Page 36 - OHS, July/August 2022

TRAINING: HAZARD COMMUNICATION
Counting on Complacency in HazCom
Complacency and memory play a much bigger role in HazCom compliance than you think.
BY RAY PREST
Safety professionals at over five million workplaces have set up a hazard communication system. They’ve trained over 40 million employees on chemical risks and how to use the system. But having a system to manage chemicals and providing knowledge of chemical dangers doesn’t mean those employees are consistently attentive to them or follow the system to the letter.
As the person responsible for hazard communication, you have the right to know that what OSHA tells you isn’t enough to ensure workers always comply with OSHA’s own standard. The safety agency gives you the what, but not all of the how. And for your employees, OSHA provides them with the right to know, but not what they should want the right to know about. In particular, there are two keys to compliance that OSHA will likely never provide.
The standard that’s known as the “right to understand” needs an update. But not the proposed update in which OSHA wants to move from an old version to a slightly less old but still outdated version of GHS. Instead, I propose that the “right to know”
part should include the right to know about human factors like complacency and memory, two elements in chemical handling failure or success. These two factors play a much bigger role in HazCom compliance than most people give them credit for.
Complacency and the Right to Know
Policymakers and safety advocates have been urging reluctant manufacturers to provide transparency on all manner of products for years, leading to information overload for end users. It’s to the point where people now give disclosure documents only a cursory skim or ignore them completely because of how common they are, as well as their length, complexity and lack of clarity.
If you’ve ever purchased a new car or agreed to a tech company’s terms of service, you’re well aware that the devil resides in the details. It doesn’t take a lawyer to know there’s all sorts of weaselly clauses in the pages of legalese you’re asked to agree to.
And yet, we all sign the contract anyway. We understand the basic contours of the bargain: you get the car in exchange for money, or you get to use the app in exchange for your user
32 Occupational Health & Safety | JULY/AUGUST 2022
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