Wednesday, September 4, 2013

Training Requirements for the Revised Hazard Communication Standard cont'd

Training on the format of the SDS must include information on:

• Standardized 16-section format, including the type of information found in the various sections

✓ For example, the employee should be instructed that with the new format, Section 8 (Exposure Controls/Personal Protection) will always contain information about exposure limits, engineering controls and ways to protect yourself, including personal protective equipment.

• How the information on the label is related to the SDS

✓ For example, explain that the precautionary statements would be the same on the label and on the SDS.

As referenced in Dr. Michaels’ OSHA Training Standards Policy Statement (April 28, 2010) – with all training, 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.

OSHA’s Hazard Communication website has the following QuickCards and OSHA Briefs to assist employers with the required training.

• Label QuickCard (English/Spanish)
• Pictogram QuickCard (English/Spanish)
• Safety Data Sheet QuickCard (English) (Spanish)
• Safety Data Sheet OSHA Brief
• Label/Pictogram OSHA Brief (to come)

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