Page 34 - OHS, July/August 2022

TRAINING: HAZARD COMMUNICATION
Three Quick Steps to Better HazCom Training
High-level considerations can go a long way to improving your facility’s effectiveness.
BY PHIL MOLÉ
When I worked as a regulatory consultant, I conducted many site visits to evaluate companies for compliance with OSHA’s HazCom Standard. During many of those visits, I would identify a disconnect. The facility’s management would have many of the right program elements in place, like a mostly complete library of safety data sheets (SDSs) and chemical inventory list, a written HazCom Plan (although not usually site-specific or detailed enough), and an obvious effort to make sure all hazardous chemical containers are labeled. But on the plant floor, when I’d ask an employee how they’d access an SDS, or who they could go to for more information about HazCom management practices, I would get lots of blank stares and shoulder shrugs in response. The causes of that disconnect were problems in the facility’s HazCom training practices.
Luckily, there are a few high-level considerations that can go a long way toward improving your training’s effectiveness. There are three simple steps you can take to build and maintain a HazCom training program that works.
Train All Employees Who Need It
The first step is to determine which of your employees need HazCom training. Some employers miss this part, because they’re so set on getting the training done, but don’t put enough thought into identifying all employees who need it.
How do we know which employees need training? It comes down to determining which employees may be exposed to hazardous chemicals at work, because 1910.1200 (b)(2) states that the HazCom Standard’s scope applies “to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or
in a foreseeable emergency.” In letters of interpretation, OSHA clarified that “foreseeable emergency” would include equipment failure, rupture of containers, or failure of control equipment, all
1 of which could result in an uncontrolled release.
This is a broad scope, and for some employers, it may mean that they need to train all employees, including temporary and contracted workers at their work locations. You’ll need to make the best decision possible based on familiarity with your operations, the job tasks involved, the associated chemicals, foreseeable emergencies and the possible routes of exposure. Consulting employees and involving them in this process is a good way to improve the quality of information available.
Include the Right Things in Your Training
Now that you’ve selected the right employees to train, you need to select the right content to include in your training. According to the standard, your HazCom training needs to cover:
■ “The requirements of this section,” as OSHA puts it in 1910.1200 (h)(2)(i). In OSHA guidance documents, such as the Small Entity Compliance Guide for Employers That Use Hazardous Chemicals, OSHA elaborates that training must cover “the general requirements of the Hazard Communication Standard.”2
■ Safety data sheets (SDSs) and labels (manufacturer shipped labels and workplace labels) and how to read, use and understand the information, including the order of information on an SDS.
■ Ways of detecting the presence or release of chemicals, whether through the use of monitoring equipment or simple observations. If you use digital monitors, talk about where they are, what they measure and how to interpret the readings. Make
30 Occupational Health & Safety | JULY/AUGUST 2022
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