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from these hazards, including specifific procedures the employer has implemented to protect employees from exposure to hazard- ous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment (PPE) to be used. 4. ThThe details of the hazard communication program devel- oped by the employer, including an explanation of the labels re- ceived on shipped containers and the workplace labeling system used by their employer and SDSs, including the order of infor- mation and how employees can obtain and use the appropriate hazard information. Make the Training Program Effective There are many modes and methods to conduct HazCom train- ing — from slide decks, videos, e-Learning, in-person classroom exercises, or all the above. When choosing a method, keep in mind that training is most effective when employees are engaged. Make the training interactive and participatory, and at the very least, encourage and allow questions. Employees are more likely to remain engaged throughout the training, and as a result, better understand the materials. OSHA focuses on determining whether employees understand the chemical hazards in their workplace and are aware of safe work practices. As OSHA says, “The Hazard Communication Standard in 1983 gave the workers the ‘right to know,’ but the Globally Har- monized System gives workers the ‘right to understand.’” How much understanding does OSHA expect workers to have? A HazCom guidance document for small business entities states, “OSHA does not expect that workers will be able to recall and recite all data provided about each hazardous chemical in the workplace. What is most important is that workers understand that they are ex- posed to hazardous chemicals, know how to read labels and SDSs, and have a general understanding of what information is provided in these documents, and how to access these tools,” and where to always find this information—even during power outages. In practice, this means that if most employees speak English, but even a small number are non-English speaking and those em- ployees work with hazardous chemicals, they must be provided training in a language and manner they understand. Employers also must account for any limitations in literacy level, vocabulary, or communications within the workforce. There are two approaches to training employees on workplace hazardous chemicals. Employees can be trained on all the individ- ual chemicals they may encounter, or on chemical hazard classes and categories. Employees need to complete training before they begin working with hazardous chemicals, whenever new hazards are introduced into the workplace, when there are changes to the HazCom management system, such as replacing your old physi- cal SDS binders with software-based access, or there’s evidence the training wasn’t effective. A high-quality training program requires measurable or observable outcomes. Establish specific objectives with perfor- mance conditions, such as test results, to demonstrate that learn- ing objectives are being met. Bringing it Together The purpose of HazCom training is to make sure employees, tem- porary workers and contractors have the information they need to protect themselves from the hazardous chemicals they work with. ThThe overall goal is to change behaviors and replace unsafe behav- iors based on incomplete knowledge with safer behaviors based on accurate hazard information. When training is done well, it pro- motes transparency and two-way communication between em- ployees and employer that is necessary to improve any EHS culture. Another resource to help with understanding HazCom train- ing requirements is OSHA’s “Small Entity Compliance Guide for Employers That Use Hazardous Chemicals,”4 specifically Appen- dix B which contains useful guidance on training. In addition, EHS software solutions that are designed with specific capabilities for HazCom management, delivery of HazCom training content, and management of training documentation can introduce a new and more effective approach to chemical management, workplace safety, and training performance. Marc Juaire, CSP, is the Solutions Executive – Safety & Opera- tional Risk for VelocityEHS, and Nicole Lyman, is the EHS Content Writer for VelocityEHS. REFERENCES 1. www.osha.gov/temporaryworkers 2. www.osha.gov/sites/default/files/mtp101703.pdf 3. www.osha.gov/sites/default/files/publications/osha2254.pdf 4. www.osha.gov/Publications/OSHA3695.pdf www.ohsonline.com JULY/AUGUST 2023 | Occupational Health & Safety 45