On OSHA’s Top 10 list of the most frequently cited standards in fiscal year 2020, Hazard Communication (HazCom) took the no. 2 spot, as it has for the last eight years. Although the HazCom standard has numerous requirements, training violations are among the most common for employers.
These violations occur even though HazCom requirements have been essentially unchanged since 2016 when OSHA’s transition timeline to GHS Revision 3 ended. What’s more, the Agency’s recently proposed alignment with GHS Revision 7 suggests compliance challenges and uncertainty will only increase.
We’ve rounded up the most common questions we receive about training obligations under the Standard, and provide some best practices for reinforcing them among your workforce.
What to include in my training program?
You’d be surprised how frequently employers put together a HazCom training program without even checking whether they’ve covered everything the standard requires.
According to the Standard, your HazCom training needs to cover:
- “The requirements of this section,” as OSHA puts it in 1910.1200 (h)(2)(i). In OSHA guidance documents such as the Small Entity Compliance Guide for Employers That Use Hazardous Chemicals, OSHA elaborates that training must cover “the general requirements of the Hazard Communication Standard.”
- Safety data sheets (SDSs) and labels (manufacturer shipped labels and workplace labels), and how to read, use and understand the information, including the order of information on an SDS.
- Ways of detecting the presence or release of chemicals, whether through the use of monitoring equipment or simple observations. If you use digital monitors, talk about where they are, what they measure, and how to interpret the readings. Make sure that the methods discussed here line up with the specific chemicals and hazards at your facility.
- The physical and health hazards of chemicals in your workplace, as well any hazards not otherwise classified. The same principle explained above applies here, too: if the hazard is present in your facility, you need to cover it in training.
- How employees can protect themselves from chemical hazards, including the use of personal protective equipment (PPE), safe work practices, engineering controls, and any other specific procedures or controls you’ve implemented. It’s important for both the safety of your workplace and the compliance of your training program that you have some form of exposure control identified for all of the specific hazards present in your facility. Be clear and detailed enough to eliminate any potential confusion.
- Details of your Hazard Communication Program, including how you manage SDSs and shipped labels, your facility’s chemical inventory, methods for accessing SDSs at your facility, the details of your workplace labeling system, how to properly store chemicals, what to do in the event of chemical emergencies, who to seek out for more information, how/where to access the written plan, and any other details you believe are important for effective HazCom management. Keep in mind that it’s not enough to simply write down (or type up) these details; your employees need to understand them. And since your training program and written HazCom plan are complementary pieces of your chemical management system, any changes or updates to one will likely necessitate changes to the other.
Who needs training?
A good rule to follow is asking yourself which employees may be exposed to hazardous chemicals at work. OSHA recognizes that this scope is intentionally broad, and purposely includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency. For some employers, this may mean needing to train all employees. Being familiar with your operations, the job tasks involved, the associated chemicals, and the possible routes of exposure help determine which members of your workforce require training.
Don’t forget contract and temporary workers. OSHA’s guidance on protecting temp workers makes it clear that it expects the staffing agency and the host employer to share responsibility for worker safety. If you use contract or temp workers at your facility, you as the host employer are responsible for training them about the hazards and HazCom management practices at your facility. Make sure that, among other things, this training includes how to access SDSs, since that becomes important very quickly in an emergency. Your staffing agency should be training their people on general HazCom requirements, and on the hazards of chemicals they regularly work with from one job site to another. Still, it’s important to keep open lines of communication with the agency to make sure that each of you understand their roles and responsibilities, and that no gaps in training or communication occur.
How do I make sure training is effective?
This seems like a no-brainer, right? Training ought to be effective. Unfortunately, we sometimes focus more on conducting the training than whether it actually worked.
When OSHA updated its HazCom Standard to align it to GHS, the Agency made it clear that it was moving from giving workers the right to know to giving them the right to understand. While OSHA doesn’t expect that workers are able to recall and recite all data provided about each hazardous chemical in the workplace, they want workers to understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, have a general understanding of what information is provided in these documents and how to access them.
Let’s talk about what this means in practice, starting with the issue of language. Some employers think they need to train in English, perhaps because they’re confusing their training requirements with language requirements for SDSs and container labels. In reality, training must occur in languages that all covered employees understand. If most of your employees speak English, but a small number are non-English speaking and those employees work with hazardous chemicals, then you must provide training for those employees in the languages they understand.
Beyond language, you also need to train in a manner your employees understand. This means accounting for any limitations in literacy, vocabulary or communications within your workforce. The more workers you have, the less likely a “one size fits all” approach to training will work. For example, training programs that heavily rely on the presentation of written material will not work very well for workers with limited literacy. As a general rule, if you find that you need to provide an employee with job instruction in a certain manner to get the information across, you should provide your HazCom training the same way.
Do you need to train on every chemical you have in your chemical inventory? No, the Standard gives you some latitude there. You can either train your employees on all the individual chemicals they may be exposed to, or you can group your chemicals by hazard classes and categories and train on those. Do what makes the most sense for your workplace. If you don’t have many hazardous chemicals, it might be best to just train your employees on all of them. If you have a huge chemical inventory, grouping your chemicals into hazard categories probably makes the most sense.
Learning management system (LMS) software can help you more easily and effectively meet your training needs by giving you the ability to deliver engaging eLearning courses covering a wide variety of training topics, and in the languages spoken in your workplace. If you’re considering LMS options, look for a solution with built-in course development tools that give you the ability to convert existing PowerPoint training materials into fully interactive eLearning courses, and readily import content from third-party eLearning content providers to help quickly build and maintain an eLearning course library that meets your workers’ training needs.
Should I document my training?
While there is no requirement to document training anywhere in the HazCom Standard, there are still pretty good reasons to do so.
One is that OSHA recommends it, and is specific about what they think ought to be documented, including:
- Date of presentation
- Learning objectives
- Training program outline
- Names of participants, identified by employee identification number or social security number
- Names of instructors
- Any objective data, such as test results, demonstrating that learning objectives were met
Remember, training must occur whenever you’ve changed any aspect of HazCom management, including the introduction of a new physical or health hazards into the workplace, or after finding evidence that training was not effective. Records containing the information listed above allows you more easily and accurately identify these training gaps, and schedule required training as quickly as possible.
The big picture
HazCom training plays a critical role in ensuring workers have the information they need to protect themselves from the hazardous chemicals they work with. But it’s really about changing people’s behavior, and replacing unsafe behaviors based on incomplete knowledge of chemical hazards with safe behavior based on accurate hazard information. Building effective and compliant HazCom training helps you accomplish just that. And when training is done well, it creates the kind of transparency and two-way communication between employees and management that is necessary to improve your EHS culture.
