Workplace Walkabout

A HazCom treasure hunt can liven up stale training on this vital topic.

To help ensure that hazardous chemicals are used and handled safety in the workplace, OSHA created the Hazard Communication (HazCom) standard, 29 CFR 1910.1200, in 1994. The standard requires employers to create a program to properly handle hazardous chemicals in their workplaces.

Employers also must teach their employees about any hazardous chemicals they will work with and how to handle them safely so they will not become injured or mishandle them. Sometimes this training can become a bit static, making it difficult to gauge whether employees have truly understood what they have been told. For facilities that conduct periodic refresher training, the matter can be compounded when employees have heard the same "lecture" for years.

Employees are typically able to tell you where you can find the material safety data sheet (MSDS) binder or where to access an MSDS electronically after training, but when they are truly taught to understand that MSDSs are a tool available for their use, the true intent of the standard can be better achieved. One way to make HazCom training more memorable and to help increase comprehension--especially when the facility requires periodic or annual refreshers--is to incorporate the training requirements into a progressive, interactive treasure hunt that tracks a chemical through its life cycle at the facility.

To prepare for the treasure hunt, begin by choosing a chemical that is commonly used throughout the facility--one that will be familiar to all or most of the employees attending the training session and is used in production, not solely warehoused for resale. Make copies of the MSDS for this chemical for each person who will attend the training.
Obtain copies of the facility diagram that each employee can use as a map. It doesn't have to be detailed; blocks indicating various areas (such as the loading dock, production, waste storage, etc.) probably will be sufficient. Highlight or mark the locations of MSDS binders, telephones, and other HazCom-related safety stations or items for them to "discover" along their hunt.

Create questions to post at the various stopping points throughout the facility and highlight the answers on the instructor's copy for reference. Mark the stopping points on the map. To finish each map, use a dotted line to connect each of the stopping points sequentially.

Determine how to handle group size. If the group is large and certain areas will not be able to safely accommodate everyone at the same time, consider dividing the group and having half do the hunt in reverse, or start the groups five minutes apart. Let people know they will not be glued to their chair for this training, and specify which safety items (steel-toed boots, safety glasses, hard hats, etc.) they should bring with them to be properly protected as they travel throughout the facility. If safety shoes are not among the required safety items, encourage everyone to wear sensible walking shoes.

If the facility has a safety incentive program, tokens, points, certificates, bingo numbers, etc. could be used as rewards for correct answers at the various stations or as the treasure at the end of the training.

Although no two facilities are the same, some common areas and questions that can be answered by referring to information on an MSDS are discussed below. If there is anything special about the chemical chosen for the hunt, be sure to incorporate it somewhere along the journey.

Receiving Dock
Receiving docks are a convenient place to begin the treasure hunt because they are where a majority of the chemicals typically enter the facility. If it is applicable, review procedures for new chemicals entering the facility: Is an MSDS needed before the chemical arrives? What is to be done with MSDSs that arrive with the chemical? What should be done if a new chemical arrives without an MSDS?

Arrange to have the chemical you're tracking available at the dock, if this is practical. What does it look like when it arrives? Discuss common packaging such as cans, drums, totes, and bulk shipments, if these terms are not familiar.

Note that docks are often fairly busy places, and employees in this area may not be accustomed to a lot of pedestrian traffic. As the training group is being led to or through this area (as well as at other stops along the way), secure a spot for them that will be out of the way of forklift or other traffic.
Other questions that could be posted in this area are, "Who manufactures this chemical?" and "Are there special handling procedures for this chemical?"

Show everyone how chemicals are segregated in storage areas to prevent reactions, if this is applicable in the facility. Point out sumps, drains, fire suppression equipment, and other safety features of the warehouse, as well as handling equipment that is used to safety transport and handle chemicals in this area.
For chemicals with a shelf life, explain how the product is rotated so the oldest stock is used first.

Use the MSDS to determine the answers to the following questions: "Are there special storage precautions for this chemical?" "What is the shelf life?" "Will it react with other chemicals?"

Product in Use
Explain what happens to the chemical when it is pulled out of the warehouse stock for use in production. Does it remain in the container? Is it piped directly to the processing line? Will it be put in a chemical storage area to be pumped out as needed?

Look at the label and information on the container itself, and, when applicable, discuss how to label smaller containers they may use at individual workstations or when transferring the chemical. If the chemical chosen is stored in above-ground or underground storage tanks, discuss how it is piped to the dispensing location, how the pipes are labeled, and where the shut-off valves are located.

From the MSDS, determine the answers for these questions:
• What are the health hazards?
• What personal protective equipment (PPE) is required?
• What first aid may be necessary if this product gets on your skin or in your eyes?
• How would a spill of this product be handled?

Waste Collection and Disposal
This part of the training may vary slightly. For example, if satellite accumulation areas are used and most employees aren't trained to prepare hazardous wastes for shipment, it may be more practical to discuss the chemical's safety in regard to the satellite accumulation areas than to march everyone to the office where shipping manifests are stored and completed.

On the other hand, if time allows, it also could be interesting for them to learn what happens after the waste leaves their station. If the employees do not prepare their wastes for shipment, explain who handles this waste and what exactly does happen to it. Discuss who packages it and what precautions they take. Explain how the containers are sealed and labeled, as well as the paperwork that accompanies hazardous wastes when they are shipped off site.

This may also be an opportunity to reinforce the importance of waste segregation, recycling, or other waste-related issues. Collection and disposal questions might include: "How will this product be disposed of after its useful life?" and "What is the proper shipping name for this product when it becomes a waste?"

Treasuring Knowledge
At the end of the hunt, all could be brought back to the training room to discuss what they learned from this exercise. Encouraging students to name three things they learned along the way is a good way to open discussion and gauge understanding. Chance are, they'll mention something more enlightening than the location of their nearest MSDS binder!

This article originally appeared in the October 2007 issue of Occupational Health & Safety.

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