Page 33 - Occupational Health & Safety, July/August 2019

of participants (employee identification number or Social Security number), names of instructors and any objective data, such as test results, demonstrating that learning objectives were met.
One reason why training documentation is important goes back the need to update training content with any changes made to your chemical management system, including the introduc- tion of new physical or health hazards into the workplace, or af- ter finding evidence that training was not effective or no longer retained. Without the right kind of training documentation, this can be difficult to accomplish.
Of course, maintaining records with this level of detail for all of your workers can be challenging, especially if you have a large workforce or are managing HazCom across multiple establish- ments. Consider the benefits of using modern EHS software to help assign and track training, which also will help you to easily verify that training is complete and understand when you need to retrain.
Why Avoid the ‘Annual Training’ Mindset?
Another common misconception about training is that OSHA requires employers to conduct annual refresher training. In real- ity, OSHA states that employees must be trained before they begin working with hazardous chemicals and whenever a new hazard is introduced into the workplace or there’s evidence that training was not effective.
The problem with the “annual training” mindset is it can be harmful to your HazCom program. Training has a way of becom-
ing fossilized; once a year, you dust off your training materials and go through the same motions to train your workforce once again. But let’s say that during the last year you’ve introduced new chemi- cal hazard categories or changed key aspects of your management system. It can be easy to neglect updating your training because you didn’t think it was time to do so, and as a result you’re now out of compliance with HazCom requirements.
Keeping an Eye on the Big Picture
Chemical safety training ensures workers have the information they necessary to protect themselves from the hazardous chemi- cals they work with. However, what we are really talking about here is changing employees’ behavior and mindset by replacing unsafe behaviors based on incomplete knowledge of chemical hazards with safe behavior based on accurate hazard information. Effec- tive HazCom training helps accomplish that and, when done well, creates the kind of transparency and two-way communication be- tween employees and management that is necessary to improve your EHS culture.
Melissa McCaffrey is an EHS & Sustainability Expert and Director at VelocityEHS, a leader in cloud environment, health, safety (EHS) and sustainability software. To learn more about VelocityEHS and the ways its MSDSonline Chemical Management solutions can help you manage your chemical inventory and reach your EHS goals fast- er, visit www.MSDSonline.com and www.EHS.com.
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