the ongoing training you do as new employees are hired and as new chemicals are introduced, especially when we, your consultants, who can’t be at your facility all the time, the training you conduct must address the following:
- 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.); and please reach out to your SSG consultant right away if there are chemicals that need to be monitored. We can conduct those samples for you.
- 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;
- 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; and,
- 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 SDS, including the format of the SDS (where each type of information is located) and how employees can obtain and use the appropriate hazard information.
Here are some really important points you need to challenge yourself with when it comes to training your team. Workers must be trained in such a way that comprehension and understanding is achieved. It is not sufficient to either just read material to the workers, or simply hand them material to read. As explained in Dr. Michaels’ OSHA Training Standards Policy Statement (April 28, 2010), OSHA requires employers to present information in a manner and language that their employees can understand. If employers customarily need to communicate work instructions or other workplace information to employees in a language other than English, they will also need to provide safety and health training to employees in the same manner. Similarly, if the employee’s vocabulary is limited, the training must account for that limitation. By the same token, if employees are not literate, telling them to read training materials will not satisfy the employer’s training obligation. In conducting a training program, you want to create a climate where workers feel free to ask questions. This will help you to ensure that the information is understood. You must always remember that the underlying purpose of the Hazcom standard is to reduce the incidence of chemical source illnesses and injuries. This will be accomplished by modifying behavior through the provision of hazard information and information about protective measures. If your program works, you and your workers will better understand the chemical hazards in the workplace, and how to protect workers from experiencing adverse effects. The procedures you establish regarding the purchasing, storing, and handling of chemicals will improve, and thereby reduce the risks posed to workers exposed to the chemical hazards involved. Furthermore, your workers’ comprehension will also be increased, and proper work practices will be more likely followed.
If you’re going to do the training yourself, you will have to understand the material and be prepared to motivate the workers to learn. This isn’t always an easy task, but the benefits are worth the effort. This is also where investing in services like ours where a consultant comes out onsite to teach and educate, and even resources like our NOW training platform where you don’t have to be the trainer but can merely facilitate the knowledge, can all be very effective in achieving these training requirements. In reviewing your hazard communication program with regard to information and training, the following items need to be considered:
1. The designation of the person or persons responsible for conducting training;
2. Format of the program to be used (audiovisuals, classroom instruction, online training, etc.);
3. Elements of the information and training program (which should be consistent with the elements in paragraph (h) of the standard); and,
4. Procedures to train new workers at the time of their initial assignment to work with a hazardous chemical, and to train workers when a new chemical hazard is introduced into the workplace.
And coming back to the first week of this emphasis, the written program should provide enough details about the employer’s plans in this area to assess whether or not a good faith effort is being made to train workers. OSHA will be looking for that structure. and that said, when assessing an employer’s compliance with hazard communication training requirements, OSHA inspectors will talk to workers to determine if they have received training, if they know they are exposed to hazardous chemicals, and if they know where to obtain substance-specific information on labels and SDSs. It should be noted that if workers do not speak English, the employer must convey the hazard communication information in the language they understand. I will say that Safety Consulting NOW continues to invest in our online training programs and are being translated into Spanish to make sure these employees are receiving the life saving knowledge we all deserve. But listen, OSHA does have bilingual inspectors, and they will be speaking to workers who speak another language to determine your compliance in this area. Now this may seem odd, but the hazcom standard does not actually require employers to maintain records of employee training, but, let me stress that you should. This will help you monitor your own program to ensure that all workers are appropriately trained and it keeps you from getting into a “if it isn’t written, it ain’t real” battle with OSHA. Keeping records that document who was trained, when the training was conducted, and what was covered is also helpful to document compliance with OSHA’s training requirement in case of an inspection. The standard does not require retraining on a regular schedule, it simply requires retraining if there is a new chemical hazard introduced into the work area. And for this reason, we train on this topic at least once a year but recommend you have a system in place to keep new hires trained ASAP.
But know this, regardless of the method or how often you train, that is all site specific, and company specific and something you need to be in tune with. You, as the employer is always ultimately responsible for ensuring that workers are adequately trained. If the OSHA inspector finds that the training is deficient, the employer will be cited for the deficiency regardless of who actually provided the training on behalf of the employer. So please reach out to us if you have any questions on the elements required in HAZCOM training.
Alright, that wraps up this week and this months emphasis program on Hazard Communication. Next week we’ll be kicking off a new emphasis topic on powered industrial trucks, aka forklifts. It’s a commonly cited topic and we wanna make sure we’re pointing you in the right direction. For Summit Safety Group and Safety Consulting NOW, I’m Jake Woolfenden and I’ll see you next week. Please check out training.safetyconsultingnow.com to subscribe to our full training library. I’ll see you in the next one.”