Page 40 - Occupational Health & Safety, July 2017

GHS/SDS TRAINING
GHS HazCom Training is More Important Than Ever
An effective HazCom training program pro- vides employees with a deeper understanding of the dangers and emergency situations they may face.
BY MELISSA MCCAFFRI
training can either concentrate on a specific chemical and its hazards or a category of similar hazards for dif- ferent chemicals; the key here is that it provides em- ployees with a deeper understanding of the dangers and emergency situations they may face.
Keep in mind that employees must also continue to receive training on some pre-GHS HazCom ele- ments if both older MSDS and newer SDS document formats still exist in the chemical inventory. Even though the final GHS changes have gone into effect, many facilities still have MSDSs in their libraries. Reasons for this include the following: a facility not yet having received a new product shipment since a manufacturer’s updated SDS was created, a facility using a chemical from a manufacturer that has gone out of business, or a facility using a manufacturer that simply hasn’t re-authored an MSDS to the new SDS format—due to their own internal delays or delays farther upstream from their source chemical suppli- ers. In general, the onus falls on the employer to know whether these pre-GHS formatted documents are still in circulation around its facility and to provide train- ing on these formats for as long as they remain in use.
Step Two: Deliver Training So
Employees Can Understand It
When OSHA first published its HazCom Standard in 1983, it championed the concept of the employee’s “right-to-know” about the hazards to which they are exposed, which has greatly shaped the safety culture currently in place at many workplaces today. That said, a primary driver for OSHA’s adoption of GHS was the desire to improve employee comprehension of critical chemical safety information.
With GHS, OSHA is saying it’s not enough for workers to just know about the hazards in their work environment; instead, they also have the “right-to- understand” those hazards and to know what related safety precautions to take. Considering the overall changes brought by GHS alignment, this subtle word adjustment is easily overlooked, but it’s a critical clue into OSHA’s expectations for employee training.
The pre-GHS employee right-to-know concept of- ten translated most literally into giving workers access to MSDSs and labels and making sure they were aware of the hazards that existed for the chemicals in their work environment. However, this approach didn’t al- ways translate to employees actually understanding the safety and health information being conveyed on the documents and labels.
GHS adoption helped solve this issue by bring- ing harmonization and consistency to the structure of safety data sheets and labels. Use of standardized hazard communication elements such as pictograms,
40 Occupational Health & Safety | JULY 2017
www.ohsonline.com
EY
n the United States, the final GHS deadline is now long behind us. However, OSHA’s alignment of the Hazard Communication Standard (HazCom) to GHS provided a wakeup call to millions of
companies across the U.S. that they need to do a bet- ter job with their HazCom programs, especially when it comes to training. HazCom violations remain num- ber two on OSHA’s top 10 list of violations, with train- ing failures being a big driver of citations.
In this article we’ll look at four steps employers can take to ensure employees understand the chemi- cal hazards present in their work environment and to comply with GHS updates to HazCom.
Step One: Build a Training Program
Focused on Efficacy
While OSHA doesn’t specify how to do training, it does state that the training must be effective. In short, employees must carry their learning into the work- place and be able to put it into use. HazCom training has two key components: one, providing employees with a basic understanding of the HazCom Standard; and two, training employees on the specific hazards of the chemicals to which they are exposed.
Regarding the first item, it’s no coincidence that OSHA’s first GHS deadline focused on employee training because workers needed to understand the new SDS and label formats that accompanied GHS adoption. For some companies, meeting this GHS training deadline wasn’t a major cause for concern. However, GHS alignment uncovered an unsettling truth: Many employers lacked a basic level under- standing of HazCom, making it difficult for them to comprehend and address the changes brought on by GHS. As a result, these employers’ workers either had never been adequately trained on HazCom in the first place or had been trained so long ago that what they had learned had been forgotten. Moving forward, it’s critical that employers continue to em- phasize basic HazCom training, which now includes GHS-aligned information to ensure employees are actually able to use that information in the course of their day-to-day activities.
The second component of an effective HazCom training program goes a step further by focusing more on the individual hazards employees face. Depending on the hazardous chemicals present in the facility, this