Page 28 - Occupational Health & Safety, July/August 2019

CHEMICAL SAFETY TRAINING
one job site to another, you should keep open lines of commu- nication with them to ensure that each of you understands the other’s roles and responsibilities and that no gaps in training or communication exist.
How to Conduct the Training
Effective training is done in a language and method that employees understand. Employers that simply conduct their training for the sake of completing the necessary task with little regard of whether the information is being retained will be unable to convince an OSHA inspector that they’ve met their HazCom training require- ments. That’s because OSHA feels its adoption of GHS in 2012 has taken the standard from being one that gave workers the right to know, to one that gives workers the right to understand, thanks to harmonized hazard communication information on SDSs and labels and the introduction of pictograms, which use images to convey hazards.
In a guidance document for small business entities, OSHA clarifies that while it does not expect workers to be able to recall and recite all of the data provided about each hazardous chemical in the workplace, it does expect that they understand how to go about getting access to specific hazard information on labels and SDSs, how to read labels and SDSs, and how to access them in their work environment.
So how does this translate into conducting effective training? Let’s first look at language. Employers often seem to think they
need to train in English, perhaps because they’re confusing train- ing requirements with the language requirements for SDSs and container labels. In reality, training must be done in a language that covered employees understand. If most of your employees speak English but some do not, then you must provide training in English to those who do understand it and also in whatever oth- er language(s) your other employees understand. This is an area where on-demand, online training solutions may be helpful, and the top solutions offer a range of course options in multiple lan- guages to help you meet this requirement.
Beyond language, you also need to train employees in a manner they understand. This means you must account for any limitations in literacy level or vocabulary within your workforce. The more employees you have, the less likely it is that a one-size-fits-all train- ing approach will work. For example, training programs that heav- ily rely only on presentation of written material will not work very well for workers with limited literacy. As a general rule, if you find that you need to provide an employee with regular job instructions in a certain manner to get the points across, you should provide your HazCom training the same way.
How to Document Training
While the HazCom Standard doesn’t specifically require employers to document training, it is something they recommend and even pro- vide suggestions for what should be documented, including: date of presentation, learning objectives, training program outline, names
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