Tuesday, October 20, 2015

Steps to an effective hazcom training for employers

5. Inform and train employees (cont'd)

HazCom 2012 requires employers to both provide certain information to employees and to train employees. The standard requires employees to be informed of:
  • The general requirements of the Hazard Communication Standard;
  • Where hazardous chemicals are located in their work areas (operations where exposure may occur); and,
  • What the workplace hazard communication program includes, and where and how they can access the program.
 Training, on the other hand, is a more active process. The training conducted to comply with HazCom 2012 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.);
  • 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 fromexposure 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.
 A properly conducted training program will ensure worker comprehension and understanding. 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 HCS 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, for example, purchasing,
storing, and handling of these chemicals will improve, and thereby reduce the risks posed to workers exposed to the chemical hazards involved.

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