Page 15 - OHS, April 2022

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practices change—something that OSHA will be checking if they visit your workplace.
Fix Your SDS Access
ThThe whole purpose of the HazCom Standard is to protect workers who are exposed to hazardous chemicals. It shouldn’t be a surprise that one of the most central responsibilities of an employer is to ensure their workforce can access the SDSs for chemicals they work with during their work shifts.
The key is that they must have access to the exact documents for the exact chemicals they work with, which means you have to maintain the SDS for the chemicals provided by the manufacturer, rather than “generic” SDSs. You also can’t have any barriers to access. Well-intentioned employers will often place binders of SDSs in a “right- to-know station” in a supervisor’s office, not realizing that the supervisor may lock the office when away, thereby preventing workers from accessing the documents in the event of an emergency.
OSHA allows for the use of internet or software-based systems to provide access to SDSs, as long as the system provides access to the specific SDSs for chemicals at your facility. The agency specifically states that this does not mean you can provide access by telling your employees to perform an internet search for the document. There’s no telling if your employee will locate the SDS for the correct chemical being used, or that the document they find online is the most current or accurate version of the SDS needed.
The real test is whether your system can provide quick access to SDSs. How quick? Think of how quickly you need to be able to retrieve an SDS in the event of a major chemical spill, fire or other emergency. If you have concerns about how well your current system would perform you should strongly consider one that can cut down response time to mere seconds, such as a cloud-based SDS management system.
Train Like Your Program Success Depends on It (Because It Does) Training for the sake of training is a common pitfall that undermines so many HazCom training efforts. Ignore any talk you hear about “annual training.” Many people speak earnestly about the need to do annual HazCom training as a requirement within the HazCom Standard.
The problem is the annual training mindset negatively impacts compliance and
jeopardizes their HazCom management success. For one thing, OSHA doesn’t say you need to conduct training annually. What they actually say is that you need to conduct training at the time of initial work assignment and “whenever a new chemical hazard the employees have not previously been trained about is introduced into their work area.” You should also provide training whenever there is evidence that it was ineffective. For example, if employees don’t know where or how to access SDSs and are unable to find emergency response information on an SDS.
This mindset also risks fossilizing your training program, causing you to trot out the same old deck year after year instead of updating it when new chemical hazards are brought onsite and redoing it when needed. This makes for poor compliance and bad HazCom safety awareness.
Don’t convince yourself that you can demonstrate compliance just by proving you’ve done the training. Just doing the training and documenting it doesn’t neces- sarily mean you’ve met your obligations. The most important thing is that employees un- derstand the training. OSHA judges training compliance on a performance basis, mean- ing that they’ll only be convinced you’ve met their requirements if employees can demon- strate they understood the training.
That said, you should still absolutely document your training. OSHA recommends documenting specific aspects of training such as the outline of the training program, the identification of employees who attended and of the trainers, test or evaluation results and dates that training was conducted. This information will also help you determine when you may need to repeat training. For instance, if you know you last conducted training before you introduced a new chemical hazard class in the facility, that means your employees need to be retrained as soon as possible.
Preparing for the Future
While it can be difficult to get your bearings straight when it comes HazCom, I guarantee righting the ship now is the best way to help you prepare for the changes to come. Use this time to identify gaps in compliance now so you can seek additional help ahead of the next transition.
Dave Risi, CIH, CSP is the Principal Solution Strategist of Industrial Hygiene Solutions at VelocityEHS.
www.ohsonline.com
APRIL 2022 | Occupational Health & Safety 11