Page 29 - Occupational Health & Safety, March 2017

uidation at the time of the sentencing.
“If a suitable risk assessment had been undertaken,” said HSE
inspector Laura Catterall, “it would have identified that the equip- ment being used was not right for the chemicals or the work being carried out. All companies who work with high-hazard chemicals should learn from this case and ensure that their workers are prop- erly protected.”
Training and the HazCom Standard’s Mandates
“EPA, OSHA, and DOT each have separate training rules, but there is often overlap among the various requirements. OSHA’s goal is to reduce worker injury and illness. DOT requires all employees who handle or transport hazardous materials to receive general aware- ness, function-specific, and safety training. EPA training focuses on eliminating the release of pollutants and wastes, both on and off site,” according to OSHA’s page on moving hazardous materials with powered industrial trucks.
The key standard2 for working with hazardous chemicals is 29 CFR 1910.1200, the revised Hazard Communication Standard (HCS), which has been aligned with the Globally Harmonized Sys- tem of Classification and Labeling of Chemicals, or GHS.
The HCS is intended to address comprehensively the issue of classifying the potential hazards of chemicals and communicating information on the hazards and appropriate protective measures to workers. It spells out how to maintain a written hazard communi-
cation program, properly label containers of chemicals in the work- place and chemical containers to be shipped to other workplaces, preparing and distributing Safety Data Sheets to employees and downstream employers, and the development and implementation of employee training programs.
Listed in 1910.1200(h) are the requirements for employee train- ing. It says that “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 (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific informa- tion must always be available through labels and safety data sheets.”
This section also says employees are to be informed of the train- ing requirements, about any operations in their work area where hazardous chemicals are present, and about the location(s) and availability of the written HazCom program, including the required lists of hazardous chemicals and the required Safety Data Sheets.
At minimum, employees’ training must include these matters:
■ 1910.1200(h)(3)(i)
Methods and observations that may be used to detect the pres- ence 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
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Circle 19 on card.