Page 26 - Occupational Health & Safety, July/August 2019

CHEMICAL SAFETY TRAINING
Getting It Right: Creating and Deploying an Effective and Compliant Chemical Safety Training Program
Make sure the methods discussed for detecting the presence or release of chemi- cals lines up with the specific chemicals and hazards you have at your facility.
BY MELISSA MCCAFFRWEY
hile employee training is a critical part of OSHA’s Hazard Communication Standard (HazCom), it’s also an area where employers often fall short and
information on the usage of personal protective equipment (PPE), safe work practices, engineering controls, and any other specific procedures or con- trols you’ve implemented.
■ Hazard Communication Program details. OSHA expects employees to understand the details within your company’s written HazCom Plan, in- cluding the specific management practices for the chemicals at your facility. A key factor here is ensur- ing that you’ve updated both your written HazCom Plan and training to reflect any changes to your chemical management system.
Who Needs to Be Trained
While many employers do a good job of providing the right training content, they often fall short in identify- ing all of the workers who need to be trained.
It basically comes down to the question of which employees may be exposed to hazardous chemicals at work. In its “Hazard Communication Guidelines for Compliance” document, OSHA states that it in- tentionally kept this scope broad and “includes any situation where a chemical is present in such a way that employees may be exposed under normal con- ditions of use or in a foreseeable emergency.” For some employers, this may mean that you need to train all of your employees, while for others it may only include a select group. The important thing is to be familiar with your operations, the job tasks involved, the associated chemicals, and the possible routes of exposure to determine which members of your workforce require training.
Don’t forget to include contract and temporary workers. OSHA’s recent guidance on protecting temp workers, including its Temporary Worker Initiative (TWI), makes it clear that they expect the staffing agency and the host employer to share the respon- sibility for worker safety. This means that if you use contract or temp workers at your facility, you as the host employer are responsible for training them about the hazards and HazCom management practices at your facility. Make sure that, among other things, your training includes how to access SDSs, because this can become important very quickly during an emergency.
While the staffing agency should be training its people on general HazCom requirements and on the hazards of chemicals they regularly work with from
struggle with the basic elements that make training effective, engaging, and, most of all, compliant.
Whether you’re establishing a new chemical safety training program or just looking to update your cur- rent program to make it more effective, it’s critical that you have a solid understanding of your training obli- gations under OSHA’s HazCom Standard. The follow- ing is a helpful overview of common training compli- ance mistakes and misconceptions, along with some best practices to help you avoid them and ensure your employees are getting the most out of your chemical safety training program.
What Information Training Must Cover
Understanding what the HazCom Standard requires for employee training is a critical first step in cre- ating an effective chemical safety training program. This includes:
■ The contents of the HazCom Standard itself. This might seem redundant, but employees should know what the standard is and understand that it re- quires chemical manufacturers to provide safety data sheets (SDSs) and shipped container labels for prod- ucts shipped to downstream users, and also employers to provide them with information about the hazards of the chemicals in their workplace.
■ Detecting the presence or release of chemicals. Whether done through use of monitoring equipment or simple observations, such as odors or visible evi- dence of sheens or stains, employees must know how to detect a chemical release. If you use digital moni- tors, include information about where they are, what they measure, and how to interpret the readings. And make sure the methods discussed for detecting the presence or release of chemicals lines up with the spe- cific chemicals and hazards you have at your facility.
■ Physical and health hazards of hazardous chemi- cals in the workplace. If the hazard is present in your fa- cility, training must cover it. This includes those from simple asphyxiants, combustible dusts, and pyrophoric gases, as well any hazards not otherwise classified.
■ How employees can protect themselves from chemical hazards. This includes clear and detailed
24 Occupational Health & Safety | JULY/AUGUST 2019
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