Page 75 - OHS, July/August 2020

How to detect the presence or release of chemicals. Whether done through use of monitoring equipment or simple observa- tions, like odors or visible evidence of sheens or stains, employees must know how to detect a chemical release. If digital monitors are used, 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 chemi- cals lines up with the specific chemicals and hazards you have at your facility.
Guidance on the storage and disposal of chemicals. Safe use of a product includes ensuring chemicals are returned to storage in the appropriate manner, using the proper equipment. Similarly, the cleanup and disposal of chemicals is often overlooked, creating hazardous conditions both for employee safety.
Hazardous chemical protection. This includes clear and de- tailed information on the usage of personal protective equipment (PPE), safe work practices, engineering controls and any other spe- cific procedures or controls you’ve implemented.
Training is only effective if employees receive it. While many employers do a good job of providing the right training content, they often fall short in identifying all the workers who require train- ing. OSHA has stated that it intentionally kept the scope of who re- quires training broad in its Hazard Communication Guidelines for Compliance document, saying this “includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.”
For some employers, this could mean that training is needed for all your employees, while for others it may only include a select group. Overall, it’s important to be familiar with your operations, the job tasks involved, the associated chemicals, and the possible routes of exposure when determining which employees require training.
One important tip is to pay attention to Section 7 of the SDS, which includes information about everyday storage and usage (mentioned above), including incompatible chemicals to avoid. Many cleaning and disinfecting chemicals are incompatible with others, and because of recent disinfectant shortages people may consider using some chemicals at the same time or blending them together, which makes it essential for your workers understand how to avoid inadvertent, dangerous chemical reactions.
A quick example is mixing acids with bases. Common cleaning products that include acids are hard water/mineral deposit remov- ers, toilet bowl cleaners, rust removers, tub and tile cleaners, mold removers and vinegar. Some common cleaning products that in- clude bases include bleach and bleach-containing products, glass and all-purpose cleaners (which often contain ammonia), drain cleaners, laundry detergents and baking soda.
Making Training Engaging
HazCom training must be delivered in a language and method that employees understand. The true test of whether training has been effective or not is whether they can put that training to use in the workplace. Employers who conduct training simply for the sake of completing the task, with little regard of whether the information is being retained, will have a difficult time convincing an OSHA inspector that they’ve met their HCS training requirements.
This is an area where today’s on-demand, online training so- lutions are useful. Feedback VelocityEHS has received from thousands of safety professionals is that the move these days is to
training software that offers an extensive library of flexible online courses with content that is interactive and engaging. Shorter, more digestible training courses are particularly appealing to younger workers, while multi-language options help ensure all employees understand the information being conveyed.
Especially in today’s climate, employers are looking to free em- ployees from a centralized classroom environment and provide workers access to courses from remote locations where they learn at their own pace.
A complete learning management system (LMS) is a flexible and intuitive system for managing e-learning assignments, training con- tent, and all of workplace training program activities—including virtual classroom (distance learning) sessions and in-person class- room training activities—across the entire organization through a centralized cloud-based system. Best of all, these systems give you the agility to complete your training in the physical workplace or re- motely, which is even more important in uncertain times like these.
Look for a solution that can turn existing PowerPoint presenta- tions into fully interactive e-learning courses or allows you to im- port content from a wide selection of third-party content providers for easier program management. The best systems even provide updated COVID-19 training content to ensure employees under- stand newer risks they encounter in the workplace.
Keeping Training Relevant & Enjoyable
While most employees understand the necessities of training, it is often not something they look forward to, which creates an addi- tional barrier for employers to overcome.
Employees respond better to HazCom training material when they understand the reasoning behind it. Ensure your training demonstrates the real-life implications of what is being taught. And continue that training out on the floor. Test your people on the course elements on-the-fly in the actual settings where they would need to know the information quickly. This will give work- ers the chance to showcase how the lesson applies to their actual work tasks, and further reinforces why it’s so important to retain the information being conveyed.
Another way to make training relevant is by adjusting the qual- ity of your training objectives. If your objectives are too vague, you won’t know whether you’ve met them or not. Challenge yourself to create specific objectives, with performance conditions spelled out that you can test against, so you know when your training is hitting the mark and can quickly fix problems when it’s not.
Worker Training for the “New Normal”
The need for dynamic HazCom training has never been greater. Traditional course lesson methods involving text-heavy presenta- tions and stand-up lecturing can have a hard time connecting with a diverse and technologically advanced workforce. As you adjust your HazCom training to the real-world conditions we are operat- ing under, be sure to look for solutions that are interactive, partici- pative and engaging so that your training helps your people meet the challenges of a changing world.
Phil N. Molé is an EHS & Sustainability Expert at VelocityEHS, the global leader in cloud environment, health, safety (EHS) and sustainability software. To learn more about VelocityEHS and its MSDSonline Chemical Management solutions, visit www.EHS.com.
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