Tuesday, November 10, 2015

Steps to an effective hazcom training program for employers

Furthermore, your workers’ comprehension will also be increased, and proper work practices will be
more likely followed in your workplace.

If you are going to do the training yourself, you will have to understand the material and be prepared to motivate the workers to learn. This is not always an easy task, but the benefits are worth the effort. More information regarding appropriate training can be found in Appendix B of this guide, which provides steps to follow in setting up and conducting training.

In reviewing your hazard communication program with regard to information and training, the following items need to be considered:

  1. Designation of person(s) responsible for conducting training;
  2. Format of the program to be used (audiovisuals, classroom instruction, etc.);
  3. Elements of the information and training program (should be consistent with the elements in paragraph (h) of the standard); and,
  4. Procedure 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.

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. When assessing an employer’s compliance with hazard communication training requirements, OSHA CSHOs 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—just like other job requirements and instructions are provided. OSHA has bilingual CSHOs, and they will be speaking to workers who speak another language to determine compliance.

The standard does not require employers to maintain records of employee training, but many employers choose to do so. This may help you monitor your own program to ensure that all workers are appropriately trained. 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. If your initial training program includes all potential hazards covered by HazCom 2012, there is no retraining required. However, it is good business practice to repeat and reinforce what is learned in training to make sure that workers retain the hazard information.

If you already have a hazard communication training program, you may simply have to update it to comply with HazCom 2012. In particular, by December 1, 2013, you will need to train your employees about the new label and SDS formats they will be seeing in their work areas. Additional
hazard training is not required if you have already trained under the existing hazard communication
requirements. However, after you receive all of the new labels and SDSs, and have updated your
hazard communication program, you may find that there is a type of hazard on which employees have
not yet received training. You will need to train employees on these new hazards at the time you
become aware of the new hazard. If you become aware of new hazards after December 1, 2015, you
will have until June 1, 2016 to ensure those hazards are included in the hazard communication program, the workplace labeling reflects these new hazards, and employees are trained on these new hazards.

An employer can provide employees information and training through whatever means are found appropriate. Although there will always have to be some training onsite (such as informing workers of the location and availability of the written program and SDSs), employee training may be satisfied in part by general training about the requirements of the HCS and about chemical hazards on the job which is provided by, for example, trade associations, unions, colleges, and professional schools. In addition, previous training, education and experience of a worker may relieve the employer of some of the burdens of informing and training that worker. Regardless of the method relied upon, however, the employer is always ultimately responsible for ensuring that workers are adequately trained. If the CSHO 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.