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TRAINING: HAZARD COMMUNICATION Building a Strong Hazard Communication Training Program An OSHA initiative means employers who use hazardous chemicals in the workplace should start preparing to update their hazard communication training programs. Who needs training, what are the elements of training, and how do you make an effective program? BY MARC JUAIRE AND NICOLE LYMAN OSHA is preparing to update its Hazard Communication Standard (HCS) to align with Revision 7 of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS). This follows Health Canada, which published a final rule to update its Hazardous Prod- ucts Regulations (HPR) in January 2023. This alignment is intended to increase worker protection and help reduce chemical-related occupational illnesses and injuries by further improving the accuracy and clarity of information on labels and safety data sheets (SDSs) for hazardous chemicals. These impending changes mean employers who use hazardous chemicals in the workplace should start preparing to update their hazard communication (HazCom) training programs. Purpose of Hazard Communication Training OSHA designed the HCS to ensure chemical safety in the work- place by informing employees about the hazards of chemicals they work with and understanding how to minimize risk of exposure. To further reduce risk of injuries and illnesses, the HCS requires employers to provide comprehensive HazCom training to their employees. Effective HazCom training equips employees with the ability to interpret and understand the hazard information provided on the chemical labels and SDSs for the chemicals they’re working with, and how to apply this information in the workplace. Proper HazCom training also helps employers comply with OSHA regulations and avoid costly fines and legal penalties. In 2022, HazCom was the second-most-common workplace violation based on OSHA’s Top 10 List of Most Frequently Cited Standards. Violations can result in fines up to $15,625 per violation, per day. In addition, potential criminal charges and possible civil lawsuits may also result from failing to meet HazCom requirements. Ineffective HazCom training is often at the root of these violations and can lead to lost profitability due to fines or lost revenue from employees being unable to work due to chemical exposure. Who Needs Training HazCom training is a foundational element of workplace safety, and it’s important to ensure the right people are being trained. According to OSHA HCS, all employees who work with or might be expected to work with hazardous chemicals require training. OSHA states that this scope is intentionally broad, and “includes any situation where a chemical is present in such a way that employees may be exposed under normal conditions of use or in a foreseeable emergency.” Having close familiarity with the operations, job tasks in- volved, associated chemicals, and the possible routes of exposure will help to determine which employees require training. At a New Africa/Shutterstock.com minimum, evaluate and verify training for all new employees, transferred employees, and temporary workers and contractors. For contract and temporary workers, OSHA’s recent guidance on protecting temporary workers, including its Temporary Work- er Initiative (TWI),1 clarifies that staffing agencies and employers share responsibility for worker safety. Staffing agencies should train their people on general HazCom requirements, and on the hazards of chemicals they regularly work with from one job site to another. Contracting (i.e., host) employers are responsible for training contract or temporary workers about workplace-specific hazards and HazCom management in their facilities. Employers should always communicate with the staffing agency/contractor provider to eliminate training gaps. Elements of a HazCom Training Program In addition to identifying who needs training, compliance with OSHA HCS means having a thorough written training program in place. OSHA provides a Draft Model Training Program2 em- ployers can use for reference, but it’s always a good idea to review the regulatory requirements, which are available under OSHA’s 29 CFR 1910.1200(h)(3). According to the HCS3, HazCom training needs to cover at least the following: 1. Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitor- ing devices, visual appearance or odor of hazardous chemicals when being released, etc.). 2. The physical, health, simple asphyxiation, combustible dust, and pyrophoric gas hazards, as well as hazards not otherwise clas- sified, of the chemicals in the work area. 3. The measures employees can take to protect themselves 44 Occupational Health & Safety | JULY/AUGUST 2023 www.ohsonline.com