Page 74 - OHS, July/August 2020

TRAINING: CHEMICAL SAFETY
Why Effective Chemical Safety Training Is More Important Than Ever
Despite being a critical component of employee safety, HazCom training is one of the most overlooked elements of employer safety programs.
BY PHIL MOLÉ
Despite being a critical component of em- ployee safety, HazCom training is one of the most overlooked elements of employer safety programs. And now, the recent global
COVID-19 pandemic has presented several new chal- lenges to millions of workplaces, as an increasing number of chemical disinfectants are being intro- duced into workplaces, creating a critical need for ad- ditional chemical safety training.
For instance, OSHA’s Hazard Communication Standard (HCS) does not require employers to in- clude consumer cleaning products in their workplace HazCom program when those products are used as intended by the manufacturer. However, those same products when used in a different manner, including in greater quantities, durations or frequencies that result in a range of exposures greater than that expe- rienced by typical consumers, can be subject to the stricter requirements of the HCS.
Today, COVID-19 has created an urgent need for more frequent disinfectant use for cleaning potentially contaminated surfaces and limiting the further spread of the SARS CoV-2 virus. As a result, workplace ex- posures may now exceed the range of the typical con- sumer, triggering coverage under OSHA’s HCS.
The five key components to OSHA’s HCS and high-level employer responsibilities are:
1. Maintain a Written HazCom Plan
2. Keep an updated written chemical inventory
3. Ensure proper labeling of hazardous chemicals 4. Maintain and provide access to safety data
sheets (SDSs)
5. Train employees on HazCom and chemical hazards As one of the main pillars of HCS, employee train-
ing is critical not just for workplace safety, but for your company’s overall regulatory compliance. While OSHA doesn’t expect workers to be able to recall and recite all the data provided about each hazardous chemical in the workplace, effective training ensures employees are aware that they are exposed to hazard- ous chemicals, know how to protect themselves from those hazards—including how to detect releases of those chemicals—and where to get specific hazard in- formation (e.g., from SDSs).
And in addition to making sure employees have access to the corresponding SDS for any new chemi- cal disinfectant introduced to the workplace when use of that product extends beyond that intended by
the consumer product manufacturer, employers must also pay special attention to the dangers that result from the misuse or mixing of these chemicals with others in use or present at your workplace, and ensure the proper safeguards and training is in place.
Following is a deeper look at how to make chemi- cal safety training effective, engaging and relevant so your employees are getting the most from it.
Building an Effective HazCom Framework
When it comes to HazCom training, OSHA requires employers to train people on the hazardous chemicals in their work areas, which can be achieved through training on specific chemical products or types of chemicals (such as acids, bases or flammables). Em- ployers are also required to train on the details of the Written HazCom Plan, which must explain how SDSs are managed and ways to access them. Additionally, your employees should be able to read and under- stand the SDSs and corresponding container labels— both the shipped and workplace/secondary labels. Outside of these parameters, OSHA gives a significant amount of bandwidth to employers to determine how they deliver training and ensure that it’s effective.
An effective chemical safety training program should include:
The HazCom standard basics. Employers are required to train on HazCom in general. An impor- tant fact that employees should know is that chemi- cal manufacturers are required to provide SDSs and shipped container labels for products shipped to downstream users, and those downstream users (em- ployers) must provide information about the hazards of the chemicals in their workplace to employees be- fore they come into contact with them.
Hazard communication program details. OSHA expects employees to understand the details within your company’s Written HazCom Plan, including, but not limited to the specific SDS and label manage- ment practices for the chemicals at your facility. A key factor here is ensuring that you’re updating both your Written HazCom Plan and training to reflect any changes to your chemical management system.
Physical and health hazards of chemicals in the workplace. If the hazard is present in your facility, training must cover it. This includes those from sim- ple asphyxiants, combustible dusts and pyrophoric gases, as well any hazards not otherwise classified.
68 Occupational Health & Safety | JULY/AUGUST 2020
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