Page 35 - OHS, July/August 2022

sure that the methods discussed here align with the specifific chemicals and hazards at your facility.
■ ThThe physical and health hazards of chemicals in your workplace, as well as any hazards not otherwise classifified. ThThe standard gives you the flflexibility to either train your employees on all the individual chemicals they may be exposed to, or to group your chemicals by hazard classes and categories and train on those. Do what makes the most sense for your workplace. Just remember that if the hazard is present in your facility, you need to cover it in training.
■ How employees can protect themselves from chemical hazards, including the use of PPE, safe work practices, engineering controls and any other specific procedures or controls you’ve implemented. It’s important for both the safety of your workplace and the compliance of your training program that you have some form of exposure control identified for all of the specific hazards present in your facility. Be clear and detailed enough to eliminate any potential confusion.
■ Details of your Hazard Communication Program, including how you manage SDSs and shipped labels, your facility’s chemical inventory, methods for accessing SDSs at your facility, the details of your workplace labeling system, how to properly store chemicals, what to do in the event of chemical emergencies, who to seek out for more information, how/where to access the written plan and any other details you believe are important for effective HazCom management. Since your training program and written HazCom plan are complementary pieces of your chemical management system, any changes or updates to one will likely necessitate changes to the other.
Review and Update Your Training Program
You won’t be able to maintain an effective HazCom training program unless you are verifying your training’s effectiveness, documenting your training, and then using that information to revise your training program.
On OSHA’s landing page for its 2012 final rule that updated HazCom Standard to align with Revision 3 of the UN’s Globally Harmonized System of Classification and Labelling of Chemicals (GHS), the Administration made it clear that it was moving from giving workers the “right to know” to giving them the “right to understand.”3 In other words, the test that you’re meeting your regulatory obligations as an employer isn’t that you’ve done the training; it’s that your employees understand the training. The standard also specifically states that you must train in a manner and language your employees understand. Training and learning software can help you more easily and effectively meet your training needs by giving you the ability to deliver engaging eLearning courses in the languages spoken in your workplace, and by offering employees the ability to complete training at their own pace.
What does that mean in practice? While OSHA doesn’t expect that workers are able to recall and recite all data provided about each hazardous chemical in the workplace, they want workers to understand that they are exposed to hazardous chemicals, know how to read labels and SDSs, have a general understanding of what information is provided in these documents and how to access them.
And while documentation of training is not the benchmark
for compliance, it’s still important because without good documentation you’ll lack the information you need to assess if your training was effffective. OSHA advises that your training documentation should include the training date, learning objectives and outline of training content, the names of trainees (by employee identification number or social security number), the names of instructors and any objective data (e.g., test results) demonstrating that employees understood the training.
Of course, the key is to actually use the feedback you’re getting to improve training. For example, if you’re either seeing in person, or via review of test results, that many employees don’t seem to understand your site-specific process for accessing copies of SDSs, you know you need to address that—and sooner rather than later, given the importance of that knowledge to everyday safety. The right level of documentation also helps you determine when you’ll need to revise content to account for major changes to your HazCom practices, such as introduction of a new chemical hazard class to the workplace, or replacement of a physical SDS library in binders with a cloud-based software system.4
Keeping HazCom Training in Perspective
Let’s wrap up by focusing on the big picture, because that might give us the perspective we need to improve our HazCom training. Before the HazCom Standard existed, fatalities and illnesses from occupational chemical exposures were far more common because employees lacked information about the hazards of the chemicals in their workplace and about the equipment and practices needed to store and use them safely. The underlying purpose of the HazCom Standard, in the words of one of OSHA’s HazCom guidance documents, is “to reduce the incidence of chemical source illnesses and injuries.”5 One of the most important ways to accomplish that is by providing employees with the information and training they need to work with chemicals as
safely as possible.
The key takeaway here is not to see your training program as a
“box checking” exercise needed to meet a regulatory requirement. Instead, see your training as what it is: a central part of your active commitment and responsibility as an employer to provide all of your employees with a safe workplace.
By following the three simple steps outlined in this article, you can build and maintain the kind of HazCom training program that you’d want if you were in your employees’ shoes. It’s training focused on outcomes that’s flexible enough to meet the needs of your entire workforce, and that has the commitment to continuous improvement needed to make your workplace safer and more sustainable.
Phil Molé currently works as an environment, health, and safety (EHS) and sustainability expert for VelocityEHS.
REFERENCES
1. https://www.osha.gov/laws-regs/standardinterpretations/1997-06-20 2. https://www.osha.gov/sites/default/files/publications/OSHA3695.pdf 3. https://www.osha.gov/hazcom
4. https://www.ehs.com/solutions/safety-management-solution/
5. https://www.osha.gov/sites/default/files/publications/OSHA3695.pdf
www.ohsonline.com
JULY/AUGUST 2022 | Occupational Health & Safety 31