Page 38 - OHS, July/August 2022

TRAINING: HAZARD COMMUNICATION
just a single click away, we never go back to read the legally binding agreements that govern our behavior. We can opt out at any time, can change our behavior if we want to. But we almost never do. All of this is to say that in many ways, the very nature of contracts breeds complacency.
This entire discussion about complacency brings us back to HazCom. In many ways, if we want to understand how workers can become complacent when working with chemicals that are clearly labeled as being extremely dangerous, we should look at contractual complacency as a primary culprit.
Remember the SDSs
Safety data sheets aren’t contracts per se, but they bear many of the hallmarks of contracts. They are often written in plain language that inadvertently downplays the seriousness of any potential incidents. This isn’t the fault of the sheets and labels, as that’s just how language and the human brain work. And while workers tend to remember the general bargain—in exchange for a paycheck they must work with hazardous substances they should be mindful of—they often forget the devilish details of what can happen if something goes wrong. Not to mention forgetting all the various chemicals, classifications and components within the system that can lead to potentially serious incidents.
There’s a handy OSHA BRIEF that “provides guidance to help workers who handle hazardous chemicals to become familiar with the format and understand the contents of the SDSs.” It’s only seven pages but it packs 16 required sections and 88 lengthy bullet points to understand and remember. No problem for Mongolian memory champion Munkhshur Narmandakh, but that’s about 81 more things than most people can hold in short- term memory while learning something new.1
To make matters worse, HazCom’s extensive details and relationship to complacency isn’t limited to contract-type zoning out of risk and information overload. The well-documented phenomenon of inattention blindness—when people fail to cognitively register certain objects in their visual field, especially if they are ever-present, like a wet-floor sign or other static hazard warning—is also at play. One classic study in the field of human factors found “evidence that on-product warnings have no measurable impact on user behavior and product safety.”2
The gist of all this research is that frequent exposure to a hazard breeds overconfidence, complacency and—in some cases—a literal inability to notice a warning label. Infrequent use or lots of variability with handling different chemicals can also present extensive challenges to memory. On the flip side, as we will see, frequent communication about the hazards fights complacency.
Safety data sheets have all sorts of thorny ways in which they can prick people with complacency. What’s a safety professional to do? It’s not like you can take a Sharpie to chemical labeling to literally underline the dangers. Even if you could, workers would quickly become familiar with your touch-ups to the point of being blind to them.
If people don’t remember the procedure or where information is, if they forget to check the label or SDS, or if they aren’t able to explain to an OSHA inspector the how of their specific chemical handling, then you’re not likely to be in regular compliance, even if the written documents, signs and labels are in place.
One way to remember HazCom training is by engaging in frequent two-way communication to disrupt complacency.
Problem, Solution, Same
Fortunately, the challenges of complacency and memory also offer a solution to effective HazCom training. One way to help people remember is by engaging in frequent two-way communication to disrupt complacency and shore up hazard-related memory.
Retrieval practice and spacing are two related learning principles that help people remember what they learn, especially where there are lots of details like GHS. Getting people to recall information in the classroom instead of just telling them the info is important. And so is engaging in two-way dialogue after classroom training with toolbox talks or one-on-one conversations between workers and their supervisor, or with you during walk-throughs. Getting employees to tell you about the chemicals they deal with and how they navigate the process helps with memory, and it helps fight complacency and other human factors too.
Frequent two-way communication does one more really important thing: It gives you the opportunity to bring feedback from the individual into the organizational HazCom system to make it better. If you’re already engaging with workers on the topic, simply asking them about their challenges or suggestions for improving the process is an easy way to identify gaps that could compromise their ability to comply in the future.
This is why you don’t need to worry too much about if/when OSHA will update its standard or accept my proposed right to know about human factors. With regular feedback from the frontline chemical handlers, your system will be able to address the otherwise unavoidable problems of complacency and memory in HazCom. Sure, you’ll still need to update some of the technical details once OSHA finishes the years-long process of tweaking its standard, but your human system will help you do it effectively and efficiently.
Ray Prest is the Director of Marketing at SafeStart, a company focused on human factors solutions that reduce preventable deaths and injuries on and off the job. Ray has educated people about safety and human factors management for over 20 years.
REFERENCES
1. https://www.osha.gov/sites/default/files/publications/OSHA3514.pdf 2. https://sci-hub.se/https:/doi.org/10.1177/154193128402800124
34 Occupational Health & Safety | JULY/AUGUST 2022
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